v'/EPA
            United States
            Environmental Protection
            Agency
            Office of the
            Inspector General
            Washington DC 20460
                                    May 1992
Office of the
Inspector General
Report to the Congress

October 1,  1991 Through
March 31, 1992
                                        Printed on Recycled Paper

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                                                    During this semiannual reporting period, the Office of
                                                    Inspector General focused attention on
                                                    improvements needed in EPA's contract
                                               management activities.  I testified before congressional
                                               committees on EPA's vulnerability to fraudulent, wasteful,
                                               abusive, and illegal practices by contractors and EPA's
                                               "culture" of managing contractors as if they were part of
                                               the EPA "family" instead of at arm's length. The
                                               Administrator and other top management officials
                                               promptly responded by initiating corrective actions which,
                                               if properly implemented, should help significantly improve
                                               the Agency's control over its  operations and contracts.
                                                 Our investigative work continued to find fraud and
                                               abuse in laboratories participating in the Superfund
                                               Contract Laboratory Program. For example, one
                                               laboratory pleaded guilty to making false statements to
                                               EPA and was fined $500,000. We will continue our
                                               coordinated audit and investigative efforts to ensure the
                                               soundness and credibility of the scientific data upon which
                                               the Agency bases its policies, regulations, and
                                               enforcement actions.
                                                 We also found that improvements were needed in
                                               other areas, including large grantees' management of
                                               their wastewater treatment facilities, the reliability of data
                                               used to measure the impact of leaking underground
                                               storage tanks on the nation's groundwater,  and the
                                               timeliness of the Agency's  efforts to clean up hazardous
                                               waste sites. We continued our efforts concerning the
                                               implementation of the Chief Financial Officers (CFO) Act
                                               and worked with the Agency  to ensure establishment of
                                               an effective CFO organization to correct its longstanding
                                               financial management problems.
                                                 The Agency's positive response to our findings on its
                                               contract management activities and its cooperation in
                                               implementing the CFO Act are examples of our mutual
                                               commitment to protecting scarce resources and
                                               enhancing the quality of the environment.
                                               John C. Martin
                                               Inspector General
OCTOBER 1,1991 THROUGH MARCH 31.1992

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 Executive Summary	  1
 Overview of EPA's Current Challenges  	  3
 Overview of Significant Trends In EPA of Concern to the DIG	  4
 Profile of Activities and Results  	  6
 Establishment of the OIG in EPA—Its Role and Authority	  7
    Organization and Resources  	  7
    Purpose and Requirements of the Office of the Inspector General
       Semiannual Report  	  7
 Section 1—Significant Problems, Abuses, and Recommendations
 Summary of Audit Activities and Results 	10
 Agency Management  	11
 Construction Grants 	15
 Other Grants and Contracts  	18
 Superfund Program  	19
 Special Reviews	22
 Section 2—Report Resolution
 Status Report on Perpetual Inventory of Reports in Resolution Process
  for the Semiannual Period Ending March 31, 1992	25
 Audit Followup	26
 Status of Management Decisions on IG Audit Reports  	27
 Resolution of Significant Reports	29
 Section 3—Prosecutive Actions
 Summary of Investigative Activity	30
 Description of Selected Prosecutive Actions	31
 Description of Selected Prosecutive and Administrative Actions
  Concerning EPA Employees	33
 Section 4—Fraud Prevention and Resource Management Improvements
 Review of Legislation and Regulations	34
 Suspension and Debarment Activities  	35
 Congressional Testimony by the Inspector General  	36
 Personnel Security Program	37
 President's Council on Integrity and Efficiency	37
 Committee on Integrity and Management Improvement	38
 Hotline Activities	38
 Professional and Organizational Development	39
 Appendices
 Appendix 1—Reports Issued	40
 Appendix 2—Reports Without Management Decisions  	57
OCTOBER 1,1991 THROUGH MARCH 31.1992

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    Executive Summary
 Section 1—
 Significant Problems,
 Abuses, and
 Recommendations

 1. Mismanagement Of
 Contractor Jeopardizes
 Agency's Control Of
 Operations And
 Procurement Practices.

 A general laissez-faire culture
 that affected EPA's
 management of its support
 contract with the Computer
 Sciences Corporation (CSC)
 resulted in (1)  lessened EPA
 control over critical program
 activities; (2) the creation  of a
 personal services relationship
 between CSC and EPA; (3)
 CSC's performance of
 inherently governmental
 functions;  (4) potential conflict
 of interest situations;  and
 (5) ineffective and inefficient
 use of Agency resources
 (page 11).

 2. After $581 Million And 27
 Years Of Mismanagement,
 Puerto Rico Still Fails To
 Meet Water Standards.

 Despite receiving an  additional
 $142.4 million from EPA since
 our  1987 report, the Puerto
 Rico Aqueduct and Sewer
 Authority (PRASA) still was not
 properly operating and
 maintaining its wastewater
 treatment facilities, nor
 meeting Clean Water Act
 standards.  The people of
 Puerto Rico continue to be
 deprived of the environmental
 and public  health benefits
 which these facilities  could
 provide (page 12).

 3. EPA Lacks  Control Over
 Automatic Data  Processing
 (ADP) Contracts.

 EPA had not established an
 adequate contract
 administration process to
 ensure that contracted ADP
 services are effectively and
 efficiently accomplished. In
 addition, EPA had not
 prepared required analyses to
 ensure that ADP services are
 acquired at the lowest cost
under existing and proposed
contracts
(page 13).

4. Underground Storage
Tank Inventory Not Reliable.

The national inventory of
underground storage tanks is
unreliable for allocating
resources and measuring
EPA's progress in minimizing
the impact of leaking tanks on
human health and the
environment (page 14).

5. Los Angeles Claims $14.3
Million Of Ineligible and
Unreasonable Costs.

The City of Los Angeles,
California, claimed $2,174,976
of ineligible construction, force
account, and engineering costs
and $12,198,906 of
unreasonable costs (page 16).

6. Over $8.4 Million
Questioned On D.C. Projects
Plagued By Delays and Cost
Overruns.

The District of Columbia
(District) experienced
excessive cost overruns and
significant construction
contract delays at its Blue
Plains Wastewater Treatment
Plant.  In addition, the District
claimed $2,047,749 of
ineligible construction and
engineering costs and
unsupported costs of
$6,372,885 for these projects
(page 16).

7. Nearly $8.8 Million Of
Ineligible And Unsupported
Costs Claimed For Western
Lake Superior, Minnesota,
Project.

The Western Lake Superior
Sanitary District, Duluth,
Minnesota, claimed $8,595,588
of ineligible  construction,
engineering, and administrative
costs.  An additional  $166,834
of unsupported costs were
questioned (page 16).
8. Over $8.7 Million Of
Ineligible And Unsupported
Costs Claimed For Amherst,
New York, Project.

The Town of Amherst, New
York, claimed $5,963,650 of
ineligible construction,
engineering, and administrative
costs. An additional
$2,739,253 of unsupported
costs were questioned (page
17).

9. Over $6 Million  Of
Ineligible Costs Claimed By
Wayne, New Jersey.

The Township of Wayne, New
Jersey, claimed $6,273,775 of
ineligible construction,
engineering, and administrative
costs (page 17).

10. San Jose, California,
Claimed Almost $2.9 Million
of Ineligible Costs.

The City of San Jose,
California, claimed $2,864,225
of ineligible construction and
engineering costs for
improvements to its
wastewater treatment facility
(page 18).

11. North Carolina State
University  Research Center
Claimed $2.1 Million in
Misused Funds.

North Carolina State University
claimed  $1,173,779 of
ineligible costs and  $898,206
of unsupported costs  under a
Superfund research grant that
were not used for their
intended  purposes (page 18).

12. Alternative Contracting
Strategy Fails to Accelerate
Cleanups of Hazardous
Waste Sites.

Poor contractor  performance
and management delayed the
cleanup  of hazardous waste
sites under the Alternative
Remedial Contracting Strategy
(ARCS) program in  Regions 1,
3, and 5 (page 20).
13. Searches For Potentially
Responsible Parties Need
Improvement In Regions 2
and 7.

Searches in Regions 2 and 7
for potentially responsible
parties were not timely,
complete, or well documented,
resulting in  unnecessary costs
and delays  in getting polluters
to accept responsibility for
cleaning up their hazardous
waste sites (page 20).

14. Los Angeles Claimed
$6.7 Million In Questioned
Costs For Cleanup of
Hazardous Waste Sites Still
Threatening Public Health.

The Los Angeles Department
of Water and Power (LADWP)
ineffectively managed its
cooperative agreement with
EPA for hazardous waste
cleanup activities at the San
Fernando Valley Ground Water
Basin, resulting  in health-
threatening  conditions at
several  adjacent residential
communities. Also, LADWP
claimed $2,321,195 of
ineligible costs and $4,354,690
of unreasonable costs (page
21).

15. Delinquent  Superfund
Reports to  Congress Have
Limited Usefulness.

For 3 of the last 4 years, EPA
submitted Superfund annual
reports to Congress  more than
1 year after their statutonly
mandated due date,
significantly reducing their
usefulness to the Congress
(page 22).

16. Accreditation Program
Needed To Ensure Integrity
of Laboratory Data.

EPA lacks assurance that
laboratories performing studies
to support applications for
pesticide registration are
operating in compliance with
the Good Laboratory Practices
(GLP) program established
pursuant to  the  Federal
Insecticide,  Fungicide, and
Rodenticide Act  (page 22).
OCTOBER 1,1991 THROUGH MARCH 31 1992

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17. Alaskan Seafood
Processor's Permit Should
Be Modified.

EPA Region 10 issued a
National Pollutant Discharge
Elimination System permit to a
seafood processor without
adequately assessing the
known negative impact on the
water quality of Captains Bay,
Alaska, or enforcing the
permit's conditions (page 23).

18. EPA May Have Paid Too
Much For Carpet Cleaning.

Over a 33-month period EPA
obtained carpet cleaning
services without competition
and without determining the
reasonableness  of prices
(page 24).

19. Use Of  EPA Fleet
Vehicles and Fuel
Credit Cards Questioned.

EPA had not provided
adequate oversight and control
of its leased vehicles, resulting
in their misuse and excessive
operational  costs (page 24).
Section 2—Report
Resolution

At the beginning of the
semiannual period, there were
296 reports for which no
management decision had
been made.  During the first
half of fiscal  1992, the Office
of Inspector General issued
1,044 new reports and closed
250. At the end of the
reporting period, 292 reports
remained in the Agency
followup system for which no
management decision had
been made.  Of the 292
reports, 99 reports remained in
the Agency followup  system
for which no management
decision was made within 6
months of issuance (page 25).
   In two followup reviews,
the Office of Inspector General
found that some problems
identified in previous reports
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 250 reports closed,
EPA management disallowed
$22.9 million of questioned
costs for recovery and agreed
with our recommendations that
$13.3 million be put to better
use (page 25). In addition,
cost recoveries in  current and
prior periods included $8.1
million  in cash collections, and
at least $17.2 million in offsets
against billings (page 6).
                               Section 3—
                               Prosecutive Actions

                               During this semiannual
                               reporting period, our
                               investigative efforts resulted in
                               39 convictions and 16
                               indictments. Also,  this
                               semiannual period  our
                               investigative work led to nearly
                               $1.3 million in fines and
                               recoveries (page 30).
                                  Results of continuing
                               investigations of EPA's
                               contract laboratory program
                               included the president and a
                               supervisor of a New York
company being charged with
40 counts of fraud; a vice
president of a Connecticut
company being fined and
placed on probation; a fine of
$500,000 for an analytical
services firm; and guilty pleas
from a Louisiana company and
3 of its employees, with
sentences to follow.
   In other cases, 18
defendants in a telemarketing
scheme were found guilty and
17 of them were sentenced; an
Illinois business pleaded guilty
to bribing a local government
official; two Pennsylvania
corporations and their chief
executive officer pleaded guilty
to violations of the Resource
Conservation and Recovery
Act and the Clean Air Act; and
two employees pleaded guilty,
and one was sentenced, in a
false claims case at a
Pennsylvania Superfund site
(page 31).
Section 4—Fraud
Prevention and
Resources
Management

Review of Proposed
Legislation and Regulations
During this semiannual period,
we reviewed 72 legislative and
regulatory items.  The most
significant were a proposed
executive order on integrity
and efficiency in Federal
programs; the proposed
Freedom of Information  Act of
1991; the proposed Electronic
Freedom of Information  Act of
1991; and an Office of Federal
Procurement Policy proposed
policy to prohibit contracting
for inherently governmental
functions (page 34).

Suspension and Debarment
Activities
We completed 24 cases during
this reporting period, resulting
in  9 debarments, 7
suspensions, and 8 settlement
agreements  (page 35).

Congressional Testimony by
the Inspector General
The Inspector General was
invited to testify 3 times  before
congressional committees on
EPA's vulnerability to
fraudulent, wasteful, abusive,
and illegal practices used by
its contractors (page 36).

Personnel Security Program
During this reporting period,
the Personnel Security Staff
reviewed 234 investigations.
Among the actions taken,
based on these reviews, were
the denial of a contractor
employee's access to
Confidential Business
Information; resignation of
three employees who had
falsified their SF-171s,
Application for Federal
Employment, by not listing
previous convictions for
assault, claiming degrees not
awarded, and previous
terminations; and oral
reprimands of three employees
regarding their failure to report
previous terminations,
convictions for theft, for driving
while intoxicated, for writing
bad checks, and for claiming  a
college degree not earned
(page 37).

Hotline Activities
The DIG toll-free Hotline
opened 31 new cases and
closed 37 cases during the
reporting period. Eight of the
closed cases resulted in
environmental, prosecutive, or
administrative corrective action
(page 38).

Professional and
Organizational Development
We approved 425 training
enrollments for a total of 932
days of training and
participation in professional
development seminars and
conferences.
   A cadre of 18 DIG Total
Quality Management (TQM)
facilitators was trained, and
members of the DIG staff
began receiving 1-day TQM
awareness training
(page 39).
                                                                                             OFFICE OF THE INSPECTOR GENERAL

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   Overview of EPA's Current Challenges
This section highlights some of
EPA's most significant
challenges for restoring and
protecting the quality of the air
we breathe, the land where we
live, and the water we depend
on.

Land

The principal sources of land
waste are:

• Underground Storage Tanks.
EPA estimates there are 3 to 5
million underground storage
tanks in the United States
containing petroleum products
or other hazardous
substances.  Thousands are
thought to be leaking now  and
many more will begin to leak in
the next 5 to 10 years.
Because half of our population
depends on ground water  as a
source of drinking water,
leaking underground storage
tanks have been recognized
as a national problem.

• Industrial Hazardous
Wastes.  The chemical,
petroleum, metals, and
transportation industries are
major producers of hazardous
industrial waste, such as dioxin
and benzene which are known
carcinogens.

• Municipal Wastes.  Municipal
wastes include household  and
commercial wastes, demolition
materials, and sewage sludge.
Solvents and other harmful
household and commercial
wastes are generally so
intermingled with other
materials that specific control
of each is virtually impossible.

• Mining Wastes. A large
volume of all waste generated
in the  United States is from
mining coal, phosphates,
copper, iron, uranium, and
other minerals and from ore
processing and  milling. Runoff
from these wastes increases
the acidity of streams and
pollutes them with toxic
materials.

Air

The Clean Air Act
   Major Laws Administered by EPA
   Statute

   Toxic Substances Control Act
   Federal Insecticide, Fungicide, and
   Rodenticide Act
   Federal Food, Drug and Cosmetic
   Act
   Resource Conservation and
   Recovery Act
  Comprehensive Environmental
  Response, Compensation, and
  Liability Act
  Clean Air Act
  Clean Water Act
  Safe Drinking Water Act
   Marine Protection, Research and
   Sanctuaries Act
   Asbestos School Hazard Abatement
   Act
  Asbestos Hazard Emergency
  Response Act
  Emergency Planning and Community
  Right-to-Know Act
 Provisions

 Requires EPA notification of any new
 chemical prior to its manufacture and
 authorizes EPA to regulate
 production, use, or disposal of a
 chemical

 Authorizes EPA to register all
 pesticides, specify the terms and
 conditions of their  use, and remove
 unreasonably hazardous pesticides
 from the marketplace.

 Authorizes EPA in cooperation with
 FDA to establish tolerance levels for
 pesticide residues on food.

 Authorizes EPA to identify hazardous
 wastes and regulate their generation,
 transportation, treatment, storage,
 and disposal.

 Requires EPA to designate
 hazardous substances that can
 present substantial danger and
 authorizes the cleanup of sites
 contaminated with such substances.

 Authorizes EPA to set emission
 standards to limit the release of
 criteria pollutants and hazardous air
 pollutants.

 Requires EPA to establish a list of
 toxic water pollutants and set
 standards.

 Requires EPA to set drinking water
 standards to protect public health
 from hazardous substances

 Regulates ocean dumping of toxic
 contaminants

 Authorizes EPA to provide loans and
 grants to schools with financial need
 for abatement of severe asbestos
 hazards.

 Requires EPA to establish a
 comprehensive regulatory framework
 for controlling asbestos hazards in
 schools.

 Requires States to develop programs
 for responding to hazardous chemical
 releases and requires industries to
 report  on the presence and release
 of certain hazardous substances
Amendments of 1990 address
three major threats to our
nation's environment and the
health of Americans: urban air
pollution, acid rain, and air
toxics. The 1990 amendments
also establish a national
operating permits program and
an improved enforcement
program to foster better
compliance with the
requirements of the Act.

• Urban Air Pollution.  Under
the 1970 Clean Air Act, EPA
established National Ambient
Air Quality Standards for
pollutants posing the greatest
overall threat to air quality.
These "criteria pollutants"
include ozone, carbon
monoxide, airborne
particulates, sulfur dioxide,
lead, and nitrogen oxides.  The
1990 amendments  require a
new classification of areas
which are not in attainment
with these standards and
establish time frames for
attainment based on the
severity of current pollution
levels. More stringent motor
vehicle emission standards,
use of alternative clean fuels,
clean-fueled fleet vehicles, and
additional controls on industrial
facilities are required.

• Acid Rain.  Emissions of
sulfur dioxide (primarily from
coal-burning power plants) and
nitrogen oxides (primarily from
motor vehicles and coal-
burning power plants) interact
with sunlight and water vapor
in the upper atmosphere to
form acidic compounds which
can fall as acid rain.  This is
recognized as a serious long-
term problem for many
industrial  nations. The 1990
amendments establish new
requirements, primarily on
coal-burning power plants,
aimed at reducing emissions of
sulfur dioxide and nitrogen
oxides emissions. Also, these
amendments provide for
banking and trading of
emission  allowances among
emission  sources to facilitate
reductions of acid ram.

• Air Toxics.  Before the 1990
amendments, EPA was
required to establish national
emission  standards for
hazardous air pollutants which
would  protect public health
with an ample margin of
safety.  Because this margin
was difficult to define and was
the subject of continued
litigation, EPA promulgated
regulations for only seven
pollutants.  The 1990
amendments shift from
regulation of individual
pollutants to categories of
sources using technology-
based standards. EPA  must
publish a list of industrial
source categories for 189
chemicals specified  in the
1990 amendments and
regulate each category within
10 years to reduce air toxic
emissions by over 75 percent.

Water

The job of cleaning and
protecting the nation's drinking
water; oceans, coastal waters,
and wetlands; and surface
waters  is made complex by the
variety  of sources of pollution
that affect them.
OCTOBER 1,1991 THROUGH MARCH 31 1992

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

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

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

Wetlands

• More than  half of the
wetlands originally in  the
contiguous United States have
been lost and others  have
been degraded by pollution
and hydrological changes so
that they no longer perform
many of their natural  functions.
To achieve its "no net loss"
goal, EPA is increasing
enforcement of Federal
restrictions on activities which
destroy  or degrade wetlands.
 This section of our report
 presents the Office of
 Inspector General's (OIG)
 perspective on significant
 vulnerabilities and crosscutting
 problems which the OIG
 believes the Agency must
 address to ensure its programs
 are conducted in a more
 effective, efficient, and
 economical manner.  These
 items have been identified by
 OIG audits and investigations,
 Agency studies and
 evaluations, and others over
 time.  The OIG's semiannual
 report for the period ended
 September 30, 1991,
 discussed five significant
 trends of concern: (1)
 Scientific Data Integrity, (2)
 Contract and Procurement
 Practices, (3) Financial
 Management: Chief Financial
 Officers Act, (4) Superfund,
 and (5)  Audit Followup. Each
 of these trends continue to be
 of concern to the OIG and has
 captured the attention of
 Agency management. For this
 reporting period,  the OIG's
 perspective on these trends is
 presented under two major
 categories—Contract
 Management and Financial
 and Management Integrity—to
 more closely correspond with
 EPA's current priorities and
 future initiatives.

 Contract Management

 Contractors have an enormous
 role in helping  the Agency
 accomplish its  mission. Each
 year EPA processes about
 8,000 contract actions,
 obligating more than $1 billion.
 Past audits and investigations
 have  identified instances of
 overcharging, including
 exorbitant markups on
 materials and services, and
 performance award  fees being
 given to contractors for less
 than satisfactory work.

• Backlog of contracts
 requiring audit.

 The Agency's needs for audits
 of contracts have never been
 met and have been  growing
 tremendously.  As of February
 1992, the Agency had 678
 active contracts with
obligations of $3 billion.
Further, there were 2,002
contracts with obligations
totaling $4.1  billion whose
performance periods had
expired, but had not been
closed out. The Agency had
about 400 unfulfilled requests
for audits to determine
contractors' final indirect cost
claims.  Significant audit
reports on contracts were
issued during the period,
including:

—An Alternative Remedial
Contracting Strategy (ARCS)
contractor's indirect cost rate
for 1987 was incorrectly
calculated because some
costs should not have been
claimed for reimbursement and
other costs should have been
part  of the base costs used for
distributing indirect costs. The
contractor's indirect costs
included $6,097,022 which
should have been included in
the base costs;  $1,411,432 of
self-insurance costs not
approved by the contracting
officer, as  the Federal
Acquisition Regulation
requires; $470,764 of
expressly unallowable costs
involving professional and
legal costs associated with
stock transactions, contingent
fees  for  lobbying services, first
class air fares, alcohol,  and
advertising; and $49,498 of
lease payments exceeding
normal costs of  ownership.

—A contractor bidding on an
EPA contract to provide
studies supporting EPA
regulation  development  and
rulemaking process proposed
$7,760,982 of fringe benefit,
overhead,  general and
administrative, and
subcontractor costs which did
not reflect current rates  or
rates not forecasted beyond
the first year and $434,704 of
automation costs calculated
using an incorrect rate.  Also,
the contractor occasionally
billed subcontractor costs
before paying them and had
not done an effective job of
determining which business
units were subject to Cost
Accounting Standards.
—$1.7 million of a
subcontractor's $3.5 million
proposal was questioned
because the subcontractor
proposed labor rates in excess
of actual costs and equipment
rates it could not support.

• Laissez-faire culture.

A general laissez-faire culture
adversely affects EPA's
management of its contracts.
During this semiannual
reporting period, we reported
EPA's management of one
contractor had resulted in
lessened EPA control over
critical  program activities, the
creation of  a personal services
relationship between the
contractor and EPA, the
contractor's performance of
inherently governmental
functions, potential conflict of
interest situations, and
ineffective and inefficient use
of Agency resources.
Specifically, EPA's heavy
reliance on the contractor for
development, enhancement,
operation, and maintenance of
most of its critical information
and financial management
systems has made the Agency
extremely dependent on the
contractor at the expense of its
own  control over critical
program operations.  Also,
EPA administered the contract
as a personal services contract
as evidenced by an employer-
employee relationship that
developed between EPA and
the contractor largely because
EPA assumed responsibilities
for supervising, hiring, firing,
evaluating,  promoting, and
training the contractor's
employees  who performed
Agency functions on site.
   With respect to the
Alternative  Remedial
Contracting Strategy program,
we found that poor contractor
performance and management
delayed the cleanup of
hazardous waste sites in three
EPA regions. Also, EPA had
not established an adequate
contract administration process
to ensure that contracted ADP
services are effectively and
efficiently accomplished.
                                                                                             OFFICE OF THE INSPECTOR GENERAL

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 •  Scientific data.

 The accuracy and reliability of
 scientific data have always
 been crucial to EPA's mission
 as a regulatory agency. Such
 data forms the basis for
 decisions that affect all major
 American industries and
 national policies to prevent
 hazards and risks to health
 and safety. EPA's Office of
 Research and Development
 (ORD)  has 12 laboratories at
 nine locations across the
 country. In addition, ORD
 devotes two-thirds of its $400
 million budget to funding
 contracts and grants.
 However, audit and
 investigative work shows that
 EPA is not always getting  the
 research for which it pays, nor
 is such research always
 accurate or objective.
    For example,  EPA has
 used independent laboratories
 under the Contract  Laboratory
 Program to test samples from
 Superfund sites.  During this
 semiannual reporting period,
 our investigations continued to
 show that contract laboratories
 have serious problems with the
 integrity of their data and
 methods, resulting in criminal
 prosecutions and fines.
 Fraudulent analyses, falsified
 data, uncalibrated equipment,
 backdated  analyses, and other
 serious problems with the
 contract laboratories used  to
 analyze samples from
 Superfund  sites could call  into
 question cleanup  decisions
 and could hamper the recovery
 of EPA's cleanup costs from
 responsible parties.

 Financial and Management
 Integrity

 EPA's budget averages about
 $6 billion annually.  Accurate
 accounting and reporting of
 these funds is crucial,
 especially with respect to the
 Superfund  and construction
 grants programs.  However,
 EPA's accounting systems
 have not provided complete,
 consistent, reliable and timely
 data for Agency decision-
 making and control  of its
 assets.
•  Accounting systems and
controls.

In March 1991, we reported
that EPA's $20 million
integrated financial
management system (IFMS),
designed to combine
accounting and budgeting
systems with other financial
and administrative systems to
comply with OMB
requirements, had not been
provided sufficient attention or
resources for its
implementation. Significant
data integrity and security
problems had led to user
dissatisfaction and the
development of duplicate
systems.
    Accounts receivable has
been an issue that the Agency
has been dealing with for at
least 10 years. Our
September 1991 review of the
Superfund for fiscal 1990
revealed that, of the Superfund
receivables, $4.6 million were
not recorded timely; $562,288
were not recorded in the
correct fiscal year; 13
receivables were delinquent
without assessed interest of
$181,468; and $2.3 million of
collections were not recorded
against the correct receivables.
Since 1983, we have reported
that amounts due as a result
of Superfund cost recovery
actions were not recorded or
were not recorded timely.
Also, a recent review of
construction grant obligations
found that nearly $43.3 million
of a $49 million sample of
unliquidated construction grant
obligations reviewed in  eight
EPA regions were invalid and
should have been deobligated.
Our March 1992 followup
report on the Comprehensive
Environmental Response,
Compensation and Liability
Information System (CERCLIS)
found there were still
significant problems with the
integrity of both financial and
nonfinancial information.

•  Audit followup.

Since 1989 we have been
assessing the effectiveness of
the Agency's audit followup
responsibilities. Our reviews
found that information in the
Agency's Management Audit
Tracking System (MATS) was
not reliable and the Agency's
Semiannual Reports to
Congress on audit followup
activity have been  inaccurate.
In our latest report, issued in
September 1991, we found in
just three regions,  almost as
much in  unreported recoveries
($7.4 million) as the Agency
reported for all ten regions
($8.3 million) in its  Reports to
Congress for 1990. As a
result of  our reviews, the
Agency has reported audit
followup  as a material
weakness in its 1989, 1990,
and 1991 Federal Managers'
Financial Integrity Act (FMFIA)
Reports to Congress and the
President.

•  Chief Financial Officers Act.

The Chief Financial Officers
(CFO) Act was enacted to
bring about much needed
improvements in accounting
systems, financial
management, and internal
controls.  In  response to the
Act and as a result of our prior
audit findings,  we are
continuing our emphasis on
performing audits in the
financial  management area to
ensure that necessary
improvements are made in the
Agency's financial systems
and data integrity.  In addition,
we are working with the
Agency to ensure that an
effective  CFO organization is
established that provides the
CFO with the responsibility
and authority needed to
correct EPA's longstanding
financial  management
problems.
OCTOBER 1,1991 THROUGH MARCH 31 1992

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   Profiles of Activities and Results
Environmental Protection Agency
Office of Inspector General
Audit Operations

DIG MANAGED REVIEWS:

Reviews Performed by EPA, Independent Public
Accountants (IPA's) and State Auditors

—Questioned Costs
 - Total Ineligible
 - Federal Share Ineligible*
 - Total Unsupported*
 - Federal Share Unsupported*
 - Total Unnecessary/Unreasonable*
 • Federal Share Unnecessary/Unreasonable*
October 1, 1991, to
   March 31, 1992
      $48.3
      $35.4
      $21.7
      $17.4
      $22.0
      $146
Million
Million
Million
Million
Million
Million
—Recommended Efficiencies (Funds be Put to Better Use)
 - Total Efficiencies*                                $57.4 Million
 - Federal Share Efficiencies*                        $57.4 Million

—Cost Disallowed to be Recovered
 - Federal Share Ineligible                           $11.0 Million
 - Federal Share Unsupported                        $10.4 Million
 - Federal Share Unnecessary/Unreasonable             $.2 Million
   (costs which EPA management agrees are
   unallowable and is committed to recover
   or offset against future payments)

—Cost Disallowed as Cost Efficiency
 - Federal Share Recommended Efficiencies            $8 0 Million
   (funds made available by EPA management's
   commitment to implement recommendations in
   DIG performance or preaward audits)

OTHER REVIEWS:

—Reviews Performed by another Federal Agency or Single Audit Act
Auditors

—Questioned Costs
 - Total Ineligible                                     $2.7 Million
 - Federal Share Ineligible*                            $2.7 Million
 - Total Unsupported*                                 $1 0 Million
 - Federal Share Unsupported*                         $1.0 Million
 - Total Unnecessary/Unreasonable*                    $0 0 Million
 - Federal Share Unnecessary/Unreasonable*            $0.0 Million

—Recommended Efficiencies (Funds be Put to Better Use)
 • Total Efficiencies*
 • Federal Share Efficiencies*
      $15.1  Million
      $15.1  Million
* Questioned Costs: Ineligible, Unsupported and
Unnecessary/Unreasonable; and Recommended Efficiencies (Funds
be Put to Better Use) are subject to change pending further review in
the audit resolution process.

" Information on recoveries from audit resolution is provided from the
EPA Financial Management Division and is unaudited.
                                                                                                                 October 1, 1991, to
                                                                                                                    March 31, 1992
                                                                            $0.7 Million
                                                                            $0 6 Million
                                                                            $0.0 Million
—Cost 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)
—Cost Disallowed as Cost Efficiency
 - Federal Share Recommended Efficiencies             $5.3 Million
  (funds made available by EPA management's
  commitment to implement recommendations in
  OIG performance or preaward audits)

Agency Recoveries:

—Recoveries from Audit Resolutions of                $25 3 Million
 Current and Prior Periods (cash collections
 or offsets to future payments)**

REPORTS ISSUED.

—OIG MANAGED REVIEWS:
 - EPA  Reviews Performed by the OIG                         48
 - EPA  Reviews Peformed by Independent
   Public Accountants                                        81
 - EPA  Reviews Performed by State Auditors                     9

—OTHER REVIEWS:
 - EPA  Reviews Performed by another Federal Agency          239
 - Single Audit Act Reviews                                  667

TOTAL  REPORTS ISSUED                                1,044

- Reports Resolved (agreement by Agency
   officials to take  satisfactory corrective  action)                 250

Investigative Operations

• Fines  and Recoveries (including civil)                 $1.3 Million
• Investigations Opened                                     138
• Investigations Closed                                      11 7
• Indictments of Persons or Firms                              16
• Convictions of Persons or Firms                              39
• Administrative Actions Taken Against EPA Employees           13

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 misconduct or poor performance)         24
• Hotline Complaints Received                                31
• Hotline Complaints Processed and Closed                     37
• Proposed Legislative  and Regulatory Items Reviewed           72
• Personnel Security Investigations Adjudicated                 234
                                                                                                  OFFICE OF THE INSPECTOR GENERAL

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    Establishment of the OIG  in EPA-lts  Role and Authority
 The Inspector General Act of
 1978 (Public Law 95-452), as
 amended, created Offices of
 Inspector General to
 consolidate existing
 investigative and audit
 resources in independent
 organizations headed by
 Inspectors General.
     EPA established its Office
 of Inspector General (OIG) in
 January 1980.  As an agency
 with a massive public works
 budget, EPA is vulnerable to
 various kinds of financial
 abuses.  The OIG's role is to
 review EPA's financial
 transactions, program
 operations, contracts, and
 administrative activities;
 investigate allegations or
 evidence of possible criminal
 and civil violations; and
 promote economic, efficient,
 and effective Agency
 operations. The OIG is also
 responsible for reviewing EPA
 regulations and legislation.
     The EPA Inspector
 General  reports directly to the
 Administrator and the
 Congress and has the
 authority to:

• Initiate and carry out
independent and objective
audits and investigations,
• Issue subpoenas for
evidence  and information,
• Obtain access to any
materials  in the Agency,
• Report serious or flagrant
problems to Congress,
• Select and appoint OIG
employees,
• Fill Senior Executive Service
positions,
• Administer oaths, and
• Enter into contracts.
    The Inspector General is
appointed by, and can be
removed only by, the
President.  This independence
protects the OIG from
interference by Agency
management and allows it to
function as the Agency's fiscal
and operational watchdog.

Organization and
Resources

The Office of Inspector
General functions through
three major offices, each
headed by an Assistant
Inspector General:  Office of
Audit, Office of Investigations,
and Office of Management.
Nationally, there are seven
Divisional Inspectors General
for Audit and five Divisional
Inspectors General for
Investigations who direct staffs
of auditors and investigators
and who report to the
appropriate  Assistant Inspector
General in Headquarters.
    For fiscal 1992, the Agency
was appropriated
$6,668,853,000 and authorized
17,569 full time equivalent
(FTE) positions to conduct the
environmental programs
authorized by Congress to
restore and  protect the
environment.  As a separate
appropriation account,  the
Office of Inspector General
(OIG) received $41.2 million to
carry the provisions of the
Inspector General Act of 1978,
as amended.  Nearly $15
million of the OIG's
appropriation was derived from
the Hazardous Substance
Superfund trust fund and
$623,000 was derived  from the
Leaking Underground Storage
Tank trust fund. The OIG has
an approved staffing level of
366 FTE positions.  The
funding and FTE available to
the OIG represent 0.6 percent
and 2.1 percent, respectively,
of the Agency's totals.
Comparisons of the OIG's
resources to the Agency's and
allocation of the OIG's
resources to its audit,
investigation, and management
functions for fiscal 1992 are
shown on the following page.

Purpose and
Requirements of the
Office of the
Inspector General
Semiannual Report

The Inspector General Act of
1978 (Public Law 95-452), as

Source
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 it.
    The specific reporting
requirements prescribed in the
Inspector General Act of 1978,
as amended, are listed below.
                                                     Section/Page
Inspector General Act, as amended.

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

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

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

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

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

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

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

Section 5(a)(8), Statistical Table 1-Reports With Questioned Costs       2

Section 5(a)(9), Statistical Table 2-Reports With Recommendations
               That Funds Be Put To Better Use              2
                                                                 Section 5(a)(10), Summary of Previous Audit Reports Without
                                                                                  Management Decisions.
                                              Appendix 2
                            34

                            10


                            10


                            57

                            30



                            40

                            10

                            28


                            28


                            57


                            57
                                                                 Section 5(a)(11), Description and Explanation of Revised Management
                                                                                Decisions                         Appendix 2

                                                                 Section 5(a)(12), Management Decisions with Which the
                                                                    Inspector General Is in Disagreement                        **

                                                                 • 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.
 OCTOBER 1,1991 THROUGH MARCH 31.1992

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                                     OIG vs Agency Resources-FY 1992
               Dollars in Mil/ions
  FTEs
                                                    OIG
                                                   '41.2
                                                        OIG,
                                                        366
                                          Distribution Of OIG Resources
           Funding = $41.2 Million
FTEs = 366
* Each year a portion of the OIG appropriation is
provided to EPA for common support items, such
as office space, utilities, communications, ADP services,
transportation, mail and copy services, and security
                                                                                         OFFICE OF THE INSPECTOR GENERAL

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

                                                 Anna Hopkins Virblck
                Office of Audit
                Kenneth A. Konz
                Assistant Inspector General
                James O. Rauch
                Deputy
Office of Investigations
Daniel S. Sweeney
Assistant Inspector General
Vacant
Deputy
Office of Management
John C. Jones
Assistant Inspector General
                    Operations Staff
                    Ellssa R. Karpf
                    Director
                                     Technical Assessment and
                                     Fraud Prevention Division
                                     Vacant
                                     Director
                   I Technical Assistance Staff
                    Gordon Milbourn
                    Director
                                     Administration and
                                     Management Services
                                     Division
                                     Michael Binder
                                     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 Tmsley, Audit
                                                                     Region 4 & 6
                                                                     Mary Boyer, Audit
                                                                     James r. 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
OCTOBER 1,1991 THROUGH MARCH 31.1992

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  Section 1-Significant Problems, Abuses and Recommendations
As required by sections
5(a)(1) and (2) of the
Inspector General Act of
1978, as amended, this
section identifies significant
problems, abuses, and
deficiencies relating to the
Agency's programs and
operations along with
recommendations for the
current period.  The findings
described in this section
resulted from audits and
reviews performed by or for
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 six areas:
Summary of Audit Activities
and Results, Agency
Management, Construction
Grants, Other Grants and
Contracts, Superfund, and
Special Reviews.
Summary of Audit
Activities and
Results
 Questioned Cost And Recommended
 Efficiencies By Type Of Assignments
 (in Millions of Dollars)
 "100
                                                                Federal Questioned
                                                           |	1  Federal Share
                                                                Recommended Efticiencies


                                                                Non-Federal Questioned
                                                           r   i  Non-Federal
                                                                Recommended Efficiencies
        Construction
Others
                Superfund
                                    Areas Of Effort By Staff Days
                                Financial & Compliance
                                8307-36%
                                                               LUST - Performance
                                                               67-0%
                                                               LUST - Financial & Compliance
                                                               196-1%
                                                 Superfund Performance
                                                 2677-12%
                                       Total -22,810 Days
10
                                                                                   OFFICE OF THE INSPECTOR GENERAL

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 Agency
 Management
 The Inspector General Act
 requires the DIG 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.
 Mismanagement Of
 Contractor
 Jeopardizes
 Agency's Control Of
 Operations And
 Procurement
 Practices

 Problem

 A general laissez-faire
 culture that affected EPA's
 management of its support
 contract with the Computer
 Sciences Corporation (CSC)
 resulted in (1) lessened EPA
 control over critical program
 activities; (2) the creation of
 a personal services
 relationship between CSC
 and EPA; (3) CSC's
 performance of inherently
 governmental functions; (4)
 potential conflict of interest
 situations; and (5) ineffective
 and inefficient use of
 Agency resources.

 Background

 EPA has contracted with CSC
 since the early 1970's for
 technical and operational
 computer systems support.
 CSC has provided such
 support nationwide  for almost
 12 years and now provides
 services to almost every  EPA
 office and major information
 system. Our audit generally
 covered the management of a
 contract awarded to CSC in
 September 1990 with a 5-year
 term and a maximum value of
 $347 million.

 We Found That

 EPA's mismanagement and
 lack of control over CSC's
 activities permitted numerous
 prohibited and improper
 actions  by both Agency and
 contractor staffs as  described
 below.

• Lessened  Agency Control
 Over Critical Program
 Activities. EPA's heavy
 reliance on CSC for
 development, enhancement,
 operation, and maintenance of
 most of its critical information
 and financial management
 systems has made the Agency
 extremely dependent on the
 contractor at the expense of its
 own control over critical
 program operations. CSC had
 substantial involvement with 17
 information systems ranked as
 "high risk" or "very high risk"
 because they contain
 sensitive, mission  critical data
 and 14 additional systems
 ranked as "moderate risk"
 because they potentially
 contain  sensitive, mission
 critical data. The contractor
 failed to adequately document
 systems it developed, and
 EPA had not retained sufficient
 expertise in some  systems'
 design and operation to
 properly monitor and control
 contractor activities or
 independently operate the
 systems.  For example, all
 primary technical knowledge of
 the National Contract Payment
 System resided with CSC staff,
 and EPA managers and staff
 referred the DIG to CSC
 personnel for assistance in
 obtaining payment information.
    In addition, neither EPA
 nor CSC performed adequate
 background investigations of
 CSC staff. In one  case, a
 CSC computer center
 employee, who had been
 arrested on numerous counts
 of fraud against various federal
 programs, had access to
 critical program support
 systems and data.

• Provision of Personal
 Services.  EPA administered
 the CSC contract as a
 personal services contract, in
 violation of Federal
 procurement regulations.  An
 employer-employee
 relationship developed
 between EPA and  CSC largely
 because EPA assumed
 responsibilities  for  supervising,
 hiring/firing, evaluating,
 promoting, and training CSC
 employees who performed
 critical Agency functions on
 site. Personal services
 contracts (1) circumvent civil
 service laws which require
 Federal agencies to obtain
their employees by direct hire
and within  Office of
 Management and Budget
 (OMB) personnel ceilings and
 (2) inappropriately augment
 Agency staff without proper
 legislation.

 • Performance of Inherently
 Governmental Functions.
 CSC's potential technical
 control over certain EPA
 systems/activities and
 participation in preparing
 delivery orders under the
 reviewed contract created the
 appearance of the contractor
 performing inherently
 governmental functions. This
 practice did not comply with
 OMB Circular A-76 which
 requires that tasks so
 intimately  related to the public
 interest be performed only by
 Federal employees.  On 23 of
 26 sampled delivery orders,
 CSC employees performed
 functions critical to the
 accomplishment of the
 Agency's mission. For
 example, CSC employees
 were  instrumental in
 developing and  maintaining
 many information systems
 critical to the Agency. CSC's
 extensive  involvement in these
 systems resulted in CSC's
 staff possessing "institutional
 knowledge" necessary  for the
 efficient and effective
 accomplishment of the
 Agency's program goals.
    Also, CSC employees
 performed tasks, such as
 preparing  responses to
 Freedom of Information Act
 (FOIA) requests and providing
 information to the public (often
 representing themselves as
 EPA employees). The Agency
 expended substantial time and
 money to train, equip,
 supervise, and develop CSC
 employees to  provide them
 with the unique and necessary
 skills to perform these tasks.

• Potential Conflicts of
 Interest.  Potential conflicts of
 interest of both an
 organizational and personal
 nature existed in CSC contract
 operations. In effect, an
 organizational conflict of
 interest existed because CSC
 assigned  itself work and
 managed its contract with
 EPA.  Specifically, CSC helped
 prepare the statements of work
OCTOBER 1,1991 THROUGH MARCH 31 1992
                                                                                                                     11

-------
for 20 of 26 delivery orders
which we reviewed, including
the number and type of labor
categories needed to perform
the desired tasks. EPA's
delivery order project officers
(DOPO) used CSC to assist in
developing delivery orders
because they were uncertain
of the needs or lacked
expertise relating to the tasks
to be performed. EPA
personnel appeared
unconcerned that CSC
managers in this role might be
more interested in maximizing
profits for CSC than  ensuring
that the services were
provided at the lowest cost.
   Daily close interaction
between CSC and EPA
personnel for over a decade
increased the risk of individual
conflicts of interest because of
the free movement of
personnel between  EPA and
CSC.  The close relationship
resulted in less than arm's-
length transactions between
EPA and the contractor. For
example, EPA DOPOs
recommended labor upgrades
for CSC staff who did not
qualify as a way to give a
valued CSC staff member a
pay raise.  EPA managers also
requested cash and
performance recognition
awards for CSC personnel.  In
one instance, CSC staff
received Gold and Bronze
awards, two of the Agency's
highest awards, which are
normally reserved for Agency
staff.  CSC on-site managers
had a profound influence on
DOPOs who often followed
their recommendations without
analyzing the need or benefit
to the Agency.

• Ineffective and Inefficient
Use of Resources.  EPA
DOPOs allowed CSC staff to
perform activities that were
outside the scope of the
contract and individual delivery
orders.  The Agency incurred
costs in excess of $192,000
for unallowable activities in
situations where the
associated cost could be
calculated.  Under 13 of 26
delivery orders reviewed, CSC
employees performed tasks
that were not included in the
approved statement of work or
which were not permitted
under the contract, but should
more appropriately be
performed by Federal
employees.
    In addition, EPA spent
$154,000 for CSC's employees
to attend unnecessary or
professional development
training for which the
contractor should have paid.
The general attitude at EPA
was to consider CSC staff as
"part of the EPA family" and to
assume responsibility for
maintaining their expertise and
development.
    Further, EPA did not
adequately  monitor the time of
CSC employees nor implement
internal controls to ensure that
idle or  improper time was not
charged to the contract.
Although the total hours of idle
time could not be determined,
instances were noted in
several locations where CSC
employees  either were not
working or participated in
activities  not included in
delivery orders' statements of
work.  Additionally, CSC
employees' time was
inappropriately charged for
their attendance at EPA
functions, such as regional
picnics, retreats, sexual
harassment training,
luncheons,  and holiday
celebrations.

• Accountability of
Government Furnished
Property. Hundreds of
thousands of dollars worth of
government property furnished
to and  acquired by CSC under
contracts had not been
properly accounted for or
adequately  protected. Despite
problems with CSC's property
control system and equipment
furnished under prior contracts,
EPA awarded the contract with
no restrictions on CSC's
acquisition of additional
equipment.  In addition, CSC's
use of  government furnished
property was not properly
supported in delivery order
justifications.  As a result,
equipment costs under the
contact were not properly
justified and EPA incurred
excessive costs on equipment
leased by CSC for  use under
the contract.
We Recommended That

The Acting Assistant
Administrator for
Administration and Resources
Management:

• Increase the use of Agency
employees and award multiple
contracts for development,
operation, and maintenance of
major Agency information and
financial systems to increase
system security and reduce
Agency reliance on any one
contractor for support.

• Require at least minimal
background investigations for
contractor personnel with
access to sensitive Agency
data or systems.

• Eliminate CSC's activities
that create potential conflict-of-
interest situations and the
appearance of less than arm's
length transactions with
Agency staff.

• Ensure proper accountability
for government furnished
property in CSC's possession
and adequate justification of
equipment costs incurred
under the contract.

The Deputy Administrator
require the Acting Assistant
Administrator for
Administration and Resources
Management:

• Issue comprehensive
guidance for EPA contract
management  staff describing
prohibitions against personal
services relationships with
contractor staff, with emphasis
on limitations  relating to
supervising, hiring, and
evaluating individuals.

• Evaluate tasks performed by
contractor staff to ensure that
such work is appropriate and
ensure that inherently
governmental functions are
performed by EPA employees.

• Have the contracting officer
and project officer monitor
monthly contractor progress
reports for indication of tasks
being performed which  are
outside the scope of the
contract or delivery orders'
statement of work.

What Action Was Taken

The final audit report
(2100295) was issued to the
Administrator on March 31,
1992. A response to the
report is due by June 29,
1992. EPA generally agreed
with the findings and
recommendations in the draft
report and initiated actions to
correct the conditions
identified.  As a first step,  the
Acting Assistant Administrator
issued a memorandum to the
Agency's top managers on
February 28,  1992, outlining
the initial actions to be taken
to  correct the abuses
described in the draft report.
After $581 Million
And 27 Years Of
Mismanagement,
Puerto Rico Still Fails
To Meet Water
Standards

Problem

Despite receiving an
additional $142.4 million
from EPA since our 1987
report, the Puerto Rico
Aqueduct and Sewer
Authority (PRASA) still was
not properly  operating and
maintaining its wastewater
treatment facilities, nor
meeting Clean Water  Act
standards. The people of
Puerto Rico continue to be
deprived of the
environmental and public
health benefits which these
facilities could  provide.

Background

In 1986, we reported that poor
internal controls,
procrastination, and lax
enforcement prevented
PRASA's wastewater
management  programs from
achieving an acceptable level
of pollution control  after 21
years of Federal financial
participation.  A 1987 followup
report noted some
improvement  in  financial
operations  but little progress in
12
                                                                                            OFFICE OF THE INSPECTOR GENERAL

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Turbid final effluent In chlorine tank
(photo by OIG staff)
correcting numerous operation
and maintenance deficiencies.

We Found That

After nearly 27 years of
Federal financial participation
totaling $581 million,
together with numerous court
ordered actions, PRASA
continued to be a poorly run
utility. As the current
management team  presented
plans for a total reorganization,
PRASA was still experiencing
major difficulties in
administering a wastewater
management program capable
of achieving a consistently
acceptable level of  water
pollution control.
    PRASA's staff increased
approximately 22 percent in
the 5 years, while suffering
from high turnover in key
management positions,
numerous terminations, and an
inability to fill vital vacancies at
wastewater treatment plants.
PRASA has not been strong
enough financially to effectively
operate and maintain a
successful wastewater
treatment program. PRASA's
financial position was
overstated because provisions
were not made for
uncollectible receivables of
$21.6 million, identifiable bad
debts ranging from  $2.9 to $14
million were not written off,
 large accounting adjustments
 were not sufficiently supported,
 and appropriate accounting
 procedures and practices were
 not always followed.  Also,
 sufficient revenues were not
 being received  because of
 ineffective and inefficient
 collection procedures.
    Our on-site  tours of 23
 wastewater facilities found
 improvement in the operation
 of some facilities.
 Notwithstanding these
 improvements, significant
 deficiencies still remained at
 many of PRASA's wastewater
 treatment facilities. Many of
 PRASA's facilities were
 noticeably understaffed, poorly
 operated and maintained,
 undersupplied and violating
 National Pollutant Discharge
 Elimination System and Clean
 Water Act requirements.
 PRASA's highly bureaucratic
 organizational structure caused
 inordinate delays in equipment
 repair or replacement, did not
 provide sufficient training, and
 did not hold managers
 accountable for safety
 violations until an accident
 occurred.

 We Recommended That

 The Regional Administrator,
 Region 2:

• Work with senior EPA
officials to obtain an
unqualified commitment from
PRASA's Board of Directors to
continue the corrective actions
they have proposed.

• Closely monitor the progress
of PRASA's reorganization
plan relative to the issues
presented in our audit report.

• Make the award of any
future Federal grants
conditioned on PRASA
achieving acceptable progress
in implementing the
reorganization plan and more
significant improvement in
PRASA's operations.

What Action Was Taken

The final audit report
(2400014) was issued to the
Regional Administrator, Region
2, on January 13, 1992.  In his
April 15, 1992, response to the
final report, the Regional
Administrator agreed with the
report's major findings.  He
added that the Agency's
sustained rigorous
enforcement approach has
produced an increasing level
of compliance with the Clean
Water Act requirements at
PRASA treatment plants,
particularly in the last 4 years.
EPA  Lacks Control
Over Automatic Data
Processing (ADP)
Contracts

Problem

EPA had not established an
adequate contract
administration process to
ensure that contracted ADP
services are effectively and
efficiently accomplished. In
addition, EPA had not
prepared required analyses
to ensure that ADP services
are acquired at the lowest
cost under existing and
proposed contracts.

Background

Effective information resources
management is crucial to
EPA's accomplishing its
mission.  Vast amounts of data
 are accumulated in Agency
 ADP systems and  used for
 such things as management
 and scientific decision making
 and reporting to Congress and
 the public. As of February
 1992, EPA had 10 existing or
 pending multi-year ADP
 support services contracts,
 each of which had an
 individual  maximum ceiling
 value over $30  million;  six
 existing ones totaling $930.2
 million and four pending award
 totaling $629 million.

 We Found That

 EPA did not have an effective
 contract administration  process
 for ADP support services
 contracts.  Two major ADP
 support services contracts with
 an aggregate ceiling price of
 $487 million lacked minimum
 standards or meaningful
 criteria for Agency acceptance
 or rejection of contractor
 support services.  In addition,
 these contracts generally did
 not contain adequate
 statements of work to enable
 the contractor to work
 independently and prepare
 reasonable cost estimates.
    As a result,  EPA cannot be
 assured that its contracted
 ADP support services will be
 effectively and efficiently
 accomplished, possibly
 increasing (1) the development
 and maintenance costs
 associated with  these services,
 (2) data integrity problems, (3)
 the risk of disruption in  normal
 operations, and (4) its
 dependency on contractors.
 The weaknesses could also
 adversery affect the quality of
 ADP support services received
 under other existing and
 pending ADP support services
 contracts valued at over $1.1
 billion.  Further, contrary to
 Federal policies and
 procedures for the acquisition
 of ADP support services,  EPA
 had not:

• Prepared prescribed
 requirements analyses,
 including analyses  of
 alternatives based on costs,
 for services to be provided
 under three existing contracts
 and two pending contracts
 valued at almost $1.2 billion.
OCTOBER 1,1991 THROUGH MARCH 31.1992
                                                                                                                       13

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As a result, EPA had no
assurance that these contracts
represented the lowest cost
alternative for acquiring these
services.

• Aggregated the costs to be
incurred under the three
existing contracts having
values totaling $651  million for
ADP equipment,  proprietary
software, maintenance
services, and ADP services,
giving the appearance of
splitting its requirements
among multiple contracts in
violation of its Delegation of
Procurement Authority (DPA)
from GSA to make such
purchases.  Therefore, the
Agency also has no  assurance
these contracts represent the
lowest overall cost to the
Federal Government.

We Recommended  That

The Acting Assistant
Administrator for
Administration and Resources
Management:

• Add to  the Agency's contract
management program Agency-
wide mandatory and formal
information  resources
management standards,
project management guidance,
and system development
methodology to efficiently
manage ADP support services
contracts and information
resources.

• Establish  procedures to
accumulate costs on ADP
support services contracts for
(1) ADP equipment,  (2)
proprietary software, (3)
maintenance services, (4) ADP
services, and (5) ADP support
services to  ensure that the
Agency obtains prior approvals
from GSA when purchases are
expected to exceed
established thresholds.

• Complete prescribed
alternative analyses  on current
and proposed ADP support
services contracts to help
ensure that the Agency
chooses the most
cost-effective acquisition
alternatives and meets GSA's
DPA requirements.
What Action Was Taken

The final audit report
(2100300) was issued to the
Acting Assistant Administrator
for Administration and
Resources Management on
March 31, 1992.  A response
to the final report is due by
June 29, 1992.  In an interim
response to  our draft report,
the Director,  Office of
Information Resources
Management, Office of
Administration and Resources
Management, agreed with
most of our recommendations
and indicated their
implementation would
strengthen the information
resources management
program and contract
administration.
Underground  Storage
Tank Inventory Not
Reliable

Problem

The national inventory of
underground storage tanks
(VST) Is unreliable for
allocating resources and
measuring EPA's progress
in minimizing the impact of
leaking tanks on human
health and the environment.

Background

Because groundwater provides
drinking water for half of the
Nation's population, the
potential environmental impact
of underground tanks leaking
petroleum products and other
hazardous substances is
significant.  The Solid Waste
Disposal Act Amendments of
1984 provided for the
establishment of  a program to
prevent, detect, and clean up
environmental impacts from
these tanks. Through a
mandatory notification process,
States obtain information from
tank owners for developing
and maintaining inventories of
regulated tanks from which
EPA develops a  national
inventory.  EPA's current
inventory shows  there  are
about 1.8 million  tanks subject
to Federal regulation.
We Found That

EPA cannot adequately
determine the progress being
made to abate the
environmental risk to the
Nation's groundwater from
leaking underground storage
tanks because it does not
maintain a complete and
accurate national inventory.
EPA had not provided
adequate guidance and
oversight to ensure the
accuracy, reliability, and
completeness of the data
provided by the States nor had
EPA required the States to
periodically update their
inventories.
    EPA and the States rely
primarily on tank owners'
voluntary compliance with the
requirement to register their
tanks with designated State
agencies.  However, a large
number of tank owners had
not complied with the
requirement.  Based on
discussions with EPA and
State officials in Region 5 and
the results of State surveys
and other activities that
discovered unregistered USTs,
the national inventory may be
understated by as much as 40
percent for individual States.
As an example, one State in
Region 5 determined that at
least 43 of more than 100
tanks located along a recent
highway project were not
registered.  State officials were
also confused about what
should and should  not be
reported, further reducing data
reliability.
    Because of the unreliability
of the data, the  allocation of
Federal funds to EPA regions
for cleaning up leaking tanks
may be inequitable. Of the
$53.2 million available in fiscal
1991, EPA allocated $38
million to its 10 regions based
on the number of confirmed
releases in the region, the
number of petroleum tanks
reported in the region, and the
region's population that
depended on groundwater as
a primary source of drinking
water. Therefore, to the extent
a region's inventory was
understated or overstated, that
region did not receive an
equitable share of funding for
cleanup of leaking tanks.

We Recommended That

The Assistant Administrator for
Solid Waste and Emergency
Response:

• Assist States in developing
strategies for identifying
unregistered tanks and require
States to update inventory
data on a recurring basis.
Storage tank being inspected for leaks
(photo by Wendell Wojnar, Wisconsin Department of Natural Resources)
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                                                                                             OFFICE OF THE INSPECTOR GENERAL

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 •  Clarity inventory reporting
 criteria and validate inventory
 data received from the States.

 •  Revise the formula for
 allocation of Federal funds to
 the regions for cleanup of
 leaking tanks to exclude the
 number of tanks reported in  a
 region until the reliability of the
 inventory is assured.

 •  Expand reporting
 requirements to include
 information needed to assess
 all program objectives.

 What Action Was Taken

 In responding to our draft
 report, the Assistant
 Administrator agreed to
 implement several of our
 recommendations for
 improving data reliability.
 However, the Assistant
 Administrator did not agree
 that the funding formula should
 be revised or that the inventory
 should be expanded and
 updated periodically. The final
 audit report (2100278)  was
 issued to the Assistant
 Administrator for Solid  Waste
 and Emergency Response on
 March 27,  1992, and a
 response is due by June 25,
 1992.
Construction
Grants
EPA's wastewater treatment
works construction grants and
State Revolving Fund (SRF)
programs are the largest
programs the Agency
administers. Under the
provisions of Public Law
92-500,  as amended, the
Agency  was authorized to
make construction grants
covering 55 percent and, in
some instances, up to 85
percent of the eligible costs of
constructing wastewater
treatment facilities.  During this
semiannual period, $14 million
was obligated on three new
construction grant awards and
90 increases to existing grants.
As of March 31, 1992, there
were 795 active construction
grants, representing $5.4
billion in Federal obligations.
   Amendments to the
construction grants program
are covered in Title II of the
Water Quality Act of 1987.
Section 212 created a new
Title VI in the Clean  Water Act,
which addresses the process
of phasing out the construction
grants program by providing
incentives for development of
alternative funding
mechanisms by the States.
The new Title VI charges EPA
with developing and
implementing a program to
provide grants to capitalize
State  revolving funds for
financing wastewater projects.
During this semiannual period,
$427  million  was awarded for
five continuation SRF grants.
As of March 31, 1992, EPA
had obligated $5.2 billion to 50
States and Puerto Rico under
the State Revolving Fund
program.
OCTOBER 1,1991 THROUGH MARCH 31 1992
                                                                                                                        15

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Los Angeles  Claims
$14.3 Million  Of
Ineligible and
Unreasonable Costs
 Los Angeles
(Questioned
   2  4  6  8  10  12  14  16  18
Millions of Dollars

••• Federal    Non-Federal
Problem

The City of Los Angeles (City),
California, claimed $2,174,976
of ineligible construction, force
account, and engineering costs
and $12,198,906 of
unreasonable costs.

We Found That

EPA awarded a grant for
$14,373,882 to the City for
planning, designing, and
constructing the Los
Angeles/Glendale Water
Reclamation Plant. The
grantee claimed $2,174,976 of
ineligible costs under that
grant, including:

•  $1,400,564 of construction
costs applicable to inoperable,
abandoned, and oversized
equipment;

•  $324,991 of engineering,
force account, and indirect
costs outside the scope of the
project; incurred after the
construction completion date;
or claimed twice;

•  $311,710 of engineering
costs applicable to ineligible
construction or in excess of
the amount supported by
accounting records; and

•  $137,711 of force account
and engineering costs related
to design errors or redesign
work.

   We also questioned
$12,198,906 of claimed costs
as unreasonable because the
grantee did not (1) comply with
special grant conditions
concerning the elimination of
sewage overflows and the
reclamation of wastewater, (2)
maintain force account records
in sufficient detail to
demonstrate benefit to the
project, and (3) limit
engineering fees to the
maximum amount considered
reasonable for this type of
construction.

We Recommended That

The Regional Administrator,
Region 9, not participate in the
Federal share of ineligible
costs ($1,196,237); determine
the eligibility of the Federal
share of unreasonable costs
($6,709,398); and recover the
applicable amount from the
grantee.

What Action  Was Taken

The final report (2300044) was
issued to the Regional
Administrator, Region 9, on
March  13, 1992.  A response
is due by June 13, 1992.
Over $8.4 Million
Questioned On D.C.
Projects  Plagued  By
Delays and Cost
Overruns
 District of Columbia
Millions of Dollars

•• Federal     Non-Federal I
Problem

The District of Columbia
(District) experienced
excessive cost overruns and
significant construction
contract delays at its Blue
Plains Wastewater Treatment
Plant.  In addition, the
District claimed $2,047,749
of ineligible construction
and engineering costs and
unsupported costs of
$6,372,885 for these
projects.

We Found That

EPA awarded seven grants to
the District for construction
projects at its Blue Plains
Wastewater Treatment Plant.
The District experienced
significant cost overruns and
delays in completing
construction and engineering
contracts awarded for these
projects because of
weaknesses in its procurement
policies and practices.  For
example, costs incurred for 14
construction contracts were
$14.7 million, or 18.4 percent,
above initial estimates (the
national average for State and
local government projects is
4.3 percent).  Similarly,  costs
for 11 engineering contracts
exceeded initial estimates by
$5.8 million, or 55.3 percent.
Further, none of the
construction contracts was
completed on time, with delays
averaging 18 months.
   Of the interim costs  of
$53,497,516 claimed by the
District, we questioned
$2,047,749 as ineligible
including:

• $1,387,253 for grit removal
which constituted normal plant
operation  and maintenance;

• $433,848 of engineering
costs exceeding the amount
allowed for design or the
ceiling imposed by the
contract;

• $159,368 for rights-of-way
needed to construct a football
field and a playground;  and

• $67,280 of construction
costs related to design errors,
normal maintenance, and work
unrelated  to the treatment
plant or applicable to another
contract.

   We also questioned
$6,372,885 of inadequately
supported construction,
engineering, equipment, and
facilities costs.
We Recommended That

The Regional Administrator,
Region 3, not participate in the
Federal share of ineligible
costs ($1,535,812); determine
the eligibility of the Federal
share of unsupported costs
($4,779,664); and require the
District to improve the
timeliness of construction
contract completion and
reduce cost overruns.

What Action Was Taken

The special review report
(2300046) was issued to the
Regional Administrator, Region
3, on March 31, 1992. A
response is due by June 29,
1992.
Nearly $8.8 Million Of
Ineligible And
Unsupported Costs
Claimed  For Western
Lake Superior,
Minnesota, Project
                                                              Western Lake Superior SO
Questioned
0 5
10
15
20
25
X
                                                              Millions of Dollars

                                                              IHH| Federal     Non-Federal
Problem

The Western Lake Superior
Sanitary District, Duluth,
Minnesota, claimed $8,595,588
of ineligible construction,
engineering, and administrative
costs.  An additional $166,834
of unsupported costs were
questioned.

We Found That

EPA awarded an $18,325,125
grant to the Western  Lake
Superior Sanitary District to
construct a combined sludge
and solid waste processing
facility. We questioned as
ineligible $8,147,071 of the
16
                                                              OFFICE OF THE INSPECTOR GENERAL

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grantee's claim for designing
and constructing equipment to
prepare solid waste for fuel to
operate a sludge disposal
system. These  costs were
determined to be ineligible
because the equipment was
for a fuel preparation process
rather than a sewage
treatment process.  We also
questioned an additional
$448,517 of the claim as
ineligible, including:

• $370,228 of engineering
costs incurred after the
approved facility's construction
completion date;

• $48,344 of legal and other
administrative costs in excess
of amounts incurred or related
to other projects; and

• $29,945 of construction
costs for ineligible change
orders  resulting from design
errors.

   We also questioned
$166,834 of unsupported
administrative costs, primarily
for salaries.

We Recommended That

The Regional Administrator,
Region 5, not participate  in the
Federal share of ineligible
costs ($6,446,691); determine
the eligibility of the Federal
share of unsupported costs
($125,126); and recover the
applicable amount from the
grantee.

What Action Was Taken

The audit report (2400004)
was issued to the Regional
Administrator, Region 5, on
December 12, 1991. A
response due by March 11,
1992, had not been received
as of April 21, 1992.
 Over $8.7 Million Of
 Ineligible And
 Unsupported Costs
 Claimed For
 Amherst,
 New York, Project
 Millions of Dollars

 §•• Federal
                Non-Federal
 Problem

 The Town of Amherst, New
 York, claimed $5,963,650 of
 ineligible construction,
 engineering, and administrative
 costs. An additional
 $2,739,253 of unsupported
 costs were questioned.

 We Found That

 EPA awarded grants totaling
 $78,171,842 to upgrade the
 Town's existing treatment
 facility; construct facilities for
 transporting and  treating
 excess wet weather flows; and
 for an innovative/alternative
 technology process.  We
 questioned $5,963,650 of the
 grantee's final claim for those
 grants as ineligible, including:

• $4,157,474 of construction
 costs which were outside the
 scope of the project since they
 exceeded the amounts
 approved by the  State of New
 York;

• $1,634,191 of architectural
 engineering fees that were
 outside the scope of the
 approved project or exceeded
 allowable fees; and

• $171,985 of administrative
 costs which were outside the
 project's scope or constituted
 ordinary expenses of local
 government.

   We also questioned
 $2,739,253 of unsupported
costs, including construction
costs for abandoned
structures, pending final
resolution of the grantee's
appeal to EPA for eligibility;
construction and engineering
costs for facilities which the
grantee had not yet
demonstrated as being
capable of operating effectively
during high flow conditions;
costs for installing electric
power lines for emergency
power, pending an EPA grant
amendment providing for their
reimbursement; and
engineering and administrative
costs for which  there was
inadequate documentation.

We Recommended That

The Regional Administrator,
Region 2, not participate in the
Federal share of questioned
costs ($4,433,158); determine
the eligibility of the Federal
share of unsupported costs
($2,046,157); and recover the
applicable amount from the
grantee.

What Action Was Taken

The audit report (2100155)
was issued to the Regional
Administrator, Region 2, on
January 3, 1992. A response
due by April 2, 1992, had not
been received as of April 21,
1992.
Over $6 Million Of
Ineligible Costs
Claimed By  Wayne,
New Jersey
 Wayne Twp, NJ
                                                                                  30
                                                              Millions of Dollars

                                                              •• Federal
                                                              Problem
                                                                             Non-Federal
 $6,273,775 of ineligible
 construction, engineering,
 and administrative costs.

 We Found That

 EPA awarded a grant for
 $21,956,375 to Wayne, New
 Jersey, to upgrade an existing
 wastewater treatment plant
 and build a sewer line,
 additional sludge and grit
 handling  equipment, and a
 sewage flow detention basin.
 We questioned $6,273,775 of
 the grantee's claimed costs as
 ineligible including:

• $6,114,064 of construction
 costs which exceeded the
 grant award amount, were
 incurred after the project
 construction completion date,
 were for litigation costs lacking
 documentation, or were for
 ineligible change orders;

• $156,273 of engineering
 costs which were
 undocumented, exceeded the
 maximum grant amount, or
 related to ineligible
 construction; and

• $3,438 of administrative
 costs related to ineligible
 construction.

 We Recommended That

 The Regional Administrator,
 Region 1, not participate in the
 Federal share of ineligible
 costs ($4,705,332)  and recover
 the applicable  amount from the
 grantee.

 WhatActiqn  Was Taken

 The audit report (2100165)
 was issued to the Regional
Administrator, Region 2, on
January 3, 1992. A response
due by April 2, 1992, had not
been received as of April 21,
 1992.
                                                             The Township of Wayne,
                                                             New Jersey, claimed
 OCTOBER 1,1991 THROUGH MARCH 31  1992
                                                                                                                     17

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San Jose, California,
Claimed Almost $2.9
Million of Ineligible
Costs
 San Jose, CA
                     20
                           25
Millions of Dollars

j^H Federal     Non-Federal
Problem

The City of San Jose (City),
California, claimed $2,864,225
of ineligible construction and
engineering costs for
improvements to its
wastewater treatment facility.

We Found That

EPA awarded a grant to the
City for improvements to the
San Jose/Santa Clara Water
Pollution Control Plant. Of the
$18,535,792 which the grantee
claimed  for the project, we
questioned as ineligible costs
of $2,864,225 including:

• $1,573,910 of construction
costs which exceeded the
grant award  amount; and

• $1,290,315 of engineering
costs and other costs which
were outside the approved
scope of the project or were
incurred prior to the grant
award date or after established
project completion dates.

   We identified $404,524 of
eligible engineering costs not
claimed  by the grantee which
were offset against the
questioned costs.

We Recommended That

The Regional Administrator,
Region 9, not participate in the
Federal  share of net ineligible
costs ($1,844,775) and recover
the applicable amount from the
grantee.
What Action Was Taken

The audit report (2300031)
was issued to the Regional
Administrator, Region 9, on
January 28, 1992.  A response
was due by April 27, 1992.
Other Grants and
Contracts
                              These are independent audits
                              of the records and
                              performance of individual
                              grantees and contractors made
                              in accordance with the U.S.
                              General Accounting Office
                              standards for audit of
                              governmental organizations,
                              programs, activities, and
                              functions. These audits are
                              conducted to determine the
                              degree of compliance with
                              statutes,  regulations, and
                              terms of the agreements under
                              which Federal funds were
                              made available. This includes
                              determining whether costs
                              claimed by the grantee or
                              contractor are eligible,
                              supported by documentation,
                              necessary, and reasonable.
North Carolina State
University Research
Center Claimed $2.1
Million in  Misused
Funds
                                                                                            North Carolina State Univ.
                              Millions of Dollars

                              l^H  Federal
                                                                                                          Non-Federal
                              Problem

                              North Carolina State
                              University (University)
                              claimed $1,173,779 of
                              ineligible costs and $898,206
                              of unsupported costs under
                              a Superfund research grant
                              that were not used for their
                              intended  purposes.

                              We Found That

                              The Superfund Amendments
                              and Reauthorization Act of
                              1986 authorized EPA to
                              establish five university-based
                              Hazardous Substance
                              Research Centers, each of
                              which would serve two EPA
                              regions.  On February 27,
                              1989, EPA awarded North
                              Carolina State University a
                              grant which, as  amended,
                              provided Federal funding of
                              $3,016,080 to establish a
                              research center for EPA
                              Regions 4 and 6.  Following
                              charges of impropriety, EPA's
                              Office of Exploratory Research
                              (OER) terminated funding  for
                              the University in 1991.
                                  The University claimed
                              ineligible costs of $1,173,779,
                              including:

                              • $976,233 for 39 projects that
                              (1) did not relate to the grant's
                              objectives and (2) were
                              conducted under contracts and
                              grants provided by third parties
                              that did not include any EPA
                              or grantee costs.
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                                                                                          OFFICE OF THE INSPECTOR GENERAL

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• $99,783 for indirect costs
related to subcontracted
research projects that
exceeded the amount
authorized by the grant;

• $97,763 for time mischarged
by the Center's Director
(almost all of the Director's
time was charged to the grant
even though he taught three
courses which in the semester
prior to the grant award had
required 61 percent of his
time).

    In addition, we questioned
$898,206 of unsupported costs
for 12 additional projects
determined by EPA's Office of
Exploratory Research as not
being technically eligible.

We Recommended That

The Director, Grants
Administration Division, not
participate in the Federal share
of questioned costs
($1,509,027) and recover the
applicable  amount from the
grantee.

What Action Was Taken

The audit report (2300045)
was Issued to the Director,
Grants Administration Division,
on March 26,  1992. A
response is due by June 26,
1992.
Superfund
Program
The Superfund program was
created by the Comprehensive
Environmental Response,
Compensation, and Liability
Act of 1980 (CERCLA). The
Act provided a $1.6 billion trust
fund 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
provided $8.5 billion to
continue the program for 5
more  years and made 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 for 4 years.
    The parties responsible for
the hazardous substances are
liable for cleaning up the site
or reimbursing the Government
for doing so.  States in which
there is a release of hazardous
materials are required to pay
10 percent of the costs of
Fund-financed remedial
actions, or 50 percent if the
source of the hazard was
operated by the State or local
government.
    The enactment of SARA
increased the audit
requirements for the Inspector
General. In  addition to
providing a much larger and
more complex program for
which the OIG needs to
provide audit coverage, SARA
gave the Inspector General a
number of specific
responsibilities.  Mandatory
annual audit areas include:

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

• Audit of Superfund claims;

• Examination of a sample of
agreements  with States
carrying out response actions;
and

• Examination of remedial
investigations and feasibility
studies.
    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 fourth annual
report, covering fiscal 1990,
was issued on September 25,
1991.
    In addition, the EPA
Administrator must submit a
detailed report to Congress on
January 1 of each year on the
progress in implementing
CERCLA during the preceding
fiscal year.  The Agency has
taken considerably longer to
prepare the report than the 3
months allowed by CERCLA.
The OIG is required to review
this report for reasonableness
and accuracy, and the Agency
must attach the result of the
OIG review to the Agency's
annual report.  On February
11, 1992, we issued our report
(2100237) on the Agency's
fiscal  1990 report which was
transmitted to Congress on
February 25,  1992 (see page
22).
                               Region 3 enforcement investigators sampling contents of 55 gallon drum (EPA photo)
OCTOBER 1,1991 THROUGH MARCH 31  1992
                                                                                                                     19

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Alternative
Contracting Strategy
Fails to Accelerate
Cleanups of
Hazardous Waste
Sites

Problem

Poor contractor performance
and management delayed
the cleanup of hazardous
waste sites under the
Alternative Remedial
Contracting Strategy (ARCS)
program in Regions 1, 3,
and 5.

Background

Superfund was created to
clean up sites contaminated
with hazardous waste.  The
most hazardous sites pass
through various phases during
the remedial or cleanup
process. In the past, different
contractors performed the
various phases of the remdial
process which proved to be
inefficient. In an effort to
expedite cleanups, EPA
decided to change its
approach by adopting ARCS.
Under this concept, the
remediation of each site
becomes the responsibility of a
single contractor as long as
performance is satisfactory.

We Found That

ARCS failed to meet the
Agency's goal of expediting
the remediation or cleanup of
Superfund sites in Regions 1,
3, and 5. Of 68 work
assignments issued during the
first 2 years of the ARCS
program, only seven had been
completed as scheduled, 19
had been completed beyond
their schedule, and  most of the
remaining assignments will
have exceeded EPA's goal by
over 1 year (11 by more than
2 years) if completed as
planned. In Region 3, the
cleanup of sites was delayed
because of ARCS contractors'
ineptitude. Delays in Regions
1 and 5 were attributed to
misdirected site samples,
inexperienced contractor and
EPA personnel, and a lack of
adequate contractor personnel.
    ARCS contracts were not
being fully used for several
reasons, including  built-in
excess capacity to allow for
the termination of contracts in
the event of poor performance,
less cleanups being available
because responsible parties
were performing  more
cleanups than anticipated, and
contractors were experiencing
great difficulties reaching the
remedial action stage of the
cleanup. As a result, program
management rates  incurred by
18 of 19 contractors reviewed
in the three regions were as
much as quadruple the
percentages of program
management costs to total
contract costs projected over
the 10-year term of the
contracts.  In addition, two
other goals of
ARCS—increased efficiency
and accountability-were not
being achieved because the
regions did not prepare
independent Government cost
estimates of work assignments
and subsequent increases to
effectively evaluate and
negotiate reasonable prices
proposed by contractors. The
Agency  lacked the experience,
knowledge, and adequate cost
data bases to prepare these
estimates.

We Recommended That

The Assistant Administrator for
Solid Waste and  Emergency
Response and the Acting
Assistant Administrator for
Administration and Resources
Management emphasize to
Regional Administrators the
need to:

• Reassess the ARCS
capacity required for the
duration of the contracts;

• Terminate for default the
ARCS contractors with the
worst performance  records;

• Withhold all award fees for a
work assignment when lack of
performance causes delay;
and

• Prepare independent
Government estimates for all
ARCS work assignments and
for all subsequent requests for
revision of work assignments.

What Action Was Taken

The final audit report
(2100209) was issued to the
Assistant Administrator for
Solid  Waste and Emergency
Response and the Acting
Assistant Administrator for
Administration and Resources
Management on February 3,
1992. A response to  the final
report is due by May 3,  1992.
In response to our draft report,
the Assistant Administrator for
Solid  Waste and Emergency
Response stated that the
Agency accepted our
recommendations, except for
terminating the ARCS
contractors with the worst
performance records.  He
stated that such termination
would have to be based on
overall unsatisfactory
performance, which had not
been encountered. According
to the Assistant Administrator
most of our concerns  had
been addressed in the
Administrator's October 1991
Task Force Report entitled,
"Implementation of the
Superfund Alternative
Remedial Contracting Strategy
(ARCS).11 A November 1991
Agency plan further elaborated
on the corrective actions to
implement the report's
recommendations.
Searches For
Potentially
Responsible  Parties
Need  Improvement In
Regions 2 and 7

Problem

Searches in  Regions 2 and 7
for potentially responsible
parties (PRP) were not timely,
complete, or well documented,
resulting in unnecessary costs
and delays in getting polluters
to accept responsibility for
cleaning up their hazardous
waste sites.
We Found That

In Region 2, searches
conducted by EPA contractors
were inadequately managed
and consistently exceeded
period of performance and
estimated hours and costs.  All
seven reviewed searches
conducted by contractors
exceeded their original level of
effort hours at an additional
total cost of $95,029.  In
addition, reports were not
prepared for the two reviewed
searches that were conducted
by in-house staff. As a result,
there is no assurance that
searches were performed
timely and that required tasks,
such as gathering site
information and establishing
PRP liability, were sufficiently
completed.
    In all nine cases reviewed
in Region 2, there was
insufficient documentation that
the Region had fully complied
with EPA search  requirements
for obtaining and assessing
necessary financial information
used to determine PRPs'
ability to pay for cleaning up a
site and to decide on
enforcement actions against
PRPs.  Also, Region 2 was  not
effectively using its tracking
system to monitor the status of
search activities and assure
that all PRPs involved in
polluting the site were
identified.
    Region 7 averaged 347
days to initiate baseline
searches to gather information
about the site and its owners,
operators,  and any associated
generators or transporters of
hazardous waste. Searches
(baseline and followup) for 3 of
5 National  Priorities List (NPL)
sites reviewed cumulatively
exceeded the Superfund
program standard by more
than 4 years and searches  for
3 of the 4 reviewed non-NPL
sites exceeded the program
standard by 8 times. The
Region's failure to initiate
timely baseline searches
contributed substantially to the
inordinate  number of days
expended for the site
searches.
    Also, in Region 7, many of
the work assignments,
statements of work, work
20
                                                                                           OFFICE OF THE INSPECTOR GENERAL

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 plans, documentation of
 completed tasks, and search
 reports could not be found.
 Contractors used scientists
 and engineers to locate PRPs
 instead of investigators as
 allowed by the contracts.  As a
 result, the Region duplicated
 work, incurred additional costs
 in identifying responsible
 parties, and encountered
 lengthy delays in establishing
 liability. For 5 of the 9
 reviewed sites, the Region
 increased the contractors' time
 by 9,358 hours at a cost of
 $428,146.  In addition, the
 Region's excessive use of
 cost-reimbursement contracts,
 instead of firm-fixed-price
 contracts, impaired its ability to
 acquire adequate PRP
 searches at the most
 reasonable costs.
    Region 7 did not evaluate
 the adequacy of internal
 controls to ensure that its PRP
 searches were being properly
 conducted.  Further, the
 Regional Administrator had  not
 reported PRP search
 weaknesses or needed
 improvements in the internal
 controls for fiscal years 1989
 and 1990.

 We Recommended That

 The Regional Administrator,
 Region 2:

• Fully implement
 Headquarters' guidance and
 procedures for planning,
 coordinating, tracking,
 monitoring and completing
 search activities in  a timely
 and effective manner and
 implement supplemental
 regional guidance to address
 search team responsibilities.

• Evaluate current  PRP search
 contract management
 practices to ensure that work
 assignments are adequately
 funded and periods of
 performance allow sufficient
 time to complete a  remedial
 PRP search.

• Required standardized PRP
 search reports to be prepared
 for in-house searches.

• Assure that required search
 tasks regarding the
determination and assessment
of all identified PRPs' financial
status is adequately completed
and documented in search
reports.

• Effectively use the regional
tracking system to monitor
efforts to identify PRPs and
develop procedures to assure
all data  regarding information
request letters, responses and
follow-up activities are timely
and accurately entered into the
system.

The Regional Administrator,
Region 7:

• Improve procedures to
ensure that PRP searches are
completed timely and that
available expertise is used to
plan and coordinate searches.

• Use firm-fixed-price contracts
when possible for the
performance of searches and
require contractors to properly
document and provide their
search results.

• Restrict increases of contract
levels of effort, costs, and
performance periods without
adequate justifications.

• Establish better internal
controls over the PRP search
process, perform required
internal control reviews, and
report control weaknesses.

What Action Was Taken

Final audit reports (2100268
and 2100301) were issued to
the Regional Administrator,
Region 2, and the Regional
Administrator, Region 7, on
March 17 and 31, 1992,
respectively. Responses are
due by June 17 and 29, 1992,
respectively. In responding to
the draft reports,  the Regions
stated that they generally
agreed with the findings and
recommendations and have
initiated corrective actions.
 Los Angeles Claimed
 $6.7 Million In
 Questioned Costs
 For Cleanup of
 Hazardous Waste
 Sites Still
 Threatening  Public
 Health

 Problem

 The Los Angeles Department
 of Water and  Power
 (LADWP) ineffectively
 managed its cooperative
 agreement with EPA for
 hazardous waste cleanup
 activities at the San
 Fernando Valley Ground
 Water Basin,  resulting in
 health-threatening
 conditions at several
 adjacent residential
 communities.  Also, LADWP
 claimed $2,321,195 of
 ineligible costs and
 $4,354,690 of unreasonable
 costs.

 We Found That

 EPA awarded  a $13.6 million
 cooperative agreement to
 LADWP for remedial
 investigation activities at the
 San Fernando Valley Ground
 Water Basin and for
 construction of the North
 Hollywood/Burbank treatment
 facility.  LADWP had not
 adequately monitored
 implementation of the Basin's
 health and safety plan as
 required by the cooperative
 agreement, resulting in the
 following conditions:

• Soil contaminated  with
 volatile organic compounds
 was stored improperly in
 uncovered, unmarked,
 unsealed, and easily
 accessible containers at
 several sites.

• Potentially contaminated
 groundwater was stored  in
 unlocked and easily accessible
 tanks at sites which  may have
 been entered by children.

• Signs were not posted at
 several sites to caution the
 public of the potential health
 hazards and the potential
 danger which could result from
 unauthorized entry.

    We questioned $2,321,195
 of the costs claimed by
 LADWP through September
 30, 1990, as ineligible,
 including:

• $1,185,421 of supervision
 and engineering costs based
 on an allocation method rather
 than documentation supporting
 direct charges,

• $805,710 of force account
 costs not supported by
 adequate labor distribution
 records,

• $287,450 in consulting and
 contracting fees that had not
 yet been incurred or paid, and

• $42,614 of contract storage
 and training costs exceeding
 the EPA approved amount.

    We also questioned
 $4,354,690 of costs as
 unreasonable, pending  EPA's
 determination of whether
 LADWP had appropriately
 included a clause required in
 all subcontracts awarded
 under the Superfund program
 which protects EPA from
 potential liabilities.

We Recommended That

The Regional Administrator,
 Region 9:

• Assure that LADWP
 implements the Basin health
 and safety plan and corrects
its financial management
deficiencies.

• Not participate in the
 ineligible  costs ($2,321,165),
determine whether EPA should
participate in the unreasonable
costs ($4,354,690), and
recover the applicable amount
from LADWP.

 What Action Was Taken

The audit report (2300043)
was issued to the Regional
Administrator, Region 9, on
March 13, 1992, A response
to the audit report is due by
July 1, 1992.
OCTOBER 1,1991 THROUGH MARCH 31.1992
                                                                                                                       21

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Special  Reviews
This section in our semiannual
report describes the results of
significant OIG 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.
           Delinquent Superfund
           Reports to Congress
           Have Limited
           Usefulness

           Problem

           For 3 of the last 4 years, EPA
           submitted Superfund annual
           reports to Congress more than
           1 year after their statutorily
           mandated due date,
           significantly reducing their
           usefulness to the Congress.

           We Found That

           EPA's Superfund Annual
           Report for fiscal 1990, its
           fourth  report, was signed by
           the Administrator on February
           12, 1992, and transmitted to
           the Congress on February 25,
           1992.  The report was more
           than a year late. The Agency
           has averaged being 412 days
           late in submitting these reports
           to Congress for fiscal years
           1987 through 1990.
              Some congressional senior
           staff believed the Superfund
           Annual Reports were not
           useful because of their
           untimeliness. Senior staff
           members of the House  and
           Senate Oversight Committees
           stated they had developed
           other sources within EPA to
           obtain information needed to
           make timely decisions and
           monitor the Agency. Further,
           they stated that the Agency's
           annual report could be useful if
           it was  more timely. During
           hearings held the past few
           years on the  implementation of
           Superfund, some members of
           Congress have expressed a
           need for timely annual reports.
Days Reports Were Delinquent

 500      498

 400
459
                     407
                                412
         1987
                   1988
                              1989
                            Fiscal Year
                     1990
                              Average
   The annual reports were
late for several reasons.  With
respect to the fiscal 1990
report, for example, the Office
of Solid Waste and Emergency
Response (OSWER) failed to
adequately plan and monitor
the annual report's
preparation.  Rather than
planning to meet the statutory
January 1, 1991, due date,
OSWER arbitrarily established
a target date for submitting the
report several months later.  In
addition, when requesting
information from EPA officials
for the report, OSWER officials
did not convey a sense of
urgency and importance or
mention the mandatory due
date.
   Also, some of the
statutorily  required information
on feasibility studies,
resources, and minority
businesses must be obtained
from other agencies.  Because
EPA did not receive this
information timely,  preparation
of the report was delayed. In
addition, OMB's mandatory
review of the annual report
accounts for a substantial part
of the lengthy report
preparation process.
   Because the Agency
depends on statutorily required
information from other
agencies and because OMB
must review the report, the
Agency is unlikely  to meet the
January 1  deadline in
submitting future annual
reports to  Congress. These
factors, in our opinion, make
the January 1 deadline
unrealistic. However, the
timeliness of the annual
report's preparation and
submission can  be
substantially improved through
better planning and stronger
oversight by EPA.

We Recommended That

The Assistant Administrator for
Solid Waste and Emergency
Response:

• Stress to officials responsible
for providing the needed
information, the report's due
date and a sense of urgency
for their submission of that
information.
• Consider alternate methods
of preparing the mandatory
estimate of resources and
information on feasibility
studies for the report.

• Encourage, in writing, other
responsible Federal agencies
to more timely submit
information needed on
feasibility studies and minority
businesses.

• Brief OMB officials each year
on the report and significant
changes from prior years'
reports to expedite  OMB's
review.

•  Work through the Office of
Congressional and  Legislative
Affairs to request that during
reauthorization hearings,
Congress consider  extending
the report's due date and
revising its required contents.

What Action Was  Taken

In unofficial oral comments on
the draft report, Agency
officials agreed to take the
report deadline more seriously.
The final report (2400033) was
issued on March 31, 1992. A
response is due by June 29,
1992.
Accreditation
Program Needed To
Ensure Integrity of
Laboratory Data

Problem

EPA lacks assurance that
laboratories performing
studies to support
applications for pesticide
registration are operating in
compliance with the Good
Laboratory Practices (GLP)
program established
pursuant to the Federal
Insecticide, Fungicide, and
Rodenticide Act (FIFRA).

Background

In a September 30, 1991, audit
report, we recommended that
EPA revise its selection
process to target medium- and
small-sized laboratories that
were never inspected for
22
                                                                       OFFICE OF THE INSPECTOR GENERAL

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 compliance with the
 requirements of the GLP
 program. In responding to the
 report, EPA stated that the
 selection process was being
 revised to include more
 uninspected laboratories, but
 additional resources were not
 available to perform more
 inspections. Accordingly, we
 initiated this review to examine
 alternatives used by other
 organizations, both public and
 private, to ensure the accuracy
 and reliability of laboratory
 data.

 We Found That

 The accuracy  and  reliability of
 laboratory data was a major
 concern of public and private
 organizations we visited,
 resulting in many different
 methods of operations. Some
 organizations maintained their
 own laboratories to control all
 studies.  Others used one or
 more contract laboratories.
 Organizations  using contract
 laboratories generally had
 strict pre-selection  criteria,
 including an on-site inspection
 and proficiency testing before
 awarding a contract or
 assigning a study.  Officials
 managing larger programs
 similar to EPA's did not have
 direct control of the laboratory,
 but generally relied on periodic
 laboratory inspections and
 audits of in-progress or
 completed studies to ensure
 the accuracy and reliability of
 data.
    There was general
 agreement among officials
 from various associations and
 accrediting organizations that
 some controls  are needed to
 limit entry into  an accreditation
 program to those laboratories
 that can demonstrate
 proficiency  in the required
 specialty or process. These
 officials believed that a
 laboratory accreditation
 program would fulfill EPA's
 need.  However, while being a
 positive first step toward
 ensuring the accuracy and
 reliability of laboratory data,
 accreditation alone would not
totally solve the Agency's
 problem. To be effective, an
accreditation program should
 be combined with (1)
 proficiency testing in the
 specific technical areas and (2)
 audits of ongoing studies.
    In addition, there was
 almost unanimous agreement
 that, rather than EPA, an
 independent third party should
 conduct the accreditation
 program, supported by
 laboratory fees, with EPA
 providing guidance and
 monitoring.  These officials
 believed that such a program
 would be more readily
 accepted by the industry  and
 would be cheaper and easier
 to manage than a government-
 run program.

 We Recommended That

 The Assistant Administrator for
 Prevention,  Pesticides and
 Toxic Substances:

• Initiate development of an
 accreditation program for the
 FIFRA GLP. The development
 plans should include,  initially,
 provision for laboratory
 inspections and, as the
 program matures, the addition
 of proficiency testing in specific
 technical areas.

• Begin discussions with
 appropriate  organizations to
 determine the feasibility of
 delegating the program to an
 independent third party
 accrediting organization with
 the Agency  acting as the
 program monitor.

 What Action Was Taken

 The Special Review Report
(2400032) was issued to the
Assistant Administrator for
Prevention, Pesticides and
 Toxic Substances on March
31, 1992.  A response to the
report is due by June 29,
 1992.
Alaskan Seafood
Processor's Permit
Should  Be Modified

Problem

EPA Region 10 issued a
National Pollutant Discharge
Elimination System (NPDES)
permit to a seafood
processor without
adequately assessing the
known negative impact on
the water quality of Captains
Bay, Alaska, or enforcing the
permit's conditions.

We Found That

Region 10 issued an NPDES
permit to an Alaskan seafood
processing plant on March 22,
1991, without a conclusive
environmental assessment
(EA) of the impact of its waste
discharges on the Bay's water
quality.  The EA concluded
that there was not sufficient
information to evaluate the
plant's environmental impacts.
Discharges of seafood waste
can smother the food sources
of fish and invertebrate
animals and consume all of
the dissolved oxygen in the
water, thereby eliminating life
in a location. Captains Bay is
a critical source of protection
and food for juvenile fish and
invertebrates, including
economically important species
such as king crab, cod, and
salmon.
    The Region had studies
identifying known water quality
problems in the Bay before
issuing the permit. For
example, an October 1990
survey concluded that seafood
wastes should not be
discharged at the proposed
site because of the Bay's poor
dispersive capacity in the
general area.  A 1977
Dissolved Oxygen Study
reported that natural dissolved
oxygen  levels near the bottom
of the Bay did  not meet water
quality standards and that
dissolved oxygen declined with
increasing depth, indicating
limited mixing with aerated
surface water.  There was no
documentation of how those
studies were considered in the
Region's finding of no
significant impact.
   Also, the Region did not
adequately respond to Federal
and State agencies' and
concerned citizens' requests
for more data before issuing
the permit.  Although the
Region acknowledged that
more data was needed to
understand the water quality
impacts of a new  discharge
into the  Bay, the Region  made
data collection  part of the
permit conditions  instead of
collecting and considering
such data as part of the permit
issuance. A study completed
by the permittee in November
1991 (8 months after the
permit was issued) validated
earlier concerns of the Federal
Captains Bay, Alaska
(photo provided by EPA Region 10, Alaska Operations Office)
OCTOBER 1,1991 THROUGH MARCH 31.1992
                                                                                                                        23

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and State agencies. Dissolved
oxygen levels were found to
be below state water quality
standards at the surface at all
5 monitoring stations near the
plant's discharge outfall,
indicating that the problem was
no longer limited  to the  lower
depths of the Bay.
    Further, the Region  failed
to take timely and appropriate
enforcement action on
numerous violations of the
State water quality standards
and permit conditions even
though the Region was  aware
of the violations for at least 10
months. Violations included
discharging seafood waste
before the permit became
effective, failing to submit
required discharge  monitoring
reports, discharging prohibited
finish waste, and  exceeding
waste discharge limits on at
least 17 different  occasions.
Although the Region could
have assessed penalties in
excess of $425,000 for  these
violations, it did not assess
any until February 1992. By
that time, the Region had
identified over 170 violations.

We Recommended That

The Regional Administrator,
Region 10:

• Modify the NPDES permit
issued to the seafood
processing plant.

• Conduct and document a
new environmental
assessment to properly
support environmental
decisions for the processing
plant.

• Improve procedures to
appropriately address all public
comments made in  response
to environmental assessments
and permit issuance decisions.

• Initiate timely and
appropriate enforcement
actions, including assessing
penalties when permit
conditions and requirements
are violated.
What Action Was Taken

A final special review report
(2400024) was issued to the
Regional Administrator, Region
10, on March 12, 1992, and a
response is due by June 10,
1992. In responding to the
draft report, the Regional
Administrator advised us that
the Region had issued a
$125,000 penalty against the
plant on February 28, 1992, for
certain permit violations and
additional administrative or civil
penalties would be imposed for
other violations.
EPA  May Have Paid
Too Much For Carpet
Cleaning

Problem

Over a 33-month period EPA
obtained carpet cleaning
services without competition
and without determining the
reasonableness of prices.

We Found That

From February 1988 through
September 1990, EPA
obtained more than $137,000
worth of carpet cleaning and
related services at three
Headquarters locations without
competition or determinations
of price reasonableness.
These prices were at least 40
percent more than competitive
prices quoted to the Agency in
1991 for these services.
    Further, the  Procurement
and Contracts Management
Division (PCMD) used an
inappropriate procurement
method- Blanket Purchase
Agreements (BPA)-to obtain
these services.  EPA's
Contract Management Manual
prescribes a $100,000
limitation over a 3-year period
for orders placed under a BPA.
Over just a 13-month period
from August 1989 to
September 1990, the Agency
paid $98,000 for carpet
cleaning services under the
July 1989  BPA,  indicating that
a competitive contract may
have been a more appropriate
method of procuring these
services.
    In August 1990, when
expenditures under the BPA
neared the $100,000 limitation,
the Facilities and Management
Services Division (FMSD)
started procuring carpet
cleaning  services from the
Agency's Waterside Mall
lessor. Because FMSD did
not enforce scheduled  cleaning
under the lease, the Agency
paid twice for some of  these
services—once to the lessor in
rental payments and again to
the lessor or BPA vendors.

We Recommended That

The Acting Assistant
Administrator for
Administration and Resources
Management:

• Direct PCMD to document its
efforts to obtain competition
and make price
reasonableness determinations
to meet the Federal Acquisition
Regulation (FAR) requirements
for procurements made under
BPAs.

• Require PCMD to review all
BPAs approaching the
$100,000 purchase limit to
determine whether
procurement methods other
than small purchase are more
appropriate or necessary to
meet FAR requirements.

• Ensure that FMSD enforces
scheduled cleaning as
provided  in the lease
agreements and ceases
procurements of carpet
cleaning from the lessor
except for emergency
situations.

What Action Was Taken

The special review report
(2400003) was issued  to the
Acting Assistant Administrator
for Administration and
Resources Management on
December 13, 1991.  A
response to the final report
due by March 13, 1992, had
not been  received as of April
21, 1992.
Use Of EPA Fleet
Vehicles and Fuel
Credit Cards
Questioned

Problem

EPA had not provided
adequate oversight and
control of its leased
vehicles, resulting in their
misuse and excessive
operational costs.

We Found That

EPA leased a fleet of large
sedans from a contractor for
the exclusive use of senior
executives. Based on our
analysis of  gasoline purchases
and actual miles driven, the
executive fleet vehicles
averaged only 6.3 miles per
gallon (mpg). The reason for
the low average mpg  could not
be identified because some
gas receipts and Daily Vehicle
Utilization Reports (DVUR)
were missing, DVUR recorded
mileage and monthly odometer
readings did not match,  and
DVURs were not filled out
completely. Documents that
were available raised  serious
questions about the propriety
of some use of executive fleet
vehicles and the Agency's
credit cards.
    Also, EPA did not regularly
analyze and control the use of
the executive vehicles.
Vehicles were used to take
executives from Waterside
Mall to other EPA buildings,
even though the Agency
provides regular shuttle service
to these same  locations.
Further, current fleet mileage
does not support the number
of vehicles in the fleet.
    GSA-leased vehicles were
also underused and poorly
controlled.  EPA currently
leases  18 vehicles from  GSA
for the  use  of EPA
Headquarters employees in
the performance of official
business.  Fifteen of the 18
vehicles did not meet  the
Federal Property Management
Regulations' average  usage
objective of 1,000 miles  per
month. Over the years, the
DIG has consistently raised
concern about underuse of
24
                                                                                          OFFICE OF THE INSPECTOR GENERAL

-------
                                  Section 2-Audit Resolution
 GSA-leased vehicles. In 1983
 usage figures also supported
 retention of less than half of
 the GSA vehicles. Using
 today's rates, the Agency
 could have saved more  than
 $250,000 over this 9-year
 period had it turned in
 underused vehicles.

 We Recommended  That

 The Director,  Facilities
 Management  and Services
 Division:

 • Reduce  the number of
 vehicles in the Agency's fleets
 to meet GSA's minimum use
 standards.

 • Maintain complete  and
 accurate records for  all fleet
 vehicles to ensure that all gas
 purchases and trips are
 justified and to support the
 need for future changes in the
 fleets.

 • Terminate the  commercial
 leases for  10  large sedans  in
 the executive  fleet and obtain
 vehicles through GSA that will
 enable the Agency to meet the
 mandated  fleet average  fuel
 economy rating.

 What Action  Was Taken

 The special review report
 (2400022)  was issued to the
 Acting Assistant Administrator
 for Administration and
 Resources Management on
 March 17,  1992.  A response
 is due by June 17, 1992.
As required by the Inspector
General Act, as amended,
this section contains
information on reports in the
resolution process for the
semiannual period.  This
section also summaries  OIG
reviews of the Agency's
followup actions on  selected
reports completed in prior
periods. In addition,
information is presented on
the resolution of significant
reports issued by the OIG
involving monetary
recommendations.
Appendix 2 summaries the
status of each report issued
before the commencement
of the reporting period for
which no management
decision had been made by
the end of the reporting
period.


EPA Office of Inspector General Status Report On Perpetual Inventory of'Reports in Resolution
Process For The Semiannual Period Ending March 31, 1992

                                                        Dollar Values (in thousands)
                                                            Report Issuance
                                                                            Report Resolution
                                                                             Costs Sustained
                                                 Questioned Recommended    To Be       As
                                              Number Costs    Efficiencies  Recovered Efficiencies
A. For which no management decision has been made
  by the commencement of the reporting period*       296

B. Which were issued during the reporting period      1,044

C. Which were issued during the reporting period
  that required no resolution                       798

   Subtotals (A + B - C)                           542

D. For which a management decision was made during
  the reporting period                            250
348,605   400,002

 71 ,091    72,435


   193     4,321

419,503   468,116


 66,573    85,428
                                                                                                          22,871
13,273
                                E. For which no management decision has been
                                  made by the end of the reporting period

                                  Reports for which no management decision
                                  was made within six months of issuance
                                              292    352,930   382,688
                                                                               99
                                                     283,317   344,730
                               * Any difference in number of reports and amounts of questioned costs or recommended efficiencies between this
                               report and our previous semiannual report results from corrections made to data in our audit tracking system.
OCTOBER 1,1991 THROUGH MARCH 31.1992
                                                                                                                       25

-------
Audit  Followup
The Inspector General Act
Amendments of 1988 have
focused increased attention
on Agency responses to the
findings of the Inspectors
General (IG). Agency
management is now required
to report semiannually, in a
separate report to Congress,
the corrective actions taken
in response to the IG's
reviews. The Office of
Inspector General reviews
the Agency's followup
actions on selected reviews.
Below are summaries of two
of these reviews.
Superfund
Management
Information System
Still  Requires
Significant
Improvements

Previous Problems and
Findings

Our March 1990 report on
the Comprehensive
Environmental Response,
Compensation and Liability
Information System
(CERCLIS) showed that the
reports generated from the
system contained material
errors and could not be
relied upon for Superfund
program decisions and
action.  Reports were
developed and modified
without  effective  controls
over documentation,
software changes, and
testing.  Our June 1990
report questioned the value
of a contractor evaluation of
the Agency's implementation
of CERCLIS because of
insufficient independent
testing and verification of
data management, change
controls, data base integrity,
and security.

Followup Findings

Our followup report (2400027)
found  that the Office of Solid
Waste and Emergency
Response (OSWER) had
implemented several
recommendations from our
prior reports.  However, there
were still significant problems
with the  integrity of CERCLIS
financial  and nonfinancial
information, including (1)
omissions of vital data, (2)
inaccurate computations, (3)
inclusion of erroneous data, (4)
data inconsistencies, and (5)
large accumulations of rejected
and/or unreconciled
transactions over extended
periods.  For example, one
report used by Superfund
program managers in EPA
regions and Headquarters to
track cumulative funding for
remedial and removal events
by site (1) overstated
commitments (authorized
funding for an event) by $1.1
billion and (2) included nearly
$203 million of invalid
unliquidated obligations for
Superfund site cleanups.

Followup Recommendations

We recommended that
OSWER (1) coordinate with
the Office of Administration
and Resources Management
to establish accuracy in
financial and CERCLIS-related
data; (2) include
reasonableness,
completeness, and edit checks
in report programs; and (3)
eliminate documentation
inconsistencies between user
guidance and technical
manuals.

What Action Was Taken

In responding to our draft
report, CERCLIS officials
generally agreed with our
recommendations and  cited
several steps already taken to
correct the noted weaknesses.
According to those officials,
the report that overstated
commitments and included
invalid unliquidated obligations
for Superfund site cleanups
has been removed from the
CERCLIS menus, and  the
Office of Solid Waste and
Emergency Response  and the
Office of Administration and
Resources Management are
working to automatically copy
financial Information from the
Integrated Financial
Management System to
CERCLIS.  The final report
was issued to the Assistant
Administrator for Solid  Waste
and Emergency Response and
the Acting Assistant
Administrator for
Administration and Resources
Management on March 27,
1992. A response is due by
June 25, 1992.
EPA Continued to
Negotiate
Unreasonably High
Equipment Rates on
Emergency Response
Cleanup Services
(ERCS)  Contracts

Previous Problems and
Findings

Our September 1986 report
showed that EPA was in a
poor negotiating position
during the award of the
initial large Superfund ERCS
contracts because of limited
competition and lack of
contractor cost data to
support contractor-proposed
fixed equipment rates. As a
result, when negotiating the
fixed equipment rates, the
Agency relied on prevailing
market rates which had
excessively high markups.

Followup Findings

Our March 27, 1992, followup
report (2100292) found that
the Agency had taken  many
of the actions needed to
improve its use of the ERCS
contracts.  However,  after 10
years, EPA continued to rely
on price analysis rather than
cost data to determine the
reasonableness of fixed
equipment  rates negotiated
with ERCS contractors. EPA
had been awarding contracts
to these contractors during the
period without insisting on cost
data and improvements in their
accounting systems. Also,
competition on these
procurements was still limited.
Because of these problems,
EPA negotiated equipment
rates that were unreasonably
high.  Unaudited annual
contractor cost and usage data
furnished to EPA for two
contracts showed an average
equipment  rate markup of 427
percent for 67 items.
   Our review also showed
that EPA did not obtain
required cost reports from
contractors. This limited the
Agency's ability to develop
reliable cost and pricing
techniques for future
procurements and to ensure
                                                                                       OFFICE OF THE INSPECTOR GENERAL

-------
 the validity and
 reasonableness of costs
 claimed by contractors for
 reimbursement under
 completed delivery orders.

 Followup Recommendations

 We recommended that the
 Acting Assistant Administrator
 for Administration and
 Resources Management
 require the Procurement and
 Contracts Management
 Division (PCMD) to:

 •  Ensure that contractors have
 adequate accounting systems
 before award  or as a condition
 of contract award.

 •  Negotiate fixed rates for
 contractor-owned equipment
 based on actual cost and
 utilization data, or negotiate
 provisional rates if this data is
 not immediately available.

 •  Update and maintain support
 for the Agency's independent
 estimates used for pricing
 techniques and establish
 controls to assure contractor
 compliance with contract data
 requirements.

 What Action Was Taken

 In responding to the draft
 fol/owup report, the Acting
 Assistant Administrator for
 Administration and Resources
 Management generally agreed
 with our recommendations
 regarding the need to obtain
 adequate cost data on fixed
 rate equipment for use in
 contract negotiations.  EPA is
 updating its national data base
 of ERCS labor and equipment
 rates using contracts awarded
 since 1987. Headquarters and
 regional contracting officers
 will be encouraged to use the
 data for price analysis.
Although the Acting Assistant
Administrator believed that
PCMD had made substantial
improvements in contract
management since the 1986
DIG report, he agreed that
further improvements were
necessary. The final followup
report was issued to the Acting
Assistant Administrator on
March 27, 1992, and a
response is due by June 25,
1992.
Status Of
Management
Decisions  On IG
Reports

This section presents statistical
information as  required by the
Inspector General Act
Amendments of 1988 on the
status of EPA management
decisions on reports issued by
the OIG involving monetary
recommendations.  In order to
provide uniformity in reporting
between the various agencies,
the President's Council on
Integrity and Efficiency issued
guidance on reporting the
costs under required statistical
tables of sections 5(a)(8) and
(9)  of the Act, as amended.
    As  presented, information
contained in Tables I  and II
cannot be used to assess
results of reviews performed  or
controlled by this office.  Many
of the reports counted were
performed by other Federal
auditors or  independent public
accountants under the Single
Audit Act.  EPA OIG staff does
not manage or control such
assignments. In addition,
amounts shown as costs
questioned or recommended  to
be put  to better use contain
amounts which were at the
time of the review unsupported
by adequate documentation or
records. Since auditees
frequently provide additional
documentation to support the
allowability of such costs
subsequent to  report issuance,
we  expect that a high
proportion of unsupported
costs will not be sustained.
   EPA OIG controlled reports
resolved during this period
resulted in $11 million being
sustained out of $15.6 million
considered ineligible in reports
under OIG control.  This is a
71 percent sustained rate.
OCTOBER 1,1991 THROUGH MARCH 31.1992
                                                                                                                       27

-------
Table 1—Inspector General Issued Reports With Questioned Cost
Semiannual Period Ending:  March 31, 1992                              Dollar Values (thousands)

A. For which no management decision has been made
by the commencement of the reporting period
B. New Reports issued during period
Subtotals (A + B)
C. For which a management decision was made during
the reporting period
(i) Dollar value of disallowed costs
(ii) Dollar value of costs not disallowed
D. For which no management decision has been made
by the end ot the reporting period
Reports for which no management decision
was made within six months of issuance
Number
156
91
247
108
91
73"
139
57
Questioned* Unsupported
Costs Costs
348,605
70,898
419,503
66,573
22,871
44,338
352,930
283,317
55,086
18,413
73,499
24,131
1 1 ,002
13,766
49,368
31 ,687
 •Questioned costs include the unsupported costs.

"On 17 audits management did not sustain any of the $7,218,657 questioned costs. Fifty-six audits are also
included in C(ii) because they were only partially sustained. Only the costs questioned that were not sustained in
C(i) are included in this category.

                                  Table 2—Inspector General Issued Reports With
                                  Recommendations That Funds Be Put To Better Use

                                  Semiannual Period Ending:  March 31, 1992
Number Dollar Value
(in thousands)
A.
B.

C.





D

For which no management decision has
been made by the commencement of the
reporting period
Which were issued during the reporting period
Subtotals (A + B)
For which a management decision was made
during the reporting period
(i) Dollar value of recommendations that
were agreed to by management
- based on proposed management action
- based on proposed legislative action
(ii) Dollar value of costs not disallowed
(iii) Dollar value of non-awards or unsuccessful
bidders
. For which no management decision has been
made by the end of the reporting period
Reports for which no management decision
was made within six months of issuance
71
37
108
55
21*
n/a
n/a
20*
24
53
25
400,002
68,114
468,116
85,428
1 3,262
n/a
n/a
34,642
37,524"
382,688
344,730
                                  * Ten of the audits were the same audits in items C(i) and C(ii). Only the
                                  related  dollars disallowed were included in C(i), whereas the dollars which
                                  were not disallowed were included in C(ii).

                                  "This amount represents the dollar value of recommendations that funds
                                  be put to better use.

28                                                                                                OFFICE OF THE INSPECTOR GENERAL

-------
Resolution of Significant Reports
Report
litutnca
FS Ouettiontd/
Report Number/ Grant**/
Report Date Contractor
S2CWL9-01-0112 MANSFIELD
MA
1100360
REPORT DATE
8/21/91
P2CW7-02-0228 WESTCHESTER CO
NY
0100139
REPORT DATE
2/1/90
P2CWLO-02-0032 CAMDEN COUNTY
MUANY
1100424
REPORT DATE
9/27/91
P2CWLO-02-0098 NASSAU COUNTY
NY
1100228
REPORT DATE
5/22/91
P2CWL9-02-0164 SAND LAKE
NY
1100270
REPORT DATE
6/27/91
P2CWL9-02-0209 WESTCHESTER
COUNTY NY
1100161
REPORT DATE
4/2/91
P2CWL9-02-0235 ROCKLAND COUNTY
SD NO. 1 NY
1100304
PFPORT DATE
7/9/91
P2CWL9-02-0246 WESTCHESTER
CO-PEEKSKILL, NY
1100136
REPORT DATE
3/4/91
P2CW7-03-0342 LEONARDTOWN
TOWN OF un
i wivii wr Fnu
1200030
REPORT DATE
8/22/91
P2CW8-03-0152 YORK COUNTY OF
VA
1100147
REPORT DATE
3/25/91
P88MN1 -03-01 25 0 4 R MANAGEMENT
CORP MD
1300100
REPORT DATE
8/23/91
P9AHN1-03-0232 ICF TECHNOLOGY
INC. VA
2300003
REPORT DATE
10/17/91
nwtum
INEL

UNSP
UNUR
RCOM
INEL

UNSP
UNUR
RCOM
INEL

UNSP
UNUR
BCOM
I'NEL

UNSP
UNUR
RCOM
INEL

UNSP
UNUR
RCOM
INEL

UNSP
UNUR
RCOM
INEL

UNSP
UNUR
RCOM
INEL

UNSP
UNUR
RCOM
INEL
UNSP
UNUR
RCOM
INEL

UNSP
UNUR
RCOM
INEL

UNSP
UNUR
RCOM
INEL

UNSP
UNUR
RCOM
mvnovu
36,626

0
0
0
459,180

1,398,695
0
0
75,155

551,531
0
0
1,339,316

2,864,704
1,636,565
0
580,617

0
0
0
1,083,074

4,508,544
0
0
777,066

134,044
0
0
39,010

3,083,611
0
0
427,655
177,964
163,504
0
831,776

852,527
0
0
300,164

228,506
0
0
0

0
0
14,327,833
Report
Retolutlon
Federal Share
to be Recovered/'

INEL

UNSP
UNUR
SUST
INEL

UNSP
UNUR
•SUST
INEL

UNSP
UNUR
SUST
INEL

UNSP
UNUR
SUST
INEL

UNSP
UNUR
SUST
INEL

UNSP
UNUR
SUST
INEL

UNSP
UNUR
SUST
INEL

UNSP
UNUR
SUST
INEL
UNSP
UNUR
SUST
INEL

UNSP
UNUR
SUST
INEL

UNSP
UNUR
SUST
INEL

UNSP
UNUR
SUST
Efficiency
36,626

636,606
0
0
442,..b4

619,"»9
0
0
75,155

491,004
0
0
773,644

891,043
0
0
580,617

0
0
0
1,062,316

3,023,762
0
0
777,066

134,044
0
0
39,009

3,011,858
0
0
411,241
0
163,504
0
553,452

81,478
0
0
300,164

228,506
0
0
0

0
0
3,336,368
Resolution of Significant Reports
Report lMu«nc*
FS Quetlioneu/
Report Number/ Grant**/
Report Date Contractor
D8AML1-04-0402 RESEARCH £
EVALUATION ASSOC
1100257
REPORT DATE
6/18/91
D8AML1 -04-0511 RESEARCH £
EVALUATION ASSOC
1100351
REPORT DATE
8/14/91
D8AML1 04-0512 RESEARCH &
EVALUATION ASSOC
1100353
REPORT DATE
8/14/91
S2CWNO-04-0040 MT JULIET
TN
1300092
REPORT DATE
8/2/91
G3HVK1 -05-0081 CINCINNATI MSD
FY890H
1500189
REPORT DATE
12/12/90
Report Ratolution
Federal Share
to b* Recovered/
Recommended
Efficiency

NC




NC




NC













P2CWN7-05-0492 CHICAGO MWRDGC
IL
1300049
REPORT DATE
3/29/91
E2AWP1 -09-01 84 WATSONVILLE,
CITY OF CA
1400062
REPORT DATE
9/30/91


MOTC












INEL

UNSP
UNUR
RCOM
INEL

UNSP
UNUR
RCOM
INEL

UNSP
UNUR
RCOM
INEL

UNSP
UNUR
RCOM
INEL

UNSP
UNUR
RCOM
INEL

UNSP
UNUR
RCOM
INEL

UNSP
UNUR
RCOM



0

0
0
584,644
0

0
0
797,867
0

0
0
2,971,658
440,284

0
0
0
383,205

382,671
0
0
924,861

110,146
0
0
0

0
0
4,272,877



INEL



UNSP
UNUR
SUST
INEL


UNSP
UNUR
SUST
INEL


UNSP
UNUR
SUST
INEL


UNSP
UNUR
SUST
INEL


UNSP
UNU

SUST
INEL


UNSP
UNUR
SUST
INEL


UNSP
UNUR
SUST



NOT b
INEL = INELIGIBLE COST
UNSP = UNSUPPORTED COST
UNUR = UNNECESSARY/UNREASONABLE
RCOM = RECOMMENDED EFFICIENCIES
COST

SUST = RECOMMENDED EFFICIENCIES SUSTAINED












































































































Sustained
Efficiency
0

0
0
584,644
0

0
0
598,433
0

0
0
2,971,658
440,284

0
0
0
383,205

382,671
0
0
798,224

110,146
0
0
0

0
0
4,272,877























OCTOBER 1,1991 THROUGH MARCH 31.1992
                                                                                                                            29

-------
   Section 3-Prosecutive Actions
The following is a summary
of investigative activities
during this reporting period.
These include investigations
of alleged criminal violations
which may result in
prosecution and conviction,
investigations of alleged
violations of Agency
regulations and policies, and
DIG personnel security
investigations.
Summary Of
Investigative
Activities
Pending Investigations as of
October 1, 1991          193

New Investigations Opened
This Period              138

Investigations Closed This
Period                  117

Pending Investigations as of
March 31, 1992          214
Prosecutive and
Administrative
Actions

In this period, investigative
efforts resulted in 39
convictions and 16
indictments. Fines and
recoveries, including those
associated with civil actions,
amounted to $1.27 million.
Thirteen administrative
actions* were taken as a result
of investigations:

Reprimands               7
Resignations/Removals      5
Restitutions              J.
TOTAL                  13

*Does not include suspensions
and debarments resulting from
Office of Investigations
activities or actions resulting
from reviews of personnel
security investigations.
                              Profiles Of Pending  Investigations By Type (Total-214)
                General EPA Programs
                               Superfund And Underground Storage Tank Program
                                                                                                         Other
                                                                                                         1-1%
                 Total Cases- 142
                                             Total Cases - 72
30
                                                          OFFICE OF THE INSPECTOR GENERAL

-------
 Description  Of
 Selected
 Prosecutive
 Actions
 Below is a brief description of
 some of the prosecutive
 actions which occurred during
 the reporting period.  Some of
 these actions resulted from
 investigations initiated before
 October 1, 1991.
Superfund  Contract
Laboratory Program
Investigation

The Office of Investigations
has a major investigative
initiative underway within the
Superfund program, directed at
fraud in the Contract
Laboratory Program (CLP).
Laboratory analyses under the
CLP are the empirical basis for
the entire Superfund program.
Based on testing for the
presence of hazardous
chemicals by these
laboratories, the Superfund
program decides which
cleanups to initiate and how to
carry them out. Fraudulent
analyses could  result in a
danger to the public health and
safety as well as the
unnecessary expenditure of
cleanup funds.  In addition,
fraudulent analyses could
hinder the Department of
Justice's efforts to collect the
cost of cleanups from the
responsible parties.
   Several actions resulting
from the contract lab
investigations are described
below.
                              New York Lab
                              Charged with 40
                              Counts of Fraud

                              The president of Nanco
                              Environmental Services, Inc.,
                              of Dutchess County, New
                              York, and a company
                              employee were  indicted in
                              October 1991 on 40 counts of
                              fraud, including  conspiracy,
                              false statements, mail fraud,
                              witness tampering, and false
                              declarations before a grand
                              jury. The charges are related
                              to analyses of soil and water
                              samples for EPA.  The
                              indictment alleges that Arun
                              Gaind, the president, and
                              Sohail Jahani, a supervisor,
                              engaged in a scheme of
                              setting back the dates on the
                              computer data systems to
                              which Gas
                              Chromatograph/Mass
                              Spectrometer instruments were
                              attached in  order to make it
                              appear that laboratory
                              analyses of samples were
performed within EPA-
approved holding times when,
in fact, they were not.
Lab Company Vice
President Pleads
Guilty

Robert Q. Bradley, vice
president of a Connecticut
company, YWC Inc., pleaded
guilty in October 1991 to
making a false statement to
EPA.  Bradley was sentenced
to 2 years probation and fined
$1,000.
   In December 1990, YWC
Inc. pleaded guilty to 2 counts
of making false statements to
EPA and was fined $500,000.
EPA's contract with YWC
required the company to
analyze water samples within
7 days of receipt and soil
samples within 10 days.
YWC's York Laboratories
Division facility in Monroe,
Connecticut, was an approved
CLP site.  YWC was charged
with backdating over 60
analyses and using a then-
unapproved laboratory at
Whippany,  New Jersey, to do
the analyses.
                              False Test Results
                              Allegedly  Provided
                              Towns, Hospital, EPA

                              As a result of  a joint
                              investigation with EPA's
                              Criminal Investigations
                              Division, Stevens Analytical
                              Laboratories, Inc., Stoneham,
                              Massachusetts, and its
                              president, Alan Stevens, were
                              charged in March 1992 with
                              providing false water quality
                              test results to  several
                              customers, including 2 towns,
                              a hospital, EPA, and the
                              Massachusetts Water
                              Resources Authority. The
                              government alleges that the
                              defendants accepted from
                              customers a large number of
                              samples to be analyzed, failed
                              to analyze them  in a timely
                              fashion, and provided false
                              and fictitious results.
Company Pleads
Guilty, Fined
$500,000

Analytical Services Corporation
pleaded guilty to making a
false claim to EPA for
$31,676.48.  The company
contracted with EPA to
analyze samples to determine
the presence of specified
volatile organic compounds.
The company did not perform
the analyses within the time
period required by EPA.
Analytical Services agreed  to
pay a criminal fine of
$500,000.
                                                                                         Testing Firm,  3
                                                                                         Employees Submitted
                                                                                         False Claims
Environmental Industrial
Research Associates, Inc.
(EIRA), a Louisiana
corporation, and three of its
employees, Annette Mailhos
Savoy, Sylvia I. Leibe, and
Elizabeth Y. Olavesen,
pleaded  guilty in November
1991 to making false claims to
EPA for analyses of soil and
water taken from Superfund
sites. EPA requires the use of
Gas Chromatograph/Mass
Spectrometer (GC/MS)
instruments, properly
calibrated,  in making the
analyses.  Calibration readings
of the GC/MS instruments can
be manually overridden by an
operator, making it seem that
the  instrument is correctly
calibrated.  This avoids the
time-consuming process of
recalibration. The defendants
overrode the readings and
taught other EIRA employees
how to do so, resulting in false
information being submitted to
EPA.
                             Defendants
                             Sentenced, Fined in
                             Texas Telemarketing
                             Scheme

                             Seventeen of 18 individuals
                             indicted in Dallas a year ago in
                             a telemarketing fraud case
                             have been sentenced. All
                             were found guilty. Douglas
OCTOBER 1,1991 THROUGH MARCH 31.1992
                                                                                                                 31

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Cox of Arlington, Texas,
received the longest prison
term, 10 years. He was also
fined $5,577 and court costs,
and will be on probation for 3
years after his release.  The
others sentenced had jail
terms ranging from home
confinement for 4 months to 6
1/2 years in prison.  Another
defendant, United Financial
Group of Beverly Hills,
California, which processed
charge card orders  in the
scheme, was fined $350,000.
   The sentences to the
defendants totalled over 34
years in prison, $352,750 in
fines, and restitution to private
individuals of $101,750.
   These cases resulted from
a joint investigation  by the
EPA DIG and the U.S. Postal
Inspection Service.
Businessman
Sentenced in Bribe
Case

An Illinois businessman,
Ronald Randich, has pleaded
guilty to bribing a Hammond,
Indiana, Sanitary District
(HSD) superintendent.
Randich was placed on 2
years probation, fined $500,
and ordered to pay a $50
special assessment to the
court. During the year in which
the bribe was made, HSD
received over $350,000 in  EPA
grants.  The EPA awarded
HSD over $17 million in grants
from 1984 through 1987.
   This case resulted from an
investigation by the Indiana
State Police in cooperation
with the EPA DIG and the
Indiana  Department of
Environmental Management.
 Defendants Plead
 Guilty to Charges of
 Environmental
 Violations

 Metro Container Corporation,
 Metro-Enterprise Container
 Corporation, and Louis
 Maslow, the chief executive
 officer and majority owner of
 the two former Trainer,
 Pennsylvania, firms, have
pleaded guilty to criminal
violations of two Federal
environmental statutes, the
Resource Conservation and
Recovery Act and the Clean
Water Act, and with conspiracy
to violate these two Federal
environmental statutes.
   A joint investigation by the
EPA OIG, the EPA Criminal
Investigations Division, and the
Federal Bureau of
Investigation was initiated after
a criminal investigation by the
EPA OIG of another allegation
involving the Superfund
program found evidence of
serious environmental
violations.
   As part of the joint
investigation, a search was
executed at the site by
members of the EPA's
National Enforcement
Investigations Center (NEIC).
NEIC personnel excavated
portions of the site where
Metro conducted a drum
recycling business.  Using
heavy equipment, NEIC
personnel excavated portions
of the site where the
hazardous waste was believed
to have been buried.  Buried
drums were uncovered, and
numerous samples taken from
the site revealed the presence
of hazardous waste in the yard
and in the building.  In
addition, the presence of
contaminants was detected in
a pipe leading from the Metro
facility to Stoney Creek, a
tributary of the Delaware River.
Duo Pleads Guilty in
Superfund Fraud
Case

Charles Daniel Workman, an
employee of Geo-Con, Inc., a
Pennsylvania company,
pleaded guilty in October 1991
to a charge of conspiracy to
defraud the U.S. with respect
to claims, in connection with
the cleanup of a Superfund
site at Bruin Lagoon, Butler
County, Pennsylvania.
   Another Geo-Con
employee, Terry Lee Tebben,
pleaded guilty in January 1992
to a count of making false
statements.  Tebben was
sentenced in March to  2
months home detention and 2
years probation.
   EPA funded a $4 million
contract between the U.S.
Army and Geo-Con to clean
up the lagoon, which was
contaminated with, among
other things, sulfuric and
hydrochloric acid.  The
adjacent Bruin Oil Company
had used the lagoon for
disposal of wastes since the
1930's.
   It was anticipated that the
cleanup work would cause the
emission of hazardous gases,
including sulfur dioxide,
creating a potential hazard not
only  to the Geo-Con
employees but also to nearby
residents.
   The indictment alleged that
Tebben used the linger of a
rubber glove and grease to
cover up the air monitors
required by the contract,
causing them to give false
readings on the amount of
hazardous gases being
released, and thereby
endangering public health and
safety.
   Another provision of the
contract required Geo-Con to
treat any water which became
contaminated as a result of the
cleanup.  The company was to
be reimbursed at a rate of $.30
per gallon of water treated.
Workman pumped air through
the water metering system,
leading to $62,000 in false
claims for reimbursement for
water treated.
Missouri Man Admits
Impersonation
Attempt

Timothy Austin, an employee
of a St. Louis, Missouri,
corporation, pleaded guilty to
one count of falsely claiming to
be an EPA employee.  Austin,
identifying himself as an EPA
employee, contacted the
Gaithersburg, Maryland, office
of a major engineering and
construction company and
demanded that the company
provide him a listing of
employees who had both
nuclear engineering and
wastewater treatment
expertise. According to the
indictment, Austin intended to
sell the listing to personnel
recruiting companies, foreign
espionage agents, and others.
City Clerk Pleads
Guilty to Embezzling
$19,000

Betty Nagy, a clerk in the city
Water Department in Chester,
West Virginia, pleaded guilty to
embezzling $19,000 in cash
bill payments received from
Water Department customers.
Nagy transferred money from
a city account containing EPA
grant funds to another account
to conceal her embezzling
activities.
   The case was jointly
investigated by the  Federal
Bureau of Investigation,  the
West Virginia State Police, and
the EPA OIG.
32
                                                                                           OFFICE OF THE INSPECTOR GENERAL

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  Description  Of
  Selected
  Prosecutive And
  Administrative
  Actions
  Concerning  EPA
  Employees
  The DIG 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 Secretary Pleads
Guilty to False
Claims

A secretary in an EPA office in
Arlington, Virginia, pleaded
guilty in October 1991 to a
charge that she stole
$1,616.48 through false claims
for travel. According to the
indictment, the secretary
prepared 33 travel vouchers in
the names of 7 employees in
her office. She then forged
the signatures of the travellers
and the reviewing officials,
added a statement authorizing
her to pick up the claim, and
then went to the Finance
Office at EPA headquarters in
Washington, D.C., where she
received the money.
OCTOBER 1,1991 THROUGH MARCH 31.1992
                                                                              33

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   Section 4-Fraud Prevention and Resource Management Improvements
 This section describes
 several activities of the
 Office of Inspector General
 to promote economy and
 efficiency and to prevent
 and detect fraud, waste, and
 abuse in the administration
 of EPA programs and
 operations. This section
 includes information
 required by statute,
 recommended by Senate
 report, or deemed
 appropriate by the Inspector
 General.
Review Of
Legislation And
Regulations
Section 4(a)(2) of the Inspector
General Act of 1978, as
amended, directs the Office of
Inspector General to review
existing and proposed
legislation and regulations
relating to Agency programs
and operations to determine
their effect on economy and
efficiency and  the prevention
and detection of fraud and
abuse.  This semiannual
reporting period, we reviewed
5 legislative and 67 regulatory
items. The most significant
items reviewed are
summarized below.
Proposed Executive
Order on Integrity
and Efficiency in
Federal Programs

We strongly support the
President's concern for
promoting integrity and
efficiency, and the prevention
and detection of fraud, waste,
and abuse by establishing two
councils of Federal Inspectors
General.  However, we believe
that the role and status of the
Federal Inspectors General
could be diluted by the
proposed Executive Order.
Since the Presidentially-
appointed Inspectors General
are the majority of the Council,
we recommended that they be
listed directly after the
chairperson, and that the Vice
Chair of the PCIE should
explicitly be one of the
Presidentially-appointed
Inspectors General.
   We also suggested that the
role of the Department of
Justice in matters involving  law
enforcement be clarified to
eliminate any ambiguities. We
disagreed with the requirement
for Council members to adhere
to professional standards
developed by the Councils.
The Inspectors General, by
statute, must adhere to the
standards of the Comptroller
General for audit work.
Therefore, we recommended
that the professional standards
referred to specify that they
relate only to non-audit work
(investigations, inspections,
administration).
                                                           Proposed Freedom of
                                                           Information Act of
                                                           1991,8.1939

                                                           We believe that this bill is
                                                           flawed and should be revised.
                                                           The bill proposes the release
                                                           of records or information not
                                                           originally compiled for law
                                                           enforcement purposes.  We
                                                           seriously disagreed with this
                                                           limitation and suggested that
                                                           the word "originally" be
                                                           deleted. The Office of
                                                           Inspector General has
                                                           numerous examples of records
                                                           or information not originally
compiled for law enforcement
purposes, such as audit
working papers, records of
interviews, or analyses of
information, which become
part of investigative files used
for law enforcement purposes.
If this proposal was enacted,
this information, which the OIG
considers pre-decisional and
not required to be released
under the existing Freedom of
Information Act, would have to
be released.
Proposed Electronic
Freedom of
Information Act of
1991, S.1940

We disagreed with the
requirement of this bill that
would make an agency
responsible for making a
reasonable effort to provide
records in electronic form
requested by any person, even
where such records are not
usually maintained in such
form.  We believe that this
could create significant
unnecessary additional
expense to an agency not
equipped for such purposes,
and may cause an agency to
create records in the process
of converting records from
paper form to electronic form
merely to comply with the
statutory requirement.
   We also disagreed with the
requirement to meet expedited
response schedules. The five
day expedited schedule for
responding to or denying
access for a waiver creates
the potential for unnecessary
litigation. The requirement for
strict adherence to schedules
enforced by penalty payments
does not consider the logistical
problems of obtaining and
reviewing geographically
dispersed records. These
potential costs and associated
resources would significantly
interfere with agencies
performing their mission by
requiring an unreasonable
amount of attention and
resources to respond to FOIA
requests.
34
                                                                                         OFFICE OF THE INSPECTOR GENERAL

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Proposed Policy
Letter on Inherently
Governmental
Functions

We supported the Office of
Federal Procurement Policy's
proposal to prohibit the use of
contracts for the performance
of inherently governmental
functions, such as conducting
criminal investigations.  We
also agreed with the  proposed
enhanced degree of
management control  and
oversight when contracting for
functions that are not
inherently governmental, but
closely support the
performance of functions such
as budget preparation,
reorganization, and planning.
   We suggested that, once
the  policy letter is issued, the
Agency may wish to  develop
more detailed guidance to
assist its officials in deciding
whether there has  been an
unacceptable transfer of official
accountability to government
contractors.
 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
contracts or assistance if there
has been a conviction of, or
civil judgment for:

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

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

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

• commission of any other
offense indicating a lack of
business integrity or business
honesty that seriously and
directly affects the present
responsibility of a Government
contractor or subcontractor.
   A contractor may also be
debarred for violating the
terms of a Government
contract or subcontract, such
as willful failure to perform in
accordance with 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 been convicted of an
offense to warrant being
debarred.  Debarments are to
be for a period commensurate
with the seriousness of the
cause, but are generally not to
exceed 3 years.
    The effectiveness of the
suspension and debarment
(S&D) program has been
enhanced by regulations that
provide all Federal agencies a
uniform system for debarring
contractors from receiving
work funded by Federal grants,
loans, or cooperative
agreements. The system,
required by Executive Order
12549, provides that a
nonprocurement debarment or
suspension by one agency is
effective in all agencies and
requires the General Services
Administration (GSA) to
publish monthly a  "List of
Parties Excluded from Federal
Procurement or
Nonprocurement Programs."
Formerly, a nonprocurement
debarment was effective only
in the programs administered
by the debarring agency, and
each agency maintained its
own list.  The EPA Grants
Administration Division
operates the S&D program at
EPA.  The OIG assists the
EPA S&D program by
providing information from
audits,  investigations, and
engineering studies; and
obtaining documents and
evidence used in determining
whether there is a cause for
suspension or debarment.
    The OIG's Suspension and
Debarment Unit works 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 results achieved during
 this reporting period:

           October 1, 1991 to
              March 31, 1992

 Cases completed:

• Suspensions              7
• Debarments              9
• Settlement                8

 Total                     24
The following are examples
of suspension and
debarment actions resulting
from direct OIG involvement:

• Terry Lee Tebben and
Charles Daniel Workman were
suspended from working on
Federal contracts and from
participating in Federal
assistance, loan, and benefit
programs based on their
indictment for fraudulent
activity in connection with the
cleanup of the Bruin Lagoon
Superfund site in Butler
County, Pennsylvania (see
page 32).

• Cavour Yen, a professor at
the University of California at
Los Angeles (UCLA), was
indicted in August 1991, for
allegedly participating in a
scheme to defraud EPA, the
Department of Defense (DOD),
and the National Science
Foundation (NSF) by
submitting fraudulent time
sheets to UCLA on  various
federally-funded research
projects,  and causing UCLA to
unknowingly submit false
claims to EPA, DOD, and
NSF. Based on the
indictment, EPA suspended
Cavour Yeh, EMtec
Engineering, Inc., his affiliate,
and Richard Yeh, Victoria
Hsia, Alan Hsia and Wei Li,
the research employees hired
OCTOBER 1,1991 THROUGH MARCH 31.1992
                                                                                                                    35

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by Cavour Yeh, who were also
indicted, from all Federal
assistance, loan, and benefit
programs.  DOD had
previously suspended all these
parties from direct Federal
procurement.

• EPA suspended American
Coastal Industries, Inc. (ACI),
Anthony Welters, ACI's
president and sole
shareholder, and other
affiliated entities, based  on
information concerning alleged
defective pricing practices on
an EPA contract for  personal
computers and related
products.  ACI allegedly
submitted defective cost or
pricing data to EPA contracting
officials negotiating change
order pricing,  and allegedly
made an unauthorized product
substitution to avoid  a
downward price adjustment.

• EPA proposed to debar
American Management
Systems, Inc. (AMS), and two
of AMS's former employees,
based on information
concerning AMS's alleged
participation in improper hiring
practices and its alleged
submission of false claims
under two EPA contracts.

• An DIG investigation
disclosed fraudulent activity
and misconduct by Edward A.
Kiela (also  known as Edison T.
Kiela), a former EPA
employee, resulting in a loss to
the Government in excess of
$9,000. Mr. Kiela engaged in
on-site consultation work while
being in a "sick leave" status
at EPA, and used his EPA
address,  EPA fax, EPA
telephone, and EPA computer
in providing service as a
consultant to the Southwestern
Power Administration (SWPA),
a Federal agency, in Tulsa,
Oklahoma. The investigation
also disclosed fraudulent
overtime and  compensatory
time claims, personal long-
distance calls charged on the
FTS telephone system,  and
other personal use of a
government computer.  As a
result of the OIG investigation,
EPA debarred Kiela from all
Federal procurement and non-
procurement programs for
three years.

• Barker Steel Company,
Waltham, Massachusetts, and
its president, Robert B. Brack,
were charged in U.S. District
Court with conspiring to
defraud the United States by
allegedly using Rusco Steel
Company as a "front
company," so that certain
expenditures would be credited
to the Minority Business
Enterprise program when they
were not eligible, since they
benefited Barker Steel
Company.  EPA suspended
Barker Steel and Brack in July
1991.  Barker Steel
subsequently entered into a
compliance agreement with
EPA and agreed to be
debarred from Federal
assistance, loan and benefit
programs and from all direct
Federal procurement for 6
months.  Brack resigned as
president of Barker Steel
Company.

• All Star Industries, Inc., and
its former Vice President,
Ronald S. Palmawere,  were
charged with conspiring to
defraud the United States.
The conspiracy consisted of a
continuing agreement,
understanding and concert of
action  among the defendants
and co-conspirators to  submit
collusive, noncompetitive and
rigged bids for pipe to be
supplied under the cost-plus
portion of contracts. EPA has
debarred All Star Industries,
Inc., and Palmawere for 3
years from participating in
Federal procurement and non-
procurement programs.

• Read Asbestos Removal,
Inc., RAR Insulation Inc., and
James Read were involved in
altering National  Asbestos
Abatement Council (NAAC)
accreditation cards.  Read
admitted to OIG investigators
that he "whited out" the names
and social security numbers of
the actual recipients and  had
his secretary type in other
names.  The altered cards
were submitted when
attempting to obtain school
asbestos abatement work.  As
a result, James Read and both
companies were debarred from
participating  in Federal
procurement and non-
procurement programs for 3
years.

• Dominic Nicassio,  Inc. (DNI),
Dominic Nicassio, Western
Pennsylvania Minority
Enterprises Inc. (WPME), and
Eugene Minard all allegedly
participated  in a scheme to
fraudulently  obtain EPA-funded
sewer construction contracts
totalling millions of dollars by
misrepresenting that WPME
was a legitimate minority
business enterprise. EPA
debarred WPME and Minard
for 3 years.  In addition to their
suspensions for 1 year, EPA
debarred DNI and Dominic
Nicassio for  2 additional years.

• In December 1991, EPA
entered into  a compliance
agreement with Gary K. Ward
to terminate  his suspension,
which EPA had taken in June
1991 for alleged violations of
the Federal  post-employment
conflict of interest statute.
Ward, a former EPA
employee, is employed as a
senior scientist by Enseco,
Inc., a laboratory in EPA's
contract laboratory program
(CLP) which performs sample
analyses for EPA's Supertund
program.  Ward agreed not to
communicate with EPA about
any claims Enseco may have
under its CLP contracts with
EPA concerning matters on
which he was involved as an
EPA employee, and to
cooperate fully with Enseco
and its parent company,
Corning Lab Services, Inc., in
implementing their contract
compliance  plan to ensure the
integrity of contracts with EPA.
Congressional
Testimony  By The
Inspector General
During this semiannual
reporting period, the Inspector
General (IG) testified three
times before congressional
committees on EPA's
vulnerability to fraudulent,
wasteful, abusive, and illegal
practices by its contractors.

• In testifying before the
Senate Committee on
Governmental Affairs on March
2, 1992, the  IG pointed  out
that many EPA managers
involved over the years in
contract management had
encouraged a "hands off"
environment in managing the
Agency's contractors.  The IG
added that this environment
(1) sacrificed cost efficiency
and effectiveness in contract
operations, (2) encouraged the
bending or circumvention of
sound contract procurement
and management practices
and regulations, (3)
inappropriately replaced EPA
staff with contractors for
vulnerable activities, and (4)
emphasized task completion
over risks and costs to Agency
programs. These problems
were demonstrated by the IG's
presentation of the results of
our recent audits of  EPA's
mismanagement of its
contracts with Computer
Sciences Corporation (CSC).

• On March  4, 1992, the IG
testified before the House
Subcommittee on Oversight
and Investigations, Committee
on Energy and Commerce, on
EPA's mismanagement of its
contracts with CSC (see page
11  for details).

• Again testifying  before the
House Subcommittee on
Oversight and Investigations,
Committee on Energy and
Commerce, on March 19,
1992, the IG  discussed the
OIG's audit at CH2M Hill, a
major EPA, contractor,  as well
as our February 1992
performance audit of EPA's
 36
                                                                                           OFFICE OF THE INSPECTOR GENERAL

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 management of the Superfund
 Alternative Remedial
 Contracting Strategy (ARCS)
 contracts, which  identified EPA
 concerns with CH2M Hill's
 performance  as a government
 contractor (see page 40 for
 details on auditing of ARCS
 contracts).
 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 234
 investigations.  The following
 conditions were identified and
 administrative actions taken:

 • 3 employees resigned rather
 than face possible disciplinary
 action for failure to list
 previous convictions for
 assault, claiming degrees not
 awarded, and failure to list
 previous terminations.

 • 1 employee resigned
 pending administrative removal
 for falsifying his SF-171 by
 claiming a college degree not
 earned.  The employee, based
 on the claimed degree, has
 served as an expert witness
 on many EPA cases.

• 1 contractor employee's
 access to Confidential
 Business Information was
 terminated because of failure
 to list a previous termination
 on the SF-86, Questionnaire
 for Sensitive Positions.

• 1 employee was found using
 multiple social security
 numbers to obtain credit. The
 information was referred to  the
 Office of Inspector General of
 the Department of Health and
 Human Services, which
 accepted the matter for
 criminal investigation.

• 3 employees received oral
 reprimands for falsifying the
 SF-171, Application for Federal
 Employment, used to gain
 employment with EPA.  One
 claimed a college degree not
 earned; the second failed to
 list convictions for writing bad
 checks and driving while
intoxicated; and the third failed
to list a conviction for theft and
termination from a previous
job.

• 10 employees were
permitted to submit corrected
SF-171s for failure to list minor
offenses.
President's
Council On
Integrity And
Efficiency
                                                                                             The Office of Inspector
                                                                                             General participates in the
                                                                                             activities of the President's
                                                                                             Council on Integrity and
                                                                                             Efficiency (PCIE), which 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
                                                                                             strengthen the effectiveness of
                                                                                             the entire Inspector General
                                                                                             community.  The PCIE is
                                                                                             headed by the Deputy
                                                                                             Director, Office of
                                                                                             Management and Budget
                                                                                             (OMB), and includes the
                                                                                             statutory Inspectors General
                                                                                             and other key Federal officials.
                                                                                                During this reporting
                                                                                             period, Inspector General
                                                                                             Martin was a member of the
                                                                                             PCIE Chief Financial Officers
                                                                                             Act Task Force.  The Task
                                                                                             Force was formed, at the
                                                                                             request of OMB, to provide a
                                                                                             vehicle for the exchange of
                                                                                             views and experiences in
                                                                                             implementing the Act.
                                                                                                Staff members of the EPA
                                                                                             OIG are participating in three
                                                                                             of the seven projects
                                                                                             undertaken by the Task Force.
                                                                                             The three projects and their
                                                                                             objectives are:  (1) auditor
                                                                                             assistance to management - to
                                                                                             determine the amount and
                                                                                             types of assistance to provide
                                                                                             management in the
                                                                                             preparation of financial
                                                                                             statements and other related
                                                                                             reports while  still maintaining
                                                                                             independence; (2) use of OIG
                                                                                             staff versus independent public
                                                                                             accountants to perform the
                                                                                             financial statement audits
                                                                                             required by the Act; (3)
                                                                                             performance measures—to
XTOBER 1,1991 THROUGH MARCH 31.1992
                                                                                                                     37

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develop standards for selecting
performance measures to be
included in annual reports.
We have also assisted the
financial statement audit policy
project team by commenting
on a polices and procedures
handbook for use in
performing financial statement
audits. During June  1992 final
reports on each of the projects
will be submitted to OMB.
Committee On
Integrity And
Management
Inprovement
The Committee on Integrity
and Management Improvement
(CIMI) was established in 1984
by EPA Order 1130.1.  The
purpose of CIMI is to
coordinate the Agency's effort
to minimize the opportunities
for fraud, waste, and
mismanagement in EPA
programs and to advise the
Administrator on policies to
improve the efficiency and
effectiveness of EPA programs
and activities. The Committee
is composed of senior EPA
program and regional officials
and is chaired by the Inspector
General.
                               Awareness Bulletin on Small
                               Purchases

                               It is essential that EPA
                               employees be aware of the
                               policies and procedures
                               governing small purchase
                               acquisitions.  Adequate
                               planning, accurate
                               descriptions, and open
                               communications are the key
                               factors in obtaining the
                               services, supplies, or
                               equipment needed for job
                               performance.  For these
                               reasons, the CIMI developed
                               an  awareness bulletin to
                               promote implementation of
                               proper small purchase
                               acquisition policies and
                               procedures.  In addition to
                               providing a better
                               understanding of the
                               acquisition process, the
                               bulletin was designed to clarify
                               EPA policy regarding
                               authorized and unauthorized
                               small purchases and to make
                               EPA employees, contractors
                               and managers aware of
                               actions that may delay small
                               purchase acquisitions. The
                               bulletin also suggests methods
                               for transacting small purchases
                               quickly and efficiently.
Travel Leaflet

The General Accounting
Office, the Office of
Management and Budget,
congressional committees, and
Inspectors General throughout
the Government have reported
on travel abuses and remedies
to curb them. One effective
way of addressing travel abuse
is through  employee
awareness of the regulations
governing  travel and of the
schemes and errors that result
in travel abuses and
mismanagement.
Consequently, the CIMI
developed a leaflet on travel
for all EPA employees, since
each employee is responsible
for using travel funds in
accordance with prescribed
policy, to avoid unnecessary
expense to the Government.
Designed to  make employees
aware of actual and potential
abuses, the leaflet highlights
aspects of travel needing
careful control and scrutiny.
Hotline  Activities
The OIG Hotline Center
opened 31 new cases and
completed and closed 36
cases during the reporting
period.  Of the cases closed 7
resulted in environmental,
prosecutive, or administrative
corrective action, while 29 did
not require action.  Cases that
did not have immediate validity
due to insufficient information
may be used to identify trends
or patterns of potentially
vulnerable areas for future
review.  The Hotline also
referred 2,294 telephone
callers to the appropriate
program office, State agency,
or other Federal agency for
assistance.
    The following is an
example of corrective action
taken as a result of information
provided to the OIG Hotline
Center:

• A complainant alleged that
an  EPA employee had abused
the Federal
Telecommunications System
by accepting long distance
telephone calls on a daily
basis.  A review of the
complaint disclosed that the
employee had accepted over
$400 in collect calls and used
approximately 36 hours of
Government time on those
calls. Further investigation
revealed that the employee
had also submitted falsified
travel authorizations for people
in the office and had kept the
money. As a result, the
employee entered into a
Pretrial Diversion Agreement
which included forty hours  of
community service and
restitution of $2,021.74 to
EPA. In addition, the
employee was terminated from
EPA.
38
                                                            OFFICE OF THE INSPECTOR GENERAL

-------
 Professional And
 Organizational
 Development
 For the semiannual period
 ending March 31, 1992, we
 approved 425 training
 enrollments for a total of 932
 days of training and
 participation in professional
 development seminars and
 conferences. Contract and in-
 house courses conducted by
 the DIG are summarized
 below.

 OIG-Developed Courses

 • Detection and Prevention of
 Fraud. Although this course
 was developed to prepare
 independent public
 accountants doing work for the
 EPA DIG to detect and refer
 possible instances of fraud to
 the DIG for criminal
 investigation, it also increases
 the awareness of  EPA
 managers and supervisors.
 During this reporting period the
 course was presented once, to
 one of the DIG CPA
 contractors.

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

 • Introduction to Government
 Auditing. This course was
 designed to enhance the new
 auditor's ability to understand
 the requirements of Federal
 Government auditing and to
 provide the individual with the
 skills necessary to meet these
 requirements.

• Behavioral Aspects of
 Government Auditing.  This
 course was designed for
 auditors, audit field
 supervisors, and audit
 managers who have contacts
 with personnel in organizations
 being audited; have contacts
 with affected organizations or
 individuals; or manage audit
 organizations. The course
 contains the basics of
 communication methods that
 are intended to make the audit
 work more productive for both
 auditor and auditee.

• Contract Auditing. This
 course was designed for
 auditors and audit supervisors
 who are responsible for the
 performance and review of
 contract audits.

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

 Total Quality Management

The Office of  Inspector
General fully supports and
participates in EPA's
commitment to Total Quality
Management  (TQM).  During
this reporting  period, a cadre
of 18 TQM facilitators was
trained.  Training of the OIG
staff has begun, with a goal of
providing all OIG employees a
1 -day TQM awareness class
by the end of  the fiscal year.
OCTOBER 1,1991 THROUGH MARCH 31.1992
                                                                                                                     39

-------
    Appendix 1-Reports Issued
THE INSPECTOR GENERAL ACT REQUIRES A LISTING, SUBDIVIDED ACCORDING TO SUBJECT MATTER, OF EACH AUDIT REPORT ISSUED BY
THE OFFICE DURING THE REPORTING PERIOD AND FOR EACH AUDIT REPORT, WHERE APPLICABLE, THE DOLLAR VALUE OF QUESTIONED
COSTS AND THE DOLLAR VALUE OF RECOMMENDATIONS THAT FUNDS BE PUT TO BETTER USE.
Audit Control
Number
                       Title
                                                                                   Questioned Costs             „         . .
                                                                       	   Recommended
                                                       Final Report     Ineligible    Unsupported    Unnecessary/      Efficiencies
                                                       Issued             Costs          Costs    Unreasonable    (Funds Be Put
                                                                                                         Costs   To Better Use)
1. INTERNAL & MANAGEMENT  ASSIGNMENTS

Adni'nistrator

E1SFG1-11-0015-2100237 SF  FY90 ANNUAL REPORT - ACCURACY  2/11/92
                      AND REASONABLENESS OF AGENCY REPORT

Assistant Adni'm'strator for Adnini strati on and Resources Management
E1XMG1-03
E1PMGM3

E1NME1-04-
E1SHD1-06-
E1NMF1-15-
         -0338-2400016
         •0038-2400022

         -0169-2100295
         5054-2100292
         0032-2100300
E6AMG2-13-0039-2400003
RESTRICTIONS ON LOBBYING           1/31/92
SECURITY & PROPERTY MANAGEMENT     3/12/92
BRANCH  REVIEW
EPA MANAGEMENT OF CSC CONTRACT     3/27/92
AWARD & MANAGEMENT OF ERCS         3/27/92
PCIE: ADP SUPPORT SERVICES         3/31/92
CONTRACT MANAGEMENT
REVIEW  OF CARPET CLEANING AT      12/12/91
EPA HEADQUARTERS
Assistant Actninistrator for Pesticides and Toxic Substances

E1EPG1-11-0028-2400032  GOOD LAB PRACTICES               3/31/92

Assistant Actninistrator for Solid Waste and Emergency Response

E1SGE2-03-0145-2100209  ARCS CONTRACTS CONSOLIDATED       2/ 3/92
E1LLC1-05-0173-2100278  UST INVENTORY                    3/19/92
E1SFG1-15-5001-2400027  CERCLIS FOLLOW-UP                3/27/92
E1SFG1-11-0015-2400033  SF FY90 ANNUAL REPORT  - TIMELINESS 3/31/92
E6ESP1-08-0037-2400029  IMPROPER CHARGES FOR RCRIS PILOT  3/30/92
                       CONFERENCE
EPA Office of  the Comptroller

E1RMG1-11-0031-2400013  FMFIA  1991 ACTIVITIES

Procurement Contracts Management Division

E1BMF1-11-0030-2100230  ADVISORY & ASSISTANCE SERVICE
                       CONTRACTS

E1SGA1-03-0054-2100200  ARCS CONTRACTS

Region 1
                                                       1/10/92



                                                       2/11/92


                                                       2/ 3/92



E1SHCO-01-0261-2100164  EPA'S EFFORTS TO RECOVER PRP      M 2/92
E1SHG1-01-0216-2400005  UNANNOUNCED SITE VISIT - QUONSET  12/16/91
                      POINT, RI
E1SHF1-02-0132-2100063  UNANNOUNCED SITE V1SIT-SOBELNJ    11/18/91
                                                                         2,390
 E1SJCO-02-0303-2100268  RESPONSIBLE PARTY SEARCHES -
                       REGION 2
                                                       3/17/92
 P6DWNO-03-0261-2300046  REVIEW OF BLUE PLAINS TREATMENT
                       FACILITY
                                                       3/31/92
                                               1,535,812
4,779,664
 E1SFG1-11-0015-2400030  SF FY90 ANNUAL REPORT - REGION 4
                       ACCOMPLISHMENTS
                                                       3/31/92
40
                                                                                                  OFFICE OF THE INSPECTOR GENERAL

-------
 Audit Control
 Number
                         Title
Final Report
Issued
Ineligible
   Costs
                                                                                        Questioned Costs
Unsupported
       Costs
Unnecessary/
Unreasonable
       Costs
Recommended
   Efficiencies
 (Funds Be Put
To Better Use)
 E1SFG1-11-0015-2400031  SF FY90 ANNUAL REPORT - REGION  5    3/31/92
                        ACCOMPLISHMENTS
 P6FJP1-05-0222-2400018  REVIEW OF MOBILE COMPANIES         2/18/92
 E1SJF1-07-0047-2100301  RESPONSIBLE PARTY SEARCHES -       3/31/92
                        REGION 7
               TOTAL  INTERNAL & MANAGEMENT REPORTS
                                                           25
               1,538,202     4,779,664
 2. CONSTRUCTION  GRANT ASSIGNMENTS
P2CWL9-01-0060-2100148 NEW LONDON
S2CULO-01-0072-2100055 SOUTHBRIDGE
S2CWL9-01-0148-2100159 AYRE
S2CWLO-01-0109-2100293 LOWELL
TOTAL OF REGION 01 = 4
E2CWM9-02-0255-2200003 WAVERLY VILLAGE
E2CWM9-02-0245-2200005 WESTCHESTER CO - MAMARONECK
E2CWM9-02-0365-2200006 CHESTER
E2CWM9-02-0289-2200007 CH1TTENANGO
E2CWMO-02-0123-2200011 ALLEGANY
E2CWMO-02-0109-2200013 ELLENVILLE
E2FWPO-02-0155-2400014 PRASA
P2CWLO-02-0037-21 00147 ONONDAGA COUNTY
P2CWL9-02-0252-2100150 WAYNE TOWNSHIP
P2CWL9-02-0311-2100155 AMHERST
P2CWLO-02-0126-2100163 WARWICK
P2CWL9-02-0258-2100165 WAYNE TOWNSHIP
P2CWL9-02-0257-2100205 SUFFERN
P2CWLO-02-0039-2100206 LIBERTY
P2CWL9-02-0031-2100241 MOODNA BASIN
P2CWLO-02-0174-2100291 GLENS FALLS
P2CWL9-02-0332-21 00294 BAT AVI A
TOTAL OF REGION 02 = 17
E2CWM9- 03 -0090- 220001 4 LEOLA SEWER AUTHORITY
E2ATT1 -03-0226-2400019 EARLY WARNING SRF
P2CW*7-03-0355-2200000 HOWARD CO DEPT PUB WORK
P2CW*7-03-0357-2200001 BALTIMORE COUNTY
P2CWM9-03-0314-2200004 GREEN VALLEY PSD
P2CWM9-03-0361-2200012 ST MARY'S METRO COMMISSION
P2CWN9-03-0262-2300007 PRINCE WILLIAM CO SERV AUTH
P2GWN9-03-0015-2300011 HARRISBURG SEWERAGE AUTH
TOTAL OF REGION 03 = 8
E2CWM1 -04-0421 -2200008 TALLADEGA WATER WORKS SEWER
P2CWN9-04-0305-2300002 LAKELAND
TOTAL OF REGION 04 = 2
P2CUP6-05-0298-2400004 W LAKE SUPERIOR SD
P2CWP8-05-0593-2400020 GROSSE ILLE
P2CWP9- 05 -0072- 2400023 WASHTENAW CO DPW
P2CWP8- 05 -0585 -2400028 KALAMAZOO
TOTAL OF REGION 05 = 4
E2EUN1 -06-0055-2300000 GARLAND
E2CUNO-06-0137-2300036 ROSUELL
P2CUN8-06-0258-2300001 LITTLE ROCK
P2CWN1 -06-0133-2300038 CORPUS CHRISTI
CT
MA
MA
MA

NY
,NY
NY
NY
NY
NY
PR
NY
NJ
NY
NY
NJ
NY
NY
NY
NY
NY

PA
PA
MO
MD
WV
MD
VA
PA

AL
FL

MN
MI
MI
MI

TX
NM
AR
TX
12/26/91
1V 8/91
12/31/91
3/27/92

11/15/91
12/20/91
V 2/92
1/15/92
3/ 9/92
3/26/92
1/13/92
12/26/91
12/27/91
12/31/91
M 2/92
V 2/92
1/30/92
1/30/92
2/20/92
3/26/92
3/27/92

3/31/92
3/ 5/92
10/ 9/91
10/ 9/91
12/16/91
3/10/92
10/28/91
10/30/91

1/16/92
10/ 9/91

12/12/91
3/ 9/92
3/12/92
3/27/92

10/ 9/91
2/20/92
107 9/91
2/21/92
203,756
106,829
159,015
1,053,505
1,523,105
176,620
32,831
227,931
69,386
99,892
504,305
174,660
4,433,158
190,527
4,705,332
290,069
437,053
1,537,669
270,562
13,149,995
170,247
86,674
140,700
188,200
92,526
601,963
955,407
2,235,717
113,424
183,016
296,440
6,446,691
96,498
449,642
63,797
7,056,628
24,938
16,593
57,026
117,556
0
565,202
102,701
785,459
28,194
578,669
0
913
3,501
346
550,951
2,046,157
0
0
3,309
170,528
13,952
707
3,397,227
182,259
56,202
12,664
41,672
6,773
73,402
698,616
1,071,588
0
0
0
125,126
293,018
0
69,984
488,128
63,432
36,655
23,191
              TOTAL OF REGION 06 =   4
                                                                            98,557
                               123,278
OCTOBER 1,1991 THROUGH MARCH 31.1992
                                                                      41

-------
                                                                                    Questioned Costs
Audit Control Tille
Number
P2CUN9-07-0092-2300029 OMAHA,
TOTAL OF REGION 07 = 1
E2CUMO-08-0033-2200009 MISSOULA
E2BUNO-08-0108-2300021 PUEBLO
E2AUT1 -08-0087-2400015 IDAHO SPRINGS
TOTAL OF REGION 08 = 3
E2CUN9-09-0090-2300022 RENO, CITY OF
E2CW*8-09-0162-2300040 PHOENIX, CITY OF
P2CW*8-09-0021 -21 00298 PRESCOTT, CITY OF
P2CWNO-09-0031-2300017 PINETOP LAKESIDE SO
S2CWM9-09-0172-2200002 SAN MARCOS CWD
S2CWN9-09-0064-2300030 NOVATO SAN D1ST
S2CWN9-09-0254-2300031 SAN JOSE, CITY OF
S2CUN9-09-0040-2300034 SOUTH BAYSIDE SYSTEM AUTH
S2CWN 1-09- 0228- 2300044 LOS ANGELES, CITY OF
TOTAL OF REGION 09 = 9
E2AWP2- 10-0002-2400024 NPOES PERMIT
P2CW*7- 10-0104-2100303 OLYMPIA, CITY OF
P2CU*7-10-0086-2300018 POCATELLO, CITY OF
TOTAL OF REGION 10 = 3
TOTAL CONSTRUCTION GRANT REPORTS

NB

MT
CO
CO

NV
AZ
AZ
AZ
CA
CA
CA
CA
CA

AK
WA
ID

-
Final Report
Issued
1/15/92

2/11/92
12/13/91
1/16/92

12/23/91
3/ 5/92
3/30/92
12/ 4/91
10/24/91
1/28/92
1/28/92
2/11/92
3/13/92

3/12/92
3/31/92
12/ 4/91

55
Ineligible
Costs
558,113
558,113
1,808
272,344

274,152
268,582
258,310
109,222
0
199,118
461,053
1,844,775
197,627
1,196,237
4,534,924

415,655
251,487
667,142
30,394,773
Unsupported
Costs
0
0
0
0

0
0
0
0
0
0
0
0
0
0
0

103,906
0
103,906
5,969,586
Unnecessary/
Unreasonable
Costs
0
0
0
0

0
1,051,547
0
0
2,453,357
0
0
0
0
6,709,398
10,214,302

0
0
0
10,214,302
raP*rWI**(IIWII*4W
Efficiencies
(Funds Be Put
To Better Use)




111,000
111,000














111,000
3. OTHER  GRANT ASSIGNMENTS
G3HVK1 -01 -0233-2500001
G3HVK2-01-0052-2500203
G3HVK2-01 -0055-2500225
G3HVK2-01 -0054-2500226
G3HVK2-01 -0068-2500254
G3HVK2-01 -0080-2500406
G3HVK2-01 -0073-2500407
G3HVK2-01 -0086-2500427
G3HVK2-01 -0087-2500428
G3HVK2-01 -0088-2500429
G3HVK2-01-0122-2500462
G3HVK2-01-0124-2500468
G3HVK2-01 -0123-2500505
G3HVK2-01-0125-2500588
G3HVK2-01 -0126-2500589
G3HVK2-01-0127-2500628
N3HVK1 -01 -0249-2500002
N3HVK1 -01 -0248- 2500003
N3HVK1 -01 -0267-2500196
N3HVK1 -01 -0164-2500204
N3HVK1 -01 -0266-2500227
N3HVK2-01 -0069-2500255
N3HVK1-01-0245-2500259
N3HVK1 -01 -0247- 2500346
N3HVK2-01-0081-2500408
N3HVK1-01-0129-2500425
N3HVK1 -01 -0224-2500426
N3HVK2-01 -0140-2500574
N3HVK2-01 -0071 -2500626
N3HVK2-01 -0139-2500627
TOTAL OF
C3HVK2-02-0061 -2500456
G3HVK1 -02-0151 -2500041
G3HVK1-02-0152-2500042
G3HVK2-02-0034-2500200
G3HVK2-02-0035-2500232
G3HVK2-02-0038-2500246
G3HVK2-02-0040-2500348
G3HVK2-02-0045-2500360
PORTLAND WATER DIST.
RI CLEAN WATER PROTECTION
CT CLEAN WATER FUND-SRF
ME MUNICIPAL BOND BANK-SRF
PLYMOUTH
ME
RI
CT
ME
MA
CT HAZARDOUS WASTE MGMT. SVSCT
LENOX
ST. JOHNSBURY
WESTBORCUGH
MA
VT
MA
MA WATER POLLUTION ABATEMENTMA
DOVER
PRESQUE ISLE SEWER DISTRICT
WALLINGFORD
NORTH HAVEN
NH RESOURCE RECOVERY ASSOC.
ROWLAND
SOUTHEASTERN REG. PLANNING
SOUTHEASTERN REG. PLANNING
LEICESTER WATER SUPPLY DIST
MONTAGUE
MASSACHUSETTS, STATE OF
GREATER PORTLAND COUNCIL
CHATHAM
PIONEER VALLEY PLANN. COM
CT DEPT OF HEALTH SERVICES
METRO AREA PLNG. COUN.
WATERBURY
CENTRAL MASS. REGIONAL PLAN
MANCHESTER
STRAFFORD REGIONAL PLANNING
REGION 01 = 30
BINGHAMTON
BUFFALO SA
CASTLETON-ON- HUDSON
MANASQUAN RIVER RSA
THERESA
MIDDLETOWN
ALEXANDRIA
SALEM
NH
ME
CT
CT
NH
ME
MA
MA
.MA
MA
MA
ME
MA
MA
CT
MA
CT
MA
NH
NH

NY
NY
NY
NJ
NY
NY
NY
NJ
10/ 2/91
12/ 2/91
12/ 5/91
12/ 5/91
12/18/91
1/15/92
1/15/92
1/23/92
1/23/92
1/23/92
2/20/92
2/24/92
2/28/92
3/16/92
3/16/92
3/20/92
10/ 2/91
10/ 2/91
11/26/91
12/ 2/91
12/ 6/91
12/18/91
12/20/91
V 2/92
1/15/92
1/21/92
1/21/92
3/11/92
3/20/92
3/20/92

2/13/92
10/23/91
10/23/91
12/ 2/91
12/ 9/91
12/16/91
V 3/92
V 3/92
                                                                                                           0
                                                                                                           0
                                                                                                           0
                                                                                                           0
                                                                                                           0
                                                                                                           0
                                                                                                           0
                                                                                                           0
                                                                                                           0
                                                                                                           0
                                                                                                           0
                                                                                                           0
                                                                                                           0
                                                                                                           0
                                                                                                           0
                                                                                                           0
                                                                                                           0
                                                                                                           0
                                                                                                           0
                                                                                                           0
                                                                                                           0
                                                                                                           0
                                                                                                           0
                                                                                                           0
                                                                                                           0
                                                                                                           0
                                                                                                           0
                                                                                                           0
                                                                                                           0
                                                                                                           0
42
                                                                                                   OFFICE OF THE INSPECTOR GENERAL

-------
Audit Control
Number
G3H VK2- 02 - 0046- 2500363
G3HVK2-02-0047- 2500376
G3HVK2-02-0049-2500413
G3HVK2-02-0051 -2500419
G3HVK2-02-0054-2500420
G3HVK2-02-0055-2500423
G3HVK2-02-0056-2500424
N3HVK1 -02-0127- 2500037
N3HVK1-02-0112-2500038
N3HVK1 -02-01 11 -2500039
N3HVK2-02-0016-2500040
N3HVK2-02-0018-2500055
N3HVK2-02-0025-2500056
N3HVK2-02-0014-2500104
N3HVKO-02-0322-2500105
N3HVK1 -02-01 19-2500106
N3HVK1 -02-0121 -2500132
N3HVK2-02-0013-2500201
N3HVK2-02-0028-2500202
N3HVK1 -02-0145-2500347
N3HVK2-02-0026-2500411
N3HVK2-02-0050-2500422
N3HVK2- 02 -0037- 2500448
N3HVK2-02-0066-2500457
N3HVK2-02-0067-2500471
N3HVK2-02-0065-2500472
N3HVK2-02-0073-2500661
Title
HUNTINGTON
HUNTINGTON
DELAWARE RIVER BASIN COMM
UOODBURY
BETHEL
CUBA
CUBA
NEW YORK STATE
SENECA NATION Of INDIANS
ST REGIS MOHAWK TRIBE
AMSTERDAM
VIRGIN ISLANDS
CHAUTAUQOA COUNTY
MONROE COUNTY
NEW YORK CITY
NEW YORK CITY
UN IV OF PUERTO RICO
WESTCHESTER COUNTY
NATIONAL URBAN LEAGUE
OSWEGO
ROCKLAND COUNTY
ESSEX COUNTY
SUFFOLK COUNTY
NORWICH
MIDDLESEX COUNTY
SCHAGHTICOKE
BURLINGTON COUNTY

NY
NY
NJ
NY
NY
NY
NY
NY
NY
NY
NY
VI
NY
NY
NY
NY
PR
NY
NY
NY
NY
NJ
NY
NY
NJ
NY
NJ
Final Report
Issued
M 6/92
1/ 7/92
1/15/92
1/17/92
1/17/92
1/21/92
1/21/92
10/23/91
10/23/91
10/23/91
10/23/91
10/24/91
10/28/91
IV 6/91
1V 6/91
IV 6/91
11/15/91
12/ 2/91
12/ 2/91
V 3/92
1/15/92
1/21/92
2/10/92
2/14/92
2/25/92
2/25/92
3/26/92

Ineligible
Costs
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
VKUD9UWiiro wvau
D *u*«*M «% AH*f »A
Unsupported Unnecessary/ Efficiencies
Costs Unreasonable (Funds Be Put
Costs To Better Use)
0
0
0
53,976
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
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 02 =  35

 C3HVK1-03-0313-2500016  ANNE ARUNDEL COUNTY
 C3HVK2-03-0183-2500391  VA STATE WATER CONTROL BOARDVA
 C3HVK2-03-0197-2500417  VA RESOURCES AUTHORITY
 C3HVK2-03-0227-2500469  SUSSEX COUNTY
 G3HVK1-03-0324-2500010  STROUD TOWNSHIP
 G3HVK2-03-0051-2500044  RIDGELY
 G3HVK2-03-0052-2500045  BRUNSWICK
 G3HVK2-03-0057-2500046  UPPER GWYNEDD-TOWAMENC1N MA PA
 G3HVK2-03-0058-2500047  TOWANDA MUNICIPAL AUTHORITY PA
 G3HVK2-03-0064-2500049  DUBLIN BOROUGH AUTHORITY
 G3HHK1-03-0017-2500107  MARIANNA-WEST BETHLEHEM
 G3HVK2-03-0087-2500110  HURLOCK
 G3HVK2-03-0089-2500111  SUSQUEHANNA RIVER BASIN
 G3HVK2-03-0090-2500128  GRANTSVILLE
 G3HVK2-03-0176-2500377  NATIONAL ASSOC ATTORNEYS GENDC
 G3HVK1-03-0321-2500378  WYSOX TOWNSHIP
 G3HVK2-03-0172-2500379  CANTON AREA SCHOOL DISTRICT PA
 G3HUK2-03-0173-2500380  CHESAPEAKE RESEARCH CONSORT.MD
 G3HVK2-03-0174-2500381  GREATER GREENSBURG SEWAGE
 G3HVK2-03-0201-2500437  PHILLIPSBURG-OSCEOLA SCHOOL PA
 G3HVK2-03-0199-2500438  GRANTSVILLE
 G3HVK1-03-0073-2500440  PHILLIPSBURG-OSCEOLA SCHOOL PA
 G3HVK2-03-0222-2500460  FAIRCHANCE-GEORGES MSA
 G3HVK2-03-0228-2500470  SNYDER CO.CONSERVATION DIST.PA
 G3HVK2-03-0238-2500552  DELMAR TOWN OF
 G3HVK2-03-0239-2500554  DELMAR TOWN OF
 G3HVK2-03-0267-2500577  HARRISBURG SCHOOL DISTRICT
 G3HVK2-03-0268-2500578  INTERSTATE COM POTOMAC RIVERMD
 G3HVK2-03-0269-2500579  WASHINGTON SUBURBAN SANITARYDC
 G3HVK2-03-0287-2500655  GARRETT CO BD  OF  EDUCATION
 G3HVK2-03-0286-2500656  TAZWELL COUNTY
 N3HVK1-03-0308-2500009  AMERICAN STATISTICAL ASSN
 N3HVK1-03-0307-2500011   AMERICAN STATISTICAL ASSN
 N3HVK1-03-0309-2500012  AMERICAN ASSN  ADV OF SCI
 N3HVKO-03-0342-2500013  FREDERICK COUNTY  6/89
 N3HVK1-03-0235-2500014   WILMINGTON CITY OF
 N3HVJ1-03-0310-2500015   PA COMMONWEALTH OF
 N3HVK2-03-0079-2500076   WEST VIRGINIA  STATE
 N3HMK1-03-0094-2500108   MARYLAND  STATE OF
 N3HVK1-03-0237-2500109   MARYLAND  STATE OF
 N3HUKO-03-0209-2500439  NATIONAL  COUNCIL  SENIOR
 N3HVJ1-03-0392-2500660   VA DEPARTMENT OF  EDUCATION
 N3HVK2-03-0221-2500662   ALLEGHENY  COUNTY
 N3HVK1-03-0086-2500663   ALEXANDRIA CITY OF
 N3HVK2-03-0169-2500664   ALEXANDRIA CITY OF
53,976
MD
!DVA
VA
DE
PA
MD
MD
i PA
1 PA
PA
PA
MD
PA
MD
NDC
PA
PA
.MD
PA
PA
MD
PA
PA
.PA
MD
MD
PA
RMD
YDC
MD
VA
VA
VA
DC
MD
DE
PA
WV
MD
MD
DC
VA
PA
VA
VA
10/ 9/91
1/14/92
1/16/92
2/24/92
10/ 9/91
10/23/91
10/23/91
10/23/91
10/23/91
10/23/91
1V 6/91
1V 6/91
1V 6/91
11/14/91
I/ 7/92
V 7/92
V 7/92
V 7/92
V 7/92
1/28/92
1/29/92
1/29/92
2/19/92
2/25/92
3/ 4/92
3/ 4/92
3/12/92
3/12/92
3/12/92
3/24/92
3/24/92
10/ 9/91
10/ 9/91
10/ 9/91
10/ 9/91
10/ 9/91
10/ 9/91
10/31/91
1V 6/91
1V 6/91
1/29/92
3/26/92
3/26/92
3/26/92
3/26/92
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
35,169
0
0
0
0
0
0
0
0
0
0
0
0
0
56,177
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
58,657
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
                     0
                     0
                     0
                     0
                     0
                     0
                     0
                     0
                     0
                     0
                     0
                     0
                     0
                     0
                     0
                     0
                     0
                     0
                     0
                     0
                     0
                     0
                     0
                     0
                     0
                     0
                     0
                     0
                     0
                     0
                     0
                     0
                     0
                     0
                     0
                     0
                     0
                     0
                     0
                     0
                     0
                     0
                     0
                     0
                     0
OCTOBER 1,1991 THROUGH MARCH 31.1992
                                      43

-------
                                                                                       Questioned Costs
Audit Control
Number
                        Title
                                  Fine! Report
                                  Issued
                 Ineligible
                    Costs
           Unsupported
                  Costs
            Unnecessary/
            Unreasonable
                   Costs
Recommended
    Efficiencies
 (Funds Be Put
To Bettei Use)
N3HVJ1-03-0278-2500665
N3HVJ1-03-0395-2500666
N3HVK1-03-0179-2500667
VA DEPT OF CONSERVATION     VA
VA DEPARTMENT OF  AGRICULTUREVA
EMMITSBURG TOWN OF          MD
              TOTAL OF  REGION 03 =  48
3/26/92
3/26/92
3/26/92
C3HVK1 -04-0401 -2500026 COLUMBIA
C3HVK1 -04-0405-2500028 COBB COUNTY
C3HVJ1 -04-0433-2500134 MONTGOMERY COUNTY
C3HVK1 -04-0534-2500248 DEKALB COUNTY
C3HVK2-04-0105-2500449 GREENSBORO
C3HVK2-04-0081 -2500459 ATLANTA
C3HVK2-04-0156-2500616 NASHVILLE & DAVIDSON COUNTY
C3HVK2-04-0249-2500645 FT. LAUDERDALE
C3HVK2-04-0272-2500670 TALLAHASSEE
C3HVK2-04-0277- 2500671 LEXINGTON- FAYETTE COUNTY
SC
GA
AL
GA
NC
GA
TN
FL
FL
KY
G3HVK1 -04-0398-2500017 SC STATE BUDGET & CONTROL BDSC
G3HVK1 -04-0360-2500018 PELAHATCHIE
G3HVK1 -04-0351 -2500019 CITRONELLE UTILITIES BOARD
G3HVK1 -04-0383-2500024 METTER
G3HVK1 -04-0393-2500025 LARGO
G3HVK1 -04-0173-2500027 LEIGHTON
G3HVK1 -04-0379-2500031 PUNTA GORDA
G3HVK1 -04-0258-2500077 MONROE
G3HVK1 -04-0458-2500078 MONROE
G3HVK1 -04-0259-2500079 MILTON
G3HVK1 -04-0365-2500085 COOPER CITY
G3HVK1 -04-0404-2500092 PAHOKEE
G3HVK1 -04-0357- 2500093 SARASOTA
G3HVK1-04-0407-2500133 BRIGHTON
G3HVK1 -04-0367- 2500135 OZARK UTILITIES BOARD
G3HVK1 -04-0316- 2500139 CLIO
G3HVK1 -04-0392-2500140 WARNER ROBB1NS
G3HVK1 -04-0447-2500141 CULLMAN
G3HVK1 -04-0452-2500142 BAXTER
G3HVK1 -04-0450-2500143 BAXTER
G3HVK1- 04- 0409- 2500197 BRUCETON
G3HVK1 -04-0461 -2500205 CHICKAWUGA
G3HVK1 -04-0475-2500206 EAST RIDGE
G3HVK1 -04-0471 -2500207 DRESDEN
G3HVK1- 04 -0449- 2500208 SOUTH PITTSBURG
G3HVK1-04-0427-2500209 CORNERSVILLE
G3HVK1 -04-0408-2500210 BRUCETON
G3HVK1- 04- 0451 -2500211 BAXTER
G3HVK1 -04-0463-2500212 CAMDEN
G3HVK1 -04-0208-2500213 CLIO
G3HVK1 -04-0462-2500214 CAMDEN
G3HVK1 -04-0209-2500216 CLIO
G3HVK1-04-0448-2500217 SOUTH PITTSBURG
G3HVK1 -04-0472-2500218 ERIN
G3HVK1-04-0210-2500219 CLIO
G3HVK1 -04-0468-2500223 MIDDLETON
G3HVK1 -04-0467-2500224 MIDDLETON
G3HVK1 -04-0492-2500234 ANNISTON WWSB
G3HVK2-04-0053-2500257 FAIRVIEW
G3HVK2-04-0036-2500260 FAIRVIEW
MS
AL
GA
FL
AL
FL
GA
GA
FL
FL
FL
FL
TN
AL
SC
GA
AL
TN
TN
TN
GA
TN
TN
TN
TN
TN
TN
TN
SC
TN
SC
TN
TN
SC
TN
TN
AL
TN
TN
G3HVK1 -04-0529-2500261 MAXEY FLATS CONCERNED CIT1ZEKY
G3HVK2-04-0084-2500262 WARTBURG
G3HVK1 -04-0493-2500269 TALLADEGA
G3HVK1-04-0470-2500270 FAYETTEVILLE
G3HVK1-04-0469-2500271 FAYETTEVILLE
TN
AL
TN
TN
G3HVK2-04-0070-2500272 WESTERN CAROLINA REGIONAL SASC
G3HVK1 -04-0515-2500273 TENNESSEE RIDGE
G3HVK1 -04-0518-2500274 TRIMBLE
G3HVK1-04-0531-2500276 TROY
G3HVK1-04-0535-2500288 BAILEYTON
G3HVK1 -04-0536-2500290 BAILEYTON
G3HUK2-04-0066-2500291 ENVIROSOUTH INC.
G3HVK2-04-0037-2500318 FAIRVIEW
G3HVK2-04-0025-2500319 MEDINA
G3HVK2-04-0038-2500320 WARTBURG
G3HVK2-04-0098-2500321 CELINA
G3HVK2-04-0087-2500354 HOKES BLUFF SEWER BOARD
G3HVK2-04-0068-2500355 SALEMBURG
G3HVK2-04-0052-2500356 GRAND STRAND WATER & SEWER
TN
TN
TN
TN
TN
AL
TN
TN
TN
TN
AL
NC
SC
10/17/91
10/18/91
11/15/91
12/17/91
2/10/92
2/19/92
3/19/92
3/23/92
3/31/92
3/31/92
10/15/91
10/15/91
10/15/91
10/17/91
10/17/91
10/18/91
10/18/91
10/31/91
10/31/91
10/31/91
11/ 1/91
11/ 4/91
IV 5/91
11/15/91
11/15/91
11/20/91
11/20/91
11/20/91
11/20/91
11/20/91
11/29/91
12/ 2/91
12/ 2/91
12/ 2/91
12/ 3/91
12/ 3/91
127 3/91
12/ 3/91
12/ 3/91
12/ 4/91
12/ 4/91
12/ 4/91
12/ 4/91
12/ 4/91
12/ 4/91
12/ 5/91
12/ 5/91
12/10/91
12/20/91
12/23/91
12/23/91
12/23/91
12/26/91
12/26/91
12/26/91
12/26/91
12/26/91
12/26/91
12/26/91
12/26/91
12/26/91
12/26/91
12/27/91
12/27/91
12/27/91
12/27/91
1/ 3/92
M 3/92
M 3/92
     0
     0
     0

91,346

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

58,657

     0
     0
     0
     0
     0
     0
     0
     0
     0
     0
     0
     0
     0
     0
     0
     0
     0
     0
     0
     0
     0
     0
     0
     0
     0
     0
     0
     0
     0
     0
     0
     0
     0
     0
     0
     0
     0
     0
     0
     0
     0
     0
     0
     0
     0
     0
     0
     0
     0
     0
     0
     0
     0
     0
     0
     0
     0
     0
     0
     0
     0
     0
     0
     0
     0
     0
     0
     0
     0
                                                                                                              0
                                                                                                              0
                                                                                                              0
                                                                                                              0
                                                                                                              0
                                                                                                              0
                                                                                                              0
                                                                                                              0
                                                                                                              0
                                                                                                              0
                                                                                                              0
                                                                                                              0
                                                                                                              0
                                                                                                              0
                                                                                                              0
                                                                                                              0
                                                                                                              0
                                                                                                              0
                                                                                                              0
                                                                                                              0
                                                                                                              0
                                                                                                              0
                                                                                                              0
                                                                                                              0
                                                                                                              0
                                                                                                              0
                                                                                                              0
                                                                                                              0
                                                                                                              0
                                                                                                              0
                                                                                                              0
                                                                                                              0
                                                                                                              0
                                                                                                              0
                                                                                                              0
                                                                                                              0
                                                                                                              0
                                                                                                              0
                                                                                                              0
                                                                                                              0
                                                                                                              0
                                                                                                              0
                                                                                                              0
                                                                                                              0
                                                                                                              0
                                                                                                              0
                                                                                                              0
                                                                                                              0
                                                                                                              0
                                                                                                              0
                                                                                                              0
                                                                                                              0
                                                                                                              0
                                                                                                              0
                                                                                                              0
                                                                                                              0
                                                                                                              0
                                                                                                              0
                                                                                                              0
                                                                                                              0
                                                                                                              0
                                                                                                              0
                                                                                                              0
                                                                                                              0
                                                                                                              0
                                                                                                              0
                                                                                                              0
                                                                                                              0
                                                                                                              0
 44
                                                                             OFFICE OF THE INSPECTOR GENERAL

-------
Audit Control Title
Number
G3HVK2-04-0091 -2500357 MCMINNVILLE TN
G3HVK2-04-0021 -2500358 NEW BERN TN
G3HVK2-04-0020-2500359 NEW BERN TN
G3HVK2-04-0050-2500361 LOUISVILLE MS
G3HVK2-04-0032-2500362 DAWSON SPRINGS WATER & SEWERKY
G3HVK2-04-0022-2500382 SOUTH FULTOM TN
G3HVK2-04-0023-2500383 SOUTH FULTON TN
G3HVK1 -04-0506-2500384 MARTIN TN
G3HVK1 -04-0505-2500386 MARTIN TN
G3HVK2-04-0093-2500387 MCMINNVILLE TN
G3HVK2-04-0054-2500390 SMITHVILLE TN
G3HVK2-04-0090-2500403 SOUTH FULTON TN
G3HVK1 -04-0538-2500404 GREENBRIER TN
G3HVK1 -04-0539-2500405 GREENBRIER TN
G3HVK2-04-0092-2500414 MCMINNVILLE TN
G3HVK2-04-0024-2500432 MEDINA TN
G3HVK2-04-0064-2500433 CLEVELAND UTILITIES TN
G3HVK2-04-0082-2500434 CARROLLTON GA
G3HUK2-04-0083-2500435 ENVIROSOUTH, INC. AL
G3HVK2-04-0132-2500436 GREENVILLE WATER WORKS & AL
G3HVK2-04-0100-2500441 BUNCOMBE SEWERAGE DISTRICT NC
G3HVK2-04-0108- 2500442 GEORGETOWN COUNTY W & SD SC
G3HVK2-04-0089-2500443 LOUISVILLE- JEFFERSON CO. MSDKY
G3HVK2-04-0103-2500463 ATHENS UTILITIES BOARD TN
G3HVK2-04-0199-2500464 CITRONELLE UTILITIES BOARD AL
G3HVK2-04-0086-2500465 CITRONELLE UTILITY BOARD AL
G3HVK2-04-0101 -2500467 ROCKY MOUNT NC
G3HVK2-04-0126-2500521 ROBERSONVILLE NC
G3HVK2-04- 0131 -2500522 LEXINGTON NC
G3HVK2-04-0122-2500523 ARDMORE WATER & SEWER SYSTEMAL
G3HVK2-04-0166-2500524 HARRISON CO. WASTEWATER MS
G3HVK2-04-0121 -2500527 SACRAMENTO KY
G3HVK2-04-0125-2500533 TRYON NC
G3HVK2-04-0197-2500534 NEW JOHNSONVILLE TN
G3HVK2-04-0153-2500535 WEST MELBOURNE FL
G3HVK2-04-0172-2500536 GASTONIA NC
G3HVK2-04-0152-2500537 CORNERSVILLE TN
G3HVK2-04-0196-2500538 MANCHESTER TN
G3HVK2-04-0198-2500539 NEW JOHNSONVILLE TN
G3HVK2-04-0185-2500540 GADSEN WATER WORKS & SEWER AL
G3HVK2-04-0187-2500541 BEAVER DAM KY
G3HVK2-04-0165-2500542 GADSDEN WATER WORKS & SEWER AL
G3HVK2-04-0149-2500543 OXFORD NC
G3HVK2-04-0220-2500546 GREENBRIAR TN
G3HVK2-04-0171 -2500547 BLOWING ROCK NC
G3HVK2-04-0158-2500548 AHOSKIE NC
G3HVK2-04-0189-2500549 GEORGETOWN COUNTY W & SD SC
G3HVK2-04-0224-2500553 CENTRAL CITY WATER & SEWER KY
G3HVK2-04-0173-2500555 GASTONIA NC
G3HVK2-04-0150-2500557 NEW BERN NC
G3HVK2-04-0170-2500558 BRUNSWICK GA
G3HVK2-04-0124-2500559 TRYON NC
G3HVK2-04-0161 -2500567 KY INFRASTRUCTURE AUTHORITY KY
G3HVK2-04-0186-2500568 BEAVER DAM KY
G3HVJ2-04-0190-2500569 AL WATER POLLUTION CONTROL AL
G3HVK2-04-0175-2500600 PRINCETON NC
G3HVK2-04-0206-2500601 GREENVILLE WW & SB AL
G3HVK2-04-0179-2500603 TARBORO NC
G3HVK2-04-0207-2500605 IRVINGTON KY
G3HVK2-04-0239-2500606 FLORENCE AL
G3HVK2-04-0178-2500607 TARBORO NC
G3HVK2-04-0191 -2500608 LAUREL MS
G3HVK2-04-0204-2500611 FAYETTEVILLE NC
G3HVK2-04-0176-2500615 SCOTLAND NECK NC
G3HVK2-04-0169-2500617 PILOT MOUNTAIN NC
G3HVK2-04-0208-2500618 IRVINGTON KY
G3HVK2-04-0244-2500623 LARGO FL
G3HVK2-04-0123-2500624 SPARTANBURG SANITARY SEWER SC
G3HVK2-04-0217-2500625 PORT ORANGE FL
G3HVK2-04-0184-2500630 VENICE FL
G3HVK2-04-0215-2500633 POPE MS
G3HVK2-04-0214-2500634 POPE MS
G3HVK2-04-0216-2500635 OZARK UTILITIES BOARD AL
G3HVK2-04-0221 -2500636 FULTON KY
G3HVK2-04-0226-2500638 LINDEN TN
Final Report
Issued
1/ 3/92
M 3/92
M 3/92
1/ 3/92
M 3/92
M 8/92
M 8/92
1/10/92
1/10/92
1/10/92
1/10/92
1/15/92
1/15/92
1/15/92
1/16/92
1/28/92
1/28/92
1/28/92
1/28/92
1/28/92
2/ 4/92
21 4/92
2/ 4/92
2/20/92
2/20/92
2/20/92
2/21/92
3/ 3/92
3/ 3/92
3/ 3/92
3/ 3/92
3/ 3/92
3/ 4/92
3/ 4/92
3/ 4/92
3/ 4/92
3/ 4/92
3/ 4/92
3/ 4/92
3/ 4/92
3/ 4/92
3/ 4/92
3/ 4/92
3/ 4/92
3/ 4/92
3/ 4/92
3/ 4/92
3/ 4/92
3/ 4/92
3/ 5/92
3/ 5/92
3/ 5/92
3/ 6/92
3/ 6/92
3/ 6/92
3/17/92
3/17/92
3/17/92
3/17/92
3/17/92
3/17/92
3/17/92
3/18/92
3/19/92
3/19/92
3/19/92
3/20/92
3/20/92
3/20/92
3/20/92
3/20/92
3/20/92
3/20/92
3/20/92
3/20/92
	 	 	 	 — nOTfUiiiniuiiwu
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
96,000
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
OCTOBER 1,1991 THROUGH MARCH 31. 1992
                                                                                                                         45

-------
                                                                                  Questioned Costs
Audit Control
Number
G3HVK2-04-0209-2500640
G3HVK2-04-0251 -2500641
G3HVK2-04-0252-2500642
G3HVK2-04-0275-2500669
G3HVK2-04-0276-2500672
N3HVK1 -04-0128-2500029
N3HVK1-04-0117-2500030
N3HVK1 -04-0213-2500083
N3HVK1 - 04- 021 2- 2500084
N3HVK1 -04-0216-2500091
N3HVK1 -04-0205-2500129
N3HVK1 -04-0246-2500130
N3HVK1 -04-0253-2500131
N3HVK1 -04-01 15-2500136
N3HVK1 -04-0222-2500144
N3HVK1 -04-0377-2500145
N3HVK1 -04-0236-2500146
N3HVK1 -04-0345-2500147
N3HVK1 -04-0278-2500148
N3HVK1-04-0231-2500170
N3HVK1 -04-0347-25001 73
N3HVK1 -04-0410-2500174
N3HVK1 -04-0399-2500187
N3HVK1 -04-0349-2500188
N3HVK1 -04-0460-2500189
N3KVK1-04-0277-2500190
N3HVK1 -04-0299-2500191
N3HVK1 -04-0350-2500192
N3HVK1 -04-0272-2500193
N3HVK1 -04-0348-2500194
N3HVJ1 -04-0540-2500198
N3HVK1 -04-0474-2500199
N3HVK1 -04-0340-2500215
N3HUK1 -04-0397-2500220
N3HVJO-04-0351 -2500221
N3HVK1 -04-0361 -2500222
N3HVJ1 -04-0528- 2500230
N3HVJ1-04-0494-2500231
N3HVK1 -04-0503-2500233
N3HVK1 -04-0457-2500235
N3HUK1 -04-0362-2500236
N3HVK1 -04-0046-2500237
N3HVK1-04-0105-2500238
N3HUK1 -04-0532-2500239
N3HVK1 -04-0374-2500247
N3HVKO-04-0327-2500249
N3HVK1 -04-0341 -2500250
N3HVJ1-04-0432-2500251
N3HVK1 -04-0108-2500252
N3HVK1-04-0500-2500253
N3HVK1 -04-0495-2500256
N3HVK2-04-0030-2500258
N3HVK2-04-0062-2500263
N3HVK1 -04-0480-2500264
N3HVK2-04-0026-2500265
N3HVK1 -04-0429-2500266
N3HVK1 -04-0380-2500267
N3HVK1 -04-0130-2500268
N3HVK1 -04-0446-2500275
N3HVK 1-04 -0464 -2500295
N3HVK2-04-0031 -2500385
N3HVK2- 04-0049- 2500402
N3HVK2-04-0060-2500430
N3HVK2-04-0146-2500444
N3HVK2-04-0057-2500450
N3HVK2-04-01 19-2500466
N3HVK2-04-0079- 2500507
N3HVK2-04-0145-2500509
N3HVK2-04-0164-2500510
N3HVK2-04-0051-2500511
N3HVK2-04-0144-2500512
N3HVK2-04-0194-2500513
N3HUK2-04-0130-2500525
N3HVK2 -04 - 0078- 2500526
N3HVK2-04-0085-2500528
Title
MCMINNVILLE
CAMDEN
CAMOEN
COLLIER COUNTY
JASPER WU & SEWER BOARD
CAMDEN
ANDALUSIA
EDENTON
EDENTON
KENLEY
BARNUELL
FLEMINGSBURG
LANCASTER
WAKE COUNTY
NORTH MYRTLE BEACH
OKALOOSA COUNTY
CLIO
KEY WEST
QUINCY
SPENCER
SUMTER
BRUCETON
HAINES CITY
ATMORE
THOMASVILLE
QUINCY
HAYWOOD COUNTY
ATMORE
PLANT CITY
MIDDLESBOROUGH
NORTH CAROLINA, STATE OF
SEMINOLE TRIBE OF FLORIDA
ST. PETERSBURG
SOUTH CAROLINA UNIVERSITY
KENTUCKY, STATE OF
SHELBY COUNTY
MISSISSIPPI, STATE OF
KENTUCKY STATE OF
CORINTH
BROWARD COUNTY
MEDICAL UNIVERSITY OF SC
CHARLOTTE
DURHAM
KENTUCKY, UNIVERSITY OF
LEE COUNTY
AUGUSTA
POMPANO BEACH
TENNESSEE STATE OF
MEMPHIS
MANCHESTER
BREVARD COUNTY
GAINESVILLE
SARASOTA COUNTY
SAVANNAH
CELINA
FLORIDA INSTITUTE OF TECH
PINELLAS COUNTY
FULTON COUNTY
KNOX COUNTY
HILLSBOROUGH COUNTY

TN
AL
AL
FL
AL
AL
AL
NC
NC
NC
SC
KY
SC
NC
SC
FL
SC
FL
FL
NC
SC
TN
FL
AL
GA
FL
NC
AL
FL
KY
NC
FL
FL
SC
KY
TN
MS
KY
MS
FL
SC
NC
NC
KY
FL
GA
FL
TN
TN
TN
FL
FL
FL
GA
TN
FL
FL
GA
TN
FL
COUNCIL OF STATE GOVERNMENTSKY
ATLANTA REGIONAL COMMISSION
AHOSKIE
FLORIDA, STATE OF
SC DEPT. OF HEALTH & ENVIRO
DADE COUNTY
MECKLENBURG COUNTY
CELINA
CENTRAL MIDLANDS PLANNING
GA
NC
FL
SC
FL
NC
TN
SC
COUNCIL OF STATE GOVERNMENTSKY
FORT MEYERS
OAK GROVE
MISSISSIPPI MEDICAL CENTER
FORSYTH COUNTY
SALISBURY
FL
KY
MS
NC
NC
Rnal Report
Issued
3/23/92
3/23/92
3/23/92
3/31/92
3/31/92
10/18/91
10/18/91
1V V91
IV 1/91
1V 4/91
11/14/91
11/14/91
11/14/91
1V18/91
11/20/91
11/21/91
11/21/91
11/21/91
11/21/91
11/22/91
11/22/91
11/22/91
11/22/91
11/22/91
11/22/91
11/22/91
11/22/91
11/12/91
11/25/91
11/25/91
11/29/91
11/29/91
12/ 4/91
12/ 5/91
12/ 5/91
12/ 5/91
12/ 6/91
12/ 6/91
12/10/91
12/10/91
12/10/91
12/10/91
12/10/91
12/10/91
12/17/91
12/17/91
12/18/91
12/18/91
12/18/91
12/18/91
12/20/91
12/20/91
12/23/91
12/23/91
12/23/91
12/24/91
12/24/91
12/24/91
12/26/91
12/26/91
1/10/92
1/15/92
1/24/92
21 7/92
2/10/92
2/20/92
3/ 2/92
3/ 2/92
3/ 2/92
3/ 2/92
3/ 2/92
3/ 2/92
3/ 3/92
3/ 3/92
3/ 3/92
Ineligible
Costs
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
3,414
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
	 — — 	 — '— rtv7«*wiiiiiivf ivv**
Unsupported Unnecessary/ Efficiencies
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
22,950
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
20,000
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
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
                                                                                                OFFICE OF THE INSPECTOR GENERAL

-------
                                                                                          Questioned
Audit Control
Number
N3HVK2-04-0120-2500550
N3HVK2-04-0167-2500551
N3HUK1 -04-01 14-2500556
N3HVK2-04-0174-2500563
N3HVK2-04-0154-2500564
N3HVK2-04-0127- 2500565
N3HVK2-04-0143-2500570
N3HUK2-04-0058-2500571
N3HVK2-04-0157- 2500572
N3HVK2-04-0188-2500602
N3HVK2-04-0193-2500604
N3HVK2-04-0213-2500609
N3HVK2-04-0241 -2500610
N3HVK2-04-0163-2500612
N3HVK2-04-0222-2500613
N3HVK2-04-0219-2500614
N3HUK2-04-0107-2500621
N3HVK2-04-0253-2500622
N3HVK2-04-0218-2500629
N3HVK2-04-0180-2500631
N3HVK2-04-0212-2500632
N3HVK2-04-0063-2500637
N3HVK2-04-0223-2500639
N3HVK2-04-0200-2500643
N3HVK2-04-0240-2500644
Title
LANCASTER
HENDERSON
SUMTER AREA TECHNOCAL
HOPE HILLS
WAKE COUNTY
UNION COUNTY
MIDDLESBOROUGH
SUMTER AREA TECHNICAL
BELHAVEN
VALDOSTA
PASCO COUNTY
WELDON

KY
NC
COLLE SC
NC
NC
NC
KY
COLLEGSC
NC
GA
FL
NC
AL DEPT. OF AGRI INDUSTRIES AL
WAUCHULA
CLAYTON
GREENVILLE
CLEMSON UNIVERSITY
HARTFORD
GREENVILLE
SOUTH BAY
SCOTLAND NECK
CHARLOTTE
GARNER
ASHLAND
MANATEE COUNTY
FL
AL
NC
SC
AL
NC
FL
NC
NC
NC
KY
FL
Final Report
Issued
3/ 4/92
3/ 4/92
3/ 4/92
3/ 5/92
3/ 5/92
3/ 5/92
3/ 6/92
3/ 6/92
3/ 6/92
3/17/92
3/17/92
3/18/92
3/18/92
3/19/92
3/19/92
3/19/92
3/20/92
3/20/92
3/20/92
3/20/92
3/20/92
3/20/92
3/20/92
3/23/92
3/23/92
Ineligible Unsupported Unnecessary/ Efficiencies
Costs Costs Unreasonable (Funds Be Put
Costs To Better Use)
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
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 04  = 244
                                                                    99,414
                                                                    42,950
C3HVJ2-05
C3HVK2-05
C3HVK2-05
G3HVK1-05
G3HVK1-05
G3HVK1-05
G3HVK1-05
G3HVK1-05
G3HVK1-05
G3HVK1-05
G3HVK1-05
G3HVJ2-05
G3HVJ2-05
G3HVJ2-05
G3HVJ2-05
G3HVJ2-05
G3HVJ2-05
G3HVK2-05
G3HVJ2-05
G3HVJ2-05
G3HVJ2-05
G3HVK2-05
G3HVK2-05
G3HVJ2-05
G3HVJ2-05
G3HVJ2-05
G3HVK2-05
G3HVJ2-05
G3HVJ2-05
G3HVJ2-05
G3HVK2-05
G3HVK2-05
G3HVJ2-05
G3HVJ2-05
G3HVJ2-05
G3HVJ2-05
G3HVK2-05
G3HVJ2-05
G3HVJ2-05
G3HVJ2-05
G3HVJ2-05-
G3HVJ2-05
G3HVJ2-05-
G3HVJ2-05-
G3HVJ2-05
G3HVJ2-05-
G3HVJ2-05-
 0107-2500412
 0135-2500486
 0139-2500487
 0447-2500005
 0433-2500006
 0452-2500057
 0453-2500058
 0481-2500059
 0479-2500060
 0478-2500061
 0460-2500064
 0023-2500088
 0035-2500089
 0049-2500151
 0051-2500152
 0077-2500153
 0086-2500228
 0081-2500229
 0111-2500364
 0109-2500365
-0115-2500366
 0101-2500368
 0102-2500369
 0092-2500372
 0091-2500373
 0093-2500374
 0090-2500375
 0128-2500388
 0129-2500389
•0131-2500392
 0137-2500410
 0138-2500475
 0146-2500476
 0163-2500477
 0161-2500478
 0148-2500479
 0167-2500480
 0166-2500481
 0165-2500483
 0164-2500484
 0160-2500485
 0191-2500508
 0174-2500514
 0173-2500515
 0187-2500516
 0185-2500517
 0186-2500518
HAMMOND FY 90
KALAMAZOO FY 90
RACINE FY 90
DOWNERS GROVE SD FY 91
UORTHINGTON FY 90
AHMEEK FY 91
MN SRF FY 91
COLD SPRING FY 90
THORN CREEK SD FY 91
CLARISSA FY 90
NISSWA FY 90
ST JOSEPH CO FY 90
RENSSELAER FY 90
LAPORTE FY 90
VI GO CO FY 90
MITCHELL FY 90
PORTSMOUTH SO FY 90
LONSDALE FY 89/90
JEFFERSON LSD FY 90
BOONVILLE FY 90
CARDINGTON LSD FY 90
NEUAYGO FY 91
SE WI RPC FY 90
WASHINGTON FY 90
NEW CHICAGO FY 89/90
JASPER FY 90
DECATUR SD FY 91
FERDINAND FY 89/90
MICHIGAN CITY FY 90
DECATUR FY 90
N KOOCHICHING ASD FY 89/90
CINCINNATI MSD FY 90
WHITE OAK FY 89/90
SYRACUSE FY 89/90
BERNE FY 90
MICHIANA ACG FY 91
PORTAGE LAKE WSA FY 91
HAUBSTADT FY 89/90
WILKINSON FY 89/90
REMINGTON FY 89/90
FOUNTAIN CITY FY 89/90
WHITING FY 90
NEW CARLISLE FY 89/90
ROSSVILLE FY 89/90
GREENTOWN FY 89/90
SILVER LAKE FY 89/90
MENTONE FY 89/90
IN
MI
WI
IL
MN
MI
MN
MN
IL
MN
MN
IN
IN
IN
IN
IN
OH
MN
OH
IN
OH
MI
WI
IN
IN
IN
IL
IN
IN
IN
MN
OH
IN
IN
IN
IN
MI
IN
IN
IN
IN
IN
IN
IN
IN
IN
IN
1/15/92
2/25/92
2/25/92
10/ 8/91
10/ 9/91
10/28/91
10/28/91
10/28/91
10/28/91
10/28/91
10/28/91
1V 1/91
11/ 1/91
11/21/91
11/21/91
11/21/91
12/ 6/91
12/ 6/91
1/ 6/92
\l 6/92
M 6/92
M 6/92
M 6/92
V 6/92
V 6/92
\t 6/92
M 6/92
1/10/92
1/10/92
1/14/92
1/15/92
2/25/92
2/25/92
2/25/92
2/25/92
2/25/92
2/25/92
2/25/92
2/25/92
2/25/92
2/25/92
3/ 2/92
3/ 2/92
3/ 2/92
3/ 2/92
3/ 2/92
3/ 2/92
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
161,915
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
64,916
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
OCTOBER 1,1991 THROUGH MARCH 31.1992
                                                                                                                          47

-------
                                                                                         Questioned Costs
Audit Control
Number
G3HVJ2-05-0140-2500580
G3HVJ2-05-0172-2500581
G3HVJ2-05-0194-2500582
G3HVJ2-05-0171 -2500583
G3HVK2-05-0175-2500592
G3HVJ2-05-0189-2500593
G3HVJ2-05-0197-2500594
G3HVJ2-05-0198-2500595
G3HVJ2- 05 -0204 -2500596
G3HVJ2-05-0203-2500597
G3HVJ2-05-0162-2500598
G3HVJ2-05-0190-2500599
N3HVK1 -05-0438-2500004
N3HMK1 -05-0276-2500062
N3HVJ1 -05-0456-2500063
N3HVJ2-05-0047-2500127
N3HVJ2-05-0039-2500149
N3HVK1 -05-0461 -2500150
N3HVK1 -05-0450-2500367
N3HVJ2-05-0048-2500370
N3HVJ2-05-0019- 2500371
N3HVJ2-05-01 18-2500482
Title
IN DEPT OF FIRE/BLDG FY 91
ROCHESTER FY 90
AVILLA FY 89/90
VALPARAISO FY 90
NIPC FY 91
SCOTTSBURG FY 90
CROTHERSVILLE FY 89/90
TELL CITY FY 90
MERRILLVILLE CD FY 89
STEUBEN LAKES RWD FY 89/90
ANDERSON FY 90
LAGRANGE FY 89/90
MUSKEGON CO FY 90
COLUMBUS FY 90
MN STATE OF FY 90
S BEND FY 90
OHIO STATE OF FY 89
WAYNE CO FY 90
EAU CLAIRE FY 90
CHICAGO BOE FY 90
MUNCIE FY 90
RED LAKE/CHIPPEWA FY 90

IN
IN
IN
IN
IL
IN
IN
IN
IN
IN
IN
IN
MI
OH
MN
IN
OH
MI
WI
IL
IN
UI
Final Report
Issued
3/12/92
3/12/92
3/12/92
3/12/92
3/17/92
3/17/92
3/17/92
3/17/92
3/17/92
3/17/92
3/17/92
3/17/92
10/ 8/91
10/28/91
10/28/91
11/13/91
11/21/91
11/21/91
M 6/92
M 6/92
V 6/92
2/25/92
Ineligible
Costs
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
• — ' — — fnwWHtlllVIIMM
Unsupported Unnecessary/ Efficiencies
Costs Unreasonable (Funds Be Put
Costs To Better Use)
15,235
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
696,130
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
C3HVK2-
G3HVK2-
G3HVK2-
G3HVK2-
G3HVK2-
G3HVK2-
G3HVK2-
G3HVK2-
G3HVK2-
G3HVK2-
G3HVK2-
G3HVK2-
G3HVK2-
G3HVK2-
G3HVK2-
N3HVJ2-
N3HVK2-
N3HVK2-
N3HVH2-
N3HVJ2-
N3HVJ2-
N3HVJ2-
N3HUK2
N3HUK2
N3HVK2
N3HVK2
N3HVK2-
N3HVK2
N3HVK2
N3HVK2
N3HVK2
N3HVK2
N3HVK2
N3NVK2
N3HVK2
N3HVK2
N3HVK2
N3HVK2
N3HVK2
N3HVK2
N3HVK2
N3HVJ2
N3HVK2
N3HVK2
N3HVK2
        TOTAL  OF  REGION  05  =  69

06-0058-2500431   NORTH  LITTLE  ROCK
06-0080-2500329   MALONE
06-0082-2500331   PRYOR  CREEK
06-0083-2500332   SPLENDORA
•06-0084-2500333   O'DONNELL
•06-0086-2500335   IDALOU
•06-0085-2500336   O'DONNELL
-06-0102-2500445   VICI
•06-0108-2500458   NEW DEAL
•06-0118-2500560   CLEO SPRINGS  PUA
•06-0119-2500562   NASH PUA
•06-0120-2500566   RUNGE
•06-0122-2500619   NOUATA
-06-0125-2500657   BEEBE  MUNICIPAL WATER & SE
-06-0130-2500668   VICTORIA  COUNTY WCID NO.2
-06-0039-2500043   TEXAS  STATE OF
-06-0041-2500048   HIGHLANDS UNIVERSITY N.M.
•06-0040-2500050   HIGHLANDS UNIVERSITY N.M.
-06-0042-2500051   NEW MEXICO UNIVERSITY OF
-06-0043-2500052   ARKANSAS  UNIVER.OF LITTLE R
-06-0044-2500053   ARKANSAS  DEPT. OF HEALTH
-06-0045-2500054   ARKANSAS  UNIVERITY OF
-06-0064-2500314   NEW MEXICO STATE UNIVERSITY  NM
-06-0065-2500315   NEW MEXICO STATE UNIVERSITY  NM
-06-0066-2500316   ALEXANDRIA
-06-0067-2500317   NORTH  TEXAS COG
-06-0068-2500322   DALLAS
-06-0069-2500323   SEYMOUR
-06-0070-2500324   BATON  ROUGE EAST
-06-0071-2500325   BATON  ROUGE EAST BATON ROUGELA
-06-0072-2500326   BATON  ROUGH PARISH OF EAST
-06-0073-2500327   SLIDELL
-06-0074-2500328   HOUSTON GALVESTON AREA CO.
-06-0081-2500330   MIDWEST CITY
-06-0078-2500334   JEFFERSON PARISH
-06-0103-2500446   UNIVERSITY OF ARKANSAS
-06-0104-2500447   FORT WORTH
-06-0109-2500461   TERREBONNE PARISH CONSOLIDATLA
-06-0113-2500488   EIGHT  NORTHERN INDIAN PUEBLONM
-06-0114-2500489   CHEYENNE  ARAPAHO TRIBES OF OOK
-06-0115-2500490   DALLAS
-06-0116-2500506   OKLAHOMA  STATE OF
-06-0117-2500561   GALVESTON COUNTY HEALTH DISTTX
-06-0127-2500658   ALBUQUERQUE
-06-0128-2500659   ALBUQUERQUE
                                                                            161,915
776,281
              TOTAL OF REGION 06 =  45
G3HVK2-07-0016-2500065
G3HVK2-07-0017-2500066
                  MANSFIELD
                  CLEARFIELD
AR
TX
OK
TX
TX
TX
TX
OK
TX
OK
OK
TX
OK
AR
TX
TX
NM
NM
NM
AR
AR
AR
' NM
1 NM
LA
TX
TX
TX
LA
;ELA
LA
LA
TX
OK
LA
AR
TX
ITLA
.ONM
OOK
TX
OK
;TTX
NM
NM
MO
IA
1/24/92
12/30/91
12/30/91
12/30/91
12/30/91
12/30/91
12/30/91
2/ 7/92
2/18/92
3/ 5/92
3/ 5/92
3/ 6/92
3/19/92
3/25/92
3/27/92
10/23/91
10/23/91
10/23/91
10/23/91
10/23/91
10/23/91
10/23/91
12/27/91
12/27/91
12/27/91
12/27/91
12/30/91
12/30/91
12/30/91
12/30/91
12/30/91
12/30/91
12/30/91
12/30/91
12/30/91
2/ 7/92
21 7/92
2/19/92
2/25/92
2/25/92
2/25/92
2/28/92
3/ 5/92
3/26/92
3/26/92
10/28/91
10/28/91
0
0
0
0
0
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
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
9,702
0
0
0
0
0
0
0
  9,702

      0
      0
                      0
                      0
                      0
                      0
                      0
                      0
                      0
                      0
                      0
                      0
                      0
                      0
                      0
                      0
                      0
                      0
                      0
                      0
                      0
                      0
                      0
                      0
                      0
                      0
                      0
                      0
                      0
                      0
                      0
                      0
                      0
                      0
                      0
                      0
                      0
                      0
                      0
                      0
                      0
                      0
                      0
                      0
                      0
                      0
                      0
48
                                                                                                      OFFICE OF THE INSPECTOR GENERAL

-------
                                                                                   Questioned Costs
Audit Control
Number
G3HVK2-07-0018-2500068
G3HVK2-07-0019-2500069
G3HVK2-07-0020-2500070
G3HVK2-07-0025-2500071
G3HVK2-07-0021 -2500072
G3HVK2-07-0024-2500073
G3HVK2-07-0023-2500074
G3HVK2-07-0022-2500075
G3HVK2-07-0031 -2500098
G3HVK2-07-0035-2500102
G3HVK2-07-0036-2500103
G3HVK2-07-0037- 25001 15
G3HVK2-07-0039-2500116
G3HVK2-07-0038-2500117
G3HVK2-07-0040-2500119
G3HVK2-07-0041 -2500120
G3HVK2-07-0043-2500122
G3HVK2-07-0046-2500124
G3HVK2-07-0045-2500125
G3HVK2-07-0078-2500162
G3HVK2-07-0077- 25 00163
G3HVK2-07-0076-2500164
G3HVK2-07-0075-2500165
G3HVK2-07-0074-2500166
G3HVK2-07-0073-2500167
G3HVK2-07-0072-2500168
G3HVK2-07-0071-2500169
G3HVK2-07-0070-2500171
G3HVK2 - 07- 0069- 25001 72
G3HVK2-07-0068-2500175
G3HVK2- 07- 0067- 25001 76
G3HVK2-07-0066-2500177
G3HVK2-07-0065-2500178
G3HVK2-07-0064-2500179
G3HVK2-07-0063-2500180
G3HVK2-07-0062-2500181
G3HVK2-07-0061 -2500182
G3HVK2-07-0060-2500183
G3HVK2-07-0059-2500184
G3HVK2-07-0058-2500185
G3HVK2-07-0057- 2500186
G3HVK2 - 07- 0089-2500277
G3HVK2-07-0092-2500280
G3HVK2-07-0094-2500282
G3HVK2-07-0096-2500284
G3H VK2- 07- 0097- 2500285
G3HVK2- 07- 0098- 2500286
G3HVK2- 07- 0099- 2500287
G3HVK2- 07- 01 00- 2500289
G3HVK2-07-0101 -2500292
G3HVK2-07-0102-2500293
G3HVK2-07-0103-2500294
G3HVK2-07-0104-2500296
G3HVK2-07-0105-2500297
G3HVK2-07-0106-2500298
G3H VK2- 07- 0 1 07- 2500299
G3HVK2-07-0108-2500300
G3HVK2-07-0109-2500301
G3HVK2-07-01 10-2500302
G3HVJ2-07-011 1-2500303
G3HVK2-07-0080-2500337
G3HVK2-07-0112-2500338
G3HVK2-07-01 16-2500342
G3HVK2-07-01 17- 2500343
G3HVK2-07-0124-2500394
G3HVK2-07-0123-2500397
G3HVK2-07-0135-2500493
G3HVK2-07-0136-2500494
G3HVK2-07-0138-2500495
G3HVK2-07-0137-2500496
G3HVK2-07-0139-2500497
G3HVK2- 07- 01 42 -2500499
G3HVK2-07-0143-2500500
G3HVK2-07-0144-2500501
G3HVK2-07-0141 -2500575
Title
CLEARFIELD
ROCKAUAY BEACH
SARCOXIE
WAYLAND
BONNER SPRINGS
SELIGMAN
SELIGMAN
HUTCHINSON
MARSHAL LTOWN
RANDALL
RANDALL
ARCHIE
CHILLICOTHE
MUSCOTAH
LITTLE BLUE VALLEY
CAMDENTON
UELLSVILLE
AIRPORT DRIVE
GOLDEN CITY
VERDIGRE
PORTAGEVILLE
ATALISSA
ANKENY
OSAGE BEACH
DIAMOND
CINCINNATI
MCPHERSON
MINER
HOLLISTER
ALGONA
ALGONA
EOLIA
GOODMAN
LOCKWOOD
TRENTON
TRENTON
MARION COUNTY
LAMAR
WESTON
EXCELSIOR SPRINGS
BRAYMER,
LILBOURN
MONTGOMERY COUNTY
LAKE OZARK
BELLE
IRONTON
IRONTON
VALENTINE
AVA
PERRY
PANAMA
MARBLE HILL
MARBLE HILL
NIXA
BLAND
MET ST LOUIS SEWER
LANCASTER
MANCHESTER
FAIR GROVE
PARMA
PARSONS
HEROJLANEUM
JACKSON
PANAMA
GREEN CITY
LOCKWOOD
LAKE WABAUNSEE
UTICA
GLASGOW
MINER
BETHEL
PANAMA
WELTON
GOLDEN CITY
FARMINGTON

IA
MO
MO
MO
KS
MO
MO
KS
IA
IA
IA
MO
MO
KS
SEWER DISMO
MO
KS
MO
MO
NE
MO
MO
IA
MO
MO
IA
KS
MO
MO
IA
IA
MO
MO
MO
MO
MO
KS
MO
MO
MO
MO
MO
KS
MO
MO
MO
MO
NE
MO
MO
NE
MO
MO
MO
MO
DIST MO
MO
KS
MO
MO
KS
MO
MO
IA
MO
MO
KS
NE
MO
MO
MO
IA
IA
MO
MO
Final Report
Issued
10/28/91
10/28/91
10/28/91
10/29/91
10/29/91
10/29/91
10/29/91
10/29/91
1V 5/91
1V 5/91
1V 5/91
1V 7/91
IV 7/91
IV 7/91
1V 7/91
1V 7/91
1V 7/91
1V 8/91
1V 8/91
11/21/91
11/21/91
11/21/91
11/21/91
11/21/91
11/21/91
11/22/91
11/22/91
11/22/91
11/22/91
11/22/91
11/22/91
11/22/91
11/22/91
11/22/91
11/22/91
11/22/91
11/22/91
11/22/91
11/22/91
11/22/91
11/22/91
12/26/91
12/26/91
12/26/91
12/26/91
12/26/91
12/26/91
12/26/91
12/26/91
12/26/91
12/26/91
12/26/91
12/26/91
12/26/91
12/26/91
12/26/91
12/26/91
12/26/91
12/26/91
12/26/91
V 2/92
V 2/92
V 2/92
V 2/92
1/14/92
1/14/92
2/26/92
2/26/92
2/26/92
2/26/92
2/26/92
2/26/92
2/26/92
2/26/92
3/11/92
Ineligible Unsupported Unnecessary/ Efficiencies
Costs Costs Unreasonable (Funds Be Put
Costs To Better Use)
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
OCTOBER 1,1991 THROUGH MARCH 31 1992
                                                                                                                         49

-------
                                                                                       Questioned
Audit Control
Number
G3HVK2-07-0176-2500646
G3HVK2-07-0172-2500648
G3HVK2-07-0171 -2500649
G3HVK2-07-0170-2500650
G3HVK2-07-0169-2500651
G3HVK2-07-0168-2500652
N3HUK2-07-0178-2500095
N3HUK2-07-0030-2500097
N3H VK2 - 07- 0032 - 2500099
N3HVK2-07-0033-2500100
N3HVK2-07-0034-2500101
N3HVK2-07-0042-2500121
N3HVK2 - 07- 0047- 25001 23
N3HVK2-07-0044-2500126
N3HVK2-07-0055-2500155
N3HVK2-07-0054-2500156
N3HVK2-07-0052-2500158
N3HVK2-07-0051 -2500159
N3HVK2-07-0079-2500161
N3HVK2-07-0090-2500278
N3HVK2-07-0093-2500281
N3HVK2- 07- 0095 -2500283
N3HVK2-07-01 13-2500339
N3HVJ2-07-01 14-2500340
N3HVK2-07-01 15-2500341
N3HUK1 -07-0139-2500344
N3HWK1 -07-0138-2500345
N3HVK2-07-01 18-2500349
N3HVK2-07-0125-2500396
N3HVK2-07-0122-2500399
N3HVH2-07-0140-2500498
N3HVK2-07-0145-2500502
N3HVK2-07-0146- 2500503
N3HVK2-07-0147-2500504
N3HVK2-07-0174-2500647
Title
CHELSEA
AIRPORT DRIVE
PLEASANT HOPE
MARCEL I NE
MENLO
LAUREL
CENTRAL COMMUNITY COLLEGE
CROUDER COLLEGE

IA
MO
MO
MO
IA
IA
NE
MO
JOINT BOARD/HEALTH-KC/WYANDOKS
POLK COUNTY
POLK COUNTY
DES MOINES
JEFFERSON CITY
WICHITA
GRANBY
PITTSBURG
RENO COUNTY
WYANDOTTE COUNTY
SALEM
OMAHA
IRONDALE
LI NEVILLE
GALENA
NEBRASKA DEPT OF HEALTH
KANSAS CITY
CROWDER COLLEGE
JOPLIN
SPRINGFIELD
AMES
OTTAWA
IOWA CITY
POPLAR BLUFF
LINN COUNTY
ST LOUIS
JOPLIN
IA
IA
IA
MO
KS
MO
KS
KS
KS
MO
NE
MO
IA
MO
NE
MO
MO
MO
MO
IA
KS
IA
MO
IA
MO
MO
Final Report
Issued
3/23/92
3/23/92
3/23/92
3/23/92
3/23/92
3/23/92
1V 5/91
1V 5/91
1V 5/91
1V 5/91
1V 5/91
IV 7/91
1V 8/91
1V 8/91
11/21/91
11/21/91
11/21/91
11/21/91
11/21/91
12/26/91
12/26/91
12/26/91
V 2/92
V 2/92
V 2/92
V 2/92
V 2/92
V 3/92
1/14/92
1/14/92
2/26/92
2/26/92
2/26/92
2/26/92
3/23/92
Ineligible Unsupported Unnecessary/ Efficiencies
Costs Costs Unreasonable (Funds Be Put
Costs To Better Use)
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
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 07 =  112
C3HWK1 -08-0105-25001 18
G3HVJ2-08-0015-2500090
G3HVK2- 08- 00 18- 2500094
G3HVK2-08-0032- 2500304
G3HVJ2-08-0033-2500305
G3HVJ2-08-0038-2500312
G3HVK2-08-0037-2500313
G3H VK2 - 08- 0055 - 2500491
G3HVK2-08-0064-2500653
G3HVK2-08-0063-2500654
N3HVK2-08-0016-2500113
N3HUK2-08-0017-2500114
N3HVK2-08-0025-2500160
N3HVK2-08-0034-2500306
N3HUK2-08-0035-2500307
N3HVK2-08-0036-2500308
N3HUJ2-08-0041 -2500309
N3HVJ2-08-0040-2500310
N3HVK2-08-0039-2500311
N3HVJ2-08-0042-2500350
N3HVK2-08-0043-2500351
N3HVJ2-08-0044-2500352
N3HVK2-08-0056-2500492
N3HVK2-08-0065-2500673
SIOUX FALLS
COOPERSTOWN
GRAND FORKS
GILLETTE
BOX ELDER
DEVILS LAKE
MISSOULA
GREEN RIVER
CODY
CHANCELLOR
SALT LAKE COUNTY
CASPER COLLEGE
TURTLE MT BAND/CHIPPEWA
CASPER
BRIGHAM YOUNG UNIVERSITY
RIVERTON
ND STATE UNIVERSITY
ND PARKS & RECREATION
FARGO
SOUTH DAKOTA
BOULDER
UTAH
LARAM1E
GREAT FALLS
SD
ND
ND
WY
SD
ND
MT
WY
WY
SD
UT
WY
INDIND
WY
UT
WY
ND
ND
ND
SD
CO
UT
WY
MT
1V 7/91
1V 4/91
1V 5/91
12/26/91
12/26/91
12/26/91
12/26/91
2/25/92
3/23/92
3/23/92
1V 7/91
1V 7/91
11/21/91
12/26/91
12/26/91
12/26/91
12/26/91
12/26/91
12/26/91
V 3/92
V 3/92
V 3/92
2/25/92
3/31/92
              TOTAL OF REGION 08 =  24

C3HVK2-09-0157-2500620  HONOLULU CITY AND  COUNTY  OF  HI
G3HVK2-09-0151-2500591  HENDERSON, CITY OF          NV
N3HUK1-09-0239-2500007  UNIVERSITY OF NEVADA SYSTEM  NV
N3HVK1-09-0223-2500008  1ND10, CITY OF              CA
N3HUK2-09-0025-2500020  CALIF., UNIV. OF,  RIVERSIDE  CA
N3HVJ2-09-0026-2500021  ALAMEDA, CITY OF            CA
N3HVK2-09-0027-2500022  GOVERNMENT OF GUAM
N3HVK2-09-0035-2500032  LOS ANGELES, CITY  OF        CA
N3HVK2-09-0034-2500033  HUGHSON, CITY OF            CA
N3HVK2-09-0036-2500034  FORT MOJAVE INDIAN TRIBE     CA
 3/19/92
 3/16/92
10/ 9/91
10/ 9/91
10/16/91
10/16/91
10/16/91
10/18/91
10/18/91
10/18/91
                                                                                 0
                                                                                 0
                                                                                 0
                                                                                 0
                                                                                 0
                                                                                 0
                                                                                 0
                                                                                 0
                                                                                 0
                                                                                 0
                                                                                 0
                                                                                 0
                                                                                 0
                                                                                 0
                                                                                 0
                                                                                 0
                                                                                 0
                                                                                 0
                                                                                 0
                                                                                 0
                                                                                 0
                                                                                 0
                                                                                 0
                                                                                 0
      0
      0
      0
      0
      0
      0
      0
220,983
      0
      0
                                      0
                                      0
                                      0
                                      0
                                      0
                                      0
                                      0
                                      0
                                      0
                                      0
                                      0
                                      0
                                      0
                                      0
                                      0
                                      0
                                      0
                                      0
                                      0
                                      0
                                      0
                                      0
                                      0
                                      0
                                    0
                                    0
                                    0
                                    0
                                    0
                                    0
                                    0
                                    0
                                    0
                                    0
                                    0
                                    0
                                    0
                                    0
                                    0
                                    0
                                    0
                                    0
                                    0
                                    0
                                    0
                                    0
                                    0
                                    0
50
                                                                                                      OFFICE OF THE INSPECTOR GENERAL

-------
                                                                                        Questioned Costs
Audit Control
Number
N3HVK2- 09- 0037- 2500035
N3HVK2-09-0038-2500036
N3HVK2-09-0057-2500081
N3HVK2-09-0056-2500082
N3HVK2-09-0058-2500087
N3HVK2-09-0067- 2500137
N3HVK2-09-0083-2500240
N3HVK2- 09- 0084 - 2500243
N3HVJ2-09-0085-2500244
N3HVK2-09-0103-2500393
N3HVK2-09-0104-2500395
N3HVJ2-09-0105-2500398
N3HVK2-09-0106-2500401
N3HVK2-09-0107-2500415
N3HVK2-09-0108-2500416
N3HVK2-09-0109-2500418
N3HVK2-09-01 10-2500421
N3HUK2-09-01 17- 2500451
N3HVK2-09-01 18-2500452
N3HVK2-09-01 19-2500453
N3HVK2-09-0121 -2500455
N3HVK2-09-0051 -2500473
N3HVK2-09-0131-2500519
N3HVK2-09-0132-2500531
N3HVK2-09-0133-2500532
N3HVJ2-09-0138-2500545
N3HVK2-09-0143-2500576
N3HVK2-09-0145-2500584
N3HVK2-09-0146-2500585
N3HVK2-09-0147-2500586
N3HVK2-09-0148-2500587
N3HVK2-09-0150-2500590
N3HVK2-09-0164-2500674
N3HVK2-09-0162-2500675
N3HVK2-09-0163-2500676
TOTAL OF
G3HVJ2-10-0019- 2500400
G3HVJ2-10-0039-2500529
G3HVK2-10-0038-2500530
G3HVJ2-10-0041-2500544
G3HVK2-10-0044-2500573
N3HVK2-10-0001-2500023
N3HVJ2- 10-0005-2500080
N3HMK1- 10-0004-2500086
N3HVJ2- 10-0009-2500195
N3HVK2- 10-0013-2500241
N3HVJ2- 10-0012-2500242
N3HUJ2-10-0014-2500245
N3HVJ2- 1 0- 0031 - 2500454
N3HVK2-10-0036-2500474
N3HVK2- 10-0037- 2500520
Title
MODOC, COUNTY OF CA
VENTURA, COUNTY OF CA
HAWAII, DEPT., OF AGRIC. HI
PHOENIX, CITY OF AZ
SAN BERNARDINO, CO., OF CA
PALMER CREEK COMM. SVCS. DI CA
KOSRAE, STATE OF
OAKLAND, CITY OF CA
STEGE SANITARY DISTRICT CA
LAKE OROVILLE AREA P.U.D. CA
BERKELEY, CITY OF CA
MARICOPA COUNTY AZ
CHUCK, STATE OF FM
WEOTT COMMUNITY SVCS. DIST CA
PLYMOUTH, CITY OF CA
BOLINAS COMMUNITY P.U.D. CA
NO. SIERRA AIR QTY MGMT DIST CA
SAN DIEGO STATE UN IV FOUND CA
ASOC NAC PRO PERSONAS MAYORECA
MODESTO, CITY OF CA
HAWAII DEPT OF HEALTH HI
COLORADO RIVER IND. TRIBES AZ
BANNING, CITY OF CA
FRESNO, CITY OF CA
MANTECA, CITY OF CA
NEVADA STATE OF NV
ASSOC. OF BAY AREA GOV'T CA
GRASS VALLEY, CITY OF CA
ALBANY, CITY OF CA
EAST BAY MUNICIPAL UTIL DISTCA
MONTEREY REG WTR POLL CTL AGCA
ASSOC. OF BAY AREA GOV'T CA
RIVERSIDE S BERN CTY IND CA
SAN DIEGO, CITY OF CA
LAKE OROVILLE AREA P.U.D. CA
REGION 09 = 45
SAMMAMISH PLATEAU W & S DISTWA
PUGET SOUND AIR POLL CTRL AGWA
FAIRBANKS NORTH STAR BOROUGHAK
RAYMOND, CITY OF WA
BROOKINGS, CITY OF OR
SUQUAMISH TRIBE WA
THURSTON COUNTY WA
OREGON STATE OF OR
WASHINGTON, STATE OF WA
PORTLAND, CITY OF OR
ALASKA, STATE OF AK
KIONA-BENTON SCHOOL DIST#52 WA
IDAHO, DEPT. OF AGRIC. ID
PUYALLUP TRIBE OF INDIANS WA
ANCHORAGE, MUNICIPALITY OF AK
Final Report
Issued
10/18/91
10/18/91
10/31/91
10/31/91
1V 1/91
11/19/91
12/11/91
12/12/91
12/12/91
1/14/92
1/14/92
1/14/92
1/14/92
1/16/92
1/16/92
1/16/92
1/17/92
2/11/92
2/11/92
2/11/92
2/12/92
2/25/92
3/ 2/92
3/ 3/92
3/ 3/92
3/ 4/92
3/11/92
3/12/92
3/12/92
3/12/92
3/12/92
3/16/92
3/31/92
3/31/92
3/31/92

1/14/92
3/ 3/92
3/ 3/92
3/ 4/92
3/10/92
10/16/91
10/31/91
11/ 1/91
11/26/91
12/12/91
12/12/91
12/12/91
2/11/92
2/25/92
3/ 2/92
Ineligible Unsupported Unnecessary/ Efficiencies
Costs Costs Unreasonable (Funds Be Put
Costs To Better Use)
0
0
0
0
0
0
441
0
0
0
0
0
5,246
0
0
0
0
0
0
0
0
0
0
0
0
0
139
0
0
0
0
0
0
0
0
226,809
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
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 10 =  15
              TOTAL OTHER GRANT REPORTS
                                                      =  667
579,484
941,566
5. SUPERFUND GRANT ASSIGNMENTS

P5BGLO-02-0280-2100103  EQB                         PR    12/ 5/91
P5BGLO-02-0280-2100132  EQB                         PR    12/19/91
P5BGLO-02-0278-2100134  EQB                         PR    12/19/91
P5BGLO-02-0335-2100145  CFTROTH AND E OF VEGA ALTA  PR    12/20/91
P5BGLO-02-0246-2100212  NJDEP BURNT FLY BOG         NJ     2/ 5/92
P5BGLO-02-0247-2100213  NJDEP PRICE'S LANDFILL      NJ     2/ 5/92
P5BGLO-02-0248-2100214  NJDEP SYNCON RESINS         NJ     2/ 5/92
P5BGLO-02-0249-2100215  NJDEP COMBE FILL NORTH      NJ     21 5/92
P5BGLO-02-0250-2100216  NJDEP COMBE FILL SOUTH      NJ     2/ 5/92
P5BGLO-02-0251-2100217  NJDEP FLORENCE LANDFILL     NJ     2/ 5/92
P5BGLO-02-0252-2100218  NJDEP GEMS                  NJ     2/ 5/92

              TOTAL OF REGION 02 =  11
                38,192
               248,063
               741,429
               584,021
               231,089
                92,566
               237,748
                14,135

             2,187,243
OCTOBER 1,1991 THROUGH MARCH 31 1992
                                                                                                                                   51

-------
                                                                                         Questioned Costs
Audit Control Title
Number
E5BFN1 -04-0268-2300035 SF COOP AGREEMENT NC
E5BKN1 -04-0290-2300045 NORTH CAROLINA STATE UNIV. NC
TOTAL OF REGION 04 = 2
S5BGNO-09-0303-2300043 L.A. DEPT WATER & POWER CA
TOTAL OF REGION 09 = 1
P5CGLO- 10-0066-2100299 WASH DOE MULTI-SITE WA
TOTAL OF REGION 10 = 1
M5BFL2-1 1-0021 -2100057 FY 90 DOE SF COST CLAIMED
M5BFL1-11-0040-2100075 FY89 FEMA RELOCATION DC
M5BFLO-11-0038-2100076 SF-IAG HHS ATSDR-FIN. AUDIT
M5BFL1 -11 -0035-2100290 FY 87-89 001 BUR OF MINES DC
TOTAL OF REGION 11 (EPA HEADQUARTERS)
TOTAL SUPERFUND GRANT REPORTS
Final Report
Issued
2/19/92
3/26/92

3/13/92

3/30/92

11/13/91
11/26/91
11/26/91
3/26/92
4
19
Ineligible
Costs
0
854,863
854,863
2,321,195
2,321,195
259,541
259,541


3,435,599
Unsupported
Costs
19,724
654,164
673,888
0
0
3,006,140
3,006,140


5,867,271
Unnecessary/
Unreasonable
Costs
0
0
0
4,354,690
4,354,690
0
0


4,354,690
Efficiencies
(Funds Be Put
To Better Use)









8. OTHER CONTRACT ASSIGNMENTS

D8DML1-01-0242-2100000  FAY SPOFFARD AND THORNDIKE
D8AML1-01-0239-2100001  ARTHUR D. LITTLE
D8AML1-01-0241-2100044  EASTERN RESEARCH GROUP
D8CML1-01-0240-2100045  MITRE CORPORATION
D8AML2-01-0025-2100051  METCALF AND EDDY INC
D8AML2-01-0048-2100060  ABB ENVIRONMENTAL SERVICES
D8DML2-01-0050-2100062  EASTERN RESEARCH GROUP INC
D8AML2-01-0024-2100077  NORMANDEAU ASSOC.
D8BML1-01-0259-2100082  ARTHUR D. LITTLE
D8AML1-01-0260-2100083  GEOSERVE, INC
D8CML2-01-0067-2100104  METCALF AND EDDY INC.
D8DML2-01-0059-2100105  TRC ENVIRONMENTAL CONSULTANTCT
D8BML2-01-0061-2100106  ABB COMBUSTION ENGINEERING
D8DML2-01-0062-2100107  ALLIANCE TECH. CORP
D8DML2-01-0058-2100108  CAMP DRESSER AND MCKEE INC.
D8AML2-01-0057-2100109  REDWING ENVIRONMENTAL TECH.  MA
D8CAL2-01-0060-2100110  TRC ENVIRONMENTAL CONSULTANTCT
D8DML2-01-0063-2100115  ALLIANCE TECH. CORP.
D8AML2-01-0035-2100126  ENSR CONSULTING & ENGIN
D8AML2-01-0042-2100128  CADMUS GROUP
D8CML2-01-0076-2100136  ALLIANCE TECHNOLOGIES CORP
D8CML2-01-0077-2100137  ALLIANCE TECHNOLOGIES CORP
D8CML2-01-0079-2100138  ALLIANCE TECHNOLOGIES CORP
D8BML2-01-0083-2100139  ARTHUR D LITTLE INC.
D8CML2-01-0074-2100140  ALLIANCE TECHNOLOGIES CORP
D8CML2-01-0075-2100141  ALLIANCE TECHNOLOGIES CORP
D8CML2-01-0078-2100142  ALLIANCE TECHNOLOGIES, COPR.MA
D8BML2-01-0082-2100144  ARTHUR D. LITTLE, INC.
D8AML2-01-0049-2100160  A D LITTLE INC.
D8AML2-01-0047-2100161  JET LINE SERVICES INC
D8AML2-01-0036-2100162  AWS SCIENTIFIC
D8CML2-01-0066-2100204  TRC ENVIRONMENTAL CONSULTANTCT
D8AML2-01-0036-2100239  AWS SCIENTIFIC
D8AML2-01-0036-2100240  AWS SCIENTIFIC
D8AML2-01-0102-2100263  SYNETICS CORPORATION
D8AML2-01-0128-2100267  INDUSTRIAL ECONOMICS INC.
P8AML2-01-0038-2100246  ALLIANCE TECHNOLOGIES CORP.
P8AXL2-01-0111-2100289  ECOLOGY & ENVIRONMENT
MA
MA
MA
MA
MA
ME
MA
MA
MA
NH
MA
TCT
CT
MA
MA
MA
TCT
MA
MA
MA
MA
MA
MA
MA
MA
MA
.MA
MA
MA
MA
NY
TCT
NY
NY
MA
MA
MA
NY
10/ 1/91
10/ 4/91
10/30/91
10/31/91
11/ 7/91
11/14/91
11/18/91
11/26/91
12/ 2/91
12/ 2/91
12/ 5/91
12/ 5/91
12/ 5/91
12/ 5/91
12/ 5/91
12/ 6/91
12/ 6/91
12/12/91
12/13/91
12/16/91
12/20/91
12/20/91
12/20/91
12/20/91
12/20/91
12/20/91
12/20/91
12/20/91
M 2/92
1/ 2/92
I/ 2/92
1/30/92
2/19/92
2/19/92
3/10/92
3/17/92
2/24/92
3/26/92
              TOTAL OF REGION 01 =  38

D8AWL2-02-0021-2100009  HYDROQUAL INC

              TOTAL OF REGION 02 =   1
D8DML2-03-0067-2100013
D8BML2-03-0068-2100014
D8DML2-03-0069-2100015
D8DML2-03-0070-2100016
EG&G WASHINGTON ANAL SERVIC MD
DYNCORP/PRI                 MD
PA STATE UNIVERSITY         PA
COM FEDERAL PROGRAMS        VA
                                           *The dollar value  of  contract  reports  have not  been shown.
                                            Public  disclosure of the  dollar  value of  financial recom-
                                            mendations could  prematurely  reveal the Government's
                                            negotiating positions or  release of this  information  is
                                            not routinely available under the Freedom of  Information
                                            Act.  The number  of  these reports and dollar value of the
                                            findings have been included in the aggregate data displayed
                                            below.   Such data individually excluded in this listing  will
                                            be provided to the Congress under separate memorandum within
                                            30 days of the transmittal  of the semiannual  report to the
                                            agency  head.  The transmitted data will contain appropriate
                                            cautions regarding disclosure.
                            NJ    10/16/91
D8AML2-03-0040-2100017  PHILLIPS CARTNER & CO. INC  VA
10/23/91
10/23/91
10/23/91
10/23/91
10/23/91
52
                                                                             OFFICE OF THE INSPECTOR GENERAL

-------
Audit Control
Number
D8AWL2-03-0042-2100018
D8AML2-03-0041-2100019
D8AML2-03-0043-2100020
D8AML2-03-0044-2100021
D8AML2-03-0076-2100022
D8AML2-03-0045-2100023
D8AML2-03-0046-2100024
D8EML2-03-0047-2100025
D8EML2-03-0048-2100026
D8AML2-03-0032-2100027
08AAL2-03-0033-2100028
D8AAL2-03-0034-2100029
D8AAL2-03-0035-2100030
D8APL2-03-0036-2100031
D8AML2-03-0038-2100033
D8AML2-03-0039-2100034
D8AML2-03-0083-2100046
D8EML2-03-0084-2100047
D8CML2-03-0086-2100048
D8CUL2-03-0085-2100049
D8EML2-03-01 16-2100065
D8AML2-03-01 13-2100066
D8AML2-03-0112-2100067
D8EML2-03-011 1-2100068
D8EML2-03-01 10-2100069
D8EML2-03-0109-2100070
D8CML2-03-0134-2100093
D8AML2-03-0017-2100101
D8AML2-03-0088-2100102
D8AML2-03-0050-2100114
D8DML2-03-0122-2100116
D8BML2-03-0143-2100117
D8CLL2-03-0082-2100121
D8AWL2-03-0094-2100127
D8AML2-03-0096-2100129
D8AWL2-03-0093-2100151
D8BML2-03-0121 -2100153
D88ML2-03-0097-2100156
D8EML2-03-0170-2100157
D8AWL2-03-0095-2100158
D8CML2-03-0161 -2100167
D8ABL2-03-0077-2100172
D8DML2-03-0160-2100174
D80ML2-03-0178-2100175
D8AML2-03-0130-2100176
D8EML2-03-0163-2100178
D8AML2-03-0125-2100180
D8AML2-03-0124-2100185
D8AML2-03-0131 -2100186
D8ABL2-03-0078-2100188
D8BAL2-03-0182-2100189
D8DML2-03-0200-2100194
D8AML2-03-0187-2100207
D8AML2-03-0185-2100226
D8DML2-03-0216-2100228
D8AML2-03-0151 -2100231
D8CWL2 - 03 - 0225 - 2 1 00244
D8AAL2-03-0210-2100257
D8DML2-03-0278-2100274
D8DML2-03-0280-2100275
D80ML2-03-0282-2100277
D8AAL2-03-0212-2100281
D8AAL2-03-021 1-2100282
D8AAL2-03-0214-2100283
D8APL2-03-0218-2100288
P8AWL2-03-0018-2100006
P8AXL2-03-0074-2100058
P8AXL2-03-0075-2100059
P8AXL2-03-0030-2100071
P8AAL2-03-0072-2100087
P8AML2-03-0152-2100146
P8AML2-03-0153-2100199
P8AXL2-03-0175-2100235
P8AXL2-03-0219-2100256
P8AML2-03-0207-2100259
Title
ROY F WESTON PA
BRUCE COMPANY DC
COM FEDERAL PROGRAMS VA
JACA CORPORATION PA
ASCI CORPORATION VA
DIVERSIFIED TECHNOLOGY VA
EA ENGINEERING SCIENCE TECH MD
PHILLIPS GARTNER & CO., INC VA
BRUCE COMPANY DC
NAA SERVICES CORP VA
ROY F. UESTON PA
JACK FAUCETT ASSOCIATES MD
JACA CORPORATION PA
MITCHELL SYSTEMS CORP WV
RAVEN SERVICES CORP VA
PACIFIC ENVIRONMENTAL SER VA
TECHNOLOGY & MANAGEMENT SYS MD
CORPORATE INFORMATION SYSTEMVA
BOOZ ALLAN HAMILTON MD
BOOZ ALLEN HAMILTON MO
ROY F. UESTON PA
VIAR VA
VIAR VA
VIAR VA
VIAR VA
VIAR VA
TRACOR TECHNOLOGY MD
DYNAMAC MD
GKY & ASSOCIATES VA
COASTAL ENVIRONMENTAL MD
PA STATE PA
NUS CORP MD
SMC MARTIN, INC PA
GREELEY-POLHEMUS GROUP PA
VIAR VA
WADE MILLER ASSOCIATES VA
BOOZ ALLEN HAMILTON MD
INFORMATION SYSTEMS & SERV MD
GKY & ASSOCIATES INC. VA
APOGEE RESEARCH MD
GANNETT FLEMING ENVIRONMENT PA
DEVELOPMENT ALTERNATIVES MD
PA STATE UNIVERSITY PA
PA STATE UNIVERSITY PA
ITS SERVICES, INC. VA
ITS SERVICES, INC. VA
SCIENTIFIC & COMMERCIAL VA
EG&G WASHINGTON ANALYTICAL MD
R.O.U SCIENCES INC MD
AMERICAN COUNCIL FOR ENERGY DC
BOOZ ALLEN HAMILTON MO
PACIFIC ENVIRONMENTAL VA
RAY COMMUNICATION PA
NETWORK MANAGEMENT INC VA
PA STATE UNIVERSITY PA
SCIENTIFIC AND COMMERCIAL VA
BOOZ ALLEN HAMILTON MD
S COHEN VA
ARTHUR YOUNG DC
ARTHUR YOUNG DC
BIONETICS-MERCURY CONSOLIDA VA
ENERGY APPLICATIONS INC VA
GEOMET TECHNOLOGIES MD
KROLOFF MARSHALL & ASSOC DC
CONSAD RESEARCH CORPORATION PA
ICF CORP - ICF INCORPORATED VA
ICF CORP VA
ICF CORP VA
ICF CORP VA
ICF CORP VA
ICF CORP VA
ICF CORP VA
ICF CORP VA
ICF CORP - ICF TECHNOLOGY VA
ICF CORP VA
Final Report
Issued
10/23/91
10/23/91
10/23/91
10/23/91
10/23/91
10/24/91
10/24/91
10/24/91
10/24/91
10/24/91
10/25/91
10/25/91
10/25/91
10/25/91
10/25/91
10/25/91
IV 4/91
11/ 4/91
11/ 4/91
11/ 4/91
11/19/91
11/19/91
11/19/91
11/19/91
11/19/91
11/19/91
12/ 4/91
12/ 5/91
12/ 5/91
12/12/91
12/12/91
12/12/91
12/12/91
12/13/91
12/17/91
12/31/91
12/31/91
12/31/91
12/31/91
12/31/91
1/ 6/92
M 6/92
M 6/92
I/ 6/92
M 6/92
M 6/92
M 6/92
V 6/92
\l 6/92
M 7/92
I/ 9/92
1/15/92
1/31/92
2/10/92
2/11/92
2/11/92
2/21/92
3/ 4/92
3/19/92
3/19/92
3/19/92
3/20/92
3/23/92
3/23/92
3/26/92
10/ 9/91
11/13/91
11/13/91
11/19/91
12/ 4/91
12/20/91
1/24/92
2/12/92
3/ 2/92
3/ 5/92
uurauuiim wv<»» Recommended
Ineligible Unsupported Unnecessary/ Efficiencies
Costs Costs Unreasonable (Funds Be Put
Costs To Better Use)











































































OCTOBER 1,1991 THROUGH MARCH 31.1992
                                                                                                                         53

-------
Audit Control
Number
                        Title
                                  Final Report
                                  Issued
                                                                                      Questioned Costs
                  Ineligible
                    Costs
Unsupported
       Costs
Unnecessary/
Unreasonable
       Costs
Recommended
    Efficiencies
 (Funds Be Put
To Better Use)
P8AXL2-03-0256-2100296
P8BMN1-03-0146-2300014
P8DXN2-03-0162-2300025
ICF CORP -  ICF  RESOURCES INCVA
O&R MANAGEMENT  CORPORATION  MO
ICF CORP -  KAISER  ENGINEERS NM
 3/27/92
IV 5/91
12/30/91
              TOTAL OF REGION 03 =  83
D8DML2-04-0018-2100002 RESEARCH & EVALUATION ASSOC NC
D8AML2-04-0096-2100195 MANTECH ENVIRONMENTAL TECH NC
D8CMLO-04-0279-2100203 NSI TECHNOLOGY SVCS CORP NC
D8CMLO-04-0281 -2100220 NSI TECHNOLOGY SVCS INC. NC
D8CMLO-04-0280-2100221 NSI TECHNOLOGY SVCS INC. NC
D8CMLO-04-0282-2100222 NSI TECHNOLOGY SVCS CORP. NC
D8CMLO-04-0283-2100223 NSI TECHNOLOGY SVCS CORP NC
D8CMLO-04-0285-2100224 NSI TECHNOLOGY SVCS CORP. NC
D8CMLO-04-0284-2100225 NSI TECHNOLOGY SVCS CORP NC
D8AML2-04-01 15-2100247 ADVANCED SYSTEMS TECHNOLOGY GA
D8AML2-04-0116-2100248 ADVANCED SYSTEMS TECHNOLOGY GA
D8AML2-04-01 17-2100250 ADVANCED SYSTEMS TECHNOLOGY GA
D8DML2-04-0231 -2100260 RESEARCH & EVALUATION ASSOC NC
D8EML2-04-0230-2100261 ADVANCED SYSTEMS TECH INC. GA
D8EML2-04-0262-2100270 ADVANCED SYSTEMS TECHNOLOGY GA
D8EHL2-04-0147-2100271 ENVIRONMENTAL INVESTIGATIONSNC
D8AML2-04-0148-2100280 RESEARCH INFO. ORGANIZERS NC
D8DML2-04-0267-2100297 SOUTHERN RESEARCH INSTITUTE AL
TOTAL OF REGION 04 = 18
D8DML2-05-0020-2100052 BATTELLE OH
D8AML2-05-0043-2100088 BATTELLE OH
D8BML2-05-0045-2100099 BATTELLE FY 88 OH
D8CML2-05-0152-2100252 LIFE SYSTEMS INC OH
D8CML2-05-0151 -2100253 LIFE SYSTEMS INC OH
E8AXP2-05-0210-2400026 PRC EMI IL
E8AXP2-05-0223-2400034 PRC EMI IL
P8AXP2- 05 -0024 -2400006 DONOHUE COE NY OH
P8AXP2-05-0040-2400012 DONOHUE WI
TOTAL OF REGION 05 = 9
D8DML2-06-0014-2100154 SOUTHWEST RESEARCH INSTITUTETX
D8AML2-06-0046-2100173 RADIAN TX
D8CML2-06-0105-2100219 RADIAN CORPORATION TX
D8CMN2-06-0056-2300041 RADIAN CORP. TX
TOTAL OF REGION 06 = 4
D8CAL2-07-0130-2100211 MRI MO
D8CLN2-07-0014-2300008 MIDWEST RESEARCH INSTITUTE MO
D8CAN2-07-0015-2300009 MIDWEST RESEARCH INSTITUTE MO
D8AMN2-07-0026-2300013 MIDWEST RESEARCH INSTITUTE MO
D8AAN2-07-01 19-2300028 MIDWEST RESEARCH INSTITUTE MO
D8DMN2-07-0128-2300032 DEV PLAN & RESEARCH ASSOCIA KS
D8BMN2-07-0129-2300033 MRI MO
TOTAL OF REGION 07 = 7
D8AML2-08-0012-2100149 RCG/HAGLER
D8AMN2-08-0014-2300012 AIR RESOURCE SPECIALIST INC
TOTAL OF REGION 08 = 2
D8CML1 -09-0232-2100005 ACUREX CORP CA
D8AWL2-09-0095-2100035 ENGINEERING-SCIENCE CA
D8CML2-09-0098-2100036 ACUREX CORP CA
D8BML2-09-0099-2100037 AEROSPACE CORP EL SEGUNDO CA
D8AML2-09-0019-2100050 ACUREX P. A. D100662L1 CA
D8CML2-09-0063-2100053 ACUREX CORP. CA
D8BML2-09-0064-2100054 EDAW INC. CA
D8AML2-09-0022-2100073 TETRA TECH RFP NO W002170-A2CA
D8AML2-09-0021 -2100078 JACOBS ENG P/A W002170-A2 CA
D8AML2-09-0065-2100079 DAMES & MOORE P/A W002170-A2CA
D8AML2-09-0050-2100084 DECISION FOCUS PRE-AWARD CA
D8AML2-09-0043-2100085 E&S ENVIR. CHEMISTRY P. A. OR
D8AML2-09-0061 -2100086 ECOS PRE-AWARD CA
D8CAL2-09-0077-2100094 ENGINEERING SCIENCE CA
10/ 7/91
1/16/92
1/29/92
2/ 7/92
2/ 7/92
2/ 7/92
2/ 7/92
2/ 7/92
2/ 7/92
2/24/92
2/24/92
2/25/92
3/ 5/92
3/ 5/92
3/18/92
3/18/92
3/20/92
3/30/92

IV 7/91
12/ 4/91
12/ 4/91
2/25/92
2/25/92
3/26/92
3/31/92
12/16/91
12/31/91

12/31/91
V 3/92
2/ 6/92
3/ 5/92

2/ 4/92
10/28/91
10/28/91
1V 4/91
V 6/92
2/ 4/92
2/ 4/92

12/26/91
IV 4/91

10/ 9/91
10/25/91
10/25/91
10/25/91
IV 5/91
1V 7/91
1V 7/91
11/19/91
11/26/91
11/26/91
12/ 3/91
12/ 3/91
12/ 3/91
12/ 4/91
54
                                                                           OFFICE OF THE INSPECTOR GENERAL

-------
Audit Control
Number
D8CAL2-09-0078-2100095
D8CWL2-09-0079-2100096
D8AML2-09-0080-2100097
D8CAL2-09- 0081 -2100098
D8EML2-09-0062-2100111
D8AAL2-09-0054-2100113
D8AAL2-09-0049-2100122
D8AAL2-09-0053-2100123
D8CPL2-09-0086-2100133
D8AAL2-09-0048-2100135
D8BML2-09-0024-2100143
D8AAL2-09-0087-2100193
D8CML2-09-0082-2100232
D8AAL2-09-0120-2100233
D8BML2-09-0122-2100236
D8DML2-09-0124-2100238
D8CML2-09-0074-2100251
D8BML2-09-0140-2100262
D8BML2-09-0149-2100284
D8CML2-09-0059-2100286
D8CML2-09-0073-2100302
D8BMN2-09-0096-2300005
D8BMN2- 09- 0097- 2300006
D8AMN2-09-0060-2300016
D8AMN2- 09- 0066- 2300026
D8AMN2-09-0042-2300027
D8FMP2-09-0123-2400017
D8FMP2-09-0161 -2400035
H8AAL2-09-0055-2100196
H8AAL2-09-0052-2100245
TOTAL OF
D8AWL2-10-0015-2100124
D8AAL2-10-0004-2100201
E8DML1-10-0055-2100305
P8AXL2- 10-0018-2100242
P8AXL2- 10-0025-2100285
P8AXL2- 10-0021 -2100287
Title
ENGINEERING SCIENCE CA
ENGINEERING SCIENCE CA
INTERNATIONAL TECHNOLOGY CA
DAMES & MOORE FINAL CA
DECISION FOCUS CA
ERC ENV & ENERGY SVC P. A. CA
AEROVIRONHENTAL PRE -AWARD CA
C.L. STEGALL PRE-AWARD CA
SAIC CLOSE-OUT CA
GLOBAL GEOCHEMISTRY P. A. CA
JONES&STOKES OH&INC COST 90 CA
C.L. STEGALL P. A. CA
ACUREX CORP., FINAL CA
C.L. STEGALL CO. FIN CAPAB CA
INTERNATIONAL TECH 87 OH&DC CA
ACUREX CORPORATION 87-OH CA
ENGINEERING-SCIENCE FINAL CA
JACOBS ENGINEERING 87 OH&DC CA
ERC ENVIRONMENTAL SVC FY'87 CA
ENGINEERING-SCI CLOSE-OUT CA
KVB FINAL CA
ROCKWELL INTL CORP CA
JACOBS ENGINEERING GROUP CA
SCIENCE APPLICATIONS P. A. CA
SAIC RFP NO U100457-AZ CA
ENGIN FUEL & EMISSION P. A. CA
RAND CORPORATION CA
ROCKWELL INTL CORP FOLLOWUP CA
DESERT RESEARCH INST P. A. NV
UC DAVIS PRE-AWARD CA
REGION 09 = 44
ROBINSON CONSTRUCTION CO OR
KEYSTONE/NEA PRE-AWARD OR
TEAM SUPPORT SERVICES OR
CH2M P. A. OR
CH2M P. A. OR
CH2M P. A. OR
Final Report
Issued
12/ 4/91
12/ 4/91
12/ 4/91
12/ 4/91
12/ 6/91
12/10/91
12/12/91
12/13/91
12/19/91
12/19/91
12/20/91
1/14/92
2/11/92
2/11/92
2/12/92
2/13/92
2/25/92
3/ 5/92
3/24/92
3/24/92
3/31/92
10/25/91
10/25/91
12/ 3/91
I/ 2/92
I/ 2/92
2/13/92
3/31/92
1/17/92
2/21/92

12/13/91
1/28/92
3/31/92
2/20/92
3/24/92
3/25/92
Ineligible Unsupported Unnecessary/ Efficiencies
Costs Costs Unreasonable (Funds Be Put
Costs To Better Use)





































              TOTAL OF REGION 10 =   6
              TOTAL OTHER CONTRACT REPORTS
                                                      =  212
694,315
540,161
33,013,923
 9.  SUPERFUND CONTRACT ASSIGNMENTS
D9AHL2-01-0051-2100061
D9AHL2-01 -0072-2100125
TOTAL OF
D9EHL2-02-0031 -2100080
D9EHL2-02-0032-2100081
D9AHN2-02-0030-2300019
P9BGLO-02-0317-2100012
P9BGNO-02-0320-2300042
TOTAL OF
D9EKL2-03-0062-2100038
D9AKL2-03-0061 -2100039
D9AKL2-03-0065-2100040
D9AKL2-03-0060-2100041
D9AKL2-03-0071 -2100042
D9EKL2-03-0066-2100043
D9AKL2-03-0016-2100056
D9AKL2-03-0031-2100074
D9AHL2-03-0108-2100089
D9AKL2-03-0081 -2100090
D9EFL2-03-0139-2100091
D9AKL2-03-0107-2100092
D9AKL2-03-0073-2100100
D9AKL2-03-0105-2100112
D9AKL2-03-0102-2100118
FRANKLIN ENV. SERVICES INC. MA
ENPRO SERVICES INC. MA
REGION 01 = 2
ENVIRONMENTAL PRODUCTS INC NY
ENVIRONMENTAL PRODUCTS INC NY
ENVIRONMENTAL PRODUCTS INC NY
SUFFOLK COUNTY WATER AUTH NY
ECOLOGY AND ENVIRONMENT NY
REGION 02 = 5
INFORMATION SYSTEMS AND SERVMD
INFORMATION SYSTEMS AND SERVMD
INFOPRO INCORPORATED MD
MARASCO NEWTON GROUP LIMITEDVA
TECHNOLOGY & MANAGEMENT SERVMD
INFOPRO INCORPORATED MD
DYNAMAC INC MD
ENVIRONMENTAL MANAGEMENT MD
GOODE ENVORONMENTAL SERVICESVA
CORPORATE INFORMATION SYSTEMVA
GOODE ENVIRONMENTAL SERVICESVA
COMPUTER DATA SYSTEMS, INC MD
SCIENTIFIC CONSULTING GROUP MD
NATIONAL BIOSYSTEMS, INC. MD
SYCOM INC VA
11/18/91
12/13/91

12/ 2/91
12/ 2/91
12/ 6/91
10/18/91
3/13/92

10/29/91
10/29/91
10/29/91
10/29/91
10/29/91
10/29/91
11/ 8/91
11/22/91
12/ 4/91
12/ 4/91
12/ 4/91
12/ 4/91
12/ 5/91
12/10/91
12/12/91
OCTOBER 1,1991 THROUGH MARCH 31 1992
                                                                                                                                55

-------
Audit Control Title
Number
D9AKL2-03-0106-2100119 CBIS FEDERAL INCORPORATED

VA
D9AFL2-03-0103-2100120 INFORMATION SYSTEMS SOLUTIONMD
D9AKL2-03-0015-2100130 GANNETT FLEMING INC
D9CKL2-03-0147-2100131 BOOZ ALLEN HAMILTON
D9DFL2-03-0123-2100152 ROY F UESTON
D9AHL2-03-0117-2100168 NCI INFORMATION SYSTEMS INC
D9AKL2-03-01 15-2100169 DYNAMAC
D9AKL2-03-01 18-2100170 BOOZ ALLEN HAMILTON
D9AKL2-03-01 19-2100171 ROY F UESTON
D9AKL2-03-0120-2100181 APEX ENVIRONMENTAL
D9AFL2-03-0189-2100227 COMPUTER DATA SYSTEMS INC
D9CFL1-03-0379-2100229 VERSAR INC
D9DFL2-03-0226-2100243 ROY F UESTON
D9AFL2-03-0188-2100249 CENTEL FEDERAL SYSTEMS
D9AFL2-03-0277-2100273 ROY F UESTON
D9BFL2-03-0281 -2100276 UNISYS
D9AKN2-03-0063-2300010 ENVIRONMENTAL OPTIONS INC
PA
MD
PA
VA
MD
MD
PA
MD
MD
VA
PA
VA
PA
VA
VA
D9AKN2-03-0080-2300020 MARASCO NEWTON GROUP LIMITEDVA
D9BFN2-03-0204-2300037 NUS CORP
D9BJP2-03-0196-2400025 ROY F UESTON
P9AHL2-03-0019-2100011 ICF CORP
P9AHN1 -03-0232-2300003 ICF TECHNOLOGY INC.
TOTAL OF REGION 03 = 37
P9BHLO-04-0384-2100007 UESTINGHOUSE-HAZTECH
P9BHLO-04-0385-2100010 ENSITE INC
P9DGLO-04-0383-2100166 UESTINGHOUSE-HAZTECH
P9DHL1 -04-0436-2100197 ENSITE INC
P9AXN2-04-0027-2300015 EHRT
TOTAL OF REGION 04 = 5
D9AGL2-05-0055-2100177 E&K HAZARDOUS UASTE
D9AGL2-05-0060-2100179 CMC INC
D9AGL2-05-0059-2100182 E&K HAZARDOUS UASTE
D9AGL2-05-0058-2100254 CITY ENVIRONMENTAL
D9AGL2-05-0057-2100255 NORTHERN A-1 SERVICES
E9DKL1 -05-0159-2100202 PRC EMI FY 89
E9AHP2-05-0036-2400001 EQM ERCS3 R5
P9AHN1-Q5-0144-2300023 OHM REM ERCS2 Z2 FY 89
P9AHN1-05-0143-2300024 OHM REM ERCS2 Z1 FY 89
P9CHP1-05-0355-2400002 OHM REM BRODERICK
P9AHP2-05-0054-2400007 MARS E/S ERCS3 R5
P9AHP2- 05 -0052- 2400010 SAMSEL SERVICES ERCS3 R5
MD
PA
VA
VA

GA
GA
GA
GA
KY

UI
KY
UI
MI
MI
IL
OH
OH
OH
OH
IL
OH
Final Report
Issued
12/12/91
12/12/91
12/17/91
12/17/91
12/31/91
M 6/92
M 6/92
M 6/92
M 6/92
\l 6/92
2/10/92
2/11/92
2/21/92
2/25/92
3/18/92
3/19/92
10/29/91
12/10/91
2/21/92
3/19/92
10/18/91
10/17/91

10/ 9/91
10/18/91
M 3/92
1/21/92
11/15/91

\l 6/92
M 6/92
M 6/92
2/25/92
3/ 2/92
1/29/92
11/27/91
12/26/91
12/27/91
12/ 9/91
12/18/91
12/26/91
	 • 	 	 	 — — 	 IIWWIIIIIIVITWU
Ineligible Unsupported Unnecessary/ Efficiencies
Costs Costs Unreasonable (Funds Be Put
Costs To Better Use)









































               TOTAL OF REGION 05 =  12

 D9CKL2-07-0127-2100210  MRI
               TOTAL OF REGION 07
                                      1
 P9AXL2-10-0006-2100072
 P9EGL2-10-0008-2100192
 P9DHLO-10-0096-2100304
 P9FHP1-10-0075-2400036
CH2M P.A. RFP#088994-A-K1
CH2M REV CAS STAT ADEQUACY
RES 87 OH
RES-CONTINGENT FEES
                                                     MO
OR
OR
OR
OR
               TOTAL OF REGION 10 =   4
               TOTAL SUPERFUND CONTRACT REPORTS
               TOTAL REPORTS =  1,044
                                   21 4/92
11/19/91
 1/14/92
 3/31/92
 3/31/92
                                                           66
                                                  1,466,141
                                       315,114
                                                  38,108,514      18,413,362
                                                     14,568,992
                                                             39,310,028


                                                             72,434,951
 901 - REPORTS ISSUED BY ASSIGNMENT TYPE AND EPA REGION
             SEMI-ANNUAL PERIOD ENDING  3/31/92
56
                                                                                                      OFFICE OF THE INSPECTOR GENERAL

-------
    Appendix 2-Reports Without Management Decision
   THE INSPECTOR GENERAL ACT REQUIRES A SUMMARY OF EACH REPORT ISSUED BEFORE THE COMMENCEMENT OF THE
REPORTING PERIOD FOR WHICH NO MANAGEMENT DECISION HAS BEEN MADE BY THE END OF THE REPORTING PERIOD (INCLUDING
THE DATE AND TITLE OF EACH SUCH REPORT), AN EXPLANATION OF THE REASONS SUCH MANAGEMENT DECISION HAS NOT BEEN
MADE, AND A STATEMENT CONCERNING THE DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION ON EACH SUCH  REPORT.
(The IG provides the summary, the date and title of each such report. The Agency provides the explanation of the reasons such management decision
has not been made, and a statement concerning the desired timetable for achieving a management decision on each such report.)

 IG Followup Status Codes of Agency's Response at 3/31/92:

 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
Title
                         Final Report
                              Issued
 ASSISTANT ADMINISTRATOR FOR PESTICIDES AND TOXIC SUBSTANCES

 E1EPF1-05-0117-1100378   PESTICIDES INERTS                   9/27/91
 Summary: EPA DID NOT ENSURE (1) ADEQUATE ENFORCEMENT OF ITS INERTS
 STRATEGY (2) PROMPT REVIEW OF THE POTENTIAL EFFECTS OF INERT
 INGREDIENTS ON HUMANS AND THE ENVIRONMENT AND (3) THE ACCURACY
 OF INFORMATION ONINERTS.

 - EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN
 MADE: THE OFFICE SUBMITTED ITS MANAGEMENT DECISION TO THE OIG ON
 MARCH 26, 1992. THE OIG REQUESTED FURTHER INFORMATION ON SEVERAL
 RECOMMENDATIONS.

 = DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION:  THE
 OFFICE PLANS TO RESPOND BY MAY 15, 1992.

 IG FOLLOWUP STATUS AS OF 3/31/92: [2]

 ASSISTANT ADMINISTRATOR FOR WATER

 E1HWEO-04-0291-1100434   CWA SECTION 404 CONSOLIDATEDGA    9/30/91
 Summary: WETLANDS MAY BE UNNECESSARILY LOST TO DREDGE AND FILL
 DISCHARGES BECAUSE OF EPA'S INCONSISTENT AND UNPREDICTABLE
 PROGRAM IMPLEMENTATION IN THE AREAS OF ENFORCEMENT, PERMITTING,
 AND STRATEGIC INITIATIVES.

 - EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN
 MADE: THE OFFICE OF WATER RESPONDED TO THE OIG ON FEBRUARY 11,
 1992. THE OIG REQUESTED ADDITIONAL INFORMATION ON MARCH 11, 1992.
 THE OFFICE OF WATER
 IS COLLECTING INFORMATION TO PRESENT TO IG TO RESOLVE AUDIT.

 = DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION:  THE
 MANAGEMENT DECISION SHOULD BE ISSUED BY JUNE 15, 1992.

 IG FOLLOWUP STATUS AS OF 3/31/92: [2]

 ASSISTANT ADMINISTRATOR FOR ADMINISTRATION AND RESOURCES
 MANAGEMENT

 E1SFG1-05-0018-1400046   CONTRACTOR PROPERTY OVERSIGHT     9/27/91
 Summary: EPA HAD COMPLETED THE REVIEW OF PROPERTY CONTROL
 SYSTEMS FOR LESS THAN ONE-THIRD OF ITS CONTRACTORS HOLDING
 GOVERNMENT PROPERTY. AS A RESULT, IT HAD NO ASSURANCE THAT
 GOVERNMENT PROPERTY IN THE HANDS OF THESE CONTRACTORS WAS
ADEQUATELY SAFEGUARDED.

- EXPLANATION OF THE REASONS MANAGEMENT DECISION  HAS NOT BEEN
 MADE: An explanation was not provided by EPA.

= DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION: THE
OFFICE FORWARDED A PROPOSED MANAGEMENT DECISION TO THE OIG ON
FEBRUARY 14, 1992.

IG FOLLOWUP STATUS AS OF 3/31/92: [4] (Report is  to be closed out in April
 1992.)
                E1XMF1-08-0033-1100441 REGION 8 MGT. OF CSC CONTRACT        9/30/91
                Summary: REGION 8 NEEDS TO STOP SUPERVISING CSC EMPLOYEES AND
                BEGIN MONITORING CSC CONTRACT ACTIVITIES  REGION 8 TREATED THE
                CSC SERVICE CONTRACT AS A PERSONAL SERVICE CONTRACT, CONTRARY
                TO FAR AND CIVIL SERVICE LAWS.

                -EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN
                MADE: An explanation was not provided by EPA.

                = DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION: THE
                OFFICE FORWARDED A PROPOSED MANAGEMENT DECISION TO THE OIG ON
                JANUARY 21, 1992.

                IG FOLLOWUP STATUS AS OF 3/31/92: [2]

                E6EMPO-15-0039-1400060   ACI CONTRACT ALLEGATIONS          9/30/91
                Summary: EPA COULD PAY UP TO $8.4 MILLION OVER DECREASING MARKET
                PRICES FOR MICROCOMPUTER WORKSTATIONS AND OTHER ADP EQUIPMENT
                BY NOT MODIFYING AND INTERIM CONTRACT AND DELAYING A COMPETITIVE
                AWARD. EPA COULD ALSO PAY THE CONTRACTOR $2.3 MILLION MORE THAN
                ACTUALLY INCURRED FOR OPERATING EXPENSES.

                - EXPLANATION  OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN
                MADE: THIS AUDIT RESPONSE IS IN THE PROCESS  OF BEING COMPLETED BY
                OARM FOR THE  OIG. THE  ISSUES IN THE IG'S REPORT HAVE BEEN
                ADDRESSED.

                * DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION: THE
                AUDIT IS EXPECTED TO BE RESOLVED WITHIN THE NEXT REPORTING PERIOD.

                IG FOLLOWUP STATUS AS OF 3/31/92: [1]

                PROCUREMENT  CONTRACTS MANAGEMENT DIVISION

                P9BHN1-04-0317-1300110   ENVIRONMENTAL HEALTH     KY      9/23/91
                Summary: LABOR COSTS TOTALING $334,856 WERE QUESTIONED BECAUSE
                THE CONTRACTOR DID NOT SUBMIT COST & PRICING DATA AS REQUIRED BY
                FAR SUBCONTRACT COSTS OF $94,236 WERE QUESTIONED BECAUSE THE
                SUBCONTRACTOR WAS SELECTED IN A MANNER  INCONSISTENT WITH FAR
                REQUIREMENTS.

                - EXPLANATION  OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN
                MADE: An explanation was not provided by EPA.

                - DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION: THIS IS A
                PREAWARD AUDIT. NEGOTIATIONS TO BE COMPLETED BY JULY 22, 1992.

                IG FOLLOWUP STATUS AS  OF 3/31/92:  [1] (This was an interim audit - not a
                preaward audit as  alleged by the above statement.  No response has been received
                on this report)
OCTOBER 1,1991 THROUGH MARCH 31 1992
                                                                                                                        57

-------
Assignment Control
Number
                       Title
                                                 Final Report
                                                      Issued
Assignment Control
Number
Title
Final Report
     Issued
 PROCUREMENT CONTRACTS MANAGEMENT DIVISION

 Cincinnati Cost Advisory Branch
 D8CML1-04-0442-1100311
 'Summary:
                      MANTECH ENVIRONMENTAL
                                                NC
                                                        7/10/91
 - EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN
 MADE:  THE CONTRACTOR IS IN AN OVERRUN SITUATION. THE CONTRACT
 OFFICER HAS REQUESTED THE CONTRACTOR TO PROVIDE DOCUMENTATION
 SUBSTANTIATING ITS CLAIM THAT IT SATISFIED THE NOTICE REQUIREMENTS
 OF THE LIMITATION OF FUNDS CLAUSE IN THE
 CONTRACT. THE AGENCY IS AWAITING THE CONTRACTOR'S RESPONSE.

 - DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION:
 ANTICIPATED RESOLUTION DATE IS MAY 25, 1992.

 IG FOLLOWUP STATUS AS OF 3/31/92: |1]

 PROCUREMENT CONTRACTS MANAGEMENT DIVISION

 Cost Policy and Rate Negotiation Section
                      PHILADELPHIA CITY OF
                                             PA
                                                         9/12/91
P2DW8-03-0174-1300105
•Summary:

- EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN
MADE: THE AGENCY IS HAVING PROBLEMS REACHING AN AGREEMENT WITH
THE CONTRACTOR. COST POLICY QUESTIONS HAVE BEEN ADVANCED TO
THE GENERAL COUNSEL AND DIG ON HOW TO ADDRESS QUESTIONED COSTS
BETWEEN INDIRECT AND DIRECT COST AUDITS.

= DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION: A desired
timetable was not provided by EPA.

IG FOLLOWUP STATUS AS OF 3/31/92: [1]

P90HL9-10-0110-1100108   RES FY86 INDIRECT COSTS   OR         1/24/91
'Summary:

- EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN
MADE: THE DIG ASKED THAT NEGOTIATIONS BE SUSPENDED PENDING THE
RESOLUTION OF OTHER ISSUES THAT MAY IMPACT THE OUTCOME OF THIS
AUDIT.

- DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION: A desired
timetable was not provided by EPA.

IG FOLLOWUP STATUS AS OF 3/31/92: [11

PROCUREMENT CONTRACTS MANAGEMENT DIVISION

Durham Cost Advisory Branch

D8ABN1-07-0162-1300083   PSI/HALL KIMBRELL       MO          7/ 2/91
'Summary:

- EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN
MADE: An explanation was not provided by EPA.

- DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION: THE
DECISION DATE FOR THIS AUDIT WAS JANUARY 15, 1992.

IG FOLLOWUP STATUS AS OF 3/31/92: [1]  (This report was  closed on 4/22/92.)

PROCUREMENT CONTRACTS MANAGEMENT DIVISION

Financial Analysis Section

P9BHNO-03-0382-1300101   GUARDIAN ENVIRONMENTAL SVC DE      8/29/91
Summary: GUARDIAN ENVIRONMENTAL SERVICES CLAIMED OVER $65 MILLION
OF QUESTIONED COSTS CONSISTING PRIMARILY OF UNAUTHORIZED
EQUIPMENT, MATERIALS AND PERSONNEL COSTS.

- EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN
MADE: An explanation was not provided by EPA.

- DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION:
NEGOTIATIONS TO BE COMPLETED BY 6/30/92
IG FOLLOWUP STATUS AS OF 3/31/92: [1]
P9AHN9-05-0347-0300036    OH MATERIALS (PR EQ RATES)  OH       3/27/90
Summary: WE HAVE RECOMMENDED REDUCTIONS OF $670,000 TO PROPOSED
FIXED RATES FOR EQUIPMENT PRIMARILY BECAUSE OF ERRORS IN
UTILIZATION METHODS, ADJUSTMENTS FOR FULLY DEPRECIATED EQUIPMENT
AND UNSUPPORTED ESTIMATES AND ASSUMPTIONS BY THE CONTRACTOR.

- EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN
MADE: NEGOTIATIONS ARE STILL PENDING.  EPA REQUESTED FURTHER
AUDITS ON THE CONTRACTOR'S EQUIPMENT UTILIZATION RATES FOR 1989
AND 1990 IN ORDER TO RESOLVE THESE COSTS.

- DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION:  AUDITS
FOR 1987 AND 1988 SHOULD BE RESOLVED WITHIN TWELVE MONTHS FROM
RECEIPT OF THESE 1989 AND 1990 AUDITS.

IG FOLLOWUP STATUS AS OF 3/31/92: [1]

P9AHNO-OWJ260-0300047    OH MATERIALS (PR EO RATES)  OH       4/27/90
Summary:  WE RECOMMENDED $182,049 IN EFFICIENCIES DUE TO PROPOSED
EQUIPMENT RATES 1) EXCEEDING CONTRACT CEILING RESTRICTIONS, 2)
BEING DEVELOPED USING ESTIMATED COSTS, AND 3) BEING DEVELOPED
USING INFORMATION OTHER THAN COST DATA.

- EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN
MADE: CONTRACT HAS NOT BEEN AWARDED YET.  NEGOTIATIONS ARE STILL
PENDING.

- DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION:  No
desired timetable was provided by EPA.

IG FOLLOWUP STATUS AS OF 3/31/92: [1]

REGION 5 - GRANTS FINANCIAL MANAGEMENT

P2CWN9-05-0336-0300076   WELLSVILLE            OH            8/6/90
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 WITH THE SSES TO BE SUBMITTED ON JULY 7, 1992. THE DIG WILL
NOT REINSTATE COSTS UNTIL SSES HAS BEEN SUBMITTED AND APPROVED

- DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION:

A desired timetable was not provided by EPA.

IG FOLLOWUP STATUS AS OF 3/31/92: [1]  (No formal response has been made to
the Divisional IG Office.)

P2CWNB-05-0273-1300090   LAKE CO DPW          IL            7/30/91
Summary:  WE QUESTIONED INELIGIBLE COSTS OF $419,805.  THEY WERE
UNALLOWABLE UNDER EPA REGULATIONS OR GUIDANCE.

- EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN
MADE: COMMENTS WERE NEEDED FROM ILLINOIS EPA REGARDING CHANGE
ORDER APPROVAL. A  PROPOSED FINAL DETERMINATION LETTER WAS SENT
TO DIG ON FEBRUARY 5,  1992. AWAITING RESPONSE TO PRELIMINARY
LETTER.

- DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION:  FINAL
DETERMINATION SHOULD BE ISSUED BY APRIL 30, 1992.
IG FOLLOWUP STATUS AS OF 3/31/92: [2]

P2CWNW)5-0086-1300115   GALiON              OH             9/26/91
Summary:  THE GRANTEE CLAIMED $95,620 FEDERAL SHARE OF INELIGIBLE
A/E COSTS. THESE COSTS WERE QUESTIONED BECAUSE THEY WERE
INCURRED AFTER THE APPROVED CONSTRUCTION CONTRACT COMPLETION
DATE. IN  ADDITION, $49,948 FEDERAL SHARE OF A/E COSTS WERE NOT
SUPPORTED.

- EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN
MADE: INTENSE DETAILED TECHNICAL REVIEW OF CLIMATOLOGICAL DATA
REQUIRED.

- DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION:  THE
REGION ANTICIPATES RESOLUTION OF THIS AUDIT BY MAY 15, 1992.

IG FOLLOWUP STATUS AS OF 3/31/92: [1]
 58
                                                                                                   OFFICE OF THE INSPECTOR GENERAL

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 Assignment Control
 Number
Title
                          Final Report
                               Issued
Assignment Control
Number
Title
                          Final Report
                               Issued
 P2CWP9-05-007S-1400037   GARY SD              IN             9/ 9/91
 Summary: ALMOST $2.8 MILLION WASTED WHEN THE GRANTEE FAILED TO
 OPERATE AND MAINTAIN A WASTEWATER TREATMENT PLANT.

 - EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN
 MADE: THE LOCAL DIG WILL NOT CONCUR WITH THE REGION'S
 MANAGEMENT DECISION UNTIL ACTIONS REQUIRED UNDER A CONSENT
 DECREE ARE COMPLETE.

 - DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION:  THE
 GRANTEE HAS UNTIL 1994 TO COMPLY WITH THE CONSENT DECREE.

 IG FOLLOWUP STATUS AS OF 3/31/92: [3]

 P2CWP8-05-0026-1400038   GARY SD              IN             9/9/91
 Summary: ALMOST $25 MILLION WASTED WHEN THE GRANTEE FAILED TO
 OPERATE AND MAINTAIN A WASTEWATER TREATMENT PLANT.

 - EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN
 MADE: THE LOCAL DIG WILL NOT CONCUR WITH THE REGION'S
 MANAGEMENT DECISION UNTIL ACTIONS REQUIRED UNDER A CONSENT
 DECREE ARE COMPLETE.

 - DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION:  THE
 GRANTEE HAS UNTIL 1994 TO COMPLY WITH THE CONSENT DECREE.

 IG FOLLOWUP STATUS AS OF 3/31/92: [3]

 P2CWP9-05-0070-1400047   INDIANAPOLIS           IN            9/24/91
 Summary: GRANTEE CLAIMS OVER $6.7 MILLION OF QUESTIONED COSTS. WE
  QUESTIONED $3,177,937 OF INELIGIBLE CONSTRUCTION COSTS, AND
 $2,072,454 OF UNSUPPORTED FORCE ACCOUNT & ENGINEERING COSTS.

 - EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN
 MADE: THE  GRANTEE HAS FORWARDED EIGHT VOLUMES OF
 DOCUMENTATION REGARDING UNSUPPORTED COSTS. THESE RECORDS
 WERE NOT MADE AVAILABLE FOR THE AUDITOR TO  EXAMINE DURING THE
 ON-SITE VISIT  DUE TO VOLUME AND COMPLEXITY OF THE DOCUMENTATION,
 REGION 5 HAS HAD TO REVIEW THESE RECORDS.

 - DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION:  THE
 FINAL DETERMINATION LETTER SHOULD BE ISSUED  BY JUNE 30, 1992.

 IG FOLLOWUP STATUS AS OF 3/31/92: [1]

 P2CWN4-05-0183-5100159   EUCLID              OH             7/12/85
 Summary: WE QUESTIONED THE ENTIRE GRANT AWARD OF ALMOST $14.3
 MILLION THE 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 BEEN
 MADE: RESOLUTION OF QUESTIONED COSTS DEPENDS UPON GRANTEE'S
 SATISFACTORY COMPLETION OF ACTIONS IMPOSED  BY CONSENT DECREE.

 - DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION: CONSENT
 DECREE ALLOWS GRANTEE UNTIL 1996 TO COMPLETE CORRECTIVE ACTIONS.

 IG FOLLOWUP STATUS AS OF 3/31/92: [3]

 P3DWL1-05-0360-51005S9   PRC ENG CT FY 80/81      IL            9/25/85
 •Summary: WE RECOMMENDED OVERHEAD RATES OF 145.36 PERCENT AND
 131 73 PERCENT FOR FISCAL 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. THE  REGION IS ALSO
 AWAITING ADDITIONAL INFORMATION FROM PRC.

 - DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION:
 TARGETED FINAL DETERMINATION DATE IS JUNE 29, 1992.

 IG FOLLOWUP STATUS AS OF 3/31/92: [2]
                                           P2CWN4-05-0357-6100389   DETROIT WSD          Ml
                                           Summary: THE CITY OF DETROIT, Ml CLAIMED OVER $169,000 OF
                                           UNREASONABLE ENGINEERING COSTS.
                                                        8/25/86
                                           - EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN
                                           MADE: THE DIG NOTIFIED THE REGION ON JANUARY 15, 1992 THAT ITS
                                           MANAGEMENT DECISION IS INCOMPLETE. THE HEADQUARTERS DIG HAS
                                           INITIATED DISCUSSIONS WITH THE OFFICE OF WATER TO CLARIFY SOME OF
                                           THE ISSUES.

                                           - DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION: NO
                                           ACCURATE RESOLUTION DATE CAN BE ESTIMATED AT THIS TIME.

                                           IG FOLLOWUP STATUS AS OF 3/31/92: [2]

                                           P2GWN4-05-0264-6100390   DETROIT WSD           Ml           8/25/86
                                           Summary: WE QUESTIONED INELIGIBLE FORCE ACCOUNT COSTS OF $20,872
                                           INCURRED PRIOR TO THE GRANT AWARD.  IN ADDITION, UNSUPPORTED
                                           FORCE ACCOUNT COSTS OF $36,370 INCURRED AFTER THE APPROVED
                                           CONSTRUCTION COMPLETION DATE WERE QUESTIONED.

                                           - EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN
                                           MADE: THE OIG NOTIFIED THE REGION ON JANUARY 15, 1992 THAT ITS
                                           MANAGEMENT DECISION IS INCOMPLETE. THE HEADQUARTERS OIG HAS
                                           INITIATED DISCUSSIONS WITH THE OFFICE OF WATER TO CLARIFY SOME OF
                                           THE ISSUES.

                                           - DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION: NO
                                           ACCURATE RESOLUTION DATE CAN BE ESTIMATED AT THIS TIME.

                                           IG FOLLOWUP STATUS AS OF 3/31/92: [2]

                                           P2CWN4-05-0263-6100391    DETROIT WSD           Ml           8/25/86
                                           Summary: THE GRANTEE CLAIMED UNREASONABLE FORCE ACCOUNT COSTS
                                           OF $286,000.  THE GRANTEE ALSO CLAIMED INELIGIBLE COSTS OF $15,000.

                                           - EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN
                                           MADE: THE OIG NOTIFIED THE REGION ON JANUARY 15, 1992 THAT ITS
                                           MANAGEMENT DECISION IS INCOMPLETE. THE HEADQUARTERS OIG HAS
                                           INITIATED DISCUSSIONS WITH THE OFFICE OF WATER TO CLARIFY SOME OF
                                           THE ISSUES.

                                           - DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION. NO
                                           ACCURATE RESOLUTION DATE CAN BE ESTIMATED AT THIS TIME.

                                           IG FOLLOWUP STATUS AS OF 3/31/92: [2]

                                           P2CWN4-05-0280-6100574   DETROIT WSD           Ml           9/30/86
                                           Summary: WE QUESTIONED INELIGIBLE COST OF $293,000 MOSTLY FOR
                                           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
                                           MADE: THE OIG NOTIFIED THE REGION ON JANUARY 15, 1992 THAT ITS
                                           MANAGEMENT DECISION IS INCOMPLETE. THE HEADQUARTERS OIG HAS
                                           INITIATED DISCUSSIONS WITH THE OFFICE OF WATER TO CLARIFY SOME OF
                                           THE ISSUES.

                                           - DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION: NO
                                           ACCURATE RESOLUTION DATE CAN BE ESTIMATED AT THIS TIME

                                           IG FOLLOWUP STATUS AS OF 3/31/92: [2]

                                           P2CWN4-05-0265-6100575   DETROIT WSD           Wl           9/30/86
                                           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:  THE OIG NOTIFIED THE REGION ON JANUARY 15, 1992 THAT ITS
                                           MANAGEMENT DECISION IS INCOMPLETE. THE HEADQUARTERS OIG HAS
                                           INITIATED DISCUSSIONS WITH THE OFFICE OF WATER TO CLARIFY SOME OF
                                           THE ISSUES.

                                           - DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION: NO
                                           ACCURATE RESOLUTION DATE CAN BE ESTIMATED AT THIS TIME.

                                           IG  FOLLOWUP STATUS AS OF 3/31/92: [2J
OCTOBER 1,1991 THROUGH MARCH 31 1992
                                                                                                                             59

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Assignment Control
Number
Title
                          Rnal Report
                               Issued
Assignment Control
Number
Title
Final Report
     Issued
P2CWN5-05-0242-7000034   DETROIT WSD           Ml           10/6/86
Summary:  WE QUESTIONED INELIGIBLE CONSTRUCTION AND ENGINEERING
COSTS OF $20,006. IN ADDITION, WE QUESTIONED UNSUPPORTED
ENGINEERING COSTS OF $40,495 INCURRED AFTER THE APPROVED
CONSTRUCTION COMPLETION DATE.

- EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN
MADE: THEOIG
NOTIFIED THE REGION ON JANUARY 15, 1992 THAT ITS MANAGEMENT
DECISION IS INCOMPLETE.  THE HEADQUARTERS OIG HAS INITIATED
DISCUSSIONS WITH THE OFFICE OF WATER TO CLARIFY SOME OF THE
ISSUES.

• DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION:  NO
ACCURATE RESOLUTION DATE CAN BE ESTIMATED AT THIS TIME.

IG FOLLOWUP STATUS AS OF 3/31/92: J2]

P2CWN5-05-0246-7000044   DETROIT WSD           Ml           10/7/86
Summary:  THE GRANTEE CLAIMED UNREASONABLE FORCE ACCOUNT COSTS
OF $336,000.

- EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN
MADE: THE OIG NOTIFIED THE REGION ON JANUARY 15, 1992 THAT ITS
MANAGEMENT DECISION IS INCOMPLETE. THE HEADQUARTERS OIG HAS
INITIATED DISCUSSIONS WITH THE OFFICE OF WATER TO CLARIFY SOME OF
THE ISSUES.

- DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION:  NO
ACCURATE RESOLUTION DATE CAN BE ESTIMATED AT THIS TIME.

IG FOLLOWUP STATUS AS OF 3/31/92: [2]

P2GWN5-05-0275-7000045   DETROIT WSD           Ml           10/7/86
Summary:  WE QUESTIONED $80,000 OF INELIGIBLE ENGINEERING AND
CONSTRUCTION COSTS. ENGINEERING COSTS OF $112,000 INCURRED AFTER
THE APPROVED CONSTRUCTION COMPLETION DATE WERE NOT SUPPORTED.

- EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN
MADE: THE OIG NOTIFIED THE REGION ON JANUARY 15, 1992 THAT ITS
MANAGEMENT DECISION IS INCOMPLETE. THE HEADQUARTERS OIG HAS
INITIATED DISCUSSIONS WITH THE OFFICE OF WATER TO CLARIFY SOME OF
THE ISSUES.

* DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION:  NO
ACCURATE RESOLUTION DATE CAN BE ESTIMATED AT THIS TIME.

IG FOLLOWUP STATUS AS OF 3/31/92: [2]

P2CWN5-05-0247-7000049   DETROIT WSD           Ml           10/8/86
Summary:  WE QUESTIONED UNREASONABLE TECHNICAL SERVICES AND
CONSTRUCTION   COSTS OF $559,000.

- EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN
MADE: THE OIG NOTIFIED THE REGION ON JANUARY 15, 1992 THAT ITS
MANAGEMENT DECISION IS INCOMPLETE. THE HEADQUARTERS OIG  HAS
INITIATED DISCUSSIONS WITH THE OFFICE OF WATER TO CLARIFY SOME OF
THE ISSUES.

- DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION:  NO
ACCURATE
RESOLUTION DATE CAN BE ESTIMATED AT THIS TIME.

IG FOLLOWUP STATUS AS OF  3/31/92: [2]

P2CWN5-05-0276-7000050   DETROIT WSD           Ml           10/8/86
Summary.  WE QUESTIONED $59,000 OF INELIGIBLE ENGINEERING COSTS.
ENGINEERING COSTS OF $433,600 INCURRED AFTER THE APPROVED
CONSTRUCTION COMPLETION DATE WERE NOT SUPPORTED.

- EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN
MADE: THE OIG NOTIFIED THE REGION ON JANUARY 15, 1992 THAT ITS
MANAGEMENT DECISION IS INCOMPLETE. THE HEADQUARTERS OIG  HAS
INITIATED DISCUSSIONS WITH THE OFFICE OF WATER TO CLARIFY SOME OF
THE ISSUES.

- DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION.  NO
ACCURATE RESOLUTION DATE CAN BE  ESTIMATED AT THIS TIME.

 IG FOLLOWUP STATUS AS OF  3/31/92: [2]
                                           E2BWL5-05-0136-7000980   SAUGET              IL             3/31/87
                                           Summary:  SAUGET, IL WAS AWARDED FEDERAL FUNDS IN EXCESS OF $7
                                           MILLION FOR INELIGIBLE AND UNNECESSARY PROJECT COSTS.

                                           - EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN
                                           MADE: AUDIT REPORT HAS COMPLEX ISSUES WITH TOTAL QUESTIONED AND
                                           UNSUPPORTED COSTS OF $15,323,316. THE REGION IS SEEKING GUIDANCE
                                           FROM REGIONAL COUNSEL AND WATER DIVISION.  A DEVIATION REQUEST IS
                                           PENDING IN EPA HEADQUARTERS.

                                           - DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT  DECISION:  A desired
                                           timetable was not provided by EPA.

                                           IG FOLLOWUP STATUS AS OF 3/31/92: [2]

                                           P2GWN5-05-0132-8000464   DETROIT WSD          Ml          1/20/88
                                           Summary:  DETROIT CLAIMED INELIGIBLE COSTS OF ALMOST $2.6 MILLION
                                           RESULTING FROM ITS FAILURE TO HONOR A CONTRACT.  WE ALSO
                                           QUESTIONED UNSUPPORTED  COSTS OF ALMOST $2.1 MILLION.

                                           - EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN
                                           MADE: THE OIG NOTIFIED THE REGION ON JANUARY 15,  1992 THAT ITS
                                           MANAGEMENT DECISION IS INCOMPLETE. THE HEADQUARTERS OIG HAS
                                           INITIATED  DISCUSSIONS WITH THE OFFICE OF WATER TO CLARIFY SOME OF
                                           THE ISSUES.

                                           - DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT  DECISION:  NO
                                           ACCURATE RESOLUTION DATE CAN BE ESTIMATED AT THIS TIME
                                           IG FOLLOWUP STATUS AS OF 3/31/92: [2]

                                           P2CWN7-05-0237-8100724   DETROIT WSD           Ml
                                           Summary: DETROIT, Ml CLAIMED OVER $274,000 OF INELIGIBLE
                                           CONSTRUCTION COSTS. WE ALSO QUESTIONED UNSUPPORTED
                                           ENGINEERING AND FORCE ACCOUNT COSTS OF $662,000.
                                                        8/29/88
                                           - EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN
                                           MADE: THE OIG NOTIFIED THE REGION ON JANUARY 15, 1992 THAT ITS
                                           MANAGEMENT DECISION IS INCOMPLETE.  THE HEADQUARTERS OIG HAS
                                           INITIATED DISCUSSIONS WITH THE OFFICE OF WATER TO CLARIFY SOME OF
                                           THE ISSUES.

                                           - DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION:  NO
                                           ACCURATE RESOLUTION DATE CAN BE ESTIMATED AT THIS TIME.

                                           IG FOLLOWUP STATUS AS OF 3/31/92: [2]

                                           P2GWN5^>5-0169-8100774   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: THE OIG NOTIFIED THE REGION ON JANUARY 15, 1992 THAT ITS
                                           MANAGEMENT DECISION IS INCOMPLETE.  THE HEADQUARTERS OIG HAS
                                           INITIATED DISCUSSIONS WITH THE OFFICE OF WATER TO CLARIFY SOME OF
                                           THE ISSUES.

                                           - DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION:  NO
                                           ACCURATE RESOLUTION DATE CAN BE ESTIMATED AT THIS TIME.

                                           IG FOLLOWUP STATUS AS OF 3/31/92: [2]

                                           REGION 3, REGIONAL ADMINISTRATOR

                                           P2CWM9-03-0238-1200037   GARRETT COUNTY SANI DIST  MD      9/30/91
                                           Summary:  GRANTEE CLAIMED $165,060 OF INELIGIBLE FEDERAL SHARE
                                           COSTS.

                                           - EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN
                                           MADE: DISCUSSIONS WITH THE PROGRAM STAFF WERE NECESSARY TO
                                           CLARIFY  RECOMMENDATIONS MADE IN RESPONSE TO THE AUDIT.

                                           - DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION:  THE
                                           FINAL DETERMINATION LETTER WAS  SUBMITTED TO LOCAL OIG ON MARCH
                                           27, 1992,  AND APPROVED ON APRIL 9, 1992.

                                           IG FOLLOWUP STATUS AS OF 3/31/92: [3]  (The proposed Final Determination
                                           Letter was received and found to be acceptable on 4f7/92.  We expect the report will
                                           be closed during April 1992.)
 60
                                                                                                  OFFICE OF THE INSPECTOR GENERAL

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Assignment Control
Number
Title
                          Final Report
                               Issued
Assignment Control
Number
Title
                           Final Report
                                Issued
 P2CWNO-03-0322-1300116    PHILADELPHIA CITY OF     PA         9/26/91
 Summary: THE CITY OF PHILADELPHIA CLAIMED $9,552,760 OF INELIGIBLE
 FORCE ACCOUNT, ENGINEERING, CONSTRUCTION, INDIRECT AND FEDERAL
 FACILITY SHARE COSTS.

 - EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN
 MADE: THIS WAS A MEGA-GRANT AUDIT INVOLVING 11 GRANTS.  THE
 RECOMMENDATION FOR THE FINAL GRANT WILL NOT BE DEVELOPED UNTIL A
 COMPLEX ENGINEERING ISSUE IS REVIEWED BY THE OIG'S TECHNICAL
 ASSISTANCE UNIT.

 - DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION: A desired
 timetable was not provided by EPA.

 IG FOLLOWUP STATUS AS OF 3/31/92: [1]

 REGION 4. REGIONAL ADMINISTRATOR

 E2CWN7-04-0302-0300054    SYLACAUGA UTILITIES BD    AL        5/10/90
 Summary: THE GRANTEE TERMINATED THE ORIGINAL  CONTRACTOR FOR
 CONVENIENCE AND DID 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 HAS NOT BEEN
 MADE: THIS AUDIT HAS BEEN REFERRED TO HEADQUARTERS FOR
 RESOLUTION. THE DIG ENGINEERS HAVE REVIEWED THE DOCUMENTATION
 AND STILL DISAGREE WITH THE MANAGEMENT DECISION.  THE DIG WILL
 WORK WITH THE  HEADQUARTERS OFFICE OF WATER AND THE GRANTS
 ADMINISTRATION  DIVISION TO RESOLVE THIS AUDIT.

 - DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION:  A desired
 timetable was not provided by EPA.

 IG FOLLOWUP STATUS AS OF 3/31/92: [6]

 E2CWN1-04-0052-1300086   HILLSBOROUGH COUNTY      FL        7/17/91
 Summary: THE GRANTEE RECEIVED EPA FUNDS TO EXPAND THEIR
 WASTEWATER TREATMENT PLANT.  WE DID NOT FIND  JUSTIFICATION FOR
 THE EXPANSION. THEREFORE, WE QUESTIONED 84% OF THE EXPANSION
 COST THAT  WAS UNNECESSARY, WHICH COMES TO $5,052,880 EPA SHARE.

 - EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN
 MADE; SYSTEM FLOWS TO JUSTIFY EXPANDING THE TREATMENT PLANT ARE
 DEPENDENT UPON THE OUTCOME OF THE CORRECTIVE ACTION PLAN FOR
 THE RUSKIN/WIMAUMA PROJECT (1400054/STOPPED DUE TO DEFECTIVE
 CONSTRUCTION)  REGION IV i DIG CONCUR THAT A FINAL DETERMINATION
 IS PREMATURE.

 =• DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION:  A desired
 timetable was not provided by EPA.

 IG FOLLOWUP STATUS AS OF 3/31/92: [2]

 S2CWN8-04-0309-1300093   MEMPHIS             TN             8/2/91
 Summary: WE QUESTIONED $3,072,793 OF ENGINEERING AND CONSTRUCTION
 COST BECAUSE IT REPRESENTED WORK OUTSIDE THE APPROVED GRANT
 SCOPE; COST OUTSIDE THE BUDGET PERIOD, EXTRA WORK DISAPPROVED BY
 THE STATE AND COST ABOVE THE LOW BID. AN ADDITIONAL $2,049,076 WAS
 UNSUPPORTED OR UNNECESSARY.

 - EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN
 MADE: THIS AUDIT REQUIRED ADDITIONAL TIME DUE TO THE COMPLEXITY OF
 THE AUDIT AND STATE AUDITORS APPLYING NEW LAWS TO AN OLD GRANT.

 - DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION:  THIS
 FINAL DETERMINATION LETTER SHOULD BE ISSUED BY JUNE 30, 1992.

 IG FOLLOWUP STATUS AS OF 3/31/92: [1J
                                           E2AWP1-04-0110-1400054   HILLSBOROUGH COUNTY      FL        9/26/91
                                           Summary: WE QUESTIONED THE TOTAL COST CLAIMED OF $7,520,816 UNDER
                                           GRANT NO. 0120682-09 BECAUSE THE GRANTEE FAILED TO CONSTRUCT AN
                                           OPERABLE SYSTEM. WE RECOMMENDED ANNULMENT OF THE GRANT.

                                           - EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN
                                           MADE: THE RUSKIN/WIMAUMA PROJECT CONSTRUCTION HAS STOPPED DUE
                                           TO DEFECTIVE CONSTRUCTION.  EPA HAS ALLOWED ADDITIONAL PROJECT
                                           TIME FOR GRANTEE TO PRESENT AN ACCEPTABLE CORRECTIVE ACTION PLAN
                                           WITH FIRM TIMETABLES FOR COMPLETION & ACCOMPLISH RETROACTIVE
                                           COMPLIANCE WITH UNIFORM RELOCATION ACT REQUIREMENTS.

                                           - DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION:  A desired
                                           timetable was not provided by EPA.

                                           IG FOLLOWUP STATUS AS OF 3/31/92: [2]

                                           REGION 5. REGIONAL ADMINISTRATOR

                                           E2AWTO-05-0223-0400020   SELLERSBURG EWS         IN          6/14/90
                                           •Summary:  REGION 5 AWARDED A $5.5 MILLION STEP 2+3 GRANT TO
                                           SELLERSBURQJN 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: THIS MATTER WAS REFERRED TO THE GENERAL COUNSEL FOR A
                                           LEGAL OPINION ON JANUARY 27, 1992.

                                           - DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION:  A desired
                                           timetable was not provided by EPA.

                                           IG FOLLOWUP STATUS AS OF 3/31/92:  [6]

                                           E2AWTO-05-0224-0400045   W TERRE HAUTE EWS       IN         9/28/90
                                           •Summary: REGION 5 AWARDED A STEP 2+3 GRANT OF $5,275,325 TO WEST
                                           TERRE HAUTE, 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: THIS MATTER WAS REFERRED TO THE GENERAL COUNSEL FOR A
                                           LEGAL OPINION ON FEBRUARY 5, 1992.

                                           - DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION:  A desired
                                           timetable was not provided by EPA.

                                           IG FOLLOWUP STATUS AS OF 3/31/92:  [6]

                                           E2AWT1-05-0134-1400007   S HENRY RSD EWS        IN           2/25/91
                                           Summary:  REGION  5 AWARDED A STEP 2+3 GRANT OF $4,461,050 TO SOUTH
                                           HENRY REGIONAL WASTE DISTRICT, 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: THIS AUDIT IS BEING DELAYED FOR THE SAME REASON AS THE
                                           SELLERSBURG AND WEST TERRE HAUTE.  THE REGION ON MARCH 25, 1992,
                                           THAT RESOLUTION OF THIS AUDIT WOULD BE DEPENDENT ON THE OUTCOME
                                           OF THOSE OTHER AUDITS.

                                           - DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION: A desired
                                           timetable was not provided by EPA.

                                           IG FOLLOWUP STATUS AS OF 3/31/92: [6]

                                           E2AWT1-05-0116-1400048    ENGLISH EWS          IN            9/25/91
                                           Summary: THE GRANTEE HAS BEGUN A SIGNIFICANT REDEVELOPMENT
                                           PROJECT WHICH RAISES QUESTIONS ABOUT THE CONCLUSIONS OF THE
                                           FACILITIES PUNNING PROCESS.  AS A RESULT THE GRANT AWARD WAS
                                           PREMATURE AND THE PRELIMINARY PLANNING NEEDS TO BE RE-EVALUATED

                                           - EXPLANATION OF  THE REASONS MANAGEMENT DECISION HAS NOT BEEN
                                           MADE: THIS MATTER WAS REFERRED TO THE GENERAL COUNSEL FOR A
                                           LEGAL OPINION ON  FEBRUARY 5, 1992.

                                           - DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION: A desired
                                           timetable was not provided by EPA.

                                           IG FOLLOWUP STATUS AS OF 3/31/92: [6]
OCTOBER 1,1991 THROUGH MARCH 31.1992
                                                                                                                              61

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Number
Title
Final Report
     Issued
Assignment Control    Title
Number
Final Report
     Issued
 E2AWT1-05-0391-1400063   LOOGOTEE EWS          IN           9/30/91
 Summary: APPROPRIATE ADVANCED TREATMENT (AT) FUNDING REVIEW
 POLICIES & PROCEDURES WERE NOT FOLLOWED FOR THIS PROJECT.  IN
 ADDITION, AT PROBABLY WAS NOT NECESSARY. ACCORDINGLY, WE
 QUESTIONED $650,000 INCREMENTAL AT COSTS AWARDED.

 • EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN
 MADE:  An explanation was not provided by EPA.

 - DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION: THE
 MANAGEMENT DECISION WAS FORWARDED TO THE LOCAL DIG ON MARCH 20,
 1992. THE DIG IS STILL REVIEWING THE RECOMMENDATIONS.

 IG FOLLOWUP STATUS AS OF 3/31/92: [4] (Proposed Management Decision
 received on April 10, 1992.)

 REGION 1, REGIONAL ADMINISTRATOR

 S2CW*8-01-0365-1100280   LOWELL              MA            7/1/91
 Summary: THE GRANTEE CLAIMED UNALLOWABLE COSTS OF $617,441
 COMPRISED OF $17,999 OF INELIGIBLE COSTS AND $599,442 OF
 UNSUPPORTED COSTS FOR THE DESIGN OF AN INTERCEPTOR SEWER.

 - EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN
 MADE:  An explanation was not provided by EPA.

 - DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION: THE
 FINAL DETERMINATION LETTER WAS ISSUED ON MARCH 12, 1992.
 IG FOLLOWUP STATUS AS OF 3/31/92: [5]  (This report was closed on 4/2/92)

 S2CWLO-01-0108-1100281   LOWELL              MA            7/1/91
 Summary: THE GRANTEE CLAIMED UNALLOWABLE COSTS OF $295,160
 COMPRISED OF $94,991  OF INELIGIBLE COSTS AND $200,169 OF
 UNSUPPORTED COSTS FOR THE CONSTRUCTION OF AN INTERCEPTOR
 SEWER,  DIVERSION CHAMBERS AND SIPHONS.

 - EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN
 MADE:  An explanation was not provided by EPA.

 - DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION: THE
 FINAL DETERMINATION LETTER WAS ISSUED ON MARCH 12, 1992.

 IG FOLLOWUP STATUS AS OF 3/31/92: [5]  (This report was closed on 4/2/92.)

 REGION 2. REGIONAL ADMINISTRATOR

 P5BGLO-02-0196-1100423   NYS LOVE CANAL REMEDIAL PROJNY     9/27/91
 Summary: THE RECIPIENT CLAIMED $953,392 OF UNALLOWABLE COSTS
 ($1,390 OF INELIGIBLE COSTS AND $952,002 OF UNSUPPORTED COSTS) FOR
 THE LOVE CANAL REMEDIAL PROJECT.

 - EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN
 MADE:  NEW YORK STATE RECENTLY ADVISED THAT IT HAS NOW ACQUIRED
 THE COMPUTER CAPABILITY NEEDED TO EXTRACT AND CONSOLIDATE THE
 SEVEN YEARS OF EXPENSE
 INFORMATION FOR THIS PROJECT. THE STATE ESTIMATES THAT DETAILED
 SCHEDULES WILL BE COMPLETE BY JULY 31, 1992.

 - DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION: THE
 REGION  EXPECTS RESOLUTION BY SEPTEMBER 30,  1992.

 IG FOLLOWUP STATUS AS OF 3/31/92: [1]

 P2CWL9-02-0036-1100425  CAMDEN COUNTY          NJ         9/27/91
 Summary: THE GRANTEE CLAIMED $14,178,770 OF WHICH WE QUESTIONED
 $365,685 AS  INELIGIBLE, $164,420 AS UNSUPPORTED AND $73,949 AS
 UNREASONABLE.

 - EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN
 MADE:  TO RESOLVE THIS COMPLEX AUDIT REQUIRED FURTHER ADDITIONAL
 CLARIFICATION AND DOCUMENTATION  FROM THE GRANTEE.

 - DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION THE
 FINAL RESOLUTION IS CURRENTLY IN DRAFT AND IS EXPECTED TO BE
 FINALIZED DURING THE THIRD QUARTER OF FY 1992.

 IG FOLLOWUP STATUS AS OF 3/31/92: [1]
                                            E1HWG1-02-6000-1400041    NPDES FOLLOWUP         NY        9/12/91
                                            Summary: REGION 2'S CORRECTIVE ACTIONS ON NY AND NJ'S NPDES
                                            ENFORCEMENT PROGRAM WERE NOT EFFECTIVE. THE REGION NEEDED TO
                                            IMPROVE ITS MONITORING SYSTEM FOR TRACKING AND RESOLVING
                                            CORRECTIVE ACTIONS.

                                            - EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN
                                            MADE: An explanation was not provided by EPA.

                                            - DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION:  THE
                                            MANAGEMENT DECISION FOR THIS AUDIT WAS SUBMITTED TO THE LOCAL OIG
                                            ON MARCH 30, 1992.

                                            IG FOLLOWUP STATUS AS OF 3/31/92: [4]

                                            REGION 9. REGIONAL ADMINISTRATOR
                                            S5BG*8-09-0202-0300037   CA DEPT OF HEALTH
                                                                                         CA
                                                                          3/30/90
                                            Summary: COSTS OF $2,419,415 QUESTIONED AS INELIGIBLE AND $1,639,629
                                            AS UNREASONABLE INELIGIBLES RELATED TO FORCE ACCOUNT AND
                                            CONTRACT COSTS  UNREASONABLE RELATED TO CONTRACT COSTS.
                                            GRANTEE'S FINANCIAL MANAGEMENT SYSTEM DETERMINED INADEQUATE.
                                            MOST INELIGIBLE COST RESULT OF THIS.

                                            - EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN
                                            MADE: A DRAFT MANAGEMENT DECISION WAS REVIEWED BY THE OIG. THE
                                            IG DEFERRED APPROVAL OF SEVERAL RECOMMENDATIONS PENDING THE
                                            COMPLETION OF ACTIONS THAT ARE UNDERWAY. THE REGION IS WORKING
                                            WITH THE LOCAL OIG TO RESOLVE THE REMAINING ISSUES.

                                            = DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION: THE
                                            FINAL MANAGEMENT DECISION IS EXPECTED BY JUNE 1992.

                                            IG FOLLOWUP STATUS AS OF 3/31/92: [2]

                                            S2CW8-09-0117-0300077   SCOTTS VALLEY, CITY OF    CA         8/ 7/90
                                            Summary: INELIGIBLE COSTS OF $533,500 REPRESENT A/E FEES OF $123,960
                                            INCURRED PRIOR TO APPROVAL $389,804 IN EXCESS OF APPROVAL $1,445
                                            AFTER COMPLETION $28,561 OF INELIGIBLE COSTS, ($10,275) ADDITIONAL
                                            CONSTRUCTION AND $44,975 OF UNREASONABLE IN EXCESS OF GRANT
                                            AMOUNT.

                                            - EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN
                                            MADE: An explanation was not provided by EPA.

                                            = DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION: THE
                                            REGION ISSUED A SUPPLEMENTAL FINAL DETERMINATION LETTER ON
                                            JANUARY 30, 1992.  THE LOCAL OIG HAD NO RECORD OF THIS LETTER. AN
                                            ADDITIONAL COPY WAS SENT TOO LATE TO BE INCORPORATED INTO THE IG'S
                                            TRACKING SYSTEM (tor semiannual reporting).

                                            IG FOLLOWUP STATUS AS OF 3/31/92: [2] (This  report was closed on 4/13/92)

                                            E2CW8-09-0024-0300090   HONOLULU  CITY &  COUNTY OF HI       9/19/90
                                            Summary: INELIGIBLE COST QUESTIONED OF $279,208 CONSISTED OF
                                            $247,009 OF UNALLOWABLE FORCE ACCOUNT/ADMIN. COSTS AND $31,649 FOR
                                            INELIGIBLE CONSTRUCTION COST. $3,786,208 OF UNREASONABLE COSTS
                                            RELATED TO INCOMPLETE STEP 1 GRANT AND UNDERUTILIZED FACILITY

                                            - EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN
                                            MADE: THE REGION SENT A DRAFT FINAL DETERMINATION LETTER TO THE
                                            LOCAL OIG.  THE OIG DID NOT  AGREE, AND FURTHER MEETINGS ARE
                                            SCHEDULED TO DISCUSS ISSUES.

                                            =• DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION: THE
                                            OUTSTANDING ISSUES ARE EXPECTED TO BE RESOLVED BY SEPTEMBER 30,
                                            1992.

                                            IG FOLLOWUP STATUS AS OF 3/31/92: [2]
62
                                                                                                   OFFICE OF THE INSPECTOR GENERAL

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 Assignment Control
 Number
Title
                           Final Report
                                Issued
 Assignment Control
 Number
Tftte
                          Final Report
                                Issued
 E2CWN9-09-0033-0300091    HONOLULU, CITY & COUNTY OF HI      9/19/90
 Summary: INELIGIBLE COST QUESTIONED OF $1,106,980 CONSISTS OF
 $446,176 OF UNDOCUMENTED ADMINISTRATION COST AND $660,744 FOR
 CONSTRUCTION COSTS RELATED TO PERMITS. UNREASONABLE COSTS OF
 $5,298,871 RELATED TO UNDERUTILIZED FACILITIES.

 - EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN
 MADE: THE REGION SENT A DRAFT FINAL DETERMINATION LETTER TO THE
 LOCAL DIG.  THE DIG DID NOT AGREE, AND FURTHER MEETINGS ARE
 SCHEDULED TO DISCUSS ISSUES.

 - DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION: THE
 OUTSTANDING ISSUES ARE EXPECTED TO BE RESOLVED BY SEPTEMBER 30,
 1992.

 1G FOLLOWUP STATUS AS OF 3/31/92: [2]

 E2CW8-09-0037-0300092   HONOLULU, CITY & COUNTY OF HI       9/19/90
 Summary: INELIGIBLE COSTS QUESTIONED OF $16,269,686 CONSISTED OF
 $552,471 OF UNALLOWABLE ADMIN/FORCE ACCOUNT COSTS, $734,663 FOR
 UNALLOWABLE A/E FEE $14,982,872 FOR INELIGIBLE CONSTRUCTION COSTS;
 ADDITIONALLY  $2,493,500 FOR UNNECESSARY COSTS FOR EQUIPMENT NOT
 IN USE BY GRANTEE.

 - EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN
 MADE: THE REGION SENT A DRAFT FINAL DETERMINATION LETTER TO THE
 LOCAL OIG  THE OIG DID NOT AGREE, AND FURTHER MEETINGS ARE
 SCHEDULED TO DISCUSS ISSUES.

 - DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION. THE
 OUTSTANDING ISSUES ARE EXPECTED TO BE RESOLVED BY SEPTEMBER 30,
 1992.

 IG FpLLOWUP STATUS AS OF 3/31/92: |1] (No formal response has been received
 on this audit.)

 S5BKN9-09-0267-0300098   SOUTH BAY MULTI-SITE     CA         9/28/90
 Summary: COSTS OF $2,903,899 WERE QUESTIONED AS UNSUPPORTED BY
 ADEQUATE SOURCE DOCUMENTATION.

 - EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN
 MADE:  A DRAFT MANAGEMENT DECISION WAS REVIEWED BY THE  OIG. THE
 IG DEFERRED APPROVAL OF SEVERAL RECOMMENDATIONS PENDING THE
 COMPLETION OF ACTIONS THAT ARE UNDERWAY.  THE REGION IS WORKING
 WITH THE LOCAL OIG TO RESOLVE THE REMAINING ISSUES.

 - DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION: THE
 FINAL MANAGEMENT DECISION IS EXPECTED BY JUNE 1992.

 IG FOLLOWUP STATUS AS OF 3/31/92: [2]

 P2BWLO-09-0175-1100436   CLARK  COUNTY SD        NV         9/30/91
 Summary. THE CLARK COUNTY SANITATION DISTRICT, NEVADA (THE
 GRANTEE) CLAIMED INELIGIBLE  COSTS OF $6,851,921, UNSUPPORTED COSTS
 OF $688,395 AND MORE SIGNIFICANTLY, CLAIMS FOR $25,390,310 WERE
 QUESTIONED AS UNNECESSARY/UNREASONABLE.

 - EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN
 MADE:  THE AUDIT RESOLUTION HAS BEEN DELAYED TO ALLOW THE REGION
 SUFFICIENT TIME TO ENSURE THE COMPLETENESS OF ITS MANAGEMENT
 DECISION. THE REGION'S WATER DIVISION IS WORKING TO RESOLVE
 SEVERAL OUTSTANDING ISSUES WITH A SINGLE MANAGEMENT  DECISION.
 THESE ISSUES INCLUDE FINDINGS OF THIS AUDIT,  AN EARLIER  APPEAL ON
 THIS GRANT AND THE GRANT'S  FINAL PAYMENT REQUEST.  THE REGION IS
 TRYING TO BE COMPLETE SO THE OIG IS NOT OBLIGATED TO REVIEW THIS
 GRANT AGAIN.
- DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION:
EXPECTS TO RESOLVE THIS AUDIT BY SEPTEMBER 30, 1992.

IG FOLLOWUP STATUS AS OF 3/31/92: [1]
                               IT
 E2CW7-09-0192-1300053   SUN VALLEY WATER & SAN DIST NV      3/28/91
 Summary: INELIGIBLE COST QUESTIONED OF $6,221,120 CONSISTS OF 1152
 FOR NOT MEETING 2/3 RULE; $995,653 FOR UNALLOWABLE A/E; $116,120 FOR
 UNALLOWABLE ADMINISTRATION AND $4,300 OF I/E CD'S ALSO $2,437,748
 QUESTIONED FOR UNDERUTILIZATION OF FACILITIES.

 • EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN
 MADE:  A DRAFT  MANAGEMENT DECISION WAS REVIEWED BY THE OIG. THE
 IG DEFERRED APPROVAL OF SEVERAL RECOMMENDATIONS PENDING THE
 COMPLETION OF ACTIONS THAT ARE UNDERWAY.  THE REGION IS WORKING
 WITH THE LOCAL OIG TO RESOLVE THE  REMAINING ISSUES.

 - DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION: THE
 FINAL MANAGEMENT DECISION IS EXPECTED BY JUNE 1992.

 IG FOLLOWUP STATUS AS OF 3/31/92: [1] (No formal response has been received
 on this audit.)

 S2CW*8-09-0157-1300112   LOS ANGELES, CITY OF      CA         9/25/91
 Summary: INELIGIBLE COSTS OF $723,627 INCLUDED: $650,255 OF
 UNALLOWABLE FORCE ACCOUNT COSTS; AND $73,372  FOR UNALLOWABLE
 ENGINEERING COSTS.  UNREASONABLE COSTS INCLUDE $879,630 OF
 UNDOCUMENTED  F/A AND $1,099,261  A/E COSTS INCURRED UNDER
 PROHIBITED CONTRACT METHOD.

 - EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN
 MADE:  THIS AUDIT IS RELATED TO TWO OTHERS ON THIS GRANTEE. THE
 STATE WATER RESOURCES CONTROL BOARD (SWRCB) INSPECTED THE LA
 TREATMENT PLANTS AND ISSUED AN INTERNAL REPORT THAT WILL BE USED
 FOR THE FINAL DETERMINATION LETTER. THE LETTER WAS DELAYED BY THE
 STATE'S REVIEW PROCESS.

 - DESIRED  TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION: THE
 REGION EXPECTS TO ISSUE THE FINAL DRAFT DETERMINATION LETTER TO
 THE LOCAL OIG BY APRIL 30, 1992.

 IG FOLLOWUP STATUS AS OF 3/31/92: [1]

 S2CWN9-09-0039-1300117   LOS ANGELES, CITY OF     CA         9/30/91
 Summary: INELIGIBLE COSTS INCLUDED $4,004,695 FOR COST INCURRED
 PRIOR TO APPROVAL $3,659,407 IN EXCESS OF APPROVAL ADDITIONAL AE
 QUESTIONED $3,999,353 RELATED TO REPLACEMENT OF BAS ENGINES WITH
 ELECTRIC MOTORS & $5,275,186 FOR INADEQUATELY DOCUMENTED FORCE
 ACCOUNT COSTS.

 - EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN
 MADE:  THIS AUDIT IS RELATED TO TWO OTHERS ON THIS GRANTEE THE
 STATE WATER RESOURCES CONTROL BOARD (SWRCB) INSPECTED THE LA
 TREATMENT PLANTS AND ISSUED AN INTERNAL REPORT THAT WILL BE USED
 FOR THE FINAL DETERMINATION LETTER. THE LETTER WAS DELAYED BY THE
 STATE'S REVIEW PROCESS.

 - DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION: THE
 REGION EXPECTS TO ISSUE THE FINAL DRAFT DETERMINATION LETTER TO
 THE LOCAL OIG BY APRIL 30, 1992.

 IG FOLLOWUP STATUS AS OF  3/31/92: [1]

 S2CWN9-09-0032-1300118   MONTEREY REG WATER POLL CON CA    9/30/91
 Summary:  COSTS QUESTIONED INCLUDED $420,412 FOR UNALLOWABLE
 ADMIN AND F/A COSTS; $2,996,703 FOR UNALLOWABLE  ENGINEERING
 $3,605,896 FOR INELIGIBLE CONSTRUCTION AND $467,996 OF INELIGIBLE
 OTHER ALSO QUESTIONED $51,118,958 PENDING AN ELIGIBILITY
 DETERMINATION.

 - EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN
 MADE:  THE SWRCB IS WORKING ON THE DRAFT FDL  WMD IS ATTEMPTING
 TO RESOLVE ALL ISSUES NOT  RELATED TO THE CAPACITY ISSUE IN AUDIT
 #1400006 OF MONTEREY.  WMD EXPECTS THIS AUDIT TO BE OVERDUE UNTIL
THE CAPACITY ISSUE ON THE OTHER MONTEREY AND  MARINA
AUDITS IS RESOLVED.

- DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION:  A desired
timetable was not provided by EPA.

 IG FOLLOWUP STATUS AS OF  3/31/92: [1]
OCTOBER 1,1991 THROUGH MARCH 31  1992
                                                                                                       63

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                               Issued
Assignment Control
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Title
Final Report
     Issued
 S2CW8-09-0156-1300119   LOS ANGELES, CITY OF     CA         9/30/91
 Summary: INELIGIBLE COSTS OF $2,483,872 INCLUDED $2,039,554 OF
 CONSTRUCTION AND FORCE ACCOUNT COST OUTSIDE SCOPE OF APPROVED
 PROJECT; $444,318 OF  F/A ALLOCABLE TO I/E CONSTRUCTION;
 UNREASONABLE COSTS OF $68,150,598 RELATED TO EXCESSIVE
 LANDSCAPING, F/A AND UNUSED FACILITIES.

 - EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN
 MADE:  THIS AUDIT IS  RELATED TO TWO OTHERS ON THIS GRANTEE. THE
 STATE WATER RESOURCES CONTROL BOARD (SWRCB) INSPECTED  THE LA
 TREATMENT PLANTS AND ISSUED AN INTERNAL REPORT THAT WILL BE USED
 FOR THE FINAL DETERMINATION LETTER. THE LETTER WAS DELAYED BY THE
 STATE'S REVIEW PROCESS.

 * DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION: THE
 REGION EXPECTS TO ISSUE THE FINAL DRAFT DETERMINATION LETTER TO
 THE LOCAL DIG BY APRIL 30, 1992.

 IG FOLLOWUP STATUS AS OF 3/31/92: [1)

 S2CWN9-09-017M300120    TRACY, CITY OF         CA           9/30/91
 Summary: I/E COSTS INCLUDED: $11,438 FOR A/E COSTS; $655,329 OF
 INTEREST EARNED; $2,916,214 FOR LITIGATION SETTLEMENT; UNREASONABLE
 COST OF $5,516,623 WERE RELATED TO FIX UP OF FAILED FACILITIES.

 - EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN
 MADE:  THE LOCAL DIG OBJECTED TO ALLOWING COSTS RELATED  TO
 ADDITIONS AND A SETTLEMENT IN THE DRAFT FINAL DETERMINATION LETTER.

 • DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION: THE
 REGION PLANS TO MEET WITH THE LOCAL DIG TO RESOLVE THESE ISSUES
 BY SEPTEMBER 30, 1992.

 IG FOLLOWUP STATUS AS OF 3/31/92: [1] (No formal response has been received
 on this audit.)

 E2AWP9-09-0189-1400006    EARLY WARNING - MONTEREY  CA      2/11/91
 Summary: REGION 9 AWARDED $8.1 MILLION GRANT AMENDMENT WHICH DID
 NOT MEET THE REQUIREMENTS OF THE CLEAN WATER ACT OR THE EPA
 REGULATIONS. IN ADDITION THE U.S. ARMY OVERPAID $6.2 MILLION FOR ITS
 SHARE OF THE CONSTRUCTION PROJECT.

 - EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN
 MADE:  THIS AUDIT IS LINKED TO THE MARINA EARLY WARNING AUDIT
 (9400043). THE REGION HAS BEEN WORKING TO RESOLVE BOTH AUDITS WITH
 THE ARMY CORPS OF ENGINEERS, THE DIG AND THE STATE WATER
 RESOURCES CONTROL BOARD. THE REGION IS TRYING TO SCHEDULE A
 MEETING WITH MONTEREY.

 - DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION: THE
 REGION EXPECTS TO RESOLVE THESE AUDITS BY SEPTEMBER 30, 1992.

 IG FOLLOWUP STATUS AS OF 3/31/92: [1]

 E1KAG1-09-6094-1400049   FOLLOW UP REVIEW REG. IX  CA        9/25/91
 'Summary:

 - EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN
 MADE:  ON DECEMBER 24, 1991, THE REGION REQUESTED A REVIEW OF ITS
 DRAFT FINAL DETERMINATION LETTER. ON JANUARY 7, 1992, THE DIG
 ACCEPTED ABOUT HALF OF THE DECISIONS. GRANTEE LETTERS WERE
 REVIEWED AND FOUND INCOMPLETE ON MARCH 23, 1992.

 - DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION: THE
 REGION SENT ITS FDL  TO THE DIG ON APRIL 2, 1992.

 IG FOLLOWUP STATUS AS OF 3/31/92: [4]

 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 FEDERAL 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:  RESOLUTION OF THIS AUDIT HAS BEEN REFERRED TO THE AUDIT
 RESOLUTION BOARD. WMD IS WORKING WITH ARB TO RESOLVE THE ISSUE
 WITHOUT AN ARB DECISION.

 - DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION: WE
 EXPECT RESOLUTION BY SEPTEMBER 30, 1992.

 IG FOLLOWUP STATUS AS OF 3/31/92: [6]
                                            E2AWP9-090230-9400043   EARLY WARNING-MARINA CWD  CA     9/26/89
                                            Summary: SPECIAL REVIEW OF GRANT TO BUY CAPACITY RIGHTS FROM
                                            REGIONAL WASTEWATER TREATMENT PLANT RESULTED IN AN EARLY
                                            WARNING LETTER TO EPA MANAGEMENT THAT THE AWARD VIOLATED 40
                                            CFR3S 2250 AND THAT TOTAL COSTS QUESTIONED OF $1,694,000 (F.S.
                                            $931,700) WOULD CAUSE 'WINDFALL'.

                                            - EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN
                                            MADE:  THIS AUDIT IS LINKED TO THE MONTEREY EARLY WARNING AUDIT
                                            (140006). THE REGION HAS BEEN WORKING WITH ARMY CORPS OF
                                            ENGINEERS, THE STATE OF CALIFORNIA AND THE DIG TO RESOLVE BOTH
                                            AUDITS. THE ISSUES AND LOGISTICS HAVE BEEN DIFFICULT.  THE REGION'S
                                            WATER DIVISION IS CURRENTLY TRYING TO SCHEDULE A  MEETING WITH
                                            MONTEREY OFFICIALS.

                                            - DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION:  THE
                                            REGION EXPECTS TO RESOLVE THESE AUDITS BY SEPTEMBER 30, 1992.

                                            IG FOLLOWUP STATUS AS OF 3/31/92: [5]

                                            REGION 6, REGIONAL ADMINISTRATOR

                                            E2CWN8-06-0037-0300055   BARTLESVILLE          OK          5/11/90
                                            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
                                            $3.1 M TO $9.8  M.

                                            - EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN
                                            MADE:  A DEVIATION REQUEST, WHICH WAS SUBMITTED ON MAY 31, 1991,
                                            WAS RECENTLY APPROVED.

                                            = DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION:  THE
                                            REGION IS PREPARING THE FINAL DETERMINATION LETTER AND EXPECTS TO
                                            ISSUE IT BY JUNE 1992.

                                            IG FOLLOWUP STATUS AS OF 3/31/92: [3]

                                            P5BFNO-06-0210-1300080   TX WATER COMMISSION      TX         6/19/91
                                            Summary: CHANGE ORDER COSTS TOTALING $3,298,679 WERE QUESTIONED
                                            BECAUSE THE RECIPIENT DID NOT CONDUCT A COST ANALYSIS OR ACQUIRE
                                            COSTS AND PRICING DATA AS REQUIRED  BY EPA REGULATIONS.

                                            • EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN
                                            MADE:  THE TEXAS WATER COMMISSION (TWC) REQUESTED A TIME
                                            EXTENSION OF SEPTEMBER 23, 1991 TO RESPOND TO THIS AUDIT, WHICH EPA
                                            GRANTED.  RESPONSE WAS RECEIVED ON SEPTEMBER 20, 1991 AND TWC
                                            DISAGREED WITH FINDINGS.  THE REGION REQUESTED A
                                            DEVIATION  FROM HEADQUARTERS ON FEBRUARY 25 1992.

                                            - DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION:  A desired
                                            timetable was not provided by EPA.

                                            IG FOLLOWUP STATUS AS OF 3/31/92: [1]
 64
                                                                                                   OFFICE OF THE INSPECTOR GENERAL

-------
Assignment Control
Number
THIe
                          Rnal Report
                               Issued
Assignment Control
Number
Title
                          Rnal Report
                               Issued
 REGION 10. REGIONAL ADMINISTRATOR

 P5CHN9-10-0151-0300095    OREGON DEO            OR          9/27/90
 'Summary:

 - EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN
 MADE: THE PROJECT OFFICER WILL MEET WITH THE REGION'S GRANTS
 OFFICE DURING THE WEEK OF APRIL 20, 1992 FOR FINAL DECISIONS ON
 QUESTIONED COSTS.  ALL COSTS SHOULD BE DISALLOWED PER FINAL AUDIT
 AND CONCURRENCE WITH THE STATE.

 - DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION: THE
 FINAL DETERMINATION LETTER SHOULD BE SENT TO THE GRANTEE BY MAY
 15, 1992.

 IG FOLLOWUP STATUS AS OF 3/31/92: [1]

 P5CG*8-10-0076-1100146   WASHINGTON DEPT OF ECOLOGY  WA     3/20/91
 Summary: COSTS QUESTIONED FOR  IMPROPER PROCUREMENT, PERSONNEL
 SERVICES AND INDIRECT COSTS.

 - EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN
 MADE: THE AUDIT REPORT HAS BEEN SENT TO THE GRANTEE AND THE
 PROJECT OFFICER FOR COMMENT. DUE TO  LACK OF HUMAN RESOURCES,
 THIS PROCESS IS TAKING LONGER THAN PREVIOUSLY ANTICIPATED.

 - DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION: THE
 FINAL DETERMINATION LETTER IS EXPECTED TO BE ISSUED BY  THE END OF
 THE THIRD QUARTER FY 1992.

 IG FOLLOWUP STATUS AS OF 3/31/92: [1]

 PSCG*8-10-0084-1100156   ALASKA DEPT OF ENV CONSER  AK      3/29/91
 Summary: COSTS QUESTIONED AS INELIGIBLE FOR SUBCONTRACTOR
 SERVICES NOT PERFORMED, EXCESS PROFIT AND ENGINEERING SERVICES
 PERFORMED ON  SITES OUTSIDE THE SCOPE OF THE COOPERATIVE
 AGREEMENT.

 - EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN
 MADE: THE ACTION OFFICIAL IS WORKING ON THE FINAL DETERMINATION
 LETTER.

 - DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION: IT
 SHOULD BE ISSUED BY APRIL 30, 1992.

 IG FOLLOWUP STATUS AS OF 3/31/92: [1]

 P2CW8-10-0057-1100419   RAYMOND, CITY OF       WA         9/25/91
 Summary:  INELIGIBLE COSTS QUESTIONED FOR ADMIN AND ENGINEERING
 COSTS ALLOCABLE TO THE INELIGIBLE CONSTRUCTION, UNSUPPORTED
 COSTS QUESTIONED FOR ADMINISTRATIVE AND FORCE ACCOUNT SERVICES.
 UNNECESSARY/UNREASONABLE COSTS FOR COSTS TO CORRECT PROJECT
 DEFICIENCIES.

 - EXPLANATION OF THE REASONS  MANAGEMENT DECISION HAS NOT BEEN
 MADE: THE WATER DIVISION NEEDED ADDITIONAL TIME DUE TO THE
 COMPLEXITY OF THE ISSUES.

 - DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION: THIS
 AUDIT RESOLUTION SHOULD BE COMPLETED  BY MAY 15, 1992.

 IG FOLLOWUP STATUS AS OF 3/31/92: [1]

 P2CW8-10-0022-1100420   SITKA, CITY OF         AK            9/25/91
 Summary: COSTS QUESTIONED ARE FOR FEES IN EXCESS OF THE AMOUNT
 APPROVED BY THE STATE.

- EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN
MADE: An explanation was  not provided  by EPA.

- DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION: THE
 REGION ISSUED A FINAL DETERMINATION LETTER WAS SENT TO THE LOCAL
DIG ON FEBRUARY 25, 1992.

IG FOLLOWUP  STATUS AS OF 3/31/92: (4] (This report was closed on 4/21/92.)
                                           P2CW7-10-0046-1200039   BRISTOL BAY, BOROUGH     AK        9/30/91
                                           Summary:  BRISTOL BAY BOROUGH, NAKNEK, ALASKA (THE GRANTEE)
                                           CLAIMED INELIGIBLE COSTS OF $1,145,973 AND UNSUPPORTED COSTS OF
                                           $6,699. ALSO, COSTS OF $148,200 WERE QUESTIONED AS
                                           UNNECESSARY/UNREASONABLE.

                                           - EXPLANATION OF THE  REASONS MANAGEMENT DECISION HAS NOT BEEN
                                           MADE: THE REGION DID NOT HAVE THE RESOURCES TO COMPLETE THIS
                                           AUDIT RESOLUTION DUE TO THE PRIORITY GIVEN THE RAYMOND AUDIT
                                           RESOLUTION.

                                           - DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION: A desired
                                           timetable was not provided  by EPA.
                                           IG FOLLOWUP STATUS AS OF 3/31/92: [1]

                                           P5CHN9-10-0155-1300047   WASHINGTON DEPT OF ECOLOGY WA
                                           'Summary:
                                                        3/26/91
                                           - EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN
                                           MADE: THIS AUDIT HAS BEEN SENT TO THE PROJECT OFFICER AND THE
                                           GRANTEE. LACK OF HUMAN RESOURCES WILL NOT ALLOW FOR A TIMELY
                                           COMPLETION OF THIS AUDIT RESPONSE.

                                           - DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION: THE
                                           FINAL DETERMINATION LETTER IS EXPECTED TO BE ISSUED BY MAY 31, 1992.

                                           IG FOLLOWUP STATUS AS OF 3/31/92: [1]

                                           P5CGNO-10-0011-1300066    WASHINGTON DEPT OF ECOLOGY WA    5/ 7/91
                                           Summary: THE WASHINGTON DEPARTMENT OF ECOLOGY DID NOT PROCURE
                                           ITS CONTRACTS IN A MANNER THAT ASSURED A REASONABLE PRICE OR
                                           THAT THE BEST OFFERORS ARE AWARDED CONTRACTS, WDOE NEEDS TO
                                           STRENGTHEN MGMT. CONTROLS. WDOE CLAIMED COSTS THAT WERE NOT
                                           ALLOCABLE TO THE COOPERATIVE AGREEMENT.

                                           • EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN
                                           MADE: THIS AUDIT HAS BEEN SENT TO THE PROJECT OFFICER AND THE
                                           GRANTEE. LACK OF HUMAN RESOURCES WILL NOT ALLOW FOR A TIMELY
                                           COMPLETION OF THIS AUDIT RESOLUTION.

                                           - DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION'  THE
                                           FINAL DETERMINATION LETTER IS EXPECTED TO BE ISSUED BY MAY 31, 1992.
                                           IG FOLLOWUP STATUS AS OF 3/31/92: [1J

                                           P2EWPO-10-0086-1400058   WASHINGTON ST REVOLVING FUND
                                           'Summary:
                                                        9/27/91
                                           - EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN
                                           MADE:
                                           - DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION: THE
                                           PROJECT OFFICER AND THE REGION'S GRANTS STAFF WILL DRAFT THE FINAL
                                           DETERMINATION LETTER THE WEEK OF APRIL 20, 1992.

                                           IG FOLLOWUP STATUS AS OF 3/31/92: [1]

                                           N3HVK1-10-0066-1500859   POCATELLO, CITY OF      ID          7/ 9/91
                                           •Summary:

                                           - EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN
                                           MADE: An explanation was not provided by EPA.

                                           - DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION: THE
                                           MANAGEMENT DECISION FOR THIS A-128 AUDIT WAS FEBRUARY 26, 1992.

                                           IG FOLLOWUP STATUS AS OF 3/31/92: [1]
XTOBER1,1991 THROUGH MARCH 31.1992
                                                                                                                             65

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Assignment Control
Number
                        Title
Final Report
     Issued
Assignment Control
Number
                                         Title
Final Report
     Issued
E3BG*6-10-0066-8100761    MOSES LAKE IRR & REHAB DIST WA      8/31/88
Summary: INTERIM AUDIT Of DEMONSTRATION GRANT TO RESTORE MOSES
LAKEAND TO CONTROL NON-POINT POLLUTION SOURCES FOUND TOTAL
COSTS QUESTIONED OF $2,439,103 (F.S. $1,205,039). GRANTEE USED
STANDARD METHODOLOGY INSTEAD OF DEVELOPING NEW INNOVATIVE
TECHNIQUES.

- EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN
MADE:  THE AUDIT REVIEW GROUP IS WORKING TO RESOLVE THE
OUTSTANDING ISSUES ASSOCIATED WITH THIS AUDIT.  THE OFFICE OF
GENERAL COUNSEL HAS DEVELOPED A LEGAL STANDARD TO RESOLVE
SEVERAL ISSUES. THE OFFICE OF WATER HAS  BEEN ASKED TO PROVIDE
DOCUMEENTATION TO SUPPORT A DECISION BASED ON THIS STANDARD.

- DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION:  A desired
timetable was not provided by EPA.

IG FOLLOWUP STATUS AS OF 3/31/92: [6J

PROCUREMENTS CONTRACT MANAGEMENT DIVISION
Washington Cost Advisory Branch

P9AHL1-02-0110-1100370   S&D ENGINEERING SERVICES  NJ       9/6/91
'Summary:

- EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN
MADE:  An explanation was not provided by EPA.

- DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION:  THIS IS A
PREAWARD AUDIT. CONTRACT TO BE  AWARDED BY 6/30/92.

IG FOLLOWUP STATUS AS OF 3/31/92: [1]

D8AML1-03-0264-1100296   COMPUTER DATA SYSTEMS INC  MD     7/ 3/91
'Summary:  DCAA RECOMMENDED EFFICIENCIES TOTALING $56,841. ALSO
DCAA NOTED THE AUDITEE UNDERBID  THE SUBCONTRACT BY $1,897,005.

• EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN
MADE:  An explanation was not provided by EPA.

= DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION:  THIS IS A
PREAWARD AUDIT. CONTRACT TO BE  AWARDED BY MAY 31,  1992.

IG FOLLOWUP STATUS AS OF 3/31/92: [1)

D8AML1-03-0286-1100305   SYSTEMS RESEARCH & APPLICA  VA     7/ 9/91
Summary: DCAA RECOMMENDED EFFICIENCIES TOTALING $640,907.  THIS
RELATES TO DIRECT  LABOR COSTS AND APPLICABLE INDIRECT COSTS.

- EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN
MADE:  An explanation was not provided by EPA.

- DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION'  THIS IS A
PREAWARD AUDIT. THE ANTICIPATED  AWARD DATE IS JULY 1992.

IG FOLLOWUP STATUS AS OF 3/31/92: [1]

D8AML1-03-0274-1100308   ELECTRONIC DATA  SYSTEMS CORPVA    7/10/91
Summary: DCAA RECOMMENDED EFFICIENCIES TOTALING $167,814,636
REPRESENTING PRIMARILY UNSUPPORTED DIRECT LABOR COSTS. ALSO,
DCAA  REVEALED THE CONTRACTOR HAD UNDERSTATED PROPOSED COSTS
BY $35,559,981.

- EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN
MADE:  An explanation was not provided by EPA.

- DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION:  THIS IS A
PREAWARD AUDIT. THE ANTICIPATED  AWARD DATE IS JULY 1992.

IG FOLLOWUP STATUS AS OF 3/31/92: [1]

D8AML1-03-0270-1100309   I-NET INC            MD             7/10/91
Summary: DCAA RECOMMENDED EFFICIENCIES TOTALING $2,153,347  OF
THIS AMOUNT $1,258,531 RELATES TO DIRECT LABOR

- EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN
MADE: An explanation was not provided by EPA.

- DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION:  THIS IS A
PREAWARD AUDIT. THE ANTICIPATED  AWARD DATE IS JULY 1992.

IG FOLLOWUP STATUS AS OF 3/31/92:  [1]
                 D8AML1-03-0254-1100321   UNISYS GOVERNMENT SYSTEMS  VA     7/22/91
                 Summary:  DCAA RECOMMENDED EFFICIENCIES TOTALING $16,559,241 OF THIS
                 AMOUNT $8,056,142 IS RELATED TO DIRECT LABOR COST. $1,605,931 IS
                 UNSUPPORTED.

                 - EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN
                 MADE:  An explanation was not provided by EPA.

                 - DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION: THIS IS A
                 PREAWARD AUDIT. THE ANTICIPATED AWARD DATE IS JULY 1992.

                 IG FOLLOWUP STATUS AS OF 3/31/92: [1]

                 D8AML1-03-0285-1100323   COMPUTER BASED SYSTEMS INC  VA     7/22/91
                 Summary:  DCAA RECOMMENDED EFFICIENCIES TOT AUNG $2,741,364. OF
                 THIS AMOUNT, $2,531,239 IS LABOR COST AND RELATED  OVERHEAD.

                 - EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN
                 MADE:  An explanation was not provided by EPA.

                 - DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION: THIS IS A
                 PREAWARD AUDIT. THE ANTICIPATED AWARD DATE IS JULY 1992.

                 IG FOLLOWUP STATUS AS OF 3/31/92: [1]

                 D8AML1-03-0363-1100401   WESTAT INC            MD           9/18/91
                 Summary:  DCAA RECOMMENDED EFFICIENCIES TOTALING $1,666,349. OF
                 THIS AMOUNT, $1,375,763 RELATES TO THE EMERGENCY PLANNING &
                 COMMUNITY RIGHT TO KNOW CENTER; $66,963 RELATES TO FIELD
                 OVERHEAD; THE REMAINDER RELATES TO G&A EXPENSES.

                 - EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN
                 MADE'  An explanation was not provided by EPA.

                 = DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION: THIS IS A
                 PREAWARD AUDIT. THE CONTRACTOR WAS AN UNSUCCESSFUL OFFEROR

                 IG FOLLOWUP STATUS AS OF 3/31/92: [1] (We received a FAX dated 4/21/92
                 notifying us of the above status of this report.)

                 D8AML1-03-0364-1100402   INFORMATION SYS & NETWORK  MD     9/18/91
                 Summary:  DCAA RECOMMENDED EFFICIENCIES TOTALING $145,673. THIS
                 AMOUNT RELATES TO G&A EXPENSES. DCAA QUESTIONS 1.12% OF FY91
                 PROJECTED G&A RATE BASED ON HISTORICAL QUESTIONED COSTS AS A
                 RESULT OF EXCESSIVE COMPENSATION TO THE COMPANY'S TWO  TOP
                 EXECUTIVES.

                 - EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN
                 MADE:  An explanation was not provided by EPA.

                 - DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION: THIS IS A
                 PREAWARD AUDIT. THIS CONTRACTOR WAS AN UNSUCCESSFUL OFFEROR

                 IG FOLLOWUP STATUS AS OF 3/31/92: [1] (We received a FAX dated 4/21/92
                 notifying us of the above status of this report.)

                 D8AML1-03-0366-1100404   KEYDATA SYSTEMS INC      MD        9/18/91
                 Summary:  DCAA RECOMMENDED EFFICIENCIES OF $403,453.  THIS AMOUNT
                 RELATES TO THE APPLICATION OF THE AUDIT DETERMINED FRINGE BENEFIT
                 RATE AND THE OVERHEAD-OFFSITE  RATE TO DIRECT LABOR.

                 - EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN
                 MADE:  An explanation was not provided by EPA.

                 - DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION: THIS IS A
                 PREAWARD AUDIT. THE CONTRACTOR WAS AN UNSUCCESSFUL OFFEROR

                 IG FOLLOWUP STATUS AS OF 3/31/92: [1] (We received a FAX dated 4/21/92
                 notifying us of the above status of this report.)

                 D8AML1-03-0371-1100406   DYNAMAC CORPORATION     MD      9/20/91
                 'Summary:

                 - EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN
                 MADE:  An explanation was not provided by EPA.

                 - DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION: THIS IS A
                 PREAWARD AUDIT. THE CONTRACTOR WAS AN UNSUCCESSFUL OFFEROR.

                 IG FOLLOWUP STATUS AS OF 3/31/92: [1] (We received a FAX dated 4/21/92
                 notifying us of the above status of this report.)
 66
                                                                                                    OFFICE OF THE INSPECTOR GENERAL

-------
Assignment Control
Number
Title
                           Final Report
                                Issued
Assignment Control     Title
Number
Final Report
     Issued
 D8AML1-03-0367-1100409    COMSIS CORPORATION      MD        9/20/91
 Summary: DCAA RECOMMENDED EFFICIENCIES TOTALING $3,120,380.  DIRECT
 LABOR COULD BE POTENTIALLY UNDERPRICED BY $2,547,564.  A MATH
 ERROR OF $5,372,080 WAS FOUND. DCAA QUESTIONED $295,864 RELATED TO
 G&A EXPENSES.

 - EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN
 MADE: An explanation was not provided by EPA.

 - DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION: THIS IS A
 PREAWARDAUDIT.  THE CONTRACTOR IS AN UNSUCCESSFUL OFFEROR.

 IG FOLLOWUP STATUS AS OF 3/31/92: [1] (We received a FAX dated 4/21/92
 notifying us of the above status of this report.)

 P9AHN1-05-0191-1300085   OHM REM ERCS3 R1        OH         7/ 9/91
 Summary: WE RECOMMENDED EFFICIENCIES OF $9,569,567  RELATED TO:
 1)PROPOSED EQUIPMENT NOT ACCEPTED DUE TO CONTRACTORS
 INADEQUATE EQUIPMENT UTILIZATION, UNSUPPORTED RENTAL COSTS, AND
 EXCESSIVE EQUIPMENT RATES, AND 2) DIRECT LABOR AND OTHER DIRECT
 COSTS ADJUSTED FOR AUDITED INDIRECT COST RATE.

 - EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN
 MADE: An explanation was not provided by EPA

 - DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION: THIS IS A
 PREAWARDAUDIT.  CONTRACT TO BE AWARDED BY JUNE  30, 1992.

 IG FOLLOWUP  STATUS AS OF 3/31/92: [1]

 P9AHP1-05-0281-1400034   OHM REM ERCS3 R5       OH          9/ 6/91
 Summary: WE  HAVE RECOMMENDED  EFFICIENCIES OF $7,348,270 PERTAINING
 TO EQUIPMENT COSTS IN EXCESS OF ACTUAL COST AND/OR UNSUPPORTED,
 REDUCTION  IN LABOR COSTS AND PROGRAM MGMT TO REFLECT
 ADJUSTMENTS TO THE RELATED INDIRECT COST RATE AND ESCALATION
 FACTORS.

 • EXPLANATION OF THE REASONS MANAGEMENT DECISION  HAS NOT  BEEN
 MADE: An explanation was not provided by EPA.

 • DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION: THIS IS A
 PREAWARD AUDIT. CONTRACT TO BE AWARDED BY JUNE 30, 1992.

 IG FOLLOWUP  STATUS AS OF 3/31/92: [1]

 P9AHP1-05-0313-1400036   OHM REM  ERCS3 R2       OH          9/ 6/91
 Summary: WE  HAVE RECOMMENDED  EFFICIENCIES OF $1,095,181 PERTAINING
 TO EQUIPMENT COSTS AND ADJUSTMENT TO THE ESCALATION FACTOR.
 ALSO, INCREASES OF $869,393 PERTAINING TO 1990 INDIRECT COSTS,
 PROGRAM MGMT LABOR COSTS AND QUALITY ASSURANCE COORDINATOR
 COSTS.

 - EXPLANATION OF THE REASONS MANAGEMENT DECISION  HAS NOT BEEN
 MADE: An explanation was not provided  by EPA.

 - DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION: THIS IS A
 PREAWARD AUDIT.  CONTRACT TO BE AWARDED BY JUNE 30, 1992

 IG FOLLOWUP STATUS AS OF 3/31/92: [1]

 P9AHP1-05-0313-1400036   OHM REM  ERCS3 R2       OH          9| 6/91
 Summary: WE  HAVE RECOMMENDED EFFICIENCIES OF $1,095,181 EXCESSIVE
 EQUIPMENT COST PROPOSED AND ESCALATION FACTOR ADJUSTMENT
 APPLIED  TO DIRECT LABOR. ALSO, INCREASES OF $869,393, 1990 INDIRECT
 COST RATES, AND  UNDERSTATEMENT OF PROGRAM MANAGEMENT, QUALITY
 ASSURANCE.

 - EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN
 MADE: An explanation was not provided by EPA.

 - DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION: THIS IS A
 PREAWARD AUDIT.  CONTRACT TO BE AWARDED BY JUNE 30, 1992.

 IG FOLLOWUP STATUS AS OF 3/31/92: [1]
                                            P9AHP1-05-0297-1400044   MAECORP ERCS3 R5        IL          9/20/91
                                            Summary:  WE RECOMMENDED THAT EPA NOT AWARD THE PROPOSED
                                            CONTRACT TOMAECORP, INC., RESULTING IN $69,782,317 OF RECOMMENDED
                                            EFFICIENCIES.

                                            - EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN
                                            MADE:

                                            =* DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION: THIS IS A
                                            PREAWARD AUDIT. CONTRACT TO BE AWARDED BY JUNE 30, 1992.

                                            IG FOLLOWUP STATUS AS OF 3/31/92: [1]

                                            P9AHP1-05-0296-1400045   MAECORP ERCS3 R5        IL          9/23/91
                                            Summary:  WE RECOMMENDED THAT THE CONTRACTOR NOT BE AWARDED
                                            THIS CONTRACT.  THEREFORE, WE HAVE  RECOMMENDED EFFICIENCIES OF
                                            $72,838,576.

                                            - EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN
                                            MADE: An explanation was not provided by EPA.

                                            - DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION:  THIS IS A
                                            PREAWARD AUDIT. CONTRACT TO BE AWARDED BY JUNE 30, 1992.
                                            IG FOLLOWUP STATUS AS OF 3/31/92: 11)

                                            TOTAL REPORTS ISSUED BEFORE REPORTING PERIOD FOR WHICH NO
                                            MANAGEMENT DECISION WAS MADE DURING THE REPORTING PERIOD:
                                                                                                       99
                                            * - Agency procedures do not require the IG's approval on Agency's Management
                                            Decision on a report (other than a preaward or an internal and management reviews)
                                            with the Federal share of questioned costs less than $100,000  Therefore, we have
                                            not provided a summary of the report.
OCTOBER 1,1991 THROUGH MARCH 31.1992
                                                                                                                               67

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Mailing Address and Telephone Numbers  •  DIG  HOTLINE (800) 424-4000 or  (202) 260-4977
Headquarters
Office of Inspector General
401 M Street, S.W. (A109)
Washington, DC 20460
(FTS or 202) 260-3137

Atlanta
Office of Inspector General
1375 Peachtree Street, NE
Suite 276
Atlanta, GA 30309
Audit  (404)347-3623 FTS 257-3623
Investigations: (404) 347-2398
FTS 257-2398

Boston
Office of Inspector General
JFK Federal Building DIG 521
Boston, MA 02203
Audit  (617) 565-3160 FTS 835-3160
lnvestigations:(617) 565-3928
FTS 565-3928

Chicago
Office of Inspector General
77 West Jackson Boulevard
13th Floor
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) 655-6621 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
Auait(919)541-1028 FTS 629-1028
Investigations: (919) 541-1027
FTC 629-1027

Sacramento
Ottice 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) 744-2445 FTS 484-2445
Investigations: (415) 744-2465
FTS 484-2465

Seattle
Office of Inspector General
1111 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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                                                                                          OFFICE OF THE INSPECTOR GENERAL

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