TD171
I .U56c
193/05
           United States
           ~nvironmental Protectior
           Agency
            Office of
            Inspector General
            (A-109)
Office of Inspector General
Semiannual Report
to the Congress
October 1,1992 through
March 31,1993
                                   350R93004
                              '" If »*
                               ..,, *r  *

-------
           On the cover: Brown pelicans at theii
northernmost rookery, Assawoman Bay. Maryland
                     (photo by Steve Delaney)

-------
      During this semiannual reporting period, the Office
      of Inspector General has extended its mission of
      promoting economy, efficiency and effectiveness
in the delivery of environmental programs to new areas
of the Agency's operations.
  Among the subjects discussed in this report are  oil spill
cleanups, contract and assistance agreements, drinking
water, energy conservation, laboratory management,
Superfund cleanups, and accounting systems.  These
are some of today's most important issues at EPA.
  OIG employees are deeply committed to improving the
environment and making sure that the scarce resources
allocated to this purpose are spent as productively as
possible. To help achieve this commitment we have
dedicated ourselves to providing Agency managers
timely, accurate, and useful products.
  We are encouraged by the Agency's actions to correct
its contract management problems, and recognize the
strength of the Administrator's commitment  to lead this
effort. We look forward to  working with the
Administrator and her staff as they deal with this and
other difficult issues facing the Agency.
John C. Martin
Inspector General

-------
i


-------
 Executive Summary 	1
 EPA High Risk Areas of Significant 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 Inspector General Semiannual Report	7

 Section 1—Significant Problems, Abuses, and Recommendations
 Summary of Audit Activities and Results	9
 Agency Management 	10
 Construction Grants  	13
 Superfund Program	16
 Special and Early Warning Reviews	18

 Section 2—Report Resolution
 Status Report on  Perpetual Inventory of Reports in Resolution Process for the
  Semiannual Period Ending March 31, 1993	22
 Audit  Followup 	23
 Status of Management Decisions on IG Reports	24
 Resolution of Significant Reports	25

 Section 3—Prosecutive Actions
 Summary of Investigative Activity	26
 Description of Selected Prosecutive and Administrative Actions	27
 Civil and  Administrative Actions to Recover EPA Funds  	29

 Section 4—Fraud Prevention and Resource Management Improvements
 Review of Legislation and Regulations	30
 Suspension and Debarment Activities	31
 Congressional Testimony by the Inspector General	32
 OIG Management Initiatives	32
 President's Council on Integrity and Efficiency  	33
 Committee on Integrity and Management Improvement	33
 Hotline Activities	34
 Personnel Security Program  	34

 Appendices
 Appendix 1—Reports Issued	35
 Appendix 2—Reports Without Management Decisions	49
                     Tb)  7 /
Tangier Island in Chesapeake Bay
(photo by Steve Delaney)
Environments! Protection Ae°ncv
                           *'

-------
 v\,
Gates of the Arctic National Monument, Brooks Range, Alaska
(photo Courtesy of National Park Service, Department of the Interior)

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

1. Better Oversight Needed
of Athens Laboratory's
Contracts and Assistance
Agreements.

EPA's Environmental
Research  Laboratory, Athens,
Georgia, did not fully comply
with applicable laws,
regulations, and Agency
policies in awarding and
administering contracts,
cooperative agreements, and
interagency agreements.  As a
result, EPA could not be
assured that these  resources
were effectively and efficiently
used (page 10).

2. EPA's Involvement in the
Sale of Quality Assurance
Materials  Potentially
Conflicts  with Its Regulatory
Role.

To provide funds for continuing
its Quality Assurance Program,
EPA granted five companies
exclusive rights to manufacture
and sell "EPA Certified" quality
assurance materials used by
laboratories to calibrate and
test equipment for analyzing
samples for hazardous
chemicals  in the environment.
As a result, EPA has created
an unfair competitive
advantage for these
companies and could
compromise its ability to
administer fair and  equitable
regulations (page 11).

3. Alaska  Not Accounting for
Safe Drinking Water Grants.

The Alaska Department of
Environmental Conservation
had not effectively accounted
for $877,500 awarded by EPA
to support  the State's safe
drinking water program or
documented accomplishment
of grant objectives (page 11).

4. EPA Region 3's
Certification Process for
Sewage Treatment Plants
Unreliable.

EPA Region 3's certification
process for wastewater
treatment facilities does not
ensure that all permit violations
and performance problems are
disclosed, (page 12).

5. Improvements Needed in
Region 7's Efforts to Identify
and Report  Internal Control
Weaknesses.

Region 7 had not effectively
implemented the Federal
Managers' Financial Integrity
Act. As a result, the Region
could not assure the
Administrator that it was
meeting its mission and
protecting its resources (page
12).

6. Nearly $14 Million of
Questioned Costs Claimed
for New York City Projects.

New York City claimed
$2,423,359 of ineligible design
and construction costs.  An
additional $11,530,366 of
unsupported costs were also
questioned (page 14).

7. Orlando,  Florida, Claimed
Over $4 Million of Ineligible
Costs.

Orlando, Florida, claimed
$4,392,846 of ineligible
engineering and construction
costs (page 14).

8. Baltimore, Maryland,
Claimed Nearly $3.9 Million
of Questioned Costs.

Baltimore, Maryland, claimed
$3,167,090 of ineligible
architectural  engineering,
construction, administrative,
and equipment costs. An
additional $730,476 of
unsupported costs were
questioned (page 14).

9. Over $3.1 Million of
Ineligible Costs Claimed  for
Parkersburg, West Virginia,
Project.

The Parkersburg, West
Virginia, Sanitary Board
claimed $3,143,885 of
ineligible legal, architectural
engineering,  and equipment
costs (page 14).
10. Sacramento, California,
Claimed Over $4 Million of
Ineligible and Unreasonable
Costs.

The Sacramento Regional
County Sanitation District,
Sacramento, California,
claimed $1,395,800 of
ineligible administrative, force
account, engineering,
construction, and land
acquisition costs.  An
additional $2,624,778 of
unreasonable project costs
were questioned (page 15).

11. Grantee's $9.1 Million
Project Claim Questioned
Pending Compliance With
Discharge Requirements.

The Sausalito-Marin City
Sanitary District, Sausalito,
California, claimed $9,082,508
of costs for the design and
construction improvements to
a wastewater treatment facility
that was not consistently
meeting waste discharge
requirements  (page 15).

12. Improvements Needed in
Timeliness and Controls
Over Responsible Party (RP)
Cleanups.

The Agency's use of RPs to
clean up Superfund sites has
been hampered by numerous
problems, including delays in
initiating cleanups, lack of
aggressive enforcement
actions, and ineffective
management of contractors
(page 16).

13. Continuing Weaknesses
in Superfund Accounting
and Controls.

Pervasive and persistent
problems related to managing
accounts receivable and
personal property have
continued during the 10 years
of the Superfund program. In
addition, the Agency's
Integrated Financial
Management System did not
provide complete and accurate
reports to Superfund
management (page 17).
14. Superfund Indirect Cost
Rates Not Adequate for Full
Recovery of Cleanup Costs.

EPA's fiscal 1987 and 1988
Superfund indirect cost rate
calculations  inappropriately
excluded $144.2 million and
$225.9 million, respectively,
severely reducing the total
amounts for recovery from
parties responsible for
hazardous waste sites (page
17).

15. $1.6 Million in EPA
Training Grants Not
Adequately Evaluated.

EPA did not adequately
monitor or evaluate the
effectiveness of training
provided to assist minority
contractors in obtaining
environmental contracts.  In
addition, EPA awarded grants
without considering alternative
lower cost sources (page 18).

16. Better Accounting
Needed For Oil Spill Funds.

EPA did not have adequate
controls or procedures to
properly account for $18.4
million available in fiscal 1992
from the Oil  Spill Liability Trust
Fund (page  18).

17. EPA Lacks an Adequate
Energy Conservation
Program.

EPA had not developed an
energy management and
conservation program as
required by statutes and
regulations.  As a result, EPA
could not adequately
determine  its energy
consumption costs and
measure its progress in
reducing consumption (page
19).

18. Improper Procurements
Circumvented Federal
Acquisition Regulation.

The Office of Communications,
Education, and Public Affairs
officials routinely obtained
goods and services without
proper authorization or
competition as required by the
Federal Acquisition Regulation
(page 19).
 OCTOBER 1, 1992 THROUGH MARCH 31, 1993

-------
19. ERA'S Administration of
the Federal Employees'
Compensation Act Needs
Improvement.

EPA has not adequately
managed claims and payments
under the Federal Employees'
Compensation Act. As a
result, EPA may be paying
benefits for individuals who are
not EPA employees and may
not be encouraging its
employees to  return to work as
soon as possible (page 20).

20. $21.5 Million Grant to
San Diego Should Be
Annulled.

San Diego, California, has no
need for a land outfall after it
canceled plans to construct a
related secondary treatment
plant (page 21).

21. $7.2 Million Middletown,
California, Project Does Not
Meet Effluent Goals.

The Lake County Sanitation
District in Middletown,
California, claimed $1.7 million
of costs for a leaking storage
pond and an unused disposal
system for treated effluent
which rendered the project in
noncompliance with its
discharge permit (page 21).

Section 2—
Report Resolution

At the beginning of the
semiannual period, there were
341 reports for which no
management decision had
been made. During the first
half of fiscal 1993, the Office
of Inspector General issued
722 reports and closed 733
reports.  At the end of the
reporting period, 330 reports
remained in the Agency
followup system for which  no
management decision had
been made. Of the 330
reports,  146 reports remained
in the Agency followup system
for which no management
decision was made within 6
months of issuance (page  22).
  In two followup reviews,  the
Office of Inspector General
found that some problems
identified in previous reports
continued (page 23).
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 224 reports closed
that required Agency action,
EPA management disallowed
$26.8 million of questioned
costs for recovery and agreed
with our recommendations that
$5.4 million be put to better
use (page 22). In addition,
cost recoveries in current and
prior periods included $4.6
million in cash collections, and
at least $14.8 million in offsets
against billings (page  6).

Section 3—
Prosecutive Actions

During this semiannual
reporting period, our
investigative efforts resulted in
6 convictions and 6
indictments.  Also, this
semiannual period our
investigative work led  to $13.2
million in fines and recoveries
(page 26).
   In the largest environmental
crimes case  prosecuted under
the Superfund law, an Illinois
corporation agreed to  pay
$11.6 million for its felony
actions at a Pennsylvania site
(page 27).
   Results of investigations of
EPA's contract laboratory
program included the
sentencing of a testing
company and its owner for
false claims; development of a
community service program by
a Louisiana firm in lieu of a
$174,000 fine, which was
suspended; and sentencing of
2 supervisors of a New York
lab company (page 27).
   In other cases, claiming
credentials not earned is
resulting in weekend jail time
for a would-be asbestos
removal instructor; and an
employee of an EPA
contractor was charged with
making $3,600 in personal
overseas phone calls at
Government expense.  Also,
an EPA office director at
Headquarters was indicted for
conspiracy and other crimes,
and another Headquarters
employee was sentenced to
jail for a false jury duty claim
(page 28).
  Also, two testing firms
agreed to civil settlements with
the Government, under which
they will pay $660,000 (page
29).

Section 4—
Fraud Prevention and
Resources
Management

Review of Proposed
Legislation and Regulations

During this semiannual period,
we reviewed one legislative
and 68 regulatory items. The
most significant  were
comments on  the Small
Business Administration's draft
position on the proposed
Regulatory Flexibility
Amendments Act of 1993;  a
proposed amendment to EPA
Order 1900.1, Use of
Contractor Services; and a
whistleblower guide developed
by the President's Council  on
Integrity and Efficiency (page
30).

Suspension and Debarment
Activities

We completed 37 cases during
this reporting period, resulting
in 19 debarments, 12
suspensions, and 6
compliance  agreements (page
31).

Congressional Testimony by
the Inspector General

The Inspector General testified
before a subcommittee of the
House Committee on
Government Operations on
elevating EPA to cabinet-level
status (page 32).

Committee  on Integrity and
Management  Improvement

The EPA Committee on
Integrity and Management
Improvement,  chaired by the
Inspector General, published
"A Brief Guide for New
Executives," a booklet
designed to provide an
overview of  many of the main
areas on which EPA
executives need to focus
(page 33).

Hotline Activities

The OIG toll-free Hotline
became part of President
Clinton's efforts to improve the
Government, serving as a
collection point for the public's
ideas.  The Hotline referred
4,587 telephone callers to the
appropropriate EPA program
office, State agency, or other
Federal agency for assistance.
Thirty-six cases were opened
and 31 were closed during the
reporting period. Of the closec
cases, 8 resulted in
environmental, prosecutive, or
administrative corrective action
(page 34).

Personnel Security Program

During this reporting period,
the Personnel Security Staff
reviewed 455 investigations
(page 34).
                                                                                          OFFICE OF INSPECTOR GENERA'

-------
 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
 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.
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
Oil Pollution Act of 1990
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.

Makes EPA responsible for oil spill prevention, preparedness,
response, and enforcement activities associated with non-
transportation-related onshore oil facilities.

-------
   EPA High Risk Areas Of Significant
   Concern To The OIG
This section of our report
presents the Office of
Inspector General's (OIG)
perspective on significant
problems which the Agency
must address to ensure its
programs are conducted in an
effective, efficient, and
economical manner.  The
OIG's semiannual report for
the period ended September
30, 1992, presented the OIG's
perspective on six major
areas: Contract Management,
Financial Management,
Scientific Data Integrity,
Information Resources
Management, Enforcement,
and Audit Followup and
Implementation of Corrective
Actions to closely correspond
with EPA's current priorities
and future initiatives.  These
areas continue to be of
concern to the OIG and have
captured the attention of
Agency management. The
Agency included these six
areas in its 1992 Federal
Managers' Financial Integrity
Act assurance letter to the
President and Congress as
material weaknesses.  For this
reporting period, the
discussion of contract
management has been
expanded to include grants,
cooperative agreements, and
interagency agreements.

Management of Extramural
Resources

EPA relies extensively on
contractors and other outside
entities to assist in carrying out
its mission to  clean up past
pollution problems, develop
national policy, and set the
environmental agenda for the
future. These outside groups
may be commercial firms that
EPA has contracts with to
provide goods and services;
public organizations, such as
universities or State  and  local
organizations that EPA funds
to pursue areas of mutual
environmental concerns
through cooperative
agreements; or other agencies
of the Federal government that
provide assistance through
interagency agreements.
   EPA is implementing the 40
recommendations of the
Standing Committee on
Contract Management's June
1992 report.  However, not
enough time has elapsed for
us to evaluate whether the
Agency's actions have
corrected the underlying
causes of the problems.
  Our recent work at the
Office of Research and
Development and the Office of
Communication, Education,
and Public Affairs has clearly
shown the pervasive nature of
resource  management
problems at  EPA. Significant
issues identified during these
audits are discussed below.

• Work Outside the Scope of
the Contract.  Contractors
were performing work outside
the scope of their contract at
seven EPA laboratories we
reviewed.  EPA contracts'
statements of work often  were
very broad and not well
defined which may encourage
questionable work.  For
example, technical lab
contractor personnel were
performing handyman duties,
such as remodeling offices,
painting, and repairing
plumbing leaks.

• Personal Services. Audits
of  Office of Research and
Development labs found that
often contractor employees
were used as personal staff,
such as secretaries to Federal
managers, although prohibited
by Federal regulations. There
were also repeated instances
of  EPA officials being involved
in the selection and hiring of
contractor employees.

• Potential Conflicts of
Interest.  EPA regulations
prohibit an Agency employee
from taking any action which
results in, or creates the
reasonable appearance of: (1)
giving preferential treatment to
an organization or person; (2)
losing independence; or (3)
undermining the confidence of
the public in the integrity  of the
Government. One of the worst
examples of potential conflicts
of  interest involved an EPA
chemist who was the technical
monitor of a contractor for
which he also worked up to 4
hours per week as a
consultant.  This  outside
employment was highly
improper and should not  have
been approved by his
supervisor.

• Procurement Process.
EPA has not competitively
awarded  certain contracts in
order to retain incumbent
contractors.  We found, for
instance, that one EPA
laboratory used  the 8(a) small
business set-aside program
repeatedly to obtain sole
source contracts for an
incumbent contractor to retain
contract employees who had
worked at the lab longer than
many EPA employees.  The
EPA laboratory then switched
to a competitive procurement,
without adequate justification,
when the contractor graduated
from the 8(a) program.  EPA's
Office of Communication,
Education, and Public Affairs
instructed contractors to
provide services although
there was no purchase order
to allow the contractor  to be
paid.  In one case, the
contractor was not paid until
the unauthorized procurement
was  ratified 8 months after the
work was performed.

• Cooperative and
Interagency Agreements.
Audits have shown that
mismanagement of extramural
resources is not limited to
contracts, but also extends to
other types of extramural
resources.  We reported that
parts of 11 cooperative
agreements that one EPA lab
had with various universities
only  benefitted EPA, violating
the purpose of assistance
agreements. We also  reported
that EPA used interagency
agreements to improperly
obtain travel funding for EPA
employees from another
Federal agency, and in return
provided that agency with
travel funds through the same
mechanism.

• Audits of EPA Contracts.
We expect EPA's extensive
use of contractors and  the
corresponding demand for
audits will continue to grow.
At the end of fiscal 1992, EPA
had  1,872 contracts with
obligations of $4.9 billion
whose performance periods
had expired, but had not been
closed out.

Financial Management

The  OIG has repeatedly
reported that EPA's accounting
systems do not  provide
complete, consistent, reliable
and timely data  for Agency
decision making. While EPA
has devoted considerable time
to improving the Agency's
overall performance in the
area, results have been less
than anticipated. Significant
issues identified during recent
audits of Superfund obligations
and disbursements and
accounting controls for the Oil
Spill Liability Trust  Fund are
discussed on pages 17 and
18.
   In response to the Chief
Financial Officers Act and our
perceived need, we will
continue emphasizing  audits in
the financial management
area.  In addition, we will
continue to work with the
Agency to ensure that an
effective organization is
established that provides the
Chief  Financial  Officer with the
responsibility and authority to
correct EPA's longstanding
financial management
problems.

Scientific Data Integrity

The accuracy and reliability of
scientific data have always
been crucial to  EPA's  mission
as a regulator/  agency
because it forms the basis for
decisions that affect all major
American industries and
national policies to  prevent
hazards and risks to health
and safety.  However, audits
and investigations show that
EPA is not always getting the
research for which  it pays, nor
is such  research always
accurate or objective.
  The Federal Insecticide,
Fungicide, and  Rodenticide Ac
requires registrants of
pesticide products to
demonstrate that products do
not cause adverse  effects to
public health  and the
environment. The  registrant
either performs  the study in-
house or contracts  with a
laboratory.  Good Laboratory
Practices standards specify th<
minimum practices and
procedures which must be
followed in order to ensure the
integrity of submitted
pesticides data.  However we
have reported that  the Agency
lacked assurance that the date
submitted by independent
laboratories in support of
pesticide registrations was
accurate and reliable.
   Under the Contract
Laboratory Program (CLP),
independent laboratories test
                                                                                           OFFICE OF INSPECTOR GENER/

-------
 samples from Superfund sites.
 Investigations have disclosed
 fraudulent analyses, falsified
 data, uncalibrated equipment,
 and backdated analyses which
 could call into question
 cleanup decisions and hamper
 the recovery of EPA's cleanup
 costs from responsible parties.
 Our audits have found that the
 controls over the Superfund
 CLP quality assurance/quality
 control program at
 Environmental Monitoring
 Systems Laboratory, Las
 Vegas, Nevada, were not
 complete or fully effective for
 evaluating contract
 laboratories' performance and
 that EPA used laboratories
 with poor performance
 histories to analyze samples
 while laboratories with superior
 performance histories were not
 used to their capacity.

 Information Resources
 Management (IRM)

 IRM is critical to the success
 of all program activities.
 Despite extensive criticism
 over the last  12 years, EPA's
 IRM program is still hampered
 by many problems, including
 significant cost overruns and
 delays in  developing and
 implementing information
 systems;  material data quality
 deficiencies; development of
 duplicate  information systems;
 failure to economically manage
 mainframe storage devices;
 exposure of the Agency's most
 sensitive information systems
 to access by unethical users;
 and lack of Agency assurance
 that ADP  support services
 contracts  are being
 implemented effectively,
 efficiently, and at the lowest
 cost to the Government. Two
 recent audits discussing these
 significant IRM problems are
 summarized below.

 • Computer Systems
 Integrity. EPA had not
 implemented certain
 fundamental management
 practices in its IRM program.
 A serious absence of top
 management central direction
 and control and the
 decentralized nature of Agency
 operations have made it
 extremely difficult to effectively
 manage IRM  activities.

 • Software Integrity.  EPA
 user and contractor access to
highly sensitive payroll,
contractor payment, and other
sensitive financial files was not
adequately controlled.
Knowledgeable users could
access systems on the
mainframe and view, modify,
or destroy information,
programs, or other important
computer resources with little
fear of detection.

Enforcement

During the  past 2 years, OIG
audits of EPA's water,
pesticide, hazardous materials,
and Superfund programs have
reported continuing instances
of ineffective Federal and
State enforcement.  Although
EPA management has worked
to improve EPA's enforcement
program in response to or
concurrent with our audit
efforts, more still needs to be
done.  For  example, in our
capping report on EPA's
management of Superfund
cleanups performed by
responsible parties, we noted
that untimeliness was a
pervasive condition.  In
addition, EPA did not
aggressively use its penalty
authority against noncompliers,
but preferred to stress
cooperation in  getting
responsible parties to clean up
hazardous waste sites.
Contractors used to monitor
responsible party cleanups
were given too much latitude
without sufficient oversight
which led to delays,
inefficiencies, and additional
expenditures.  We also
reported the lack of
documentation in all phases of
the Superfund  enforcement
process (page  16).
  EPA has initiated actions to
speed up the Superfund
cleanup process, drafted
guidance on proper use of
penalty authorities, improved
contractor monitoring, and
recognized  the need for
improved documentation. We
will continue to assist EPA in
assessing its success in
Superfund enforcement and
enforcement activities in other
program areas.

Audit Followup and
Implementation of Corrective
Actions

Since 1988 we have been
assessing the effectiveness of
EPA's audit followup
responsibilities. EPA has
elevated the issue of audit
followup to the highest
management levels  and
appears committed to making
improvements.  However, we
are still  reporting problems.  In
a recent followup audit on
EPA's Suspended and
Canceled  Pesticide  Program,
we reported that the Office of
Prevention, Pesticides and
Toxic Substances did not use
the established Management
Audit Tracking System to
monitor  corrective action plans
for audit recommendations.
This was reportedly  due to
problems interfacing with the
Agency's main computers at
the Washington Information
Center and Research Triangle
Park (see  page 23).
  The Office of Prevention,
Pesticides and Toxic
Substances is working to
remedy  this problem and
expects  to review the accuracy
of all data on corrective
actions taken in response to
audits by the summer of  1993.
Likewise, EPA is working with
the OIG to strengthen audit
followup throughout  the
Agency. A Quality Action
Team made up of OIG and
Agency  representatives is
updating the EPA Order on
"Management of EPA Audit
Reports  and Followup
Actions." The goal is to
identify procedural changes
that will  result in a timely, fair
audit resolution process.
OCTOBER 1, 1992 THROUGH MARCH 31, 1993

-------
   Profile Of Activities And  Results
Environmental Protection Agency
Office of Inspector General
                                        October 1, 1992, to
                                           March 31, 1993

Audit Operations

OIG Managed Reviews:

-  Reviews Performed by EPA, Independent
  Public Accountants and State Auditors
  -  Questioned Costs
    (Ineligible, Unsupported, and
    Unnecessary/Unreasonable)
    -  Total                                  $170.3 Million
    -  Federal Share *                         $127.8 Million
  -  Recommended Efficiencies
    (Funds be Put to Better Use)
    -  Total Efficiencies*                        $23.4 Million
    -  Federal Share Efficiencies*                 $12.9 Million
  -  Cost Disallowed to be Recovered
    -  Federal Share (costs which EPA
      management agrees are unallowable
      and is committed to recover or
      offset against future payments)             $26.3 Million
  -  Cost Disallowed as Cost Efficiency
    -  Federal Share (funds made available
      by EPA management's commitment to
      implement recommendations in OIG
      performance and preaward audits)           $3.3 Million

Other Reviews:

-  Reviews Performed by another
  Federal Agency or Single Audit Act Auditors
  -  Questioned Costs
    -  Total                                    $5.1 Million
    -  Federal Share *                           $4.5 Million
  - Recommended Efficiencies
   - Total Efficiencies*                          $3.4 Million
   - Federal Share Efficiencies*                  $3.4 Million
  -  Cost Disallowed to be Recovered
    -  Federal Share                            $0.7 Million
  -  Cost Disallowed as Cost Efficiency
    -  Federal Share                            $2.1 Million
                                        October 1,1992, t
                                            March 31, 199

Agency Recoveries:

- Recoveries from Audit Resolutions of
  Current and Prior Periods (cash collections
  or offsets to future payments)**                $19.4 Millio

Reports Issued:
- OIG Managed Reviews:
  - EPA Reviews Performed by the OIG
  - EPA Reviews Performed by Independent Public
    Accountants and State Auditors

- Other Reviews:
  - Single Audit Act Reviews and EPA Reviews
    Performed by another Federal Agency

Total Reports Issued
Reports Resolved (agreement by Agency officials
to take satisfactory corrective action)***
         7'

         4



        60

        72


        22
Investigative Operations

  -  Fines and Recoveries (including civil)
  -  Investigations Opened
  -  Investigations Closed
  -  Indictments of Persons or Firms
  -  Convictions of Persons or Firms
  -  Administrative Actions Against EPA Employees
Fraud Detection and Prevention Operations

  -  Debarments, Suspensions and Settlement
    Agreements
  -  Hotline Cases Opened
  -  Hotline Cases Processed and Closed
  -  Personnel Security Investigations Adjudicated
$13.2 Millio
        12:
        13'
         3
         3l
         3
       45!
* Questioned Cost and Recommended Efficiencies 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.
"" Reports resolved are subject to change pending further review.
                                                                               OCTOBER 1, 1992 THROUGH MARCH 31, 19

-------
    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 eight
 Divisional Inspectors General
 for Audit and seven 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 1993, the Agency
 was appropriated
 $6,892,400,000 and authorized
 17,917 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 $42.8 million to
 carry out 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
 $610,000 was derived from  the
 Leaking Underground Storage
Tank trust fund.  The OIG has
an approved staffing level of
456 FTE positions.  The
funding  and FTE available to
the OIG represent 0.6 percent
and 2.5  percent, respectively,
of the Agency's totals.
 Purpose and
 Requirements of the
 Office of the
 Inspector  General
 Semiannual  Report

 The Inspector General Act of
 1978 (Public Law 95-452), as
 amended, requires the
 Inspector General to keep the
 Administrator and Congress
 fully and currently informed of
 problems and  deficiencies in
 the Agency's operations and to
recommend corrective action.
The IG Act further specifies
that semiannual reports will be
provided to the Administrator
by each April 30 and October
31, and to Congress 30 days
later.  The Administrator may
transmit comments to
Congress along with the
report, but may not change
any part of it.
  The specific reporting
requirements prescribed in the
Inspector General Act of 1978,
as amended, are listed below.
Source                                           Section/Page
Inspector General Act, as amended.

Section 4(a)(2),  Review of Legislation and Regulations         4   30

Section 5(a)(1),  Significant Problems, Abuses, and            1     9
           Deficiencies

Section 5(a)(2),  Recommendations with Respect to            1     9
           Significant Problems, Abuses, and
           Deficiencies

Section 5(a)(3),  Prior Significant Recommendations on
           Which Corrective Action Has Not
           Been Completed                    Appendix 2    49

Section 5(a)(4),  Matters Referred to Prosecutive Authorities     3    26

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

Section 5(a)(6),  List of Audit Reports               Appendix 1     35

Section 5(a)(7),  Summary of Significant Reports              1      9

Section 5(a)(8),  Statistical Table 1-Reports With
           Questioned Costs                            2     24

Section 5(a)(9),  Statistical Table 2-Reports With
           Recommendations  That Funds Be Put
           To  Better Use                               2     24

Section 5(a)(10), Summary of Previous Audit Reports
           Without Management Decisions        Appendix 2     49

Section 5(a)(11), Description and Explanation of Revised
           Management Decisions              Appendix 2     49
                               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, 1992 THROUGH MARCH 31, 1993

-------
                       Office of  Inspector General - Who's Who
       Headquarters
                                              Inspector General
                                             John C. Martin
                                           Deputy Inspector General
                                         Anna Hopkins Virbick
        Office of Audit
        Kenneth A. Konz
        Assistant Inspector General
        James O. (touch
        Deputy
 Internal & Performance
 Audit Staff
 Vacant
  Policy and Resources
  Management Staff
  Kenneth D. Hockman
  Director
               Office of Investigations
               Daniel S. Sweeney
               Assistant Inspector General
               Michael J. Fitzsimmons
               Deputy
Acquisition Assistance
Staff
Vacant
Technical Assistance
Division
Gordon C. Milbourn
Director
Office of Management
John C. Jones
Assistant  Inspector General
    Program Management
   ! Division
    John T. Walsh
    Director
    Resources Management
    Division
    Michael J. Binder
    Director
       Divisional inspectors General
Region 9 & 10
Truman R. Beeler,
Audit

H Brooks Griffin
Investigations
                                               Region 5
                                               Anthony C. Carrollo, Audit

                                               Region 5, 7, & 8
                                               Allen P. Fallin, Investigations
                       Region 7 & 8
                       Nikki Tinsley, Audit
                                                            Region 4 & 6
                                                            Mary Boyer. Audit
                                                            Patricia K. Brady, Acting,
                                                            Investigations
                                                                  Region 1 & 2
                                                                  Paul McKechnie, Audit
                                                                  Robert M. Byrnes,
                                                                  Investigations

                                                                  Region 3
                                                                  Paul R  Gandolfo, Audit
                                                                  Martin Squitien
                                                                  Investigations
                                                             Headquarters
                                                             Edward Gekosky
                                                             HQs Audit Div.

                                                             Melissa M. Heist
                                                             Financial Audit  Div.

                                                             Francis C. Kiley
                                                             Washington Field Div.
                                                             Investigations

                                                             Emmett D. Dashiell
                                                             Procurement Fraud Div.
                                                              Investigations
                                                                                         OFFICE OF THE INSPECTOR GENER

-------
   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 five areas:
 Summary of Audit Activities
 and Results, Agency
 Management, Construction
 Grants, Superfund, and
 Special and Early Warning
 Reviews.
 Summary Of Audit
 Activities And
 Results
Questioned Costs And Recommended
Effeciencies By Type Of Assignment
  rieo
  •140
  120
  100
  80
  60
  .40
  20
                                                                   Non Federal
                                                                   Rec EH
                                     Construction
                                                         Superfund
                                                                             Other
                   Source Of Reviews
                                    Areas Of Effort By Staff Days
                                             State
                                             Auditors-6
                                               LUST
                                               Performance-89
                EPA-70
                                                                                           LUST
                                                                                           Financial-36
                                                                                     SUPERFUND
                                                                                     Performance-1,889
                              IPA
                              Firms-38
                    Total-722 Reviews
                                                                      Total-18,564 Days
OFFICE OF INSPECTOR GENERAL

-------
Agency
Management
The Inspector General Act
requires the OIG to initiate
reviews and other activities
to promote economy and
efficiency and to detect and
prevent fraud, waste, and
mismanagement in  EPA
programs and operations.
Internal and management
audits and reviews are
conducted to accomplish
these objectives largely by
evaluating the economy,
efficiency, and effectiveness
of operations.
  The following are the most
significant internal and
management audit and
review findings and
recommendations.
Better Oversight
Needed of Athens
Laboratory's
Contracts and
Assistance
Agreements

Problem

EPA's Environmental
Research Laboratory (ERL),
Athens, Georgia, did not
fully comply with applicable
laws, regulations, and
Agency policies in awarding
and administering contracts,
cooperative agreements
(CA), and interagency
agreements (IAG).  As a
result, EPA could not be
assured that these
resources were effectively
and efficiently used.

We Found That

Between 1986 and 1992, the
Office of Research and
Development and ERL
became highly dependent on
contracts, CAs, and lAGs to
perform critical laboratory
research and support
operations.  Our review
covered 20 contracts, CAs,
and lAGs with total maximum
values of $44 million. There
were a number of questionable
actions by ERL in the award,
use,  and funding of contracts,
CAs, and lAGs.  More
specifically ERL improperly
used extramural resources by:
• Awarding repetitive sole-
source Small Business Act,
section 8(a) contracts over 7
years to retain long-term on-
site contractors and contractor
staff.  In one case when the
contractor became too large
for an 8(a) award, the
laboratory removed the
requirement from the program
without justification to allow the
incumbent contractor to
compete for the new award.
The laboratory then
established ranking factors
which assigned the most value
to experience and key
personnel, favoring the
incumbent and permitting it to
easily win the $16.8 million
award.

• Splitting and  underestimating
contract requirements to avoid
the  $3 million competition
threshold established for sole-
source contracts under the
8(a) set-aside program.  For
example, ERL split its on-site
support contract into an off-site
and on-site 8(a) sole-source
procurement.  However, the
off-site work was actually
performed near the site with
the same site manager and
statement of work.

• Supplementing ERL's in-
house staff with contractor
personnel who performed
inherently governmental
functions, such as quality
assurance and health and
safety activities.
•  Improperly awarding CAs and
lAGs, rather than contracts, to
obtain services for the direct
benefit of ERL research
projects, including a $5.2
million CA awarded to the
University of Georgia (UGA).
At least 14 UGA employees
worked on-site in 1992 under
the CA to support ERL
scientists in their research or
provided administrative support
to ERL staff.  Also, there were
potential conflict-of-interest
situations in the  award of 9 of
the 11 CAs included in our
sample.

ERL's procurement problems
were due largely to inadequate
controls over extramural
resources at the laboratory,
management's emphasis on
mission accomplishment by
any means, and lack of
oversight of ERL operations by
EPA Headquarters.

We Recommended That

The Acting Assistant
Administrator  for Research and
Development:

•  In collaboration with the
Grants Administration Division
and the Comptroller, issue
additional guidance to
laboratories regarding
competitive awards of
extramural agreements and
the proper use of research and
development funds under
assistance agreements.

•  Strengthen Headquarters
oversight and control of
laboratories' management of
extramural resources to
include periodic  on-site
reviews of laboratory
operations performed jointly
with other appropriate
Headquarters offices.

•  Ensure that  ERL properly
implements FMFIA
requirements  and establishes
effective internal controls over
all critical phases of laboratory
operations.

The Assistant Administrator for
Administration and Resources
Management:
 EPA's lab in Athens, Georgia
 (OIGphoto by Southern Audit Division staff).
10
                                                           OFFICE OF INSPECTOR GENER,

-------
 • Strengthen and streamline
 the contracting process to
 ensure that proposals are
 thoroughly reviewed,
 questionable actions are
 quickly and properly resolved,
 and unnecessary
 administrative burden on
 program offices is reduced.

 • Provide definitive guidance to
 project officers and  program
 managers on the
 award.administration, and
 appropriate uses  of assistance
 agreements and contracts.

 What Action  Was Taken

 The final audit report
 (3100156) was issued to  the
 Acting Assistant Administrator
 for Research and Development
 and the Assistant Administrator
 for Administration and
 Resources Management on
 March 31, 1993.  In
 responding to the draft report,
 the Agency generally agreed
 with our recommendations and
 provided substantive planned
 or already initiated actions to
 correct the identified
 weaknesses.  A response to
 the final report is due by June
 29, 1993.
 EPA's Involvement in
 the Sale of Quality
 Assurance Materials
 Potentially Conflicts
 with Its Regulatory
 Role

 Problem

 To provide funds for
 continuing its Quality
 Assurance Program, EPA
 granted five companies
 exclusive rights to
 manufacture and sell "EPA
 Certified" quality assurance
 (QA) materials used by
 laboratories to calibrate and
 test equipment for analyzing
 samples for hazardous
 chemicals in the
 environment. As a result,
 EPA has created an unfair
 competitive advantage for
 these companies and could
 compromise its ability to
 administer fair and equitable
 regulations.
 Background

 The Federal Technology
 Transfer Act (FTTA) allows
 Government-operated
 laboratories to enter into
 Cooperative Research and
 Development Agreements
 (CRADA) with other Federal
 agencies and private industry
 to encourage the development
 and transfer of technology to
 the private  sector, thereby
 improving the nation's
 economic, environmental, and
 social well-being.  The FTTA
 permits Federal laboratories
 and employees to collect
 royalties from patents and
 licensing agreements for
 Government-owned inventions.
   In the early 1970s, EPA
 promulgated new regulations
 requiring testing for hazardous
 chemicals in the environment.
 In order to test for the various
 regulated chemicals,
 laboratories needed calibration
 standards to adjust equipment
 settings and quality control
 samples to  periodically check
 the operations of their
 equipment.  At the time,  many
 of the QA materials were not
 available for many of the
 regulated chemicals. As a
 result, under its QA Program,
 the Environmental Monitoring
 Systems Laboratory  in
 Cincinnati, Ohio (EMSL-Cin)
 began to develop,
 manufacture, and distribute
 these materials free to
 qualified users.  Eventually,
 these materials were largely
 produced, stored, and
 distributed by EPA contractors.

 We Found  That

 In the mid 1980s, due to a
 combination of increased costs
 and budget  reductions, EMSL-
 Cin began looking for ways to
 continue funding its QA
 program. When the  FTTA was
 enacted in 1986, EMSL-Cin
 saw an opportunity to obtain
the needed  funds.  In 1991,
 EMSL-Cin entered into five
 CRADAs to  develop,
 manufacture, and sell QA
 materials needed to calibrate
and test instruments  used by
 laboratories to analyze
samples for regulated
 hazardous chemicals. The five
 companies were required to
 advertise their products as
 "EPA Certified." EMSL-Cin
 also made available for sale
 about 750,000 ampuls of
 material valued at over $26
 million to the five CRADA
 companies.  EMSL-Cin would
 receive a percentage of the
 companies' sales of the
 transferred inventory and any
 new materials manufactured
 by the CRADA companies.
  By granting the five CRADA
 companies exclusive rights to
 sell the existing inventory and
 any new material,  EPA created
 conditions for a Government-
 controlled oligopoly. Although
 other firms manufacture similar
 materials, only the five
 companies can advertise the
 products they manufacture as
 "EPA Certified."  As is typical
 of an oligopoly, QA material
 prices increased substantially
 from 1990 to 1991, the year
 the CRADAs were established.
 For example, the price for the
 QA material for chlordane
 increased from $.20 to $1.40.
  By requiring the CRADA
 companies to market their
 products as "EPA Certified,"
 the Agency created the
 appearance of a conflict of
 interest because it may have
 to choose between fair and
 equitable regulations and a
 desire to increase  revenue
 through sales of QA materials.
 As a regulator, the
 Government must  not be
 biased towards the community
 it is regulating or provide a
 competitive advantage  to
 commercial enterprises.
  Although EMSL-Cin officials
 said that the CRADAs were
 established under the  FTTA,
they are an inappropriate use
 of the Act. No new technology
was transferred to the private
sector (only QA materials from
 EPA's inventory). Any
 research conducted involved
developing and marketing QA
 materials and  not the
development of new
technology. Also, by making
available marketable QA
 materials to the CRADA
companies, EMSL-Cin
provided a source of funds to
the companies, which is not
permitted under the FTTA.
We Recommended That

To ensure that the Agency no
longer competes with private
industry, the Acting Assistant
Administrator for Research and
Development instruct the
Director, EMSL-Cin, to
immediately cancel the
laboratory's participation in
these five CRADAs, recover
any inventory which had been
transferred to the five
companies which has not yet
been sold, and determine the
proper method to dispose of
those QA materials not needed
to meet existing obligations,
such as under memorandums
of understanding with other
agencies.

What Action was Taken

The final audit report
(3100153) was issued to the
Acting Assistant Administrator
for Research and Development
on March 31, 1993.  A
response to the final report is
due by June 29,  1993. In
responding to the draft report,
the Acting Assistant
Administrator did not agree
with our recommendations and
proposed several actions
which the Office of Research
and Development would take
to determine whether CRADAs
are the best way to continue
the reference material
program. However,  until ORD
completes its analyses, we
continue to believe that the
five CRADAs are
inappropriate.
Alaska  Not
Accounting for Safe
Drinking Water
Grants

Problem

The Alaska Department of
Environmental Conservation
(ADEC) had not effectively
accounted for $877,500
awarded by EPA to support
the State's safe drinking
water (SOW) program or
documented
accomplishment of grant
objectives.
OCTOBER 1, 1992 THROUGH MARCH 31, 1993
                                                                                     11

-------
Background

EPA provides direct financial
assistance to any State that
assumes primary enforcement
responsibility for its public
drinking water program,
provided that its drinking water
standards are not lower than
national standards and that it
establishes adequate reporting
and enforcement procedures.

We Found That

ADEC's fiscal and accounting
procedures were inadequate to
maintain effective control and
accountability of the $877,500
in 1991  SOW grant funds
received from EPA.  Rather
than charging actual costs
incurred in administering its
SOW program, ADEC charged
costs to the grant based on
budget allocations.  In addition,
ADEC did not have written
procedures for charging costs
to the grant nor did it have a
cost allocation plan for
distributing some joint
administrative costs.
  Personnel costs were the
major portion of the claimed
grant expenditures, but it was
impossible to trace  employees
charged to the grant because
of incompatibilities between
Alaska's payroll  system and
accounting system used to
record grant expenditures.
Further, ADEC charged costs
for non-drinking water activities
to the grant and lacked
documentation for other
expenditures. For example,
from our randomly selected
sample of 48 non-personnel
transactions, only 12 were
adequately documented as
grant-related expenditures-all
involving travel.  Also, ADEC
either did not fully or timely
complete six reviewed work
plan objectives.  For example,
none of the State regional
offices consistently  reported
the  number of engineering
plans for public drinking water
systems which were received
and reviewed.

We Recommended That

The Regional Administrator,
Region 10, withhold additional
SOW grant awards until
ADEC:

• Establishes written policies
and procedures for charging
costs to the grant based upon
actual costs incurred; and

• Ensures the State/EPA
Agreement work plan tasks are
performed and reported on
consistently and
documentation is submitted to
support reported activities.

What Action Was  Taken

The final audit report
(3300012) was issued to the
Regional Administrator, Region
10, on  February  10, 1993.  A
final response is due from the
Regional Administrator by May
11, 1993.  ADEC agreed with
many of the conditions
described in our draft report
and advised us of corrective
actions taken or planned.
EPA  Region 3's
Certification Process
for Sewage
Treatment Plants
Unreliable

Problem

EPA Region 3's certification
process for wastewater
treatment facilities does not
ensure that all permit violations
and performance problems are
disclosed.

Background

In January 1983, EPA
implemented the Water
Management Division (WMD)
Certification  process. The OIG
believes that a positive
certification indicates that a
facility  is operating properly
and is complying with its
National Pollutant Discharge
Elimination System  (NPDES)
permit.  However, the Office of
Water and Region 3 WMD
contend that a positive
certification means only that
the plant's flow is at least 75
percent of the planned initial
flow, Federal funds  were not
used for unnecessary or
unreasonable aesthetic
features, and there were no
abandoned,  unused or
inoperable facilities.
Certifications were intended to
provide the OIG information,
other than a project's dollar
size, for deciding (1) whether
to initiate an audit and (2) the
scope of such audit.  A
negative certification, indicating
performance problems, could
influence the OIG to initiate an
audit on a project that might
not otherwise meet its criteria
or focus attention in that area
when a project would routinely
be audited.  Conversely, a
positive certification could
influence the OIG to perform
little or no review of a project's
operations.

We Found That

Of 16 facilities reviewed by the
OIG for which WMD project
officers had provided  positive
certifications, six  facilities, or
37 percent were violating their
NPDES permits,  and four
facilities were experiencing
infiltration and inflow (I/I)
problems. Facilities with new
and existing sewers were
hydraulically overloaded
because of excessive I/I and
deficient maintenance
procedures.  The excessive
flows resulted in the discharge
of untreated wastewater into
receiving waters.
   For example, one grantee
received over $2  million from
EPA to construct  a treatment
facility and install a sewer
system. After 1 year of
operation, the facility began to
experience a serious  I/I
problem which appeared to be
the direct result of poor
construction of the collection
system. Subsequently, the
grantee received  a $100,000
State grant to repair the
problem. If the certification
process had been operated
properly, Region  3 could have
identified the problem and
encouraged the grantee to
request the installing
contractors to make the
needed repairs.
   It is essential that such
performance problems be
highlighted by the certification
process. Improved
certifications would ensure that
performance problems are
disclosed so that corrective
action could be required before
the grant is closed.  An
improved certification process
would help ensure that
Federal, as well as grantee,
monies were spent for projects
that operated properly.

We Recommended That

The Regional Administrator,
Region 3, assure that
certifications identify to the
OIG whether a facility is
operating properly or
complying with its NPDES
permit requirements and
highlight any problems with its
performance.

What Action Was Taken

The final report (3100111)  was
issued to the Regional
Administrator, Region 3, on
February 23, 1993.  A
response to the final report is
due by May 24, 1993.
Although disagreeing with our
draft report, the Region
indicated a willingness to
revise the certification process
to make it more meaningful.
Improvements
Needed  in Region 7's
Efforts to Identify
and Report Internal
Control  Weaknesses

Problem

Region 7 had not effectively
implemented the Federal
Managers' Financial Integrity
Act (FMFIA). As a result, the
Region could not assure the
Administrator that it was
meeting its mission and
protecting its resources.

We Found That

Region 7 had not properly
administered FMFIA to
incorporate management
controls into the Region's day-
to-day activities and
understand the importance of
maintaining and using up-to-
12
                                                                                          OFFICE OF INSPECTOR GENERAI

-------
 date, documented controls.
 While managers completed
 required FMFIA paperwork,
 they did not relate FMFIA to
 program activities or perform
 sufficient control assessments
 to disclose program
 weaknesses or resources
 highly vulnerable to abuse,
 loss, or theft.
   From 1988 through  1992,
 Region  7 had not reported
 weaknesses in its assurance
 letter to the Administrator,
 although OIG audits and other
 reviews had identified
 significant weaknesses in the
 Region's operations. For
 example, the Region had not
 addressed  contracts
 management as  a high risk
 area, although OIG reviews
 and the Agency Research
 Triangle Park's Contract
 Management Division had
 disclosed weaknesses. In
 another case, the Region had
 not rated state monitoring as
 highly vulnerable, although
 adequate controls had not
 been established to evaluate
 states' compliance with air
 program requirements.
  Because the Region did not
 have a strong commitment to
 FMFIA,  Region 7 managers
 had not developed plans for
 determining whether subunit
 managers scheduled
 necessary management
 reviews. As a result,
 managers had not identified
 high risk areas and taken
 appropriate corrective action.

 We Recommended That

 The Acting  Regional
 Administrator, Region 7:

 • Require managers to identify
 and report material control
weaknesses and track
 corrective actions.

 • Require managers to report
the status of control systems
based on documented control
 reviews  which have been
scheduled in proper
management plans.

• Require the Management
Control Coordinator to develop
annual workplans and monitor
managers' performance.
• Ensure that managers'
performance agreements
include internal control
responsibilities and managers
are trained on their FMFIA
responsibilities and appraised
on their performance.

What Action Was Taken

The final audit report
(3100148) was issued to the
Acting Regional Administrator,
Region 7,  on March 30, 1993.
A response to the final report
is due by June 28, 1993. In
responding to the draft report,
the Acting Regional
Administrator generally agreed
with the findings and
recommendations and agreed
to take corrective action.  Until
our recommendations are fully
implemented, the Region
cannot assure the
Administrator that its internal
controls are adequate.
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, $124
million was obligated on 9 new
construction  grant awards and
109 increases to existing
grants. As of March 31, 1993,
there were 2,498 grants
involving $18.8 billion which
were potentially subject to
audit.  Of this total, there were
502 active construction grants,
representing $4.6 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,
$136 million was awarded for
three continuation SRF grants.
As of March 31, 1993, EPA
had obligated $6.7 billion to 50
States and Puerto Rico under
the State Revolving Fund
program.
OCTOBER 1, 1992 THROUGH MARCH 31, 1993
                                                                                                                       13

-------
                                                                                           • $188,870 of administrative
                                                                                           and architectural engineering
                                                                                           costs attributed to ineligible
                                                                                           construction;

                                                                                           • $80,895 of administrative and
                                                                                           engineering costs incurred
                                                                                           after the project cutoff date;
                                                                                           and

                                                                                           • $37,540 of costs for
                                                                                           equipment purchased without
                                                                                           prior EPA approval.

                                                                                           We also questioned $730,476
                                                                                           of costs primarily associated
                                                                                           with a litigation claim against a
                                                                                           contractor.

                                                                                           We Recommended That

                                                                                           The Acting Regional
                                                                                           Administrator, Region 3, not
                                                                                           participate in the Federal share
                                                                                           of ineligible costs ($2,375,318)
                                                                                           and determine the eligibility of
                                                                                           the Federal share of
                                                                                           unsupported costs ($547,877).

                                                                                           What Action Was Taken

                                                                                           The final report (3300026) was
                                                                                           issued to the Acting Regional
                                                                                           Administrator, Region 3, on
                                                                                           March 25,  1993. A response
                                                                                           is due by June 23, 1993.
                                                                                           Over $3.1  Million of
                                                                                           Ineligible Costs
                                                                                           Claimed for
                                                                                           Parkersburg, West
                                                                                           Virginia, Project

                                                                                           Problem

                                                                                           The Parkersburg, West
                                                                                           Virginia, Sanitary Board
                                                                                           claimed $3,143,885 of
                                                                                           ineligible legal, architectural
                                                                                           engineering, and equipment
                                                                                           costs.

                                                                                           We Found That

                                                                                           EPA awarded grants to the
                                                                                           Parkersburg Sanitary Board to
                                                                                           construct a wastewater
                                                                                           treatment plant designed to
                                                                                           treat 9.7 million gallons of
                                                                                           wastewater daily. We
                                                                                           questioned $3,143,885 of the
                                                                                           grantee's final claim as
                                                                                           ineligible for Federal grant
                                                                                           participation, including:
Nearly $14 Million of
Questioned Costs
Claimed for New
York City Projects

Problem

New York City claimed
$2,423,359 of ineligible
design and construction
costs. An additional
$11,530,366 of unsupported
costs were also questioned.

We Found That

EPA awarded eight grants
totalling $309,355,670 to New
York City for the design and
construction of additions and
alterations to eight existing
facilities. The grantee claimed
$2,423,359 of ineligible costs
under those grants, including:

• $1,496,343 of construction
costs determined to be
ineligible because of
understated deductions for
change orders, costs
previously declared ineligible
by the New York State
Department of Environmental
Conservation (NYSDEC),
unapproved change orders,
and ineligible bid items;

• $574,239 of architectural
engineering fees which
exceeded the NYSDEC's
approved contract amounts
and related to ineligible
construction; and

• $352,777 of force account
costs related to ineligible
construction.

We also questioned
$11,530,366 of unsupported
costs, including construction
and engineering costs which
exceeded approved contract
amounts and force account
costs which were incurred
beyond the construction
contracts' completion dates.

We Recommended That

The Acting Regional
Administrator, Region 2, not
participate in the Federal share
of ineligible costs ($1,337,198),
determine the eligibility of the
Federal  share of unsupported
costs ($6,380,330), and
recover the applicable amount
from the grantee.

What Action Was Taken

The final report (3100118) was
issued to the Acting Regional
Administrator, Region 2, on
March 2, 1993.  A response is
due by June 1, 1993.
Orlando, Florida,
Claimed Over $4
Million of Ineligible
Costs

Problem

Orlando, Florida, claimed
$4,392,846 of ineligible
engineering and
construction costs.

We Found That

EPA awarded a construction
grant to Orlando to upgrade its
McLeod Road Wastewater
Treatment Plant, including the
construction of a transmission
pipeline and a distribution
network for spray irrigation.
The grantee claimed
$4,392,846 of ineligible costs,
including:

• $3,373,326 for engineering
fees computed under the cost-
plus-percentage-of-cost
contract method, which is
prohibited by EPA regulations;

• $378,169 for design
allowance in excess of the
amount allowed by EPA
regulations;

• $367,916 for engineering
fees applicable to construction
outside the project's scope;

• $152,831 for profit under
change orders  in excess of the
amount allowed under the
construction contract; and

• $120,604 for maintenance
and other costs claimed under
change orders that were the
responsibility of the grantee or
its contractors and
miscellaneous engineering
fees.
We Recommended That

The Acting Regional
Administrator, Region 4, not
participate in the Federal share
of ineligible costs ($2,914,127)
and recover this amount from
the grantee.

What Action Was Taken

The final report (3300011) was
issued to the Acting Regional
Administrator, Region 4, on
Februarys, 1993.  On April
26,  1993, Region 4 issued a
letter to  the grantee requesting
that $2,914,006 be refunded to
EPA.
Baltimore,  Maryland,
Claimed Nearly $3.9
Million of Questioned
Costs

Problem

Baltimore, Maryland, claimed
$3,167,090 of ineligible
architectural engineering,
construction, administrative,
and equipment costs. An
additional $730,476 of
unsupported costs were
questioned.

We Found That

EPA awarded a grant to the
City of Baltimore to construct
sludge handling and disposal
facilities for the Patapsco
Wastewater Treatment Plant.
The grantee claimed
$3,167,090 of ineligible costs
under the grant, including:

• $2,095,075 of project
inspection costs that exceeded
incurred costs;

• $498,119 of administrative
and architectural engineering
costs not supported by the
expenditure report;

• $266,591 of construction
costs claimed in excess of
eligible bid items and change
orders and costs not related to
the project;
14
                                                                                         OFFICE OF INSPECTOR GENERAL

-------
  • $1,448,446 of legal fees,
  including those incurred for
  litigation against the
  architectural engineering firm
  related to the treatment plant's
  inability to operate as
  designed, which had
  previously been disapproved
  by EPA and the West Virginia
  Department of Natural
  Resources (WVDNR);

  • $1,058,287 of architectural
  engineering and project
  inspection fees which
  exceeded the engineer's
  budget and grant ceiling
  without any increase in scope
  of work, was  included in
  another agreement for
  corrective work, or was
  applicable to  ineligible
  construction;

  • $553,392 of construction and
  project improvement  costs for
  duplicate and unused
  equipment, repair and
  maintenance  equipment,
  change orders related to
  alternative technology, i.e., gas
  recovery for gas generation;
  and

  • $83,760 of administrative
  expenses previously
  determined ineligible  for grant
  participation by WVDNR.

  We Recommended That

  The Acting Regional
  Administrator, Region 3, not
  participate in the Federal share
  of ineligible costs ($1,856,114)
  and recover the applicable
  amount from the grantee.

  What Action Was Taken

  The final report (3300013) was
  issued to the  Acting Regional
  Administrator, Region 3, on
  February 10,  1993. A
  response is due by May 9,
  1993.
 Sacramento,
 California, Claimed
 Over $4 Million of
 Ineligible and
 Unreasonable Costs
 Problem

 The Sacramento Regional
 County Sanitation District,
 Sacramento, California,
 claimed $1,395,800 of
 ineligible administrative,
 force account, engineering,
 construction, and land
 acquisition costs. An
 additional $2,624,778 of
 unreasonable project costs
 were questioned.

 We Found That

 EPA awarded five grants
 totaling $288,800,986 to the
 County for the design and
 construction of wastewater
 treatment  facilities. These
 facilities included a cryogenic
 plant, an interceptor, an outfall,
 solids handling facilities,  and a
 combined wet weather control
 system. We questioned
 $1,395,800 of the costs
 included in the grantee's final
 claim as ineligible, including:

 • $961,744 of administrative,
 force account, construction,
 and relocation costs which
 were outside the scope of the
 approved  project;

 • $257,738 of administrative,
 force account, and engineering
 costs allocable to the ineligible
 portion of  the construction
 project; and

 • $176,318 of engineering and
 land acquisitbn costs related
 to easements and rights-of-
 way which had previously
 been disallowed by EPA as
 unnecessary for the
 construction of the project.

  Additionally, we questioned
 $2,624,778 of unreasonable
 costs claimed in excess of the
 approved grant amount.

We Recommended That

The Acting Regional
Administrator, Region 9, not
participate in the Federal share
 of ineligible costs ($1,049,051)
 and determine the eligibility of
 the Federal share ($1,968,584)
 of unreasonable costs.

 What Action Was Taken

 The final report (3300010)  was
 issued to the Acting Regional
 Administrator, Region 9, on
 February 1,  1993.  A response
 to the final report is due by
 May 2, 1993.
 Grantee's $9.1  Million
 Project Claim
 Questioned Pending
 Compliance With
 Discharge
 Requirements

 Problem

 The Sausalito-Marin City
 Sanitary District, Sausalito,
 California, claimed
 $9,082,508 of costs for the
 design and construction
 improvements  to a
 wastewater treatment facility
 that was not consistently
 meeting waste  discharge
 requirements.

 We Found That

 EPA awarded two grants to
 the Sausalito-Marin City
 Sanitary District for the design
 and construction of
 improvements to its
 wastewater treatment facility.
 At the time of the California
 State Water Resources Control
 Board's (SWRCB) final
 inspection in May 1990, the
 grantee was  not consistently
 meeting waste discharge
 limitations. The grantee is
 responsible for completing the
 facility to specifications,
 maintenance and operation,
 and correction of deficiencies
 to meet discharge
 requirements for the facility's
 design  life.
  A January 1992 inspection
 by the California Regional
 Water Facility Board indicated
that modifications to the facility
 had resulted  in its successfully
 meeting standards for
suspended solids, but not  for
settleable solids. Although,
the grantee has  apparently
expended significant efforts
since start-up of the facility in
1987, the costs claimed cannot
be accepted without the
SWRCB's certification that the
facility is meeting its discharge
limitations. Therefore, we
questioned $8,023,895 of the
grantee's claim as
unreasonable, pending EPA's
receipt of such certification.
  Should the grantee
eventually obtain a certification
from the SWRCB, we still
question $1,058,613 of the
costs included in the grantee's
final claim as ineligible,
including:

• $1,002,874 of costs allocable
to the facility's capacity
reserved for the United States
Department of Interior; and

• $55,739 of administrative and
engineering costs considered
outside the scope of the
approved project or allocable
to the ineligible portion of
construction.

We Recommended That

The Acting Regional
Administrator, Region 9,
disallow the Federal share of
ineligible costs ($793,961),
assess the eligibility of the
Federal share of unreasonable
costs ($6,017,921), and
recover the applicable amount
from the grantee.

What Action Was Taken

The final report (3300022) was
issued to the Acting Regional
Administrator, Region 9, on
March 16, 1993. A response
is due by June 14,  1993.
OCTOBER 1, 1992 THROUGH MARCH 31, 1993
                                                                                                                        15

-------
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
program changes.  On
Novembers, 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 sixth annual
report, covering fiscal 1992,
must be issued by September
1993.
Improvements
Needed in Timeliness
and Controls Over
Responsible Party
(RP) Cleanups

Problem

The Agency's use of RPs to
clean up Superfund sites
has been hampered by
numerous problems,
including delays in initiating
cleanups, lack of aggressive
enforcement actions, and
ineffective management of
contractors.

Background

Through September 1992,
EPA had negotiated over $7
billion of settlements with RPs,
of which over $5 billion had
been negotiated since 1989.
During the past 4 years, the
OIG and the U.S. General
Accounting Office issued  15
audit reports covering all
aspects of Superfund
enforcement activities which
are summarized in this
capping  report.

We Found That

EPA's cleanup process was
extended by many delays in
all phases of the process.
These delays included
initiating searches for RPs;
negotiating settlement
agreements after  RPs were
identified; EPA Regions'
review and approval of  RP
deliverables, such as work
plans and project operation
plans; and contractor
submissions of deliverables
such as reports on RP
searches.  The Agency was
reluctant to set time frames for
its own actions because of
individual site uniqueness.
Project managers, who were
mainly responsible for many
cleanup tasks, had inadequate
supervision, training, guidance,
resources, or monitoring tools
to assist them in
accomplishing their work.
  There was a lack of
aggressiveness  in EPA's
Superfund enforcement
program.  Stipulated penalties
were not pursued. EPA
primarily relied on verbal
negotiations and warning
letters in an attempt to
encourage RPs to comply.
Agency officials believed the
use of stipulated penalties
should be discretionary and
there should be a balance
between cooperation and
enforcement.
  EPA ineffectively managed
contractors used to identify
and monitor RP  activities at
cleanup sites. There were
insufficient safeguards to
assure appropriate contractor
performance. Moreover,
planning was ineffective
because the differences and
complexities of required tasks
were not considered.
  EPA's automated tracking
systems were not always
sufficiently comprehensive,
current  or accurate to allow
timely and effective
management oversight.
Systems were not always
designed to monitor essential
data on the cleanup  process,
and some offices still used
manual systems.  Program
personnel were not always
aware of the existence or
capability of these monitoring
tools, encouraged to use them,
or sufficiently motivated to
assure timely and accurate
data input.
  There was a lack of
documentation in all phases
of the Superfund
enforcement process.  Key
decisions and significant
events were not always
recorded or maintained in
official files. Reports and
minutes of meetings  were not
16
                                                                                        OFFICE OF INSPECTOR GENERAL

-------
 prepared, and justifications of
 strategies or positions were
 not written or retained.
 Personnel did not give priority
 to preparing or maintaining
 appropriate documentation and
 files.
   EPA has made progress in
 getting RPs involved in
 cleaning  up Superfund sites
 and taking responsibility for
 their share of costs associated
 with the cleanups.  However,
 EPA's enforcement program
 provided  little incentive for RP
 compliance and sometimes
 tended to delay the overall
 cleanup progress.  Despite
 EPA's efforts, there has not
 been  a marked  increase in
 enforcement efforts against
 noncomplying RPs.  In
 addition,  EPA Headquarters
 still had not determined the
 types and composition of
 Agency systems needed for
 tracking cleanups to allow
 timely and effective
 management oversight.

 We Recommended That

 The Assistant Administrators
 for Solid Waste  and
 Emergency Response and
 Enforcement:

 • Require EPA Headquarters
 policy guidance  be
 established, updated,
 reinforced, or implemented
 with respect to Superfund
 cleanup activities in the areas
 of RP oversight, timeliness,
 stipulated penalty, cost
 recovery  enforcement, contract
 monitoring, data input, and
 documentation;

 • Require EPA Headquarters
to perform in-depth  annual
 reviews which evaluate the
quality and consistency of
program performance; and

• Establish a task force to
review all enforcement
management systems.

 What Action Was Taken

 The final  report (3100152) was
issued on March 31, 1993,  to
the Acting Assistant
Administrator for Solid Waste
and Emergency Response and
the Acting Assistant
Administrator for Enforcement.
A response to the final report
is due by June 29, 1993.  In
responding to the draft report,
the Acting Assistant
Administrator for Solid Waste
and Emergency Response
generally agreed with our
findings.  EPA had initiated
several actions to address the
problems discussed in the
report, including issuing new
guidance to speed the
negotiation process,
reorganizing to facilitate closer
regional management
involvement, and streamlining
the cleanup process.

Continuing
Weaknesses in
Superfund
Accounting and
Controls

Problem

Pervasive and persistent
problems related to
managing accounts
receivable and personal
property have continued
during the 10 years of the
Superfund program. In
addition, the Agency's
Integrated Financial
Management System (IFMS)
did not provide complete
and accurate reports to
Superfund management.

We Found That

While Superfund obligations
and disbursements for fiscal
years 1981 through 1990
appropriations were presented
fairly,  there were continuing
weaknesses  in controls over
resources and assets, primarily
relating to managing accounts
receivable and personal
property.  In addition, although
the  Agency's IFMS was
implemented in fiscal 1989 to
provide a comprehensive
financial management system,
IFMS  did not provide complete
and accurate reports for
management.
  From 1983 through 1990,
over $94  million of receivables
were not posted timely.  For
example,  in 1989 and  1990,
$40.3 million of receivables
were not posted in the correct
year.  In addition, the Agency
did not always take action
required to follow up on late
accounts or assess added
charges to such accounts.
Without proper management of
receivables, EPA cannot
collect funds to which it is
entitled.
   Problems have persisted in
recording, locating, and
accounting for property since
1982. As of September 30,
1990, Superfund property
recorded in the property
system totaled $76.5 million,
but $12 million in property
purchased since 1981 had not
been  recorded.  Property was
not recorded because
contracting offices, custodial
officers, and  receiving
personnel did not always
forward obligating documents
and receiving reports to
property officials. Also,
several regional offices had
not performed annual
inventories and reconciliations
of their property for years.
   In some cases, the Agency
reported the above problems
to the President as required by
the Federal Managers'
Financial Integrity Act.  The
Agency has generally
completed or initiated actions
to correct the  problems found
in the Superfund program.
However, most of the
procedures and  internal
controls reviewed cross
program lines and were
applicable Agency-wide.

We Recommended That

The Assistant Administrator for
Administration and Resources
Management, who is also the
Chief  Financial Officer and the
senior internal control official,
inform other principal
managers within the Agency
and the Senior Council on
Management Controls about
the persistent weaknesses
found  in the Superfund
program over the past decade.

What  Action Was Taken

The audit report (3100058)
was issued to the Assistant
Administrator for
Administration and Resources
Management and the Assistant
Administrator for Solid Waste
and Emergency Response on
December 29, 1992.  In
response to the audit report,
the Assistant Administrator for
Administration and Resources
Management agreed to
implement our
recommendation.
Superfund Indirect
Cost Rates Not
Adequate for Full
Recovery of  Cleanup
Costs

Problem

EPA's fiscal 1987 and 1988
Superfund indirect cost rate
calculations inappropriately
excluded $144.2 million and
$225.9 million, respectively,
severely reducing the total
amounts for recovery from
parties responsible for
hazardous waste sites.

Background

The cost of removal and
remedial  actions incurred by
EPA include direct and indirect
costs, both  of which are
recoverable from responsible
parties (RP) under the
Comprehensive Environmental
Response,  Compensation, and
Liability Act. On August 6,
1992, EPA  published in the
Federal Register a major
proposed change in the
methodology for calculating
indirect cost rates  that would
provide for  "full cost recovery."

We Found  That

Although the present
conservative method for
calculating Superfund indirect
cost rates complies with
Agency guidance,  this method
did not present fairly the
Superfund indirect cost rates
for fiscal years 1988 and 1987
in  conformity with generally
accepted accounting
principles.  Because significant
costs were  excluded from the
indirect cost pools, EPA's
indirect cost rates were not
high enough to ensure full
recovery from RPs of costs
incurred by  the Government in
OCTOBER 1, 1992 THROUGH MARCH 31, 1993
                                                                                      17

-------
cleaning up hazardous waste
sites. These costs are for
assessment of sites before
starting remedial, removal, and
enforcement activities,
research and development,
and depreciation for capital
expenditures.
  The costs excluded from the
indirect cost pools amounted
to $370 million for fiscal 1988
and 1987.  If these costs are
not included in the indirect cost
pools and then sought, they
will never be recovered from
RPs.  In addition to costs
omitted from the indirect
costpool, the way costs were
allocated to sites resulted in
the Agency not recovering part
of the indirect costs.
  Further,  delays in
establishing indirect cost rates
result in underrecoveries from
RPs  of costs incurred by the
Government in cleaning up
hazardous waste sites. The
fiscal 1987 indirect cost rates
were not established until
September 28, 1989, and the
fiscal 1988 rates were not
established as of February 22,
1993.

We Recommended That

The Comptroller establish a
time  frame for timely
completion of  calculations and
establishment of provisional
indirect cost rates  in
accordance with its proposed
rule which  provides for full cost
recovery of cleanup costs.

What Action  Was Taken

The final audit report
(3100114) was issued to the
Assistant Administrator for
Administration and Resources
Management on February 22,
1993. A response to the final
report is due by May 24,  1993.
In response to our draft report,
the Assistant Administrator
generally agreed with our
findings and recommendation.
Special And  Early
Warning Reviews
This section in our semiannual
report describes the results of
significant and potential
findings, deficiencies, and
recommendations which have
been identified through
evaluations, analyses, projects,
and audits.  These reviews are
intended to help Agency
managers correct problems
and recognize the potential for
savings before resources are
fully committed.
Special Reviews

Special reviews are narrowly
focused studies of programs or
activities providing
management a timely,
informative, independent
picture of operations.  Special
reviews are not statistical
research studies or detailed
audits. Rather, they are
information gathering studies
that identify issue areas for
management attention.
$1.6 Million in EPA
Training Grants  Not
Adequately Evaluated

Problem

EPA did not adequately
monitor or evaluate the
effectiveness of training
provided to assist minority
contractors in obtaining
environmental contracts.  In
addition, EPA awarded
grants without considering
alternative lower cost
sources.

We Found That

The Office of Small and
Disadvantaged Business
Utilization (OSDBU) had
awarded grants totalling $1.6
million to the National
Association of Minority
Contractors (NAMC) to provide
training to small, minority and
disadvantaged  businesses in
the areas of Superfund,
Leaking Underground Storage
Tanks,  Asbestos, and Radon.
Neither NAMC  or OSDBU
determined whether the
minority contractors who
attended the training
subsequently received
contracts in the above areas,
which was the principal
objective of the grants.  Of 33
minority contractors we
contacted, only 15, or 45
percent, were working in the
environmental field for which
NAMC  had provided them
training.
  In addition, as a result of
OSDBU's and the Grants
Administration Division's failure
to adequately monitor the
grantee, NAMC did not (1)
submit  progress and financial
status reports; (2) perform
need surveys; (3) develop
indirect cost rate proposals;
and (4) comply with OMB
Circular A-133  requiring
nonprofit institutions receiving
$100,000 or more each year in
Federal awards to  have annual
audits conducted.  These
deficiencies resulted primarily
from a  lack of supervisory
review  and insufficient training
of the project officer.
  Also, during fiscal 1989
through 1991, EPA awarded
grants totaling $1.8 million
(including the $1.6 million of
grants funded by OSDBU) to
NAMC without considering
lower cost alternative training
sources.  NAMC's costs per
course ranged from $442 to
$3,425 per person. Other
nonprofit institutions were
providing similar training for
between $325 and $775. As a
result, EPA may have paid
unreasonably high costs to
train minority contractors.

We Recommended That

The Directors of OSDBU and
the Grants Administration
Division (GAD) provide
sufficient training and
increased supervisory review
of project officers to ensure
that training  grants are
adequately monitored.

What Action Was Taken

The final special review report
(3400017) was issued to the
Directors of  OSDBU and GAD
on January 25,  1993. In
responding to the draft report,
the Directors agreed  with the
issues and recommendations
presented in the draft report.
A response due to the final
report by April 26, 1993, had
not been received as of April
28, 1993.
                                                             Better Accounting
                                                             Needed  For Oil Spill
                                                             Funds

                                                             Problem

                                                             EPA did not have adequate
                                                             controls or procedures to
                                                             properly account for $18.4
                                                             million available in fiscal
                                                             1992 from the Oil Spill
                                                             Liability Trust Fund.

                                                             Background

                                                             A five-cent tax on each barrel
                                                             of imported oil is charged and
                                                             deposited in the Oil Spill
                                                             Liability Trust Fund.  These
                                                             funds are earmarked for oil
                                                             pollution prevention and
                                                             cleanup actions by Federal
                                                             agencies.
18
                                                                                           OFFICE OF INSPECTOR GENERAI

-------
 We Found That

 EPA's Offices of Research and
 Development (ORD) and
 Enforcement (OE) received
 $2,571,400 in fiscal 1992 from
 the Oil Spill Liability Trust
 Fund without account numbers
 for separately tracking Oil Spill
 expenditures or guidance from
 the EPA Comptroller.  Further,
 these two offices were not
 formally advised that they had
 been allocated Oil Spill funds.
 Also, the Office of the
 Comptroller did not act to
 make the appropriated Oil Spill
 funding available for
 disbursement until after we
 raised the issue in March
 1992, nearly 7 months into the
 fiscal year.

 We Recommended That

 The Chief Financial Officer:

 • Review the Agency's fiscal
 1992 obligations and
 expenditures and adjust the
 Agency's accounting records
 to accurately reflect EPA's  use
 of the Oil Spill Liability Trust
 Fund.

 • Establish policies and
 procedures to ensure that the
 Agency's annual
 appropriations act is reviewed,
 all necessary accounting
 codes have been established,
 and adequate guidance has
 been provided to program and
 regional offices.

 • Develop procedures and
 assign responsibility for
 ensuring that all funds
 appropriated from the Trust
 Fund are properly transferred
 to an EPA account so that
 they are available for EPA's
 use.

 What Action Was Taken

 The final special review report
 (3100039) was issued to the
 Chief Financial Officer on
 March 31, 1993.  The Chief
 Financial Officer, in responding
 to the draft report, generally
 agreed with our findings and
 recommendations. He stated
 that a survey of all offices that
 received funds during fiscal
 1992 indicated that all funds
 were used for their intended
 purposes.  Also, he stated that
 steps had been taken to
 ensure that all funds
 appropriated from the Trust
 Fund are properly transferred
 to an EPA  account.  A
 response to the final report is
 due by June 29, 1993.
 EPA Lacks an
 Adequate Energy
 Conservation
 Program

 Problem

 EPA had not developed an
 energy management and
 conservation program as
 required by statutes and
 regulations.  As a result,
 EPA could not adequately
 determine its energy
 consumption costs and
 measure its progress in
 reducing consumption.

 Background

 The 1975 Energy Policy and
 Conservation Act and
 subsequent energy
 conservation legislation
 requires Federal agencies to
 develop a 10-year plan to
 conserve energy in Federally
 owned or leased buildings.
 The 1992 Energy Policy Act
 requires all  Federal Inspectors
 General to review each
 Agency's compliance with
 energy conservation
 requirements.

 We Found That

 EPA was not in substantial
 compliance with energy
 conservation requirements.  In
 1984 EPA began to develop
 an Agency-wide program but
 did  not complete the project.
 The Agency recently re-
 initiated the effort, with EPA's
 Facilities Management and
 Services Division assuming
 responsibility for developing a
program, but did not assign
clear organizational
responsibilities or commit the
resources necessary to
implement the program.  As a
result, EPA did not have an
Agency-wide 10-year plan for
reducing energy consumption.
Although EPA had initiated an
energy program for its
Washington, D.C. site,  formal
energy programs were not
implemented at the other eight
field sites reviewed.
   In addition, EPA did  not
have a complete Agency-wide
data base of energy
consumption and cost data for
fiscal 1985 through fiscal 1992.
Therefore, EPA was unable to
monitor its progress in  meeting
required energy consumption
reduction of 20 percent from
its fiscal 1985 base.  EPA's
fiscal 1992 energy
consumption data base did not
include  an estimated 38
percent of the total square
footage of facilities for which
EPA was required to report,
resulting in substantial
understatement of energy
consumption costs.
   EPA implemented a "Green
Lights" program for retrofitting
buildings with energy efficient
lighting. However, EPA had
not developed a centrally
organized and comprehensive
survey and retrofit program to
identify, install, and monitor all
types of potential retrofit
projects.

We Recommended That

The Assistant Administrator for
Administration and Resources
Management:

•  Establish and implement an
Agency-wide energy
management and conservation
program in compliance with
applicable statutes and
regulations.

•  Formally designate an
Agency-wide energy
coordinator and assign  clear
organizational responsibilities
and authority to implement the
program.

•  Establish a program to
identify and monitor retrofit
activities.
• Establish controls and
procedures to maintain timely
and accurate energy
consumption data.

• Establish controls and
procedures to ensure that 10-
year plans and progress
reports are prepared and
updated.

• Request sufficient  resources
to comply with applicable
energy conservation statutes
and regulations.

What Action Was Taken

The special review report
(3400024) was issued to the
Assistant Administrator for
Administration and Resources
Management on February 22,
1993. A response to the final
report is  due by May 23, 1993.
The Assistant Administrator's
response to the draft report
generally agreed with our
findings and recommendations.
Improper
Procurements
Circumvented
Federal  Acquisition
Regulation

Problem

Office of Communications,
Education, and Public
Affairs (OCEPA) officials
routinely obtained goods
and services without proper
authorization or competition
as required by the Federal
Acquisition Regulation.

We Found  That

OCEPA staff preselected
vendors and prepared vague
or inadequate statements of
work.  For one procurement
action, a contractor was asked
to provide two other sources to
compete with its bid.  This
same vendor was paid for a
videotape that was  never
received. In another case,
OCEPA officials split one
requirement into three
separate purchase orders to
avoid  the competitive  process
OCTOBER 1, 1992 THROUGH MARCH 31, 1993
                                                                                                                     19

-------
and requested the
Procurement and Contracts
Management  Division (PCMD)
to process a fourth purchase
order, which PCMD refused to
do. Also, OCEPA used
contracts or interagency
agreements established by
other offices to ensure that
services were obtained from
contractors of choice. OCEPA
made unauthorized
procurements by receiving
goods and services before
purchase orders were issued,
or occasionally without
purchase orders being issued
at all.
  OCEPA made improper
procurements because
managers did  not adequately
plan for anticipated
requirements and placed more
importance on "who" was to
provide goods and services,
rather than "what" goods and
services were needed. And,
the Senior Procurement Officer
failed to ensure the
effectiveness and integrity of
OCEPA's procurement
activities.

We Recommended That

The Associate Administrator
for Communications,
Education, and Public Affairs:

•  Ensure that contract
requirements are competed;
statements of  work are
complete; and no work is
performed before a contract or
purchase order has been
issued.

•  Ensure that staff involved in
procurement are properly
trained and designate a senior-
level official as OCEPA's
Senior Procurement Officer.

What Action  Was Taken

The special review report
(3400035) was issued on
March 31, 1993. In
responding to our draft report,
the Associate  Administrator for
Communications, Education,
and Public Affairs agreed with
our report's findings and has
implemented or is in the
process of implementing all of
our recommendations.  A
response to the final report is
due by June 29, 1993.
ERA'S Administration
of the  Federal
Employees'
Compensation Act
Needs Improvement

Problem

EPA has not adequately
managed claims and
payments under the Federal
Employees' Compensation
Act(FECA). As a result,
EPA may be paying benefits
for individuals who are not
EPA employees and may not
be encouraging its
employees to return to work
as soon as possible.

We Found That

Despite knowing that it  is often
charged by the Department of
Labor (DOL) for benefits paid
to individuals who are not EPA
employees,  EPA was not
verifying or correctly assigning
FECA costs. Under the
chargeback system, the costs
of compensation for job-related
injuries and deaths paid by
DOL are assigned to
employing agencies.  FECA
charges to EPA in 1992
totalled $2,142,269.
  Costs are not being charged
to the lowest organizational
level and managers may not
have a monetary incentive for
seeking their employees'
return to work.  Instead, most
employees are  lumped
organizationally under the
Office of Administrator,  even
though they are assigned to a
region or headquarters
program office.  Of the  353
employee cases that EPA paid
in 1992, 231  cases, or 66
percent, were coded as
belonging to  the Office  of the
Administrator.
  EPA had not designated
organizational responsibility for
all FECA functions and  there
was no national FECA policy,
guidance, or oversight.  The
Agency had not adequately
trained supervisors, managers,
and employees about their
FECA responsibilities, nor had
it effectively communicated
and coordinated FECA
activities with DOL. EPA had
not established a light
duty/return-to-work program.
Lack of prompt action to return
employees to work or
accommodate employees with
special needs can increase
FECA costs.

We Recommended That

The Assistant Administrator for
Administration and Resources
Management:

• Verify the FECA chargeback
report and work with  DOL to
assign chargeback codes at
the lowest practical
organizational level;

• Clearly identify the offices
responsible for  FECA functions
and establish or update
Agency policy, procedures,
and guidance to accurately
reflect current FECA
requirements.

• Establish an Agency-wide
light duty/return-to-work
program and FECA monitoring
and evaluation program; and

• Disseminate information to all
employees about FECA's
coverage, responsibilities, and
claims processing
requirements.

What Action Was Taken

The special review report
(3400033) was issued to the
Assistant Administrator for
Administration and Resources
Management on March 26,
1993. In responding to the
draft report,  the Assistant
Administrator generally
concurred with our findings
and recommendations.  A
response to the final  report is
due by June 14, 1993.
Construction  Grant
Early Warning
System

This program is designed to
identify potential problem
construction projects early in
their life cycle so that EPA
management can take
appropriate corrective action.
   The long-range goal of the
construction grants program is
to reduce the discharge of
municipal wastewater
pollutants to improve water
quality and protect public
health.  EPA provides grants
to municipal agencies to assist
in financing the construction of
wastewater treatment works, a
process which takes 2 to 10
years to complete.
   Because audits are
generally performed after the
project is complete, problems
which affect the efficient
design, construction,
management, or operation of a
treatment plant are not
disclosed until thousands or
millions of dollars have been
spent.  Under its early warning
system, the OIG reviews
projects to identify problems
and preclude  the ineffective
expenditure of funds.  Some
reviews focus on certain
indicators and attributes that
can suggest the likelihood of a
potential problem.
20
                                                                                         OFFICE OF INSPECTOR GENERAL

-------
 $21.5 Million Grant to
 San Diego Should Be
 Annulled

 Problem

 San  Diego, California, has
 no need for a land outfall
 after it canceled plans to
 construct a related
 secondary treatment plant.

 We Found That

 EPA awarded a $21.5 million
 grant to San Diego in 1989 to
 participate in a 2.3 mile, 12-
 foot diameter land outfall to
 serve two proposed secondary
 wastewater treatment plants
 (San Diego and International
 Treatment Plants).  Although
 required by a special grant
 condition, San Diego canceled
 its plans to construct the
 secondary plant.  Therefore,
 the nearly  completed land
 outfall will  not be  used by San
 Diego for its intended purpose,
 nor will it be used in the
 foreseeable future.
   San Diego maintained that,
 although the treatment plant
 may  not be built,  the land
 outfall could be used for future
 flows from other projects.
 Because these projects are not
 scheduled to be built until
 2025, they cannot satisfy the
 special grant condition.
   The award of the land outfall
 grant was premature.   San
 Diego's primary purpose in
 seeking the grant was to take
 advantage of EPA
construction grant funds which
were expiring in 1988.
However, at the time of grant
award, San Diego had not
decided on whether a
treatment plant would be built
or designated the area to be
served.

We Recommended That

The Regional Administrator,
Region 9:

• Not participate in the Federal
share of ineligible costs ($11.8
million) by annulling the land
outfall grant, unless the
secondary treatment plant is
constructed in accordance with
the approved facility plan.

• Advise San Diego that the
use of  available land outfall
capacity to accommodate
future flows from other projects
which exceeded its existing
needs  are ineligible for grant
funding.

What Action Was Taken

The special review report
(3400037) was issued to the
Regional Administrator, Region
9, on March 29, 1993. In
response to our March 1,
1993, position paper,  San
Diego disagreed that it had
violated the grant condition
requiring construction of the
secondary treatment plant,  A
response to the final report is
due by June 29,  1993.
$7.2 Million
Middletown,
California, Project
Does  Not Meet
Effluent Goals

Problem

The Lake County Sanitation
District in Middletown,
California, claimed $1.7
million of costs for a leaking
storage pond and an unused
disposal system for treated
effluent which rendered the
project  in noncompliance
with its discharge permit.

We Found That

EPA awarded a $7.2 million
grant to the Lake County
Sanitation District for
construction  of a sewage
treatment facility, including a
storage  pond of about 20
acres (with a capacity of about
79 million gallons) and an 88-
acre disposal area.  The
facility was designed to
provide controlled disposal of
treated wastewater by spray
irrigation.  We questioned $1.7
million of the grantee's claimed
costs as ineligible, including:

• $300,000 for the storage
pond which had not been
properly constructed or
adequately tested and leaked
excessively,  even after being
repaired; and

• $1.4 million for the disposal
system that was not being
used for irrigation because of
the lower than expected flows
into the storage pond and the
leakage of the storage pond.

Consequently, the District had
not fulfilled the grant objective
requiring the disposal of the
wastewater effluent into an 88-
acre area for crop irrigation.
As a result, the District  was
violating its waste discharge
permit because the leakage
experienced in the storage
pond caused the effluent to
flow directly into the ground.
After several years, the
concentration of nitrates in the
groundwater would likely
approach or exceed the state's
drinking water standards,
thereby potentially threatening
the community's public  water
supply.

We Recommended That

The Acting Regional
Administrator, Region 9,
disallow the costs of the
storage pond and disposal
system for grant funding,
unless the District
demonstrates that the facilities
are being used and the project
is in compliance with the waste
discharge permit.

What Action Was Taken

The special review report
(3400016) was issued to the
Acting Regional Administrator,
Region 9, on January 21,
1993.  A response due  by April
20, 1993, had not been
received as of April 28,  1993.
          The
   unnecessary
 2.3 mile outfall
     (photo by
  Western Audit
  Division staff)
OCTOBER 1, 1992 THROUGH MARCH 31, 1993
                                                               Lake County Sewage Treatment Plant
                                                               (OIG photo by Western Audit Division staff)
                                                                                                                        21

-------
   Section 2-Report Resolution
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 summarizes
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 summarizes 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 31,1993

                                                 Dollar Values (in thousands)
                                  Report Issuance
                                       Report Resolution
                                         Costs Sustained
                          Number
Questioned Recommended
Costs        Efficiencies
To Be
Recovered
                                                                                      As
                                                                              Efficiencies
A. For which no             341       437,616         233,670
  management decision
  has been made by the
  commencement of the
  reporting period*

B. Which were issued        722       132,332          16,296
  during the reporting
  period

C. Which were issued        509            0              0
  during the reporting
  period that required no
  resolution

  Subtotals (A + B - C)       554       569,948         249,966

D. For which a              224       66,965         118,388
  management decision
  was made during  the
  reporting period

E. For which no             330       502,983         131,578
  management decision
  has been made by the
  end of the reporting
  period

Reports for which no        146      371,0632         115,579
management decision
was made within six
months of issuance
                            26,808
             5,398
* 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.
22
                                                                                           OFFICE OF INSPECTOR GENERAL

-------
 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 semiannual/y, 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.
 Despite Progress in
 Superfund Post-
 settlement Activities,
 Additional Actions
 Are Still Needed

 Previous Problems and
 Findings

 Our March 1990 audit
 concluded that Region 2
 needed to intensify its
 oversight of responsible
 party (RP) activities to
 assure timely completion of
 Superfund cleanups and
 proper compliance with
 settlement requirements.
 We reported that the
 initiation of Superfund
 cleanup  work was
 unnecessarily delayed
 because of the Region's
 lengthy review and approval
 of plans and  other
 documents before work
 could be undertaken;
 stipulated penalties were not
 being assessed for
 noncompliance with
 settlement milestone dates;
 improvement was needed in
 the oversight of Technical
 Enforcement  Support (TES)
 contractors; and oversight
 costs were not being
 recovered from RPs.

 Followup Findings

 Our followup report  (3400005)
 found that Region 2 had
 initiated actions to correct
 many of the findings from our
 prior audit.  Several of these
 had been implemented, while
 others were in the
 development stage.
  Regional internal review
 problems were still resulting in
 the approval process for RPs'
 plans and documents taking
 more than a year. Recent
 regional initiatives to decrease
 the project manager/site ratio
 and supervisor/staff  ratio could
 further improve the timeliness
 of the approval process.
  The Region  had not
 implemented an effective
 system for the timely recovery
from  RPs of costs incurred by
 EPA  in overseeing the cleanup
of Superfund sites.  EPA had
collected  or initiated actions to
collect oversight costs for only
3 of the 8 cases totaling
$627,761  cited in our prior
report, while costs continued to
accumulate.

Followup Recommendations

We recommended that the
Regional Administrator, Region
2:

• Complete  and implement
guidance on timely regional
review and approval of plans
and other documents
submitted by RPs for
Superfund cleanups.

• Implement the Region's
proposal on stipulated
penalties.

• Implement an effective
system for the timely recovery
of Superfund cleanup oversight
costs.

• Use a computerized narrative
containing sufficient detail to
record the conditions observed
at TES contractors' sites.

What Action Was Taken

The special review report
(3400005) was issued on
November 24, 1992, to the
Regional Administrator,  Region
2. A response due by
February 24, 1993, had not
been received as of April 28,
1993. In responding to  the
draft report,  the Region
generally agreed with the
report's findings and
recommendations.  However,
the Region did not concur with
the recommendation that
specific time frames be
established for review and
approval of RP submissions.
 Major Improvements
 Made to Properly
 Dispose of Banned
 Pesticides

 Previous Problems and
 Findings

 After hearings in 1986 and
 1987, the House Government
 Operations Committee
 recommended that EPA
 develop a policy for holders
 to properly store and report
 emergency suspended and
 cancelled (banned)
 pesticides.  EPA had banned
 three pesticides—Ethylene
 Dibromide, 2,4,5-T/silvex,
 and dinoseb.  Our
 September 1990 report
 found that EPA still had not
 ensured that banned
 pesticides holders safely
 controlled their stocks and
 complied with disposal
 rules.  Regions and States
 could not fully identify and
 inspect all known banned
 pesticide storage locations
 because EPA had not
 developed procedures to
 match Headquarters, Region
 and State records.  Also,
 emergency planners and fire
 officials were not aware of
 banned pesticide storage
 locations or emergency
 handling procedures.

 Followup Findings

 Our followup report found that
 the Office of Prevention,
 Pesticides and Toxic
 Substances (OPPTS) had
 initiated action to address most
 of the findings and
 recommendations in our 1990
 report. For those findings
 where corrective action had
 not been taken, OPPTS
 proposed to take such action
 during the next year.
  The OPPTS Office of
 Compliance Monitoring (OCM)
 still did not have complete
 information to track dinoseb
 inspections and did not track
 referrals separately from the
 regular inspections. Also,
 even though OPPTS had
distributed  lists of dinoseb
 holders, the emergency
 planners and fire officials still
did  not have the information.
OCTOBER 1, 1992 THROUG> JARCH 31, 1993
                                                                                                                 23

-------
OPPTS had nearly completed
its collection and disposal of
dinoseb, but agreed to
continue to improve its
program to ensure safe
storage and disposal of any
uncollected amounts of the
pesticide.
  OPPTS also agreed to take
action to improve its  internal
control system.  Our review
found that OPPTS did  not
follow the Agency's guidance
for documenting alternative
internal control reviews or
training.  Also, OPPTS did not
use the Management Audit
Tracking System to monitor
corrective action plans for OIG
audits.  Without improving its
internal control system,
OPPTS may not detect or
correct program deficiencies.
  The 1988 amendments to
the Federal Insecticide,
Fungicide, and Rodenticide Act
eliminated the requirement that
OPPTS must accept banned
pesticides and dispose of
them.  OPPTS can now
require registrants to recall
banned pesticides.  However,
OPPTS has not completed
new regulations for storage
and disposal of banned
pesticides.  It is unclear how
OPPTS will ensure the safe
disposal of future banned
pesticides until the regulations
are completed.

What Action Was Taken

The final report (3400030) was
issued to the Acting Assistant
Administrator for Prevention,
Pesticides and Toxic
Substances on March 26,
1993.  A response to the final
report is due by June 14,
1993.  In responding to the
draft report, the Agency
agreed with our findings and
proposed corrective actions to
address all of our
recommendations. As a result,
the final report contained no
recommendations and was
closed upon issuance.
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 1 and 2
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 $21.7 million being
sustained out of $31.8 million
considered ineligible in reports
under OIG control.  This is a
68 percent sustained rate.
 Table 1—Inspector General Issued Reports With Questioned
 Costs Semiannual Period Ending:  March 31,1993

                                             Dollar Values (thousands)
                                             Questioned*  Unsupported
                                    Number      Costs        Costs

 A For which no management decision has been     155     437,616     89,358
   made by the commencement of the reporting
   period"

 B. New Reports issued during period              71      132,332     38,611

   Subtotals (A + B)                         226      569,948     127,969

 C. For which a management decision was made      79       66,965      23,207
  during the reporting period
  (i)  Dollar value of disallowed costs              61       26,808       2,273

  (ii) Dollar value of costs not disallowed"*          46       40,157      20,934

 D. For which no management decision has been     147      502,983     104,762
  made by the end of the reporting period
 Reports for which no management decision was      81      371,063      66,151
 made within six months of issuance

 * Questioned costs include the unsupported costs.
 " 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.
 *** On 18 reports management did not sustain any of the $20,777,579 questioned costs
 Twenty-eight reports are also included in C(u) 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 31,1993
                                      Number
  Dollar Value
(in thousands)
A. For which no management decision has           67             233,670
  been made by the commencement of the
  reporting period*

B. Which were issued during the reporting penod       15              16,296

  Subtotals (A + B)                            82             249,966

C. For which a management decision was            41             118,388
  made during the reporting period
  (i) Dollar value of recommendations that            13              5,398
    were agreed to by management

  - based on proposed management action           n/a                n/a

  - based on proposed legislative action              n/a                n/a
  (ii) Dollar value of recommendations that            14"             26,800
    were not agreed to by management

  (iii) Dollar value of non-awards or                 18              86,190*"
    unsuccessful bidders
D. For which no management decision has           41              131,578
  been made by the end of the reporting penod

Reports for which no management decision           29             115,579
was made within six months of issuance
' 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.
" Four of the reports were the same reports 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 jn C(ii).
'" This amount represents the dollar value of recommendations that funds be put to better
use
24
                                                                                                   OFFICE OF INSPECTOR GENERAL

-------
Resolution of Significant Reports
Repoer Number / Grantee /
Report Date Contractor
E2CWMO-02-0268
2200027
REPORT DATE
9/2/92
E2CWM1-02-0118
2200034
REPORT DATE
9/22/92
P2BW8-02-0268
2100450
REPORT DATE
7/5/92
P2CWL9-02-0019
2100328
REPORT DATE
4/16/92
D8AML2-03-0406
2100534
REPORT DATE
8/28/92
E2AWT2-03-0603
2400084
REPORT DATE
9/30/92
NORTH CASTLE
NY


MIDDLESEX
COUNTY NJ


NYC-OAKWOOD
BEACH NY


WESTCHESTER
COUNTY NY


BIONETICS VA



EW PHILADELPHIA
PA


Report Issuance
FS Questioned /
Recommended
Efficiency
INEL
UNSP
UNUR
RCOM
INEL
UNSP
UNUR
RCOM
INEL
UNSP
UNUR
RCOM
INEL
UNSP
UNUR
RCOM
INEL
UNSP
UNUR
RCOM
INEL
UNSP
UNUR
RCOM
469,490
0
0
0
264,500
1,188,912
0
0
304,715
917,165
0
0
1,766,797
0
0
0
0
0
0
2,646,339
0
0
0
3,311,261
Report Resolution
Federal Share
to be Recovered /
Sustained
Efficiency
INEL
UNSP
UNUR
SUST
INEL
UNSP
UNUR
SUST
INEL
UNSP
UNUR
SUST
INEL
UNSP
UNUR
SUST
INEL
UNSP
UNUR
SUST
INEL
UNSP
UNUR
SUST
469,489
0
0
0
264,500
564,049
0
0
304,715
917,165
0
0
1,766,797
0
0
0
0
0
0
672,643
0
0
0
3,311,261
Resolution of Significant Reports
Repoer Number / Grantee /
Report Date Contractor
E2CW7-09-0192
1300053
REPORT DATE
3/28/91
E2CWMO-09-0052
2200030
REPORT DATE
9/15/92
E2CWNO-09-0071
2300085
REPORT DATE
9/29/92
S2BWN1 -09-0095
2300090
REPORT DATE
9/30/92
P2CW7-10-0104
2100303
REPORT DATE
3/31/92

SUN VALLEY
WATER & SAN
DIST NV

HAWAII COUNTY
HI


HONOLULU CITY &
COUNTY, HI


SAN FRANCISCO
C&C SEWWTP CA


OLYMPIA WA




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

4,665,840
0
1,760,811
0
5,218,260
0
0
0
1,292,855
0
4,516,290
0
5,425,295
0
0
0
778,712
226,892
0
0

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

296,105
0
1,760,811
0
5,218,260
0
0
0
664,383
0
695,902
0
5,425,295
0
0
0
720,332
0
0
0

INEL = INELIGIBLE COST
UNSP = UNSUPPORTED COST
UNUR = UNNECESSARY/UNREASONABLE COST
RCOM = RECOMMENDED EFFICIENCIES
E2BWN1 -04-0050
2300081
REPORT DATE
9/24/92
P2CWP9-05-0072
2400023
REPORT DATE
3/12/92
E3CLN1 -06-01 57
2300052
REPORT DATE
5/20/92
E2AWP2-09-0243
2400076
REPORT DATE
9/24/92
FT LAUDERDALE
FL


WASHTENAW CO
DPW (ANN ARBOR)
Ml

LUST
COOPERATIVE
AGREEMENTS OK

SAN DIEGO CA



INEL
UNSP
UNUR
RCOM
INEL
UNSP
UNUR
RCOM
INEL
UNSP
UNUR
RCOM
INEL
UNSP
UNUR
RCOM
1,475,976
55,610
0
0
449,642
0
0
0
501,190
7,891
0
0
0
0
0
5,500,000
INEL
UNSP
UNUR
SUST
INEL
UNSP
UNUR
SUST
INEL
UNSP
UNUR
SUST
INEL
UNSP
UNUR
SUST
1 ,451 ,688
55,610
0
1,507,298
449,642
0
0
0
408,632
0
0
0
0
0
0
5,500,000
SUST = RECOMMENDED EFFICIENCIES SUSTAINED


























































































OCTOBER 1, 1992 THROUGH MARCH 31, 1993
25

-------
   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
OIG personnel security
investigations. The  Office of
Investigations tracks
investigations in the
following categories:
preliminary inquiries and
investigations, joint
investigations with other
agencies, and OIG
background investigations.
Summary Of
Investigative
Activities
Pending Investigations as of
September 30, 1992      205

New Investigations Opened
This Period              125

Investigations Closed This
Period                  137

Pending Investigations as of
March 31, 1993          193
Prosecutive and
Administrative
Actions

In this period, investigative
efforts resulted in 6 convictions
and 6* indictments. Fines and
recoveries, including those
associated with civil actions,
amounted to $13.2 million.
Eighteen administrative
actions** were taken as a
result of investigations:

Reprimands               6
Resignations/Removals      5
Suspensions               3
Other                    4

Total                   ?8

* Does not include indictments
obtained in cases in which we
provided investigative
assistance.

** Does not include
suspensions and debarments
resulting from Office of
Investigations activities or
actions resulting from reviews
of personnel security
investigations.
                                      Profiles Olf Pending Investigations By Type
                                                     (Total-193)
                     General EPA Programs
                          Total Cases-138
                                             Superfund And LUST
                                                 Total Cases-55
        Other-14
                                                          Other-1
26
                                                                                       OFFICE OF INSPECTOR GENERAL

-------
 Description of
 Selected
 Prosecutive and
 Administrative
 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, 1992.
 $11.6 Million
 Settlement Reached
 in Pennsylvania
 Superfund Case

 Chemical Waste Management
 (CWM), Inc., of Oak Brook,
 Illinois, reached an $11.6
 million settlement with the
 Government in October 1992,
 regarding the Lackawanna
 Refuse Superfund Site in
 Lackawanna County,
 Pennsylvania.  The $11.6
 million in fines, penalties,
 restitution, and costs
 associated with the criminal
 and civil settlement to be paid
 by the company makes  this
 the largest environmental
 crimes case ever prosecuted
 under the Superfund law.
   The Lackawanna site was
 originally used for disposal of
 municipal and  commercial
 refuse.  In the  late 1970's,
 thousands of 55-gallon drums
 containing hazardous
 substances such as solvents,
 paint thinners,  sludge, organic
 acids and toxic metals were
 illegally dumped at the site.  In
 June 1987, EPA, through the
 Army Corps of Engineers,
 awarded CWM a contract to
 clean up the site, specifying
 that all drums containing over
 one inch of material were to be
 carefully removed from the
 excavation area and placed in
 85 gallon overpacks for
 shipment to qualifying landfill
 facilities.
   CWM pleaded guilty to six
 felony violations of the
 Superfund law. CWM
 employees knowingly and
 intentionally crushed numerous
 drums containing over one
 inch of material in order to
 speed up the project. The
 hazardous substances
 contained in the drums leaked
 out into the environment and
 contributed to the
 contamination of the site.
 CWM failed to  report this
 activity, in violation of the
 Superfund law.
   In addition to the  monetary
settlement, CWM agreed to
terminate and/or discipline  six
CWM employees; continue its
newly instituted Contracts
Compliance Program and
 Environmental Compliance
 Program; subject itself to EPA
 audits for 3 years to ensure
 compliance with the
 agreement; and be subject to
 debarment if it fails to strictly
 adhere to its compliance
 program.
   The Defense Criminal
 Investigative Service, U.S.
 Army Criminal Investigation
 Command, and Defense
 Contract Audit Agency
 assisted EPA OIG in
 developing this case.

 Superfund Contract
 Laboratory Program
 Investigations

 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.

 l-Chem  Research and Its
 President Sentenced in
 Contaminated Container
 Case

 l-Chem Research, Inc., and
 Anita C. Rudd, its president,
chief executive officer, and a
principal owner, were
sentenced  in February 1993
after pleading  guilty to making
a false claim to EPA for
$35,000. Also, in October
1992, Marvin W. Rudd, a co-
owner and former president of
the California research
 company, pleaded guilty to two
 counts of making false claims
 to the Agency, totaling
 approximately $50,000.
   The sentence against Anita
 Rudd was suspended and she
 was placed on three years
 probation. The conditions of
 her probation require that she
 pay a $50,000 fine and a $50
 assessment.  The sentence
 against l-Chem was
 suspended, the company was
 placed on three years
 probation, and is required to
 pay a $100,000 fine and a
 $100 assessment.  These
 fines  are in addition to the
 $435,000 that defendants
 Anita Rudd, Marvin Rudd, and
 l-Chem previously agreed to
 pay the Department of Justice
 as part of a settlement of civil
 claims related to the case,  I-
 Chem and Anita Rudd had
 also agreed to an 18  month
 voluntary exclusion from
 participating in Government
 contracts or grants.
   From June  1983 until
 December 1987, the company,
 as EPA's sole supplier under
 contract, was  required to
 provide clean, contaminant-
 free sample containers for
 laboratory use, and to perform
 quality control testing on the
 containers. The sample
 containers were used to collect
 site samples for laboratory
 analysis  under EPA's Contract
 Laboratory Program.
  The investigation found that
 the company  had defrauded
 EPA by intentionally failing to
 perform the required testing
 and by creating records to
 disguise that fact.

 EIRA Inc. of Louisiana
 Pleads Guilty to Fraud

 Environmental Industrial
 Research Associates, Inc.
 (EIRA), a Louisiana
 corporation, was sentenced in
 March 1993 after pleading
 guilty to conspiracy to defraud
the Government. EIRA was
fined $174,000,  which was
 suspended, and placed on 5
years probation.  As a
condition of its suspended fine
 EIRA must implement a 2-year
community service program
consisting of at least 24
seminars in Louisiana,
OCTOBER 1, 1992 THROUGH MARCH 31, 1993
                                                                                                                     27

-------
Mississippi, and North Carolina
to increase industry and public
awareness of problems
associated with the quality of
analytical data produced by
laboratories. Also, EIRA must
prepare and publish a
comprehensive article to assist
the national laboratory
community in implementing a
suitable data integrity and self-
audit program.

In conjunction with the criminal
sentence,  EIRA also entered
into a compliance agreement
with EPA (see page 29).

   EIRA and three of its
employees pleaded guilty to
making false claims to EPA for
analyses of soil and water
samples taken from Superfund
sites.  EPA requires the use of
properly calibrated Gas
Chromatograph/Mass
Spectrometer (GC/MS)
instruments in making the
analyses.  EIRA,  through the
employees who pleaded guilty,
manually overrode the GC/MS
instruments' calibration
readings to falsely reflect that
the instruments were properly
calibrated. By doing so, EIRA
avoided the time-consuming
process of recalibration.
However, the analytical results
that EIRA then reported to
EPA, and for which EIRA  billed
the Agency, were
compromised, resulting  in
EIRA's submission of false
data and false claims.

Two New  York Lab
Supervisors Sentenced

Two supervisors at Nanco
Environmental Services, Inc.,
of Dutchess County, New
York, have been sentenced for
submitting false test reports to
EPA on analyses of soil and
water samples. The scheme
involved setting back the dates
on the computer data systems
attached to Gas
Chromatograph/Mass
Spectrometer instruments to
make it  appear that laboratory
analyses were performed
within EPA-approved  holding
times when, in fact, they were
not. Sohail Jahani, who
pleaded guilty in May 1992 to
conspiracy to defraud EPA,
was sentenced to 3 years
probation, ordered to perform
100 hours of community
service, and fined $5,000.
James Daly, another
supervisor at Nanco, who
pleaded guilty  in October 1991
to causing false submissions
to be  made to  EPA, received  1
year of probation and was
fined $50.
Other Cases

False Credentials Result In
Jail Time

After pleading guilty to
submitting false statements to
EPA, Christopher Tate, of
Altoona, Pennsylvania, an
owner of the Safety
Management Institute (SMI),
was sentenced in January
1993 to 2 years probation and
fined $3,000. Tate was also
sentenced to jail for ten
consecutive weekends.
  Tate submitted two resume
packages to EPA, Region 3, in
which he falsely claimed both
to be a Certified  Industrial
Hygienist and to  hold a
Bachelor of Science degree in
chemistry.  The falsified
information was submitted to
the Agency so that SMI could
be approved as a training
center under the Asbestos
Abatement Training Program.

Contractor Employee
Charged with Telephone
Abuse

An employee of a contractor at
Region 5 in Chicago has been
charged with making over
$3,600 in personal overseas
telephone calls at Government
expense. The case was
developed by the EPA OIG in
cooperation with  the  Federal
Protective Service Division of
the General Services
Administration and the U.S.
Immigration and  Naturalization
Service.

Office Director at
Headquarters Indicted

An EPA Headquarters office
director was indicted in March
1993 and charged with
conspiracy, bank fraud, filing
false income tax returns,
money laundering, and making
false statements to Federal
agents.
  The EPA OIG investigation
grew out of an OIG Hotline
complaint on an unrelated
matter.  Information developed
during the investigation of this
complaint led to evidence of
possible criminal violations.
  This case was investigated
jointly by agents of the Internal
Revenue Service, the Federal
Bureau of Investigation, the
Defense Criminal Investigative
Service, Department of
Defense Inspector General,
the United States Postal
Inspection Service, and the
EPA OIG.

Headquarters  Employee
Guilty in Jury Duty Scam

In November 1992, an EPA
Headquarters employee
pleaded guilty of submitting
false statements and theft of
government property. In
January 1993, the employee
was sentenced to 2 years
probation. As a special
condition to the probation, she
was ordered to serve 3 months
in jail and pay EPA restitution
of $5,960.
  The investigation by the OIG
determined that, in late 1991,
the employee received a
notice for jury duty for 2
weeks. The employee altered
the form so that it appeared
that she would  be needed for
6 months of jury service in
1992. The Agency excused
the employee from work for 6
months with pay, when,  in fact,
the employee actually served
on a petit jury for only seven
days and took four months off
from work, receiving nearly
$6,000 in salary during that
time.  The woman's
employment at EPA has been
terminated.

Chicago Employee
Convicted in Time Card
Fraud Case

An  EPA Region 5 employee in
Chicago resigned in March
1993, after her August 1992
conviction in Cook County
Circuit Court on a
misdemeanor theft charge, in
addition to her admission to
falsifying her time card.
  The employee, a division
secretary responsible for
obtaining cash travel advances
and airline tickets for official
travel by division staff, stole
portions of their cash
advances. The secretary
altered the office copy of the
travel authorizations to reflect
that less than the full advance
was approved and disbursed
by the Region 5 imprest
cashier.  The employee also
falsified one of her time cards
by deleting 20 hours charged
to annual leave.
  As a result of the guilty plea
in the county court, the
employee was sentenced to 1
year of court supervision.

Contract Specialist Loses
Job

In October 1992, a contract
specialist was terminated from
employment with EPA based
on her falsification of
information on two SF-171's,
Application for Federal
Employment, submitted to the
Agency.
  The investigation determined
that the employee failed to
disclose a prior felony
conviction for defrauding an
insurance company in Florida.
In addition to the undisclosed
criminal record, there was an
outstanding warrant for her
arrest issued after she failed to
appear for sentencing following
the felony conviction.
28

-------
 Civil and
 Administrative
 Actions to
 Recover EPA
 Funds
 Investigations and audits
 conducted by the Office of
 Inspector General provide the
 basis for civil and
 administrative actions to
 recover funds fraudulently
 obtained from EPA.  Through
 the Inspector General Division
 (IGD) of the Office of General
 Counsel, the OIG uses a
 variety of tools to obtain
 restitution. These include
 cooperative efforts with the
 Department of Justice in filing
 civil suits under the False
 Claims Act, the Program Fraud
 Civil Remedies Act, and other
 authorities; working with
 grantees using their own civil
 litigation authorities; invoking
 the restitution provisions of the
 Victim and Witness Protection
 Act during criminal sentencing;
 using the Agency's authority to
 administratively offset future
 payments and to collect debts;
 and negotiating voluntary
 settlements providing for
 restitution in the context of
 suspension and debarment
 actions. Civil and
 administrative actions to
 recover funds usually extend
 over several semiannual
 reporting periods.
Government's allegations that
ChemWest had engaged in
fraudulent data manipulation.

Environmental Industrial
Research Associates

Working with EPA's
Suspension and Debarment
Division, the IGD negotiated a
compliance agreement with
Environmental Industrial
Research Associates, Inc.
(EIRA) as part of the global
resolution of a laboratory fraud
case. Under the compliance
agreement EIRA agreed to
repay EPA approximately
$160,000, which includes
approximately $56,000 for the
Office of Inspector General's
costs of investigating EIRA's
fraud. Under the compliance
agreement EIRA is obligated
to make full restitution to EPA,
enforce its data integrity
program, provide ethics
training to all laboratory
employees involved in data
analysis, employ a full-time
compliance officer, and
establish a hotline to receive
anonymous reports of
violations.  EIRA's promise to
make restitution of
approximately $160,000 has
been made part of EIRA's
criminal sentence.
Two Testing  Firms
Agree to Pay
Government

ChemWest Analytical
Laboratories

The IGD, working  with EPA's
Office of Regional Counsel for
Region 9 and the United
States Attorney's Office for the
Eastern District of California,
finalized a civil settlement
agreement with ChemWest
Analytical Laboratories,  Inc.
(ChemWest).  Under the
agreement ChemWest paid
$500,000 to resolve the
OCTOBER 1, 1992 THROUGH MARCH 31, 1993
                                                                                                                     29

-------
     Section 4-Fraud Prevention And  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.  During this semiannual
reporting period, we reviewed
one legislative and 68
regulatory items.  The most
significant items  reviewed are
summarized below.
                                Proposed Regulatory
                                Flexibility
                                Amendments Act of
                                1993(H.R. 830)

                                We reviewed and commented
                                on the Small Business
                                Administration's (SBA) draft
                                position on H.R. 830, the
                                proposed  Regulatory Flexibility
                                Amendments Act of  1993.
                                  The Regulatory  Flexibility
                                Act of 1980 (Act) requires
                                Federal agencies to  consider
                                the economic impact their
                                regulations will have on small
                                entities. Under the Act's
                                provisions, agencies are
                                required to conduct a
                                regulatory flexibility analysis if
                                a rule will  have a significant
                                economic  impact on a
                                substantial number of small
                                entities so that alternatives can
                                be considered to accomplish
                                the objectives of the applicable
                                statutes while minimizing the
                                cost to small businesses. SBA
                                maintains  that, although the
                                Act has helped to  assure that
                                the effect  of new rulemakings
                                on small business is properly
                                considered, often the burdens
                                on small entities have either
                                been underestimated or
                                ignored since there is no
                                enforcement mechanism in the
                                Act.
  To address this concern,
H.R. 830 would require
agencies to work more closely
with the SBA's Chief Counsel
for Advocacy, who is
responsible for monitoring
compliance with the Act, by
requiring agencies to transmit
a copy of any proposed rule
30 days prior to publication in
the Federal Register, along
with a copy of the initial
regulatory flexibility analysis for
the rule or  an explanation of a
determination that such an
analysis is  not required. If the
Chief Counsel transmits to the
agency a written statement of
opposition  to the proposed rule
within 15 days, the agency
must publish that statement,
together with  its response, in
the Federal Register at the
same time  the notice of
proposed rulemaking is
published.  In our  opinion, this
procedure  would likely lead to
increased litigation, since it
would provide potential
litigants information to block or
delay proposed rules.
Accordingly, we recommended
that the proposed  legislation
contain language specifying a
mechanism for resolving
interagency differences, if
possible, prior to a rule's
publication.
  In addition, the SBA's draft
position referred to the lack of
an "enforcement mechanism"
for addressing the concerns of
small businesses under the
current legislation.  We
recommended that SBA's
comments  specifically describe
how the proposed legislation
resolves this concern.
Proposed
Amendment to EPA
Order 1900.1,  Use of
Contractor Services

The purpose of EPA Order
1900.1 is to assist EPA
personnel in avoiding personal
services arrangements in
contract management
activities. Unless specifically
allowed by the Congress, it is
illegal for the Government to
contract out for the services of
people who in the course of
their work are treated as if
they were Government
employees.  EPA Order
1900.1 explains the nature of a
personal services contract and
the duties and responsibilities
of EPA employees to ensure
that such relationships are
avoided.
  The proposed amendment
includes specific guideJines for
communications between
Agency and contractor
employees and requirements
concerning space and
equipment for contractors
working in EPA facilities.  We
supported the intent of the
amendment, but were
concerned that distribution of
the guidance would  be limited
to EPA employees only.
Accordingly, we recommended
that guidance concerning
contractor employees be
distributed to the contractor
community, since these
requirements will  clearly affect
them  in the everyday
performance of their duties.

PCIE Whistleblower
Guide

The PCIE's Investigative
Standards and  Training
Subcommittee's Hotline
Working Group developed a
proposed guide to processing
whistleblower reprisal
allegations. The document
outlined current legislation
pertaining to whistleblowers,
the purpose of  such legislation,
and how it should be
implemented. It is essentially
an implementing guide for the
development of draft standard
operating procedures for
agency hotlines.
30
                                                                                           OFFICE OF INSPECTOR GENERAl

-------
   The whistleblower paper
 offered guidelines for the
 handling of allegations of
 reprisal, and indicated that the
 processing of such complaints
 is governed by the employee
 status of each complainant.
 While the paper provided
 information on the statutes and
 implementing agency
 guidelines that are in force to
 protect whistleblowers in
 various employment capacities
 (non-federal employees,
 appropriated and non-
 appropriated fund employees,
 military personnel, and DOD
 contractor employees) and the
 procedures to be taken in each
 instance, it was still essentially
 general in nature.
   We generally agreed with
 the paper's approach to
 handling hotline calls, with the
 following reservations. We
 were concerned about an
 apparent discrepancy between
 language in the paper which
 stated that  non-Federal
 employees have  no statutory
 protection  against reprisals
 and an attachment that lists
 several statutes designed to
 protect public or private
 employees from reprisal. We
 recommended a correction or
 clarification of this issue. In
 addition, the procedures
 outlined for processing
 referrals of appropriated fund
 employees were somewhat
 unclear. We suggested
 modifying the language and
 revising the format of that
 section to avoid confusion
 among those handling such
 calls.
 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 Office of
 Grants and Debarment (OGD)
 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
 OGD to further educate and
 inform State and local
 governments and
 environmental interest groups
 about the effective use of
 suspensions and debarments.
   During this period, cases
 with direct OIG involvement
 led to 12 suspensions, 19
 debarments and 6 compliance
 agreements, a total of 37
 actions.

The following are examples:

 • At the request of EPA's
Office of General Counsel
 (OGC), Inspector General
 Divisjon (IGD), EPA
suspended Caribe General
Constructors, Inc. (Caribe);
Osvaldo J. Ortiz, its president;
and Jose M.  Bonnin, its vice
president for operations.  An
OIG investigation indicated
 that Caribe had submitted
 false claims to EPA in
 connection with the
 construction of an  EPA-funded
 sanitary sewer system in
 Ponce, Puerto Rico.

 • Stevens Analytical
 Laboratories, Inc. (SAL) and a
 related company, Stevens
 Environmental Technology,
 Inc. (SET), under an
 agreement negotiated by
 OGC's IGD, voluntarily
 consented to debarment from
 participation in Federal
 assistance, loan, and benefit
 programs and activities for 3
 years.  SAL and SET had
 previously been suspended,
 based on an  indictment of SAL
 and its president, Alan
 Stevens, for providing false
 and fictitious  analyses of
 drinking water and waste water
 samples.  Further,  based on
 Alan Stevens' conviction for
 mail fraud, EPA proposed to
 debar Mr. Stevens, who had
 previously been suspended by
 EPA.

 • Robert Q. Bradley was
 debarred by EPA for 3 years
 following his conviction for
 making false  statements. His
 2 year prison sentence was
 suspended, but he was fined
 $1,000. Mr. Bradley made
 false certifications on a
 contract laboratory program
 data package which indicated
 that water samples for EPA
 were analyzed within a
 prescribed holding  time.  Some
 of the samples whose holding
 times had expired had been
 analyzed on testing
 instruments that had been
 backdated to  make it appear
 that the samples had been
 analyzed within the prescribed
 holding time.

 • Pipex Inc., and C. Square
 Inc., of Kansas, along with
 James and Elizabeth
 O'Connor, were debarred by
 EPA for 3 years. The
 O'Connors formed  Pipex to
 sell materials used in the
construction of municipal water
systems and waste water
treatment  plants. At the time
the O'Connors formed Pipex,
James O'Connor was under
OCTOBER 1, 1992 THROUGH MARCH 31, 1993
                                                                                        31

-------
contract to sell water works
materials exclusively for
Midwest Pipe Fabrications Inc.
O'Connor bid against Midwest
on EPA-funded projects,  using
bribes and confidential
information he obtained as a
salesman for Midwest. A civil
judgment was entered against
Pipex Inc. and the O'Connors
for violation of the Racketeer
Influenced and Corrupt
Organization Act.  As a result,
James O'Connor was held
liable for damages of
$745,500, and the O'Connors
and Pipex were held jointly
and severally liable for
$325,000.

• EPA debarred Ivan Clay
Kimbrough for 3 years. Mr.
Kimbrough, a contract
computer operator assigned to
the Information Management
Branch, Office of Policy and
Management, EPA Region 4,
pleaded guilty of violating the
Georgia Racketeer Influenced
and Corrupt Organization Act
and was sentenced to 5 years
in jail.

• EPA debarred Carol H.
Byington, Executive Vice
President and Chief Operating
Officer of MetaTrace Inc., for  7
years.  Initially MetaTrace,
located in Earth City, Missouri,
reported a limited falsification
of test data by first line
supervisors and a  small
number of technicians working
in the gas chromatograph
laboratory.  Laboratory
personnel had falsified and
fraudulently submitted
computer-generated test  data
on pesticides/polychlorinated
biphenyls to  EPA.  Also,
pesticides analyses for certain
samples submitted to EPA
were not performed in
compliance with the protocols
required by EPA contracts.
Evidence showed the company
normally falsified test data, and
Ms. Byington instructed
supervisors on falsifying test
data and records.  She was
convicted of making false
statements and
representations.
Congressional
Testimony  by the
Inspector General
On March 29, 1993, the IG
testified before the
Subcommittee on Legislation
and National Security and the
Subcommittee on
Environment, Energy and
Natural Resources, House
Committee on Government
Operations, on elevating EPA
to cabinet level status. While
fully supporting this initiative,
the IG discussed significant
problems confronting EPA in
its management of extramural
resources (contracts,
cooperative agreements, and
interagency agreements),
information resources
management, financial
management, and internal
control systems. The IG
stated that these areas of
concern were not in need of
new legislation as a remedy.
In his view, the Chief Financial
Officers Act, the Federal
Managers' Financial Integrity
Act, the Federal Grant and
Cooperative Agreement Act,
the Competition in Contracting
Act, Office of Management and
Budget circulars, and EPA
regulations provide sufficient
legislative authorities and
administrative guidance that a
strong EPA management team
can use successfully to
address the problems.
OIG Management
Initiatives
 This section discusses OIG
 initiatives to promote
 management and financial
 improvements and integrity in
 EPA's operations. During this
 semiannual period, we are
 highlighting OIG efforts to
 conduct financial audits of EPA
 contracts.

 Expansion of Audit Program
 of Contractors

 The OIG continued to
 implement its long-term
 program for conducting
 financial audits of EPA
 contracts during  this
 semiannual period.  Two  new
 branch offices were
 established while the OIG
 continued to conduct
 significant financial audits of
 the 14 contractors over which
 it has cognizance and work
 with DCAA  to reduce audit
 backlog. The OIG also worked
with the Office of Management
 and Budget (OMB), EPA's
 Office of Acquisition
 Management (OAM), and other
 Federal agencies to complete
the OMB SWAT Team  effort
 on civilian agency contracting,
 implement the
 recommendations of the EPA
 SWAT Team, and improve the
 Federal Acquisition Regulation
which governs Government
contracting.
  The OIG  established branch
offices in the Cincinnati, OH,
 and Washington, DC, areas to
 perform financial audits of EPA
contractors. Both offices  will
 have OIG staff on-site at  major
 EPA contractor facilities.  The
 Cincinnati, OH, office will  also
 include performance auditors.
 Close coordination between
financial and performance
 auditors will enhance reviews
of EPA operations by helping
 ensure that contracting
 activities are efficiently  covered
 in those audits.  The new
offices will also facilitate close
coordination between auditors
 and investigators and thereby
 enhance the efficiency  of
reviews of potentially
fraudulent activities.
  The OMB SWAT Team
report was completed with the
participation of the OIG in the
project management group.
The EPA SWAT Team,
composed of representatives
of EPA OAM and  the OIG,
developed 38 of the 115
Government-wide and 41  of a
total 136 Agency-specific
recommendations presented in
the OMB SWAT Team report.
The Government-wide
recommended improvements
include changes to the Federal
cost principles governing
employee morale  and
entertainment costs, insurance
costs and contingent fees.
The corrective actions
identified will significantly
improve Federal cost principles
and EPA cost review
procedures.  The OIG assisted
EPA OAM in the development
and implementation of its
action plan to address the
issues identified in the EPA
SWAT Team report. OIG
involvement in Government
contracting has also included
commenting on contemplated
changes to the  Federal
Acquisition Regulation
concerning service contracting
and Cost Accounting
Standards coverage
thresholds.

OIG Training Catalog

To  help OIG supervisors
identify and select appropriate
development opportunities for
members of  their staffs, we
have issued the FY 1993
edition of the OIG training
catalog. This catalog
describes national CPA
training sources, lists video
tapes available, and provides
schedules of over 97 courses
that are included in the OIG
career profiles for auditors,
investigators, and  support
staff.  For the first time, the
catalog was provided to the
field offices on a diskette.

Total Quality Management

The Office of Inspector
General has adopted the
management philosophy
known as Total Quality
32
                                                            OFFICE OF INSPECTOR GENERAL

-------
 Management (TQM). A
 Quality Council consisting of
 the Deputy Inspector General,
 the three Assistant Inspectors
 General, and the Quality
 Coordinator directs the TQM
 process within the OIG. Also,
 the Deputy Inspector General
 participates as a member of
 EPA's Deputy Leadership
 Team.  Quality Action Teams
 (QAT) have  been established
 within OIG to improve training,
 recruiting, data gathering and
 sharing, and processing of
 interagency agreements.
 During this reporting period, a
 new QAT was created to
 examine the distribution of
 administrative and secretarial
 assignments.  In addition to
 the teams within OIG, OIG
 employees are members of
 Headquarters and Regional
 Quality Action Teams seeking
 to improve processes such as
 performance management,
 employees recognition and
 awards, audit followup,
 procurement, and
 implementation of the Chief
 Financial Officers Act.
   During this reporting  period
 OIG's TQM facilitators
 provided 1-day awareness
 training in Dallas, Texas, for
 10 employees, and 2-day TQM
 "tools" training to 33 OIG
 members of  Quality Action
 Teams.
 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
 12301  in March 1981 to attack
 fraud and waste, and to
 improve management in the
 Federal Government. The
 PCIE was re-established by
 Executive Order 12805 on May
 11, 1992. 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
 for Management, Office of
 Management and Budget
 (OMB), and includes all civilian
 Presidentially appointed
 Inspectors General and other
 key Federal officials.
   Inspector General John C.
 Martin chairs the Internal
 Operations  Committee of the
 PCIE.  During this six month
 period, the Committee
 completed the transfer of
 responsibility for distribution of
 PCIE publications to the
 National Technical Information
 Service (NTIS) of the
 Department of Commerce.
   NTIS is the largest single
 source for public access to
federally-produced information.
 It provides a centralized
 information  management
system that can store,
process, and distribute
publications. The cost of each
publication ordered from NTIS
is paid for by the requestor.
An advantage of using NTIS to
distribute PCIE publications is
that they will be made
permanently available and
become part of the NTIS
computerized  bibliographic
database.  NTIS believes that
PCIE publications may be of
interest to a wide untapped
audience.
  The second symposium for
Assistant Inspectors General
for Administration was held in
November 1992.  The topic
was "Contracting for Audit
Support." This symposium,
conducted  under the auspices
of the Internal Operations
Committee, provides an
opportunity to exchange ideas,
problems, and solutions
regarding many administrative
issues of common interest.
 Committee on
 Integrity  and
 Management
 Improvement
 The Committee on Integrity
 and Management Improvement
 (CIMI) was established in 1984
 by EPA Order 1130.1. The
 purpose of CIMI is to
 coordinate the Agency's effort
 to minimize the opportunities
 for fraud, waste, and
 mismanagement in EPA
 programs and to advise the
 Administrator on policies  to
 improve the efficiency and
 effectiveness  of EPA programs
 and activities.  The Committee
 is composed of senior EPA
 program and  regional officials
 and is chaired by the Inspector
 General.

 A Brief Guide for New
 Executives

 As Federal employees,
 executives represent the
 Government to many people
 and their actions must always
 be beyond reproach.  To  guide
 them in this effort, a significant
 number of rules have been
 developed. To actively
 promote the highest degree of
 integrity in EPA, the CIMI
 developed a booklet designed
 to briefly cover many of the
 main areas on which
 executives need to focus  their
 attention.  The booklet
 discusses standards of
 conduct, financial disclosure
 requirements, prohibited use of
 personnel, employment
 principles, contract
 management, the procurement
 of products and services,  and
travel policies and regulations.
The booklet highlights the
 need for executives to comply
with the rules  to ensure that
Government business is
conducted properly, and that
the high ethical standards of
public service are met.
OCTOBER 1, 1992 THROUGH MARCH 31, 1993
                                                                                    33

-------
Hotline Activities
During this period, the Hotline
was part of President Clinton's
efforts to "reinvent" the
Government by serving as a
collection point for the ideas of
American citizens.  This
initiative requests the public to
directly participate by calling
IG Hotlines to make
suggestions for improving the
Government and saving
money. Attended operating
hours were expanded to serve
the needs of the public.
  During this period, the
Hotline referred 4,587
telephone callers to the
appropriate EPA program
office, State agency, or other
Federal agency for assistance.
The OIG Hotline opened 36
new cases and  completed and
closed 31 cases. Of the cases
closed, 8 resulted in
environmental, prosecutive, or
administrative corrective
action, while 23 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 following are
examples of  corrective action
taken as  a result of information
provided  to the OIG Hotline.

• A complainant alleged that
an inspector for a State
agency used undue influence
to secure a subcontract on an
EPA-funded project for a
company in which the
inspector had a financial
interest.  In addition, the
complainant stated that the
inspector falsified records so
that the company could obtain
funds in excess of the contract
price.  A  review of the
complaint disclosed violations
which resulted in the State
taking action against three
individuals. The inspector
resigned  rather than be
terminated, another State
official was suspended without
pay for 8 weeks, and a third
State official pleaded guilty to
a misdemeanor and was
suspended without pay for 12
weeks.

• A complainant alleged that
an employee inflated two local
travel claims and received
payment.  A review of the
complaint disclosed that the
employee  had submitted 2
fraudulent local travel claims.
As a result, the employee was
liable under the  Program
Fraud Civil Remedies Act and
was penalized 10 times the
amount of the fraud.

• A complainant alleged that a
company was fraudulently
violating vehicle emission and
safety laws.  A review of the
complaint disclosed that the
company had tampered with
emission control equipment.
As a result, a notice of
violation was issued to the
company for 11 tampering
violations and the company
was fined $16,500.
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 455
investigations.
34
                                                                                            OFFICE OF INSPECTOR GENERAL

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

 Office  of the Administrator

 E1SFF2-11-0019-3100095  SUPERFUND REPORT TO  CONGRESS
                       FISCAL 1991
                                 21 4/93
 E6AMG2-13-2052-3400035   PROCUREMENT ACTIVITIES BY OFFICIALS
                        IN THE OFFICE OF COMMUNICATION,
                        EDUCATION AND PUBLIC AFFAIRS      3/26/93

 E6AMG3-15-0071-3400042   OFFICE OF COMMUNICATION, EDUCATION
                        AND PUBLIC AFFAIRS COMPLIANCE
                        WITH FEDERAL COPYRIGHT LAWS
                        PROTECTING COMPUTER SOFTWARE      3/31/93

 Assistant Administrator  for Administration and Resources Management
 E1XMG3- 24-0024-3400024


 E1XMG3-03-0044-3400029

 E1MXG2-13-0046-3400033



 E1AHP2-20-0019-3400039

 P1SFF1-11-0027-3100058


 E1SKC1-06-0123-3100143


 P1SFFO-11-0041-3100114
ERA'S ENERGY MANAGEMENT AND
CONSERVATION PROGRAM

NEW RESTRICTIONS ON LOBBYING

EPA'S ADMINISTRATION OF THE
FEDERAL EMPLOYEES' COMPENSATION
ACT
                                 2/22/93

                                 3/ 8/93
                                 3/24/93

OIL SPILL  TRUST FUND FISCAL  1992   3/29/93
DECADE OF  SUPERFUND TRUST FUND
AUDITS

MANAGEMENT OF SUPERFUND SUPPORT
CONTRACTS

EPA'S SUPERFUND  INDIRECT COST
RATES FOR  FISCAL YEARS 1987
AND 1988
                                 M 4/93


                                 3/26/93
                                                         2/24/93

 Assistant Administrator  for Solid Waste and Emergency Response

 E1SJE2-02-0063-3100152   CAPPING REPORT ON  WHETHER EPA HAS
                        MAXIMIZED THE USE  OF POTENTIALLY
                        RESPONSIBLE PARTIES TO EFFECT
                        SUPERFUND SITE CLEANUPS            3/31/93

 Assistant Administrator  for Prevention. Pesticides and Toxic Substances
 E1EPF2-06-6131-3100097
 E1EPG2-05-6008-3400030
 E1EPP2-15-7001-3400043
PESTICIDES  IMPORTS PROGRAM
FOLLOWUP REVIEW                   2/10/93

EPA'S EMERGENCY SUSPENDED AND
CANCELED PESTICIDES PROGRAM
FOLLOWUP REVIEW                   3/26/93

EDP INTERNAL CONTROLS FOR SELECTED
PESTICIDE REVOLVING FUNDS
INFORMATION SYSTEMS               3/31/93
OCTOBER 1, 1992 THROUGH MARCH 31, 1993

-------
  Assignment
  Control Number
                        Title
                             Questioned Costs             _          .  .
                	  Recommended
Final Report     Ineligible    Unsupported    Unnecessary/     Efficiencies
Issued             Costs          Costs    Unreasonable   (Funds Be Put
                                                  Costs  To Better Use)
   Assistant Administrator for Research and Development

   E1XMG2-04-0102-3400007  CONTRACTING ACTIVITIES AT ORD'S
                          ATHENS LAB                        11/30/92

   E1BMG2-01-0372-3400006  CONTRACTING ACTIVITIES AT ORD'S
                          NARRAGANSETT LAB                  12/ 2/92

   E1JBG2-10-0080-3400019  CONTRACTING ACTIVITIES AT ORD'S
                          CORVALLIS LAB                      2/ 3/93

   E1JBP3-24-0019-3400025  CONTRACTING ACTIVITIES AT ORD'S
                          AEERL LAB                          2/26/93

   E1JBG2-09-0329-3400041  CONTRACTING ACTIVITIES AT ORD'S
                          EMSL LAB                           3/31/93

   E1JBF2-04-0300-3100156  ORD'S ATHENS LAB MANAGEMENT OF
                          EXTRAMURAL RESOURCES               3/31/93

   E6ABF2-11-0032-3100153  ORD'S USE OF COOPERATIVE RESEARCH
                          AND DEVELOPMENT AGREEMENTS         3/31/93

   Office of the Comptroller

   E1RMG2-11-0052-3400023  EPA 1992 FMFIA ACTIVITIES          2/19/93


   Office of Acquisition Management

   E1BMF2-11-0050-3100089  ADVISORY AND ASSISTANT CONTRACTS   1/29/93

   Regional Administrator. Region 3

   E1HWF1-03-0339-3100111  PROJECT CERTIFICATION PROGRAM OF
                          UASTEWATER TREATMENT PLANTS -
                          REGION 3                           2/23/93

   E6ASG3-03-0023-3400003  RCRA ENFORCEMENT ACTION           11/ 9/92

   Regional Administrator. Region 7

   E1RMF2-07-0134-3100H8  FMFIA ACTIVITIES - REGION 7        3/30/93

   Regional Administrator. Region 1

   E1HWF2-01-0100-3100035  ESTUARY PROGRAM - REGION 1        11/18/92

   E1HWG3-01-0023-3400034  ENFORCEMENT OF THE SURFACE         3/25/93
                          WATER TREATMENT RULE

   Regional Administrator. Region 2

   E1HWD3-02-0018-3400010  SAFE DRINKING WATER ACT
                          PRIMACY ACTIVITIES - REGION 2     12/22/92

   E1SJG2-02-5000-3400005  POST-SETTLEMENT FOLLOWUP          11/24/92

   Regional Administrator. Region 8

   E1SGG2-14-0016-3400018  UHITEWOOD CREEK RI/FS REVIEW       1/28/93

   Regional Administrator. Region 10
36
                                                                                                  OFFICE OF THE INSPECTOR GENERAL

-------
                                                                                 Questioned Costs
Assignment Title
Control Number

Final Report
Issued
Ineligible
Costs
Unsupported
Costs
Unnecessary/
Unreasonable
Costs
Efficiencies
(Funds Be Put
To Better Use)
E6EWN2-10-0020-3300012 REVIEW OF ALASKA'S SAFE DRINKING
WATER ACT ACTIVITIES
TOTAL INTERNAL & MANAGEMENT AUDITS
2. CONSTRUCTION GRANT AUDITS
D2CWL3-01 -01 16-3100140 CONCORD
S2CWLO-01 -0130-3100030 MWRA
S2CWLO-01 -0293-3100098 CONCORD
TOTAL OF REGION 01 = 3
D2CWL3-02-0030-3100021 NYCDEP - NORTH RIVER
D2CWL3-02-0031-3100022 NYCDEP - OAKWOOD BEACH
E2CWM1 -02-0018-3200002 PAWLING JT SEWER
E2CWMO-02-0275-3200003 FALLSBURG
E2CWM1- 02- 00 11 -3200009 ONONDAGA
E2CWMO-02-0300-3200010 TRI -MUNICIPAL SEWER
E2CWM1- 02- 001 0-320001 3 THOMPSON
E2CWM1 -02-0087-3200043 SAUGERTIES
E2AWT3-02-0016-3400002 EARLY WARNING-RED HOOK WPCP
P2EUQ1 -02-0104-31001 18 NYCDEP
TOTAL OF REGION 02 = 10
P2CWM9-03-0363-3200041 BALTIMORE MAYOR & CTY COUN
P2CWN9-03-0019-3300003 HOPEWELL CITY OF
P2CWNO-03-0412-3300005 ALLEGHENY CTY SANI DIST
P2CWNO-03-0104-3300013 PARKERSBURG CITY OF
P2CWN9-03-0256-3300026 BALTIMORE MAYOR & CTY COUN
TOTAL OF REGION 03 = 5
E2CWM2-04-0425-3200001 HUNTSVILLE
E2CWM2-04-0160-3200035 PRICHARD
E2CUM2-04-0417-3200036 GREENVILLE
E2CWM3-04-0054-3200037 ANDALUSIA
E2CUM2-04-0289-3200038 UNION SPRINGS UTIL. BOARD
E2CWM2-04-0320-3200039 02ARK UTILITIES BOARD
E2CWM3-04-0085-3200040 ANNISTON WWSB
E2CWM3-04-0033-3200042 CULLMAN
E2CWN1 -04-0417-3300006 GARNER
E2CWNO-04-0399-3300015 FT LAUDERDALE
P2CWNO-04-0392-3300011 ORLANDO
TOTAL OF REGION 04 = 11
E2CWL3-05-0121 -3100141 CLEVELAND NEORSD
P2CWP7-05-0079-3400038 FLINT
TOTAL OF REGION 05 = 2
E2CWN1 -06-0139-3300014 ST TAMMANY PARISH SEW DIS 7
E2CWN1 -06-0155-3300025 KENNER
P2CUN2-06-0088-3300024 TULSA
TOTAL OF REGION 06 = 3
P2CWN2-07-0183-3300027 DES MOINES
P2BWN2-07-0184-3300029 DES MOINES
TOTAL OF REGION 07 = 2
E2CUN1 -08-0095-3300009 LAPLATA COUNTY
E2CWN7-08-0139-3300028 CASPER
P2CWL8-08-0104-3100144 NORTHGLENN

=

NH
MA
MA

NY
NY
NY
NY
NY
NY
NY
NY
NY
NY

MD
VA
MD
WV
MD

AL
AL
AL
AL
AL
AL
AL
AL
NC
FL
FL

OH
MI

LA
LA
OK

IA
IA

CO
wr
CO
2/10/93
32

3/24/93
11/17/92
2/10/93

11/ 3/92
11/ 3/92
IV 2/92
11/17/92
12/17/92
12/22/92
1/28/93
3/29/93
10/28/92
3/ 2/93

3/25/93
IV 4/92
11/10/92
2/10/93
3/25/93

10/27/92
3/ 9/93
3/17/93
3/19/93
3/19/93
3/19/93
3/24/93
3/26/93
11/23/92
2/18/93
2/ 4/93

3/26/93
3/29/93

2/17/93
3/24/93
3/19/93

3/29/93
3/29/93

1/29/93
3/29/93
3/29/93




184,928
77,041
261,969
19,447
24,693
1,534,439
2,495,355
344,247
1,649,932
958,042
688,654

1,337,198
9,052,007
779,784
588,283
378,702
1,856,114
2,375,318
5,978,201
184,224
36,829
19,666
34,902
63,069
50,332
122,944
87,692
479,707
8,743
2,914,127
4,002,235
1,157,669
891,778
2,049,447
0
962,313
0
962,313
74,328
60,635
134,963
163,574
0
360,939




0
0
0
721,541
0
0
0
0
0
4,642
170,607

6,380,330
7,277,120
30,949
326,419
1,678,345
0
547,877
2,583,590
0
0
0
0
0
0
0
0
2,375,049
136,516
0
2,511,565
9,041,738
189,244
9,230,982
17,852
22,697
11,320
51,869
0
200,209
200,209
74,742
0
0




0
0
0
0
0
0
0
0
0
0
0

0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
367,177
0
367,177
27,664,633
11,640
27,676,273
133,350
0
175,026
308,376
0
0
0
0
4,810,578
0















89,663

89,663































            TOTAL OF  REGION 08
                                                                     524,513
74,742
4,810,578
OCTOBER 1, 1992 THROUGH MARCH 31, 1993
                               37

-------
                                                                                     Questioned Costs
Assignment Title
Control Number
E2CWMO-09-0291 -3200028 NIPOMO COMM SERV. DIST.
E2CWM1- 09- 0035 -3200034 TURLOCK. CITY OF
E2CWN1 -09-0034-3300017 BANNING, CITY OF
E2AWT2-09-0333-3400016 LAKEPORT SD MIDDLETOWN
E2AWT3-09-0082-3400037 SAN DIEGO, CITY OF
S2CUN9-09-0028-3300010 SACRAMENTO RCSD
S2CWNO-09-0242-3300022 SAUSLITO MAR IN CSD
S2CWN2-09-0046-3300023 WATSONVILLE, CITY OF
S2CWNO-09-0077-3300031 FRESNO, CITY OF
TOTAL OF REGION 09 = 9
P2CWN1-10-0030-3300021 ROSEBURG URBAN SD
P2CWNO- 10-0008-3300030 CHEHAL1S, CITY OF
TOTAL OF REGION 10 = 2
TOTAL CONSTRUCTION GRANT AUDITS

CA
CA
CA
CA
CA
CA
CA
CA
CA

OR
UA

=
Final Report
Issued
2/11/93
3/ 3/93
2/23/93
1/21/93
3/29/93
21 1/93
3/16/93
3/18/93
3/29/93

3/11/93
3/29/93

50
Ineligible
Costs
33.927
63,076
0


1,049,052
793,961
390,764
1,090,822
3,421,602
94,535
89,388
183,923
26,571,173
Unsupported
Costs
0
0
1,392,714


1,968,584
0
0
0
3,361,298
0
0
0
25,291,375
Unnecessary/
Unreasonable
Costs
3,640,207
0
0


0
6,017,921
19,993,784
325,076
29,976,988
0
0
0
63,139,392
nct*uniiiidiui;i
Efficiencies
(Funds Be Put
To Better Use



935,000
11,800,000




12,735,000



12,824,663
3. OTHER  GRANT AUDITS
C3HVK2-01 -0375-3500178
G3HVK2-01 -0364-3500026
G3HVK2-01 -0360-3500027
G3HVK2-01-0371-3500126
G3HVK2-01 -0370-3500138
G3HVK3-01 -0041 -3500186
G3HVK3-01-0051-3500187
G3HVK3-01 -0059-3500194
G3HVK3-01 -0056-3500226
G3HVK3-01 -0065-3500281
G3HVK3-01 -0066-3500325
G3HVK3-01 -0085-3500358
G3HVK3-01 -0086-3500412
G3HVK3- 01 -0084-3500460
G3HVK1 -01 -0123-3500461
G3HVK3-01 -0094-3500465
N3HVJ2-01 -0255-3500127
N3HVJ2-01 -0374-3500137
N3HVK2-01 -0330-3500180
N3HVK2-01 -0210-3500188
N3HUK3-01 -0047-3500192
N3HVK3-01-0070-3500326
N3HVK1 -01 -0213-3500456
N3HVK3-01 -0109-3500457
TOTAL OF
C3HVK3-02-0092-3500266
G3HVK3- 02 -002 1-3500041
G3HVK3-02-0026-3500042
G3HVK3-02-0027-3500043
G3HVK3-02-0023-3500051
G3HVK3-02-0081 -3500134
G3HVK3-02-0084-3500156
G3HVK3-02-0089-3500221
G3HVK3 - 02-0096- 3500255
G3HVK3-02-0097-3500259
G3HVK3-02-0104-3500260
G3HVK3-02-0106-3500268
G3HVK3-02-01 15-3500392
G3HVK3-02-0117-3500411
G3HVK3-02-0122-3500448
G3HVK3-02-0123-3500449
N3HVK2-02-0142-3500040
N3HVK3-02-0029-3500075
N3HVK2-02-0149-3500135
N3HVK2-02-0151 -3500136
N3HUK3-02-0017-3500157
N3HVK2-02-0154-3500256
N3HVK3-02-0045-3500270
N3HVK3- 02- 0091 -3500329
N3HVK3-02-01 12-3500330
PITTSFIELD MA
FAIRHAVEN MA
GARDNER MA
PRESQUE ISLE SEWER DISTRICT ME
ORLEANS, BREUSTER, EASTHAM MA
MATTAUAMKEAG TOWN OF ME
PLYMOUTH CT
CT HAZARDOUS WASTE MGT SER CT
RI CLEAN WATER PROTECTION AGRI
WALPOLE, TOWN OF MA
DOVER, CITY OF NH
WALLINGFORD, TOWN OF CT
MANCHESTER CITY OF NH
MASS WATER POLLUTION TRUST MA
DUDLEY MA
NORTH HAVEN, TOWN OF CT
MASSACHUSETTS, STATE MA
OCVERMONT, STATE OF VT
CHATHAM MA
AMERICAN METEOROLOGICAL SOC.MA
AMERICAN METEOROLOGICAL SOC MA
STRAFFORD REGIONAL PLAN.COMMNH
NORTHAMPTON MA
MAINE AUDUBON SOCIETY ME
REGION 01 = 24
BINGHAMTON NY
BERGEN COUNTY UA NJ
OXFORD NY
LOVE CANAL AREA REVITALIZATINY
MANASQUAN RIVER RSA NJ
SALEM NJ
PORT WASHINGTON WPCD NY
MIDDLETOWN NY
BOLIVAR NY
MIDDLESEX COUNTY UA NJ
DELAWARE RIVER BASIN COMM NJ
HUDSON REGIONAL HEALTH COMM NJ
FLORHAM PARK SA NJ
OCEAN COUNTY UA NJ
GOWANDA NY
GOWANDA NY
ROCKLAND COUNTY NY
ELIZABETH NJ
MONROE COUNTY NY
NEW HARTFORD NY
RENSSALAER POLYTECHNIC INST NY
OSWEGO NY
MIDDLESEX COUNTY NJ
WESTCHESTER COUNTY NY
PR DEPT OF AGRICULTURE PR
12/ 3/92
10/ 8/92
10/ 8/92
11/16/92
11/17/92
12/10/92
12/10/92
12/11/92
12/28/92
1/22/93
2/10/93
2/19/93
3/ 9/93
3/22/93
3/22/93
3/24/93
11/16/92
11/17/92
12/ 8/92
12/10/92
12/10/92
2/10/93
3/19/93
3/19/93

1/15/93
10/27/92
10/27/92
10/27/92
10/28/92
11/17/92
11/24/92
12/21/92
1/12/93
1/14/93
1/14/93
1/20/93
3/ 1/93
3/ 9/93
3/18/93
3/18/93
10/27/92
11/ 2/92
11/17/92
11/17/92
11/24/92
1/12/93
1/20/93
2/1 V93
2/11/93
                                                                              0
                                                                              0
                                                                              0
                                                                              0
                                                                              0
                                                                              0
                                                                              0
                                                                              0
                                                                              0
                                                                              0
                                                                              0
                                                                              0
                                                                              0
                                                                              0
                                                                              0
                                                                              0
                                                                              0
                                                                              0
                                                                              0
                                                                              0
                                                                              0
                                                                              0
                                                                              0
                                                                              0
                                                                              0
                                                                              0
                                                                              0
                                                                              0
                                                                              0
                                                                              0
                                                                            900
                                                                              0
                                                                              0
                                                                              0
                                                                              0
                                                                              0
                                                                              0
                                                                              0
                                                                              0
                                                                              0
                                                                              0
                                                                            956
                                                                              0
                                                                              0
                                                                              0
                                                                              0
                                                                              0
                                                                              0
                                                                              0
  38
0               0
0               0
0               0
0               0
0               0
0               0
0               0
0               0
0               0
0               0
0               0
0               0
0               0
0               0
0               0
0               0
0               0
0               0
0               0
0               0
0               0
0               0
0               0
0               0
0              0
0              0
0              0
0              0
0              0
0              0
0              0
0              0
0              0
0              0
0              0
0              0
0              0
0              0
0              0
0              0
0              0
0              0
0              0
0              0
0              0
0              0
0              0
0              0
0              0
   OFFICE OF THE INSPECTOR GENERAL

-------
                                                                                        Questioned Costs
   Assignment
   Control Number
                         Title
                                   Final Report
                                   Issued
                        Ineligible
                           Costs
                            Unsupported
                                   Costs
                        Unnecessary/
                        Unreasonable
                               Costs
Recommended
   Efficiencies
 (Funds Be Put
To Better Use)
 N3HVK2-02-0113-3500331
 N3HVK3-02-0088-3500447
 N3HVK3-02-0093-3500471
 N3HVK3-02-0090-3500472
 N3HVK3-02-0024-3500473
NEW YORK STATE
ST REGIS MOHAWK TRIBE
NORWICH
KINGSTON
NEW JERSEY
NY
NY
NY
NY
NJ
               TOTAL OF  REGION  02
            30
 C3HVK2-03-0475-3500029   BALTIMORE  COUNTY
 C3HVK3-03-0048-3500172   WASHINGTON COUNTY
 C3HVK3-03-0059-3500214   VA  RESOURCES AUTHORITY
 C3HVK2-03-0570-3500241   ANNE ARUNDEL COUNTY
 C3HVK3-03-0080-3500244   CARROLL  COUNTY
 C3HVK3-03-0118-3500304   HARFORD  COUNTY
 C3HVK3-03-0118-3500305   HARFORD  COUNTY
 C3HVK3-03-0084-3500480   SUSSEX COUNTY
 C3HVK3-03-0193-3500485   FAIRFAX  COUNTY
 E3FMP2-03-0364-3400017   OSDBU-NAMC
 G3HVK3-03-0047-3500084   SUSQUEHANNA RIVER BASIN
 G3HVK3-03-0060-3500168   PLUM BOROUGH SEWAR AUTH
 G3HVK3-03-0061-3500169   BOONSBORO
 G3HVK3-03-0063-3500170   HAMPTON  ROADS SANITATION
 G3HVK3-03-0058-3500171   RIDGELY
 G3HUK3-03-0064-3500213   ENVIRONMENTAL LAW INSTITUTE  DC
 G3HVK3-03-0079-3500243   CAMBRIDGE
 G3HVK3-03-0115-3500298   MARIANNA-WEST BETHLEHEM
 G3HVK3-03-0116-3500299   WASHINGTON SUBURBAN  SANITAT  MD
 G3HUK3-03-0117-3500306   RESOURCES  FOR THE FUTURE
 G3HVK3-03-0154-3500384   WYOMING  VALLEY SANITARY AUTHPA
 G3HVK3-03-0155-3500385   GARRETT  COUNTY
 G3HVK3-03-0156-3500386   PATTERSON  TOWNSHIP MA
 G3HUK3-03-0157-3500387   NATIONAL ASSOC.ATTORNEYS GENDC
 G3HUK2-03-0476-3500446   NAMC
 G3HUK3-03-0190-3500482   NAT ASSOC  ATTORNEYS  GENERAL  DC
 G3HVK3-03-0191-3500483   JACKSON  TOWNSHIP MUA
 G3HVK3-03-0192-3500484   MARIANNA-WEST BETHLEHEM
 G3HVK3-03-0195-3500489   BUCKINGHAM TOWNSHIP
 N3HUK3-03-0046-3500079   AMERICAN STATISTICAL ASSN
 N3HVK2-03-0536-3500085   PA COMMONWEALTH OF
 N3HVJ2-03-0535-3500086   VA COMMONWEALTH OF
 N3HUK2-03-0573-3500099   GEORGETOWN  UNIVERSITY
 N3HUK2-03-0532-3500100   GEORGETOWN  UNIVERSITY
 N3HUK2-03-0533-3500101   UNIVERSITY  OF MARYLAND
 N3HUK3-03-0049-3500212   NATIONAL COUNCIL OF  SENIORS  DC
 N3HVK2-03-0604-3500242   WEST VIRGINIA STATE
 N3HVK2-03-0091-3500307   DC DEPT OF  PUBLIC WORKS
 N3HVH2-03-0571-3500308   PHILADEPHIA CITY
 N3HVK3-03-0081-3500381   FREDERICK  CITY
 N3HVK3-03-0083-3500382   HENRICO  COUNTY
 N3HVK3-03-0123-3500383   ALLEGHENY  COUNTY
 N3HVK2-03-0528-3500477   BALTIMORE  CITY OF
 N3HVK2-03-0524-3500478   DC DEPT OF  PUBLIC WORKS
 N3HVK3-03-0121-3500479   METRO WASHINGTON COG
 N3HUK3-03-0194-3500488   ACADEMY OF  NATURAL SCIENCES  PA

              TOTAL OF REGION 03 =  46

 C3HVK2-04-0472-3500229   DEKALB COUNTY                GA
 C3HVJ3-04-0119-3500378   JEFFERSON  COUNTY             AL
 C3HVK3-04-0128-3500391   NASHVILLE/DAVIDSON COUNTY    TN
 C3HVK3-04-0152-3500470   GREENSBORO                   NC
 G3HVK2-04-0474-3500005   CLEVELAND UTILITIES          TN
 G3HVK2-04-0461-3500010  MUNFORD                      TN
 G3HVK2-04-0475-3500011  ATHENS UTILITIES BOARD-SEWERTN
 G3HVK3-04-0027-3500017   LAWRENCEBURG                 TN
 G3HVK2-04-0469-3500018  ATOKA                        TN
 G3HVK2-04-0468-3500020  MUNFORD                      TN
 G3HVK2-04-0467-3500021  MUNFORD                      TN
G3HVK3-04-0026-3500022  LAWRENCEBURG                TN
G3HVK2-04-0450-3500033  ATOKA                       TN
G3HVK2-04-0453-3500038  LAKE CITY                   TN
G3HVK2-04-0452-3500039  LAKE CITY                   TN
G3HVK2-04-0459-3500044  OLIVER  SPRINGS               TN
G3HVK2-04-0454-3500045  LAKE CITY                   TN
2/12/93
3/18/93
3/26/93
3/26/93
3/26/93
                                  12/29/92
                                   2/23/93
                                   3/  1/93
                                   3/25/93
                                  10/  5/92
                                  10/  7/92
                                  10/  7/92
                                  10/  7/92
                                  10/  7/92
                                  10/  7/92
                                  10/  7/92
                                  10/  7/92
                                  10/  9/92
                                  10/26/92
                                  10/26/92
                                  10/27/92
                                  10/27/92
    0
    0
    0
    0
    0

1,856
MD
MD
VA
MD
MD
MD
MD
DE
VA
DC
PA
PA
MD
VA
MD
DC
MD
PA
MD
:oc
1PA
MD
PA
JDC
DC
DC
PA
PA
PA
VA
PA
VA
DC
DC
MD
DC
WV
DC
PA
MD
VA
PA
MD
DC
DC
PA
10/ 7/92
11/30/92
12/17/92
12/31/92
12/31/92
1/28/93
1/28/93
3/30/93
3/30/93
1/25/93
11/ 4/92
11/24/92
11/24/92
11/24/92
11/25/92
12/17/92
12/31/92
1/28/93
1/28/93
1/28/93
2/26/93
2/26/93
2/26/93
2/26/93
3/17/93
3/30/93
3/30/93
3/30/93
3/30/93
11/ 3/92
11/ 4/92
11/ 4/92
1V 6/92
11/ 6/92
11/ 6/92
12/17/92
12/31/92
1/28/93
1/28/93
2/26/93
2/26/93
2/26/93
3/30/93
3/30/93
3/30/93
3/30/93
0
0
0
2,000
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
2,372,761
0
0
0
                      2,374.761

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

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

                                                             0
                                                             0
                                                             0
                                                             0
                                                             0
                                                             0
                                                             0
                                                             0
                                                             0
                                                             0
                                                             0
                                                             0
                                                             0
                                                             0
                                                             0
                                                             0
                                                             0
                                                             0
                                                             0
                                                             0
                                                             0
                                                             0
                                                             0
                                                             0
                                                             0
                                                             0
                                                             0
                                                             0
                                                             0
                                                             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, 1992 THROUGH MARCH 31, 1993
                                                                                                                                39

-------
Assignment
Control Number
G3HVK2-04-0476-3500108
G3HVK2- 04- 0473-35001 16
G3HVK2-04-0478-3500125
G3HVK3-04-0019-3500130
G3HVK3-04-0035-3500143
G3HVK3-04-0036-3500144
G3HVK3-04-0049-3500201
G3HVK3-04-0047-3500202
G3H VK3 - 04 - 0064 - 3500228
G3HVK3-04-0074-3500231
G3HVK3-04-0050-3500236
G3 H VK3 - 04 - 0077- 3500237
G3HVK3-04-0075-3500245
G3HVK3-04-0078-3500246
G3H VK3 - 04 - 0082 - 3500247
G3HVK3-04-0098-3500249
G3HVK3-04-0091 -3500250
G3HVK3-04-0101 -3500253
G3HVK3-04-0104-3500269
G3HVK3-04-0107-3500278
G3HVK3-04-0103-3500279
G3HVK3-04-0106-3500280
G3HVK3-04-01 18-3500318
G3HVK3-04-0132-3500338
G3HV<3-04-0133-3500339
G3HVK3-04-0138-3500351
G3HVK3-04-0145-3500399
G3HVK3-04-0127-3500401
G3HVK3-04-0149-3500413
G3HVK3-04-0135-3500414
G3HVK3-04-0158-3500417
G3HVK3-04-0155-3500425
G3HVK3-04-0160-3500450
G3HV<3-04-0157-3500452
G3HVK3-04-0154-3500462
G3HVK3-04-0153-3500463
G3HVK3-04-0159-3500494
N3HVJ2-04-0401 -3500058
N3HVJ2-04-0466-3500124
N3HVK2-04-0427-3500129
N3HVK2-04-0350-3500145
N3HVK2 - 04 - 0449-3500 1 46
N3HVK2-04-0412-3500199
N3HVK2-04-0451 -3500203
N3HVIC3-04-0020-3500216
N3H VK2 - 04 - 0462 - 3500230
N3H V J 2 - 04 - 0407- 3500254
N3HUK3-04-0046-3500315
N3HUK3-04-0090-3500316
N3HUIC3-04-01 10-3500337
N3H VK3 - 04 - 0089- 3500349
N3HUK3-04-0100-3500350
N3HVK3-04-0109-3500352
N3HVK3-04-0173-3500353
N3HVJ2-04-0477-3500379
N3HVK3-04-0105-3500380
N3HVIC3-04-0136-3500400
N3HVK3-04-0097-3500402
N3HVK3-04-0147-3500403
N3HVK3-04-0156-3500415
N3HVK3-04-0164-3500416
N3HVK3-04-0150-3500426
N3HUK3-04-0120-3500440
N3HVK2-04-0481 -3500451
N3HVK3-04-0108-3500453
N3HVK3-04-0126-3500459
N3HVK3 - 04 - 0025 - 3500492
M3HUJ3-04-0163-3500493
Title
CULLMAN AL
MEDINA TN
ANNISTON WATER WORKS & SEWERAL
OLD HICKORY UTILITY DIST TN
PARRISH AL
ROGERSVILLE TN
CARYVILLE TN
SALEMBURG NC
WESTERN CAROLINA REGIONAL SESC
BENSON NC
IRVINGTON KY
UNION COUNTY NC
SMITHVILLE TN
GALLAWAY TN
LOUISVILLE MS
SPARTANBURG SANITARY SEWER SC
WASHINGTON NC
GRAND STRAND WATER & SEWER SC
NEW BERN NC
SNEEDVILLE TN
FAYETTEVILLE NC
LEXINGTON NC
BAY RIVER METROPOLITAN SEWAGNC
OZARK UTILITIES BOARD AL
CENTRAL CITY KY
SPRINGFIELD GA
STAR NC
CELINA TN
BURLINGTON NC
PILOT MOUNTAIN NC
NASHVILLE GA
CHOCOWINITY NC
CHARLESTON MS
HENDERSON NC
STALL INGS NC
STALL INGS NC
LOUISVILLE & JEFFERSON SEWERKY
SOUTH CAROLINA SC
KENTUCKY COMMON WEALTH KY
AUGUSTA GA
SEMINOLE TRIBE OF FLORIDA FL
ROCK HILL SC
BROWARD COUNTY FL
SAVANNAH GA
DADE COUNTY FL
HILLSBOROUGH CO. FL
FLORIDA, STATE OF FL
NORTHERN KENTUCKY UNIVERSITYKY
WESTERN KENTUCKY UNIVERSITY KY
DUKE UNIVERSITY NC
MECKLENBURG COUNTY NC
CLEMSON UNIVERSITY SC
KNOX COUNTY TN
OKALOOSA COUNTY FL
NORTH CAROLINA STATE NC
SALISBURY NC
MANCHESTER GA
FORSYTH COUNTY NC
BELHAVEN NC
CLAYTON AL
ELIZABETH CITY NC
RALEIGH NC
LOUISVILLE UNIVERSITY OF KY
GEORGIA RESEARCH FOUNDATION GA
BUNCOMBE COUNTY NC
RESEARCH TRIANGLE INSTITUTE NC
NE REGIONAL DEVELOPMENT CTR GA
MISSISSIPPI STATE UNIVERSITYMS
Final Report
Issued
11/10/92
11/12/92
11/13/92
11/16/92
11/18/92
11/18/92
12/15/92
12/16/92
12/29/92
12/29/92
12/30/92
12/30/92
M 4/93
M 4/93
M 4/93
I/ 7/93
M 7/93
M 8/93
1/20/93
1/22/93
1/22/93
1/22/93
21 9/93
2/18/93
2/18/93
2/18/93
3/ 3/93
3/ 3/93
3/ 9/93
3/ 9/93
3/ 9/93
3/11/93
3/18/93
3/18/93
3/23/93
3/23/93
3/31/93
10/29/92
11/13/92
11/16/92
11/18/92
11/18/92
12/15/92
12/16/92
12/18/92
12/29/92
M 8/93
2/ 4/93
2/ 4/93
2/18/93
2/18/93
2/18/93
2/18/93
2/18/93
2/24/93
2/24/93
3/ 3/93
3/ 3/93
3/ 3/93
3/ 9/93
3/ 9/93
3/11/93
3/17/93
3/18/93
3/18/93
3/19/93
3/30/93
3/30/93
	 ' — I1C«*VRF IIIW1IWU
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
            TOTAL OF REGION 04 =  85
40
                                                                                           OFFICE OF THE INSPECTOR GENERAL

-------
                                                                             Questioned Costs
Assignment Title
Control Number
C3HVK2-05-0451 -3500035 GRAND RAPIDS FY 91
C3HVJ3-05-0032-3500083 FT UAYNE FY 91
C3HVJ3-05-0051 -3500155 HAMMOND FY 91
G3HVJ2-05-0425-3500036 LAKE DALECARLIA RUD FY 90/1
G3HVJ2-05-0424-3500037 LAKE DALECARLIA RWD FY 89
G3HVK2-05-0447-3500048 DOWNERS GROVE SD FY 92
G3HVJ2-05-0453-3500063 LOOGOOTEE FY 91
G3HVJ2-05-0452-3500064 BOONVILLE FY 91
G3HVK2-05-0456-3500065 N SHORE SD FY 92
G3HVK2-05-0458-3500066 E LANSING SD FY 92
G3HVJ3-05-0030-3500081 ST PAUL MWCC FY 91
G3HVK3-05-0033-3500082 AHMEEK FY 92
G3HVJ3-05-0023-3500112 DECATUR FY 91
G3HVK3-05-0025-3500113 STACY FY 91
G3HVJ3-05-0043-3500140 TOLEDO LSD FY 90
G3HVJ3-05-0040-3500141 TOLEDO LSD FY 87
G3HVJ3-05-0041 -3500142 TOLEDO LSD FY 88
G3HVJ3-05-0029-3500147 SULLIVAN FY 91
G3HVK3-05-0067-3500148 NEWAYGO FY 92
G3HVK3-05-0065-3500149 DECATUR SD FY 92
G3HVK3-05-0046-3500160 ADDISON FY 92
G3HVJ3-05-0086-3500162 BERNE FY 91
G3HVK3-05-0044-3500198 PINCKNEY FY 92
G3HVK3-05-0104-3500217 GARDEN CITY FY 92
G3HVK3-05-0102-3500218 INKSTER FY 92
G3HVK3-05-0094-3500219 COPPER HARBOR FY 92
G3HVJ3-05-0109-3500273 WANATAH FY 90/91
G3HVJ3-05-01 10-3500274 JASPER FY 91
G3HVJ3-05-01 14-3500275 MCDONALD FY 90
G3HVJ3-05-0123-3500314 RENSSELAER FY 91
G3HVJ3-05-0137-3500333 U WAYNE RSD FY 90/91
G3HVK3-05-0145-3500369 NIPC FY 92
G3HVJ3-05-0149-3500370 CLARKSVILLE FY 91
G3HVJ3-05-0144-3500371 JEFFERSONVILLE FY 91
G3HVK3-05-0151 -3500372 CINCINNATI MSD FY 91
G3HVJ3-05-0150-3500373 BAINBRIDGE FY 90/91
G3HVJ3-05-0152-3500374 TURKEY CREEK RSD FY 90/91
G3HVJ3-05-0164-3500419 COATSVILLE FY 90/91
G3HVJ3-05-0162-3500420 PALMYRA FY 90/91
G3HVJ3-05-0163-3500422 CARBON FY 90/91
G3HVJ3-05-0160-3500423 AMO FY 90/91
G3HVJ3-05-0159-3500424 VAN BUREN FY 90/91
G3HVJ3-05-0183-3500428 MIDDLETOWN FY 90/91
G3HVJ3-05-0182-3500429 ETNA GREEN FY 90/91
G3HVJ3-05-0181 -3500431 MITCHELL FY 91
G3HVJ3-05-0171-3500441 GEORGETOWN FY 90/91
G3HVJ3-05-0165-3500442 LAPAZ FY 90/91
G3HVJ3-05-0166-3500443 MICHIGAN CITY FY 91
G3HVJ3-05-0161 -3500444 DALE FY 90/91
N3HVJ2-05-0454-3500034 MN U OF FY 91
N3HVK2-05-0292-3500046 COLUMBUS FY 91
N3HVK2-05-0365-3500047 CHICAGO PD FY 90
N3HVJ2-05-0446-3500049 ELKHART FY 91
N3HUK2-05-0382-3500050 TOLEDO U FY 91
N3HVK2-05-0378-3500060 MENOMINEE IT FY 91
N3HVK2-05-0344-3500061 DANVILLE FY 91
N3HVK2-05-0428-3500062 TRAVERSE CITY FY 91
N3HVK2-05-0444-3500067 NEWARK FY 91
N3HVJ2-05-0381 -3500068 INDIANA BOH FY 91
N3HUK2-05-0432-3500069 OAKLAND U FY 91
N3HVJ2-05-0433-3500080 SUMMIT CO FY 90
N3HVKO-05-021 1-3500106 CHICAGO BOE FY 88
N3HVK2-05-0449-3500107 CHIPPEWA INDIANS
N3HVJO-05-0454-3500109 MARENGO FY 89
N3HUJ2-05-0450-3500110 INDIANA U FY 91
N3HVK2-05-041 1-35001 11 EAU CLAIRE FY 91
N3HVJ2-05-0427-3500131 S BEND FY 91
N3HUJ1-05-0385-3500132 PURDUE U FY 90
N3HVK3-05-0026-3500133 STOCKBRIDGE MUNSEE FY 91
N3HVK1 -05-0033-3500139 INDIANAPOLIS FY 89
N3HVJ1 -05-0482-3500150 WILLOUGHBY FY 89
N3HVK1 -05-0223-3500151 WARREN FY 89
N3HUK2-05-0455-3500195 MN U OF FY 91
N3HUK3-05-0089-3500196 ST MARYS COLLEGE FY 91

MI
IN
IN
IN
IN
IL
IN
IN
IL
MI
MN
MI
IN
MN
OH
OH
OH
IN
MI
IL
IL
IN
MI
MI
MI
MI
IN
IN
OH
IN
IN
IL
IN
IN
OH
IN
IN
IN
IN
IN
IN
IN
IN
IN
IN
IN
IN
IN
IN
MN
OH
IN
IN
OH
WI
IL
MI
OH
IN
MI
OH
IL
WI
IN
IN
WI
IN
IN
WI
IN
OH
OH
MN
MN
Final Report
Issued
10/ 9/92
11/ 3/92
11/23/92
10/ 9/92
10/ 9/92
10/27/92
10/30/92
10/30/92
10/30/92
10/30/92
11/ 3/92
1V 3/92
11/10/92
11/10/92
11/17/92
11/17/92
11/17/92
11/18/92
11/18/92
11/18/92
11/24/92
11/24/92
12/15/92
12/18/92
12/18/92
12/18/92
1/21/93
1/21/93
1/21/93
2/ 3/93
2/17/93
2/23/93
2/23/93
2/23/93
2/23/93
2/23/93
2/23/93
3/ 9/93
3/ 9/93
3/ 9/93
3/ 9/93
3/ 9/93
3/11/93
3/11/93
3/11/93
3/17/93
3/17/93
3/17/93
3/17/93
10/ 9/92
10/27/92
10/27/92
10/27/92
10/27/92
10/30/92
10/30/92
10/30/92
10/30/92
10/30/92
10/30/92
11/ 3/92
11/10/92
11/10/92
11/10/92
11/10/92
11/10/92
11/16/92
11/16/92
11/16/92
11/17/92
11/18/92
11/18/92
12/15/92
12/15/92
Ineligible Unsupported Unnecessary/ Efficienc
Costs Costs Unreasonable (Funds Be f
Costs To Better U
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
11,414
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
n
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
n
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
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, 1992 THROUGH MARCH 31, 1993

-------
Assignment Title
Control Number
N3HVK3-05-0090-3500197 IRONWOOO ASD FY 92 MI
N3HVJ3-05-0103-3500220 BLOOMINGTON FY 90 IN
N3HVJ3-05-0052-3500272 WISCONSIN U OF FY 90/91 WI
N3HVK2-05-0227-3500327 WARREN FY 90 OH
N3HVK3-05-0130-3500328 LEECH LAKE RES FY 91 MN
N3HVK2-05-0370-3500334 OAKLAND CO FY 91 MI
N3HVK3-05-0099-3500335 LEECH LAKE RES FY 90 MN
N3HUK3-05-0120-3500368 CINCINNATI U OF FY 91 OH
N3HVK3-05-0082-3500418 TOLEDO FY 91 OH
N3HUK3-05-0105-3500421 BUTLER U FY 91/92 IN
N3HUK3-05-01 19-3500427 MICHIGAN TECH U FY 92 MI
N3HVK2-05-0274-3500430 INDIANAPOLIS FY 90 IN
N3HVJ3-05-0087-3500445 EVANSVILLE FY 91 IN
TOTAL OF REGION 05 = 87
G3HVK3-06-0044-3500115 VICTORIA COUNTY WCID #2 TX
G3HVK3-06-0052-3500204 COLLINSVILLE OK
G3HVK3-06-0053-3500206 COLLINSVILLE, OK
G3HVK3-06-0054-3500207 COLLINSVILLE OK
G3HVK3-06-0059-3500211 BROWNSVILLE TX
G3HVK3-06-0085-3500398 TAHLEQUAH OK
G3HVK3-06-0086-3500434 CLEO SPRINGS OK
G3HVK3-06-0087-3500435 IDALOU TX
G3HVK3-06-0091 -3500436 NASH OK
N3HVK3-06-0022-3500012 NO. CENTRAL TX COUNCIL OF GOTX
N3HVK3-06-0023-3500013 CENTRAL TEXAS COUNCIL OF GOVTX
N3HVK3-06-0024-3500015 HOUSTON TX
N3HVK3-06-0025-3500016 HOUSTON TX
N3HVK3-06-0026-3500019 ST. BERNARD PARISH POLICE JULA
N3HVK3-06-0027-3500023 SANTA FE NM
N3HUK3-06-0028-3500024 UNIVERSITY OF OKLAHOMA OK
N3HVK3-06-0029-3500025 TERREBONNE PARISH CONSOL.GVMLA
N3HVK3-06-0030-3500028 ALBUQUERQUE NM
N3HVK3-06-0035-3500070 EL PASO TX
N3HUK3-06-0034-3500071 ROSE STATE COLLEGE OK
N3HVK3-06-0033-3500072 CHEROKEE NATION OF OKLAHOMA OK
N3HVK3-06-0038-3500073 GALVESTON COUNTY HEALTH DISTTX
N3HVK3-06-0040-3500076 LOWER RIO GRAND VALLEY DEV. TX
N3HVK3-06-0041 -3500077 AUSTIN TX
N3HVK3-06-0042-3500078 POJOAQUE PUEBLO NM
N3HVK3-06-0043-3500114 PUEBLO OF SANDIA NM
N3HVK3-06-0045-3500120 ARKANSAS DEPT. OF ED.GEN.DIVAR
N3HVK3-06-0046-3500121 ARKANSAS DEPT OF ED.GEN.DIV.AR
N3HVK3-06-0057-3500209 LOWER RIO GRANDE VALLEY DEV.TX
N3HVK3-06-0058-3500210 BAYTOWN TX
N3HUJ3- 06- 0062-3500257 UNIVERSITY OF AR MEDICAL SCIAR
N3HUJ3-06-0061 -3500258 UNIVERSITY OF AR MED.SCIENCEAR
N3HUK3-06-0080-3500365 OKLAHOMA ST. UNIVERSITY^ OK
N3HVK3-06-0081 -3500366 EDMOND OK
N3HVK3-06-0082-3500367 CENTRAL TEXAS COG TX
N3HVK3-06-0084-3500390 ENERGY MINERALS NATURAL RS. NM
TOTAL OF REGION 06 = 36
C3HVJ3-07-0069-3500345 DEPT OF ENVIRON CONTROL NE
C3HVK2-07-0212-3500466 KANSAS CITY KS
G3HVK2-07-0217-3500004 ARCADIA MO
G3HVK3-07-0023-3500091 LOUP CITY NE
G3HVK3-07-0024-3500092 LANSING KS
G3HVK3-07-0027-3500095 MONETT MO
G3HVK3-07-0031 -3500128 JUNCTION CITY KS
G3HVK3-07-0045-3500239 MCPHERSON KS
G3HVK3-07-0052-3500262 LAKE WABAUNSEE IMPROVEMENT KS
G3HVK3-07-0068-3500263 OWENSVILLE MO
G3HVK3-07-0053-3500276 ANKENY IA
G3HVK3-07-0051 -3500277 DIAMOND MO
G3HVK3-07-0074-3500286 FORSYTH MO
G3HVK3-07-0077-3500291 MINATARE NE
G3HVK3-07-0079-3500292 SCOTTSBLUFF NE
G3HVK3-07-0082-3500309 HORACE KS
G3HVK3-07-0056-3500310 MET ST LOUIS SEWER DISTRICT MO
G3HVK3-07-0089-3500320 TILDEN NE
G3HVK3-07-0086-3500321 GORDON NE
Final Report
Issued
12/15/92
12/18/92
1/21/93
2/10/93
2/10/93
2/17/93
2/17/93
2/23/93
3/ 9/93
3/ 9/93
3/11/93
3/11/93
3/17/93

11/10/92
12/17/92
12/17/92
12/17/92
12/17/92
3/ 2/93
3/15/93
3/15/93
3/16/93
10/ 7/92
10/ 7/92
10/ 7/92
10/ 7/92
10/ 7/92
10/ 7/92
10/ 8/92
10/ 8/92
10/ 8/92
1V 2/92
11/ 2/92
11/ 2/92
11/ 2/92
11/ 2/92
11/ 2/92
11/ 2/92
11/10/92
11/12/92
11/12/92
12/17/92
12/17/92
1/12/93
1/12/93
2/23/93
2/23/93
2/23/93
2/26/93

2/18/93
3/24/93
10/ 5/92
1V 6/92
1V 6/92
IV 6/92
11/16/92
12/30/92
1/14/93
1/14/93
1/22/93
1/22/93
1/27/93
1/27/93
1/27/93
1/28/93
1/29/93
21 9/93
2/ 9/93
Ineligible Unsupported Unnecessary/ Efficiencies
Costs Costs Unreasonable (Funds Be Put
Costs To Better Use
0
0
1,558
0
0
275
0
0
o
o
0
36,053
0
49,300
0
o
0
0
0
0
0
0
0
0
0
o
0
o
0
o
0
0
0
o
0
0
0
0
0
0
0
0
0
o
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
o
n
U
o

0
0
o
o
o
0
o
o
o
o
o
o
0
o
o
o
o
o
o
o
o
o
o
o
0
o
0
o
o
o
0
o
0
o
0
o
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0

o

0
0



o
o
o
o
o
o

o

o

o

o
o
o

o
o
o
o
o
o
o
o
o
n
U
o
o
o
o
o
0
0
o
o
o
o
o
o
o
o
o
o
o
0
o
o
o
o
o
o
0
42
                                                                                           OFFICE OF THE INSPECTOR GENEFW

-------
Assignment
Control Number
G3HVK3- 07- 0088-3500323
G3HVK3-07-0084-3500324
G3HVK3-07-0090-3500340
G3HVK3-07-0085-3500347
G3HVK3-07-0083-3500348
G3HVK3-07-0081 -3500354
G3HVK3-07-0093-3500355
G3HVK3-07-0094-3500359
G3HVK3-07-0091 -3500360
G3HVK2-07-0220-3500393
G3HVK3-07-0057-3500394
G3H VK3 - 07- 0055 - 3500396
G3HVK3-07-0107-3500454
G3HVK3-07-0105-3500481
G3HVK3-07-0102-3500486
G3HVK3-07-01 18-3500491
N3HVK2-07-0215-3500007
N3HVK3-07-0022-3500090
N3HVK3-07-0029-3500103
N3HUK3-07-0030-3500105
N3HVK3-07-0042-3500158
N3HVK2-07-021 1-3500161
N3HVK3-07-0040-3500164
N3HVK3-07-0041 -3500165
N3HVK3-07-0043-3500174
N3HVK3-07-0066-3500248
N3HVJ3-07-0026-3500264
N3HVK3-07-0067-3500265
N3HVK3-07-0075-3500267
N3HUK3-07-0058-3500271
N3HVJ3-07-0076-3500284
N3 H VK3 - 07- 0060 - 3500285
N3HVK3-07-0059-3500297
N3HVJ2-07-0216-3500362
N3HVJ2-07-0199-3500363
N3HVK3-07-0028-3500364
N3HVK3-07-0092-3500395
N3HVK3-07-0096-3500404
Title
NEVADA,
SUMMERSVILLE
ALTAMONT
WEBB CITY,
PUXICO
BENNET
LOCKWOOD
PORTSMOUTH
ST MARYS
DODGE CITY
LAUREL
FAIR GROVE
CUMMING
ST PETERS
AINSWORTH
HARVEY
BONNER SPRINGS
SELIGMAN
TOPEKA
MISSOURI UNIV OF-COLUMBIA
WICHITA
JOHNSON COUNTY
RENO COUNTY
DOUGLAS COUNTY
IRONDALE
MARION COUNTY
NEBRASKA DEPT OF HEALTH
MERAMEC REGIONAL PLANNING
NEVADA
JR COLLEGE DIST
KIRKWOOD COMMUNITY COLLEGE
WINNEBAGO TRIBE
OMAHA
IOWA STATE OF
MISSOURI STATE
KANSAS STATE OF
GOLDEN CITY
FARMINGTON

IA
MO
MO
MO
MO
NE
MO
IA
IA
KS
IA
MO
IA
MO
NE
IA
KS
MO
KS
MO
KS
KS
KS
NE
MO
KS
NE
MO
IA
MO
IA
NE
NE
IA
MO
KS
MO
MO
Final Report
Issued
21 9/93
2/ 9/93
2/18/93
2/18/93
2/18/93
2/18/93
2/18/93
2/19/93
2/19/93
3/ 1/93
3/ 1/93
3/ 1/93
3/18/93
3/30/93
3/30/93
3/30/93
10/ 6/92
11/ 6/92
11/ 6/92
1V 6/92
11/24/92
11/24/92
11/24/92
11/24/92
12/ 2/92
V 6/93
1/14/93
1/14/93
1/15/93
1/21/93
1/27/93
1/27/93
1/28/93
2/22/93
2/22/93
2/22/93
3/ 1/93
3/ 3/93
Ineligible Unsupported Unnecessary/ Efficiencie
Costs Costs Unreasonable (Funds Be Pu
Costs To Better Use
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
1,148
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
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 =  57

G3HVK3-08-0023-3500102  MINOT
G3HVJ3-08-0026-3500123  CENTRAL CASS SCHOOL DIST
G3HVK3-08-0040-3500287  MISSION
G3HVJ3-08-0042-3500295  LIDGERWOOD
G3HVK3-08-0036-3500303  CUSTER CITY
G3HVK3-08-0051-3500336  CASPER
G3HVK3-08-0045-3500341  CHEYENNE
G3HVK3-08-0047-3500342  GILLETTE
G3HVK3-08-0048-3500343  WHEATLAND
G3HVK3-08-0046-3500356  MISSOULA
G3HVK2-08-0102-3500397  LONGMONT
G3HVK3-08-0059-3500437  LAKE ANDES
G3HVK3-08-0060-3500438  SARATOGA - CARBON COUNTY
G3HVK3-08-0061-3500439  LARAMIE
G3HVK2-08-0072-3500458  HAZEL
G3HVK3-08-0063-3500467  SILVERTON
G3HVK3-08-0064-3500474  THE KEYSTONE CENTER
G3HVK3-08-0062-3500487  KEYSTONE CENTER
G3HVK3-08-0067-3500490  GREAT FALLS
N3HVK2-08-0101-3500008  FARGO
N3HVK2-08-0098-3500009  ASSINIBOINE & SIOUX TRIBES
N3HVK3-08-0024-3500104  MINOT
N3HVK2-08-0099-3500159  OGLALA SOUIX TRIBE
N3HVK3-08-0029-3500173  LOWER BRULE SIOUX TRIBE
N3HVK3-08-0030-3500175  DEPT. HEALTH & SOCIAL SER
N3HVK3-08-0028-3500176  CHEYENNE RIVER SIOUX TRIBE
N3HVK3-08-0027-3500177  BISMARCK
N3HVK2-08-0084-3500261  LOVELL
N3HVJ2-08-0100-3500288  UTAH STATE OF
N3HVK3-08-0034-3500289  BOULDER
N3HVJ3-08-0025-3500293  SOUTH DAKOTA, STATE OF
N3HVJ2-08-0103-3500300  MONTANA STATE OF
N3HVK3-08-0037-3500319  PLATTE
ND
ND
SD
ND
SD
WY
WY
WY
WY
MT
CO
SD
WY
WY
SD
CO
CO
CO
MT
ND
MT
ND
SD
SD
WY
SD
ND
WY
UT
CO
SD
MT
SD
11/ 6/92
11/13/92
 1/27/93
 1/28/93
 1/28/93
 2/17/93
 2/18/93
 2/18/93
 2/18/93
 2/18/93
 3/ 1/93
 3/16/93
 3/16/93
 3/16/93
 3/19/93
 3/24/93
 3/30/93
 3/30/93
 3/30/93
10/ 6/92
10/ 6/92
1V 6/92
11/24/92
12/ 2/92
12/ 2/92
12/ 2/92
12/ 2/92
 1/14/93
 1/27/93
 1/27/93
 1/28/93
 1/28/93
 2/ 9/93
 1,148

     0
     0
     0
     0
     0
     0
     0
     0
     0
     0
     0
     0
     0
     0
     0
     0
     0
     0
     0
     0
     0
     0
     0
     0
     0
     0
     0
     0
     0
     0
20,812
     0
     0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
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, 1992 THROUGH MARCH 31, 1993

-------
Assignment
Control Number
N3HVK3-08-0043-3500357
N3HVK3-08-0050-3500405
N3HVK3-08-0052-3500406
N3HVK3- 08- 0049-3500407
N3HVK2-08-0088-3500408
N3HVJ2-08-0087-3500409
N3HVK3- 08- 0065 - 3500475
N3HVK3-08-0066-3500476
TOTAL OF
C3HVK3-09-0142-3500495
G3HVK3-09-0067-3500191
G3HVK3-09-0068-3500193
G3HVK3-09-0079-3500238
G3HVK3-09-01 14-3500361
G3HVK3-09-0133-3500455
N3HUK2-09-0280-3500031
N3HVK2-09-0288-3500032
N3HVK2-09-0038-3500052
N3HVK2-09-0324-3500053
N3HVK3-09-0039-3500056
N3HVK3-09-0042-3500087
N3HVK2-09-0291 -3500088
N3HVK2- 09- 0284 - 3500093
N3HVK3-09-0047-3500094
N3HVK3-09-0048-3500098
N3HVK2-09-0294-3500118
N3HVK2-09-0287-3500119
N3HVK2-09-0286-3500122
N3HVK2-09-0356-3500152
N3HVK2-09-0325-3500153
N3HVK2-09-0283-3500154
N3HUK3-09-0057-3500166
N3H VK2 - 09- 0277- 3500 1 79
N3HVK2-09-0276-3500183
N3HVK3-09-0061 -3500185
N3HVK2-09-0353-3500189
N3HVK3-09-0033-3500200
N3HVK2-09-0330-3500225
N3HVK3 - 09- 0077- 3500227
N3HVK2-09-0301 -3500232
N3HVK3 - 09-0078-3500234
N3HVK2-09-0282-3500235
N3HVK3- 09- 0088-3500252
N3HVK3-09-0059-3500282
N3HVK3-09-0103-3500312
N3H VK2 - 09- 0323-35003 1 3
N3HUK2-09-0289-3500317
N3HVK2-09-0275-3500332
N3HVK3-09-01 15-3500376
N3HVK2- 09- 0295 -3500388
N3HUK3-09-0050-3500389
N3HVJ3-09-0071 -3500410
N3HVK3-09-0127-3500432
N3HVK2-09-0355-3500433
N3HUK3-09-0028-3500464
N3HVK3-09-0139-3500468
TOTAL OF
G3HVJ3- 10-0022-3500181
G3HVK3-10-0024-3500184
G3HVJ3-10-0028-3500190
G3HVK3- 10-0029-3500222
G3HVK3- 10-0030-3500223
G3HVK3- 10-0031 -3500224
G3HVK3- 1 0- 0037-3500251
N3HVK2- 10-0131 -3500014
N3HVK2- 10-0104-3500030
N3HVJ2- 10-0095-3500054
N3HVJ2-10-0090-3500055
N3HVK2- 10-0094-3500057
N3HUK2- 10-0091 -3500059
N3HVJ2- 10-0099-3500089
Title
TURTLE HTN BAND OF CHIPPEWA ND
PUEBLO CO
MISSOULA COUNTY MT
CASPER COLLEGE UY
WELD CO
CASS COUNTY ND
THE KEYSTONE CENTER CO
THE KEYSTONE CENTER CO
REGION 08 = 41
HONOLULU CITY AND COUNTY OF HI
SEDONA, CITY OF AZ
PINETOP-LAKESIDE SAN DIST AZ
LITTLE COLORADO SAN IT DIST CO
AVONDALE, CITY OF AZ
LAKE HAVASU CITY AZ
CALIF PUBLIC HEALTH FOUNDAT CA
CLARK COUNTY HLTH DIST NV
MODESTO, CITY OF CA
VENTURA, COUNTY OF CA
SONOMA, COUNTY OF CA
SAN DIEGO COUNTY OF CA
GILA RIVER INDIAN COMMUNITY AZ
BAY AREA AIR QTY MGM DIST CA
GUALALA COMMUNITY SVCS DIST CA
KINGS, COUNTY OF CA
KAUAI, COUNTY OF HI
CLARK COUNTY NV
CLARK COUNTY NV
LAKE HAVASU CITY AZ
HAWAII, DEPT OF HEALTH HI
ASOC NAC PRO PERS CA
POINT REYES BIRD OBSERVATORYCA
CHUUK, STATE OF FM
POHNPEI, STATE OF FM
L.A. DEPT OF WATER & POWER CA
WHITE MOUNTAIN APACHE TRIBE AZ
FORT MOJAVE IND. TRIBE CA
NEVADA, STATE OF NV
WHITE MOUNTAIN APACHE TRIBE AZ
SONOMA STATE UN IV ACAD FOUN CA
MADERA, CITY OF CA
AMERICAN SAMOA GOVERNMENT AS
AMERICAN SAMOA GOVERNMENT AS
SANTA ANA WTRSHED PROJ AUT CA
FIELDBROOK COMM SERVICES DISCA
LOS ANGELES, CITY OF CA
PIMA CNTY COMM COLLEGE DIS AZ
PALAU, REPUBLIC OF PU
LAKE, COUNTY OF CA
PRESCOTT, CITY OF AZ
CA POLYTECH STATE UN IV FOUN CA
PIMA COUNTY AZ
SAN DIEGO, CITY OF CA
HAWAII, DEPT OF AGRICULTURE HI
HORNET FOUNDATION, INC CA
ALBANY, CITY OF CA
REGION 09 = 47
CAMAS, CITY OF WA
TROY, CITY OF ID
BLACK DIAMOND, CITY OF WA
POST FALLS, CITY OF ID
POST FALLS, CITY OF ID
POST FALLS, CITY OF ID
NEWPORT, CITY OF OR
CORVALLIS, CITY OF OR
SUQUAMISH TRIBE WA
MUNI OF METRO SEATTLE WA
ALASKA, STATE OF AK
LUMMI BUSINESS COUNCIL WA
BOISE STATE UNIVERSITY ID
CAMAS, CITY OF WA
Final Report
Issued
2/18/93
3/ 3/93
3/ 3/93
3/ 3/93
3/ 3/93
3/ 3/93
3/30/93
3/30/93

3/31/93
12/10/92
12/10/92
12/30/92
2/22/93
3/18/93
10/ 8/92
10/ 8/92
10/28/92
10/28/92
10/28/92
IV 4/92
IV 4/92
1V 6/92
1V 6/92
1V 6/92
11/12/92
11/12/92
11/12/92
11/19/92
11/19/92
11/19/92
11/24/92
12/ 4/92
12/ 8/92
12/ 9/92
12/10/92
12/15/92
12/23/92
12/28/92
12/29/92
12/29/92
12/29/92
V 7/93
1/26/93
1/29/93
1/29/93
2/ 4/93
2/12/93
2/23/93
2/26/93
2/26/93
3/ 4/93
3/11/93
3/11/93
3/23/93
3/25/93

12/ 8/92
12/ 8/92
12/10/92
12/22/92
12/22/92
12/22/92
V 7/93
10/ 7/92
10/ 8/92
10/28/92
10/28/92
10/28/92
10/29/92
1V 4/92
	 II^VWII •• « 1^1 l*J*iV*
Ineligible Unsupported Unnecessary/ Efficiencies
Costs Costs Unreasonable (Funds Be Put
Costs To Better Use)
0
0
0
1,373
0
0
0
0
22,185
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
17,227
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
2,035
0
0
0
0
0
0
0
0
19,262
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
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

-------
                                                                               Questioned Costs
Assignment Title
Control Number
N3HVK2-10-0117-3500097 YAK I MA INDIAN NATION
N3HUK3- 10-0009-35001 17 IDAHO, UNIV OF
N3HVK2- 10-0097-3500167 ANCHORAGE, MUNICIPALITY OF
N3HVK3- 10-0023-3500182 MAKAH TRIBAL COUNCIL
N3HVJ2-10-0105-3500233 TACOMA, CITY OF
N3HVK2-10-0114-3500283 MUCKLESHOOT INDIAN TRIBE
N3HVK2- 10-0102-3500311 LEWISTON, CITY OF
N3HVK2- 10-0098-3500375 BOISE CITY
N3HVJ2- 10-0103-3500377 MUNI OF METRO SEATTLE
N3HVJ3- 10-0045-3500469 CLARK COUNTY
TOTAL OF REGION 10 = 24
TOTAL OTHER GRANT AUDITS
5. SUPERFUND GRANTS
P5BKN1 -03-0305-3300004 SF COOPERATIVE AGREEMENTS
P5BGN1 -03-0306-3300008 SF COOPERATIVE AGREEMENTS
TOTAL OF REGION 03 = 2
P5EGN1 -07-0191 -3300032 MISSOURI DNR
TOTAL OF REGION 07 = 1
P5BGN2-08-0019-3300033 DEPT OF HEALTH & ENVIR SCI
TOTAL OF REGION 08 = 1
H5BFL2-11-0046-3100041 SF lAG'S HHS FY 90
H5BFL2-1 1-0046-3100042 SF lAG'S HHS FY 90
M5BFL2-1 1-0025-3100040 SF-IAG FY90 DOT-COAST GUARD
M5BFL3-1 1-0014-3100046 SF IAG DOI USGS
M5BFL2-1 1-0045-3100059 SF-IAG FY91 DOI
M5BFL2-1 1-0026-3100090 SF-IAG FY 91 DOT
M5BFL2-11-0027-3100123 SF-IAG FY 91 ARMY
M5BFL2-11-0023-3100142 SF-IAG FY91 FEMA EXPEND.
M5BFL2-11-0045-3100158 SF-IAG FY91 DOI
TOTAL OF REGION 11 = 9
TOTAL SUPERFUND GRANTS
D8DML2-01 -0355-3100028 EASTERN RESEARCH GROUP, INC
D8AML2-01 -0259-3100031 INTERNATIONAL FUEL CELLS
D8AAL3-01 -0019-3100032 ENSR
D8BML2-01 -0162-3100047 COMBUSTION ENGINEERING CORP
D8AML3-01 -0022-3100048 EASTERN RESEARCH GROUP
D8AAL3-01 -0018-3100049 SIGMA RESEARCH CORP.
D8CAL2-01 -0155-3100105 COMBUSTION ENGINEERING INC.
D8AML3-01 -01 17-3100139 INDUSTRIAL ECONOMICS INC
D8AMP3-01 -0078-3400020 CADMUS GROUP INC.
D8AMP3- 01 -0075 -3400028 MULTISYSTEMS INC
E8AXP3- 01 -0055 -340001 3 TRC ENVIRONMENTAL CORP.
E8AXP3-01 -0058-3400021 TRC ENVIRONMENTAL CORP
E8AAP3-01 -0077-3400031 TRC ENVIRONMENTAL CORP
E8AAP3- 01 -0076- 3400032 TRC ENVIRONMENTAL CORP
P8AML2-01 -0367-3100009 ALLIANCE TECH. CORP.
TOTAL OF REGION 01 = 15
D8DML3-02-0080-3100029 MALCOLM PIRNIE INC.
D8CML3-02-0124-3100138 SYRACUSE RESEARCH CORP
P8AXP3- 02 -0098 -3400022 ECOLOGY & ENVIR
P8AXP3- 02 -0094 -3400026 ECOLOGY & ENVIR

ID
ID
AK
UA
UA
UA
ID
ID
UA
UA

=

DC
MD

MO

MT



DC




DC


=
.MA
CT
MA
.CT
MA
MA
CT
MA
MA
MA
CT
CT
MA
MA
MA

NY
NY
NY
NY
Final Report
Issued
1V 6/92
11/12/92
11/24/92
12/ 8/92
12/29/92
1/26/93
1/29/93
2/23/93
2/23/93
3/25/93

477

1V 6/92
1/27/93

3/30/93

3/31/93

12/ 1/92
12/ 1/92
12/ 1/92
12/ 3/92
V 4/93
21 1/93
3/ 9/93
3/25/93
3/31/93

13
Ineligible Unsupported Unnecessary/ Efficiencie
Costs Costs Unreasonable (Funds Be Pu
Costs To Better Use
000
000
000
000
000
000
000
000
000
000
000
2,468,512 0 0

3,140 699,988 0
214,804 83,578 0
217,944 783,566 0
135,781 62,643 0
135,781 62,643 0
0 12,057,987 0
0 12,057,987 0










353,725 12,904,196 0
11/16/92 *The dollar value of contract audits have not been shown.
11/17/92
11/17/92
12/ 3/92
12/ 8/92
12/ 9/92
2/18/93
3/19/93
2/16/93
3/ 8/93
V 8/93
2/19/93
3/22/93
3/22/93
10/ 8/92

11/17/92
3/19/93
2/19/93
3/ 1/93
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 displayei
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.








            TOTAL  OF REGION 02 =
OCTOBER 1, 1992 THROUGH MARCH 31, 1993
                                                                                                                45

-------
Assignment Title
Control Number
D8AWL3-03-0020-3100033 ENGINEERING TECHNOLOGIES AS MD
D8AWL3-03-0019-3100034 JACA PA
D8BML3- 03 -0072-31 00063 VIKING SYSTEMS INTERNATIONALPA
D8EML3-03-0086-3100064 NETWORK CORPORATION VA
D8BML3-03-0087-3100065 EG&G WASHINGTON MD
D8BHL3-03-0088-3100066 VIGYAN INCORPORATED VA
D8EML3-03-0089-3100067 SCIENTEX CORP VA
D8EML3- 03- 0090-31 00068 CIEL, INC. DC
D8DML3-03-0091 -3100069 CONSOLIDATED COAL CO. PA
D8BML3-03-0092-3100070 PA STATE UNIVERSITY PA
D8EML3-03-0095-3100071 ECG, INC VA
D8ALL3-03-0022-3100072 MERIDIAN RESEARCH INC MD
D8AAL3-03-0018-3100073 SULLIVAN ENVIRONMENTAL VA
D8AAL3-03-0104-3100100 MCWANE & COMPANY VA
D8CML3-03-0147-3100107 VERSAR VA
D8CML3-03-0148-3100108 VERSAR VA
D8CML3-03-0149-3100109 VERSAR VA
D8CML3-03-0150-3100110 VERSAR VA
D8AAL3-03-0097-3100120 E.H. PECHAN VA
D8AAL3-03-0099-3100121 VIGYAN VA
D8AAL3-03-0102-3100122 E.H. PECHAN VA
D8AAL3-03-0109-3100134 SOCIOECONOMIC TECHNICAL VA
D8AAL3-03-0103-3100135 PACIFIC ENVIRONMENTAL VA
P8AXP3-03-0073-3400008 ICF CORP. VA
TOTAL OF REGION 03 = 24
D8AML3-04-0059-3100020 TRIGON ENGINEERING CONSULTI NC
D8AML3-04-0028-3100025 EC/R NC
D8EML3-04-0037-3100039 ENVIRONMENTAL INVESTIGATIONSNC
D8CML3-04-0021 -3100043 MANTECH NC
D8AML3-04-0079-3100057 SYSTEMS RESEARCH & DEVELOP. NC
D8CML3-04-0058-3100060 MANTECH NC
D8CML3-04-0057-3100081 SOUTHERN RESEARCH INSTITUTE AL
D8AML3-04-0122-3100115 EC/R NC
D8AML3-04-0114-3100116 TRIGON ENGINEERING NC
D8AML3-04-0116-3100117 ALPHA-GAMMA NC
D8AML3-04-01 13-3100125 EMAC NC
D8BML3-04-0189-3100126 MANTECH NC
D8AML3-04-01 12-3100127 EC/R NC
D8AMU3-04-0129-3100128 EASTERN TECHNICAL NC
D8BML3-04-0190-3100131 GEORGIA TECH GA
D8AML3-04-0115-3100133 ENTROPY NC
H8CML2-04-0344-3100026 RESEARCH TRIANGLE INST NC
H8AML3-04-01 17-3100154 RESEARCH TRIANGLE INSTITUTE NC
TOTAL OF REGION 04 = 18
D8BML2-05-0383-3100011 FEV OF AMERICA FY 92 MI
D8BML2-05-0313-3100052 AT KEARNEY FY 89 IL
D8CML3-05-0088-3100080 COLEJON MECH OH
D8AML3-05-0108-3100093 AUTO TESTING LAB OH
D8CML3-05-0097-3100112 LIFE SYSTEMS INC OH
D8BML3-05-0155-3100124 SHINGOBEE BUILDERS MN
D8BML2-05-0310-3100136 CHAMBERLAIN FY 90 IL
E8AXP3- 05 -003 1-3400009 PRC EMI (ARMY GOCO) IL
P8DMLO-05-0176-3100088 PEI ASSOC FY 86 OH
P8DMLO-05-0178-3100137 PEI ASSOC FY 87/88 OH
P8AAP3-05-0147-3400027 EQM (AIR SUB) OH
TOTAL OF REGION 05 = 11
D8AAL2-06-0195-3100013 LOCKHEED TX
D8CML3-06-0031 -3100014 SOUTHWESTERN PUBLIC SERVICE TX
D8AML3-06-0065-3100129 RADIAN TX
D8EML3-06-0088-3100130 TRINITY CONSULTANTS, INC. TX
D8AML3-06-0066-3100132 TRINITY CONSULTANTS INC. TX
TOTAL OF REGION 06 = 5
D8AHL2-07-0166-3100000 MRI KS
D8AML2-07-0194-3100001 MIDWEST RESEARCH INSTITUTE MO
D8CUL2-07-0150-3100002 DEV PLAN & RESEARCH ASSOC KS
D8CPL2-07-0151 -3100003 DEV PLAN & RESEARCH ASSO KS
D8CML2-07-0148-3100004 DEV PLAN & RESEARCH ASSOC KS
Final Report
Issued
11/17/92
11/17/92
M 6/93
M 6/93
1/ 6/93
V 6/93
M 6/93
M 7/93
V 7/93
M 7/93
M 8/93
V 8/93
M 8/93
2/11/93
2/22/93
2/22/93
2/22/93
2/22/93
3/ 8/93
3/ 8/93
3/ 8/93
3/16/93
3/16/93
12/ 3/92

11/ 2/92
IV 6/92
11/20/92
12/ 2/92
V 4/93
V 4/93
1/22/93
2/26/93
3/ 1/9^
3/ 1/93
3/11/93
3/11/93
3/11/93
3/11/93
3/11/93
3/11/93
11/13/92
3/31/93

10/ 9/92
12/15/92
1/21/93
2/ 3/93
2/23/93
3/ 9/93
3/17/93
12/14/92
1/28/93
3/17/93
3/ 2/93

10/26/92
10/27/92
3/11/93
3/11/93
3/11/93

10/ 7/92
10/ 7/92
10/ 7/92
10/ 7/92
10/ 7/92
Ineligible Unsupported Unnecessary/ Efficiencies
Costs Costs Unreasonable (Funds Be Put
Costs To Better Use)



































































46
OFFICE OF THE INSPECTOR GENERAL

-------
                                                                                       Questioned Costs
   Assignment
   Control Number
                        Title
                                                    Final Report
                                                    Issued
                       Ineligible
                           Costs
                             Unsupported
                                   Costs
Unnecessary/
Unreasonable
       Costs
Recommended
   Efficiencies
 (Funds Be Put
To Better Use)
D8EML3-07-0019-31UUU1f
D8AML3-07-0001-3100036
D8AAL3-07-0072-3100106
D8AAL3-07-0073-3100150
                 BLACK & VEACH
                 MIDWEST RESEARCH INSTITUTE
                 MR I
                 TRINITY CONSULTANTS
MO
MO
MO
KS
              TOTAL OF REGION 07 =   9

D8AML2-08-0086-3100023  ROGERS & ASSOC ENG CORP

              TOTAL OF REGION 08 =   1
D8AAL3-
D8HLL3-
D8AWL3-
D8CAL3-
D8AML3-
D8AML2-
D8AAL3-
D8CBL3-
D8CML3-
D8CML3-
D8AWN2-
D8AAN3-
D8AAN3-
D8AAN3-
D8EMP3-
09-0022-3100050  SONOMA TECHNOLOGICAL INC PA CA
09-0037-3100051  SCS ENGINEERS PA            CA
09-0036-3100053  TETRA TECH PA               CA
09-0070-3100076  ROCKWELL INTL-ROCKETDYNE    CA
09-0073-3100083  HAMILTON TEST SYSTEM PA     AZ
09-0318-3100084  STERLING FEDERAL SYSTEMS PA CA
09-0094-3100092  ACUREX ENVIRONMENTAL CORP   CA
09-0074-3100113  ACUREX ENV. CORP FINAL      CA
09-0075-3100119  ACUREX ENV CORP FINAL       CA
09-0141-3100146  SAIC FINAL                  CA
09-0299-3300002  TETRA TECH P.A.             CA
09-0092-3300018  SAIC P.A.                   CA
09-0093-3300019  ENGINEERING SCIENCE         CA
09-0091-3300020  ENGINEERING SCIENCE         CA
09-0049-3400004  ENERGY & ENVL RES CORP      CA
              TOTAL OF REGION 09 =  15
P8AXL3-10-0017-3100104  CH2M P.A.

              TOTAL OF REGION 10 =   1

              TOTAL OTHER CONTRACT REPORTS
                                                    OR
10/28/92
11/18/92
 2/19/93
 3/30/93
                                                   11/ 4/92
      12/ 9/92
      12/ 9/92
      12/15/92
       1/13/93
       1/25/93
       1/25/93
       2/ 2/93
       2/23/93
       3/ 5/93
       3/29/93
      10/29/92
       2/23/93
       2/25/93
       2/25/93
      11/10/92
                                                    2/11/93
                                               103
                         94,083
                                                               3,098,342
9. SUPERFUND CONTRACTS

D9CFL2-01-0381-3100006  INDUSTRIAL ECONOMICS, INC.  MA

              TOTAL OF REGION 01 =   1
              TOTAL OF REGION 04 =   6
  OCTOBER 1, 1992 THROUGH MARCH 31, 1993
                                                   10/ 8/92
D9DGL2-02-0094-3100007
D9BFL2-02-0076-3100019
D9DFL2-02-0282-3100054
D9CFL3-02-0107-3100082
D9EGL3-02-0082-3100096
D9EGP2-02-0380-3400001
E9BGLO-02-0242-3100145
M9BGL2-02-0273-3100005
M9EGL2-02-0272-3100008
TOTAL OF
D9AKL3-03-0016-3100027
D9AKL3-03-0015-3100045
D9BFL2-03-0234-3100085
D9BFL2-03-0184-3100086
D9BFL2-03-0273-3100099
D9EFL3-03-0125-3100101
D9EFL3-03-0141-3100102
D9EFL3-03-0142-3100103
P9EKN3 - 03 - 0096-3300007
P9AXN3-03-011 1-3300016
P9DGN3-03-01 13-3300034
TOTAL OF
D9BKL3-04-0034-3100010
D9AICL3 - 04 - 0084 - 3 1 00094
P9DHL2-04-0047-3100012
P9BGL2-04-0046-3100015
P9BHL2-04-0353-3100061
P9DHL2-04-0352-3100091
TAMS CONSULTANTS INC.
LEONARD G. BIRNBAUM & COMP.
TAMS CONSULTANTS INC.
LEONARD BIRNBAUM & COMPANY
TAMS CONSUTANTS, INC.
EBASCO
MALCOLM PIRN IE INC
EBASCO
EBASCO
REGION 02 = 9
APOGEE RESEARCH INC
ECG INC
UNISYS
COMPUTER SCIENCE CORP
ROY F WESTON
COMPUTER SCIENCE CORP
COMPUTER SCIENCE CORP
COMPUTER SCIENCE CORP
ICF CORP
ICF INC.
ICF, INC. ESAT
REGION 03 = 11
EHRT
MANTECH ENVIRONMENTAL
WESTINGHOUSE HAZTECH
WESTINGHOUSE HAZTECH
ENSITE INC
ENSITE INC
NY
NJ
NY
NJ
NY
NY
NY
NY
NY

MD
VA
VA
VA
PA
VA
VA
VA
VA
VA
VA

KY
NC
GA
GA
GA
GA
10/ 8/92
1V 2/92
12/23/92
1/25/93
2/10/93
10/ 8/92
3/29/93
10/ 8/92
10/ 8/92

11/13/92
12/ 3/92
1/26/93
1/26/93
2/11/93
2/11/93
2/11/93
2/11/93
1/21/93
2/19/93
3/31/93

10/ 9/92
2/ 4/93
10/ 9/92
10/28/92
M 5/93
2/ 2/93
                                                                                                                       47

-------
  Assignment
  Control Number
                        Title
                                                    Final Report
                                                    Issued
                                                                                       Questioned Costs
                       Ineligible
                          Costs
                            Unsupported
                                   Costs
Unnecessary/
Unreasonable
       Costs
Recommended
   Efficiencies
 (Funds Be Put
To Better Use)
D9AKL3-05-0047-3100074
E9AHP2-05-0415-3400000
E9EGP2-05-0438-3400011
E9EHP2-05-0278-3400015
E9EKP1-05-0400-3400040
P90HL1-05-0282-3100155
                 EQM  (RCRA SUB)
                 OHM  REM (ADD TO 2400058)
                 PSI-JAMMAL
                 OHM  REM D/S
                 PRC  EMI FY 86-FY 87
                 OHM  REM FY 90
              TOTAL OF REGION 05 =
D9AGL3-06-0048-3100056
D9CKN2-06-0194-3300001
                 LOCKHEED ENG. & SCI. CO.
                 LOCKHEED ENGR & SCI
              TOTAL OF REGION 06 =
D9BGL2-07-0132-3100018
D9BGL3-07-0021-3100024
D9BGL3-07-0035-3100037
D9DGL3-07-0018-3100062
D9DFL3-07-0117-3100149
                 SVERDRUP
                 SVERDRUP
                 SVERDRUP ENVIRONMENTAL
                 SVERDRUP CORP
                 DPRA  INC
OH
OH
IL
OH
IL
OH
TX
TX
MO
MO

MO
KS
              TOTAL OF REGION 07 =   5

D9CGL2-08-0061-3100016  TECHLAW INC

              TOTAL OF REGION 08 =   1
D9BGL2
D9BGL2
E9AGP3
E9DGP2
P90GL2
P90HL1
 1/12/93
10/ 7/92
12/23/92
 1/21/93
 3/30/93
 3/31/93
12/30/92
10/26/92
10/28/92
11/ 4/92
11/18/92
 M 5/93
 3/30/93
                                             CO    10/28/92
09-0134-3100075  BECHTEL  GROUP.  INC 89 OH&DC CA     1/12/93
•09-0072-3100079  AQUA TERRA OH & DC FY 89-91 CA     1/20/93
•09-0083-3400014  ENG COMPUTER OPTECNOMICS    MD     1/19/93

        TOTAL OF  REGION  09 =   3

•10-0081-3400036  CH2M HILL TRAVEL DECREMENT  OR     3/26/93
•10-0128-3100038  CH2M 1992 FUD PRICING - OH  OR     11/19/92
•10-0005-3100147  RES 89 OH                  OR     3/29/93

        TOTAL OF  REGION  10 =   3

        TOTAL SUPERFUND  CONTRACT  REPORTS        =    47
                                                                          1,093,753
                                             0

                                       415,397
                                                                 372,951
              TOTAL AUDITS =   722

901 - REPORTS ISSUED BY ASSIGNMENT TYPE AND EPA REGION
            SEMI-ANNUAL PERIOD ENDING  3/31/93
                                                                  30,581,246     38,610,968      63,139,392       16,295,95<
 48
                                                                                                  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 REASON SUCH MANAGEMENT DECISION HAS NOT BEEN MADE, AND A STATEME
     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 why 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 9/30/92

             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 Resolution Under Negotiation in Headquarters
   Assignment Control
   Number
Title
                                 Final Report
                                      Issued
Assignment Control
Number
Title
Final Report
     Issued
 ASSISTANT ADMINISTRATOR PDB PREVENTION. PESTICIDES HO TOXIC SUBSTANCES

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

   - EXPLANATION OF THE REASONS HANAGDCHT DECISION HAS NOT BEEN NUDE:  THE
 PROCESS OF ENFORCEMENT BY THE STATES PROVED TO BE MORE COMPLICATED THAN
 ANTICIPATED.  INFORMATION THAT WAS TO BE PROVIDED TO THE STATES WAS
 DETERMINED TO BE CONFIDENTIAL BUSINESS INFORMATION.

   = DESIRED TIMETABLE FOR ACHIEVING A HANACDCMT DECISION:  AN OFFICE OF
 GENERAL COUNSEL ISSUE PAPER ALLOUED THE ISSUANCE OF THE MANAGEMENT DECISION
 ON APRIL 8, 1993.

  IG FOLLQUP STATUS AS OF  3/31/93   El

 ASSISTANT ADMINISTRATOR FOR ADMINISTRATION AND RESOURCES HANAGEMENT

  E1WC1-04-0169-2100295 EPA MGT OF CSC CONTRACT       3/27/92
   Suimary:  A GENERAL LAISSEZ-FAIRE CULTURE THAT AFFECTED EPA'S MANAGEMENT OF
 ITS SUPPORT SERVICES CONTRACT WITH COMPUTER SCIENCES CORPORATION LESSENED EPA
 CONTROL OVER CRITICAL PROGRAM ACTIVITIES AND PERMITTED NUMEROUS PROHIBITED
 AND IMPROPER ACTIONS BY BOTH AGENCY AND CONTRACTOR STAFFS.

   - EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN NUDE:  THE
 AGENCY HAS BEEN WORKING WITH DIG TO RESOLVE OPEN ISSUES. SIGNIFICANT PROGRESS
 HAS BEEN MADE AND ONLY SEVERAL ITEMS REMAIN OUTSTANDING. ON FEBRUARY 26, 1993
 OIG REJECTED OARM'S RESPONSE TO SETTLE TVJD ISSUES.

  = DESIRED TIHETABJE FOR ACHIEVING A NAMACDCNT DECISION:  THE RESPONSE IS
 EXPECTED TO BE COMPLETED BY APRIL 30, 1993.

  IG FGUCUJP STATUS AS OF  3/31/93   El

 E1NMF1-15-0055-210tE91 ERA SYS. SOFTWARE INTEGRITY    9/22/92
  Surmary:  INADEQUATE EMPHASIS ON MAINFRAME SECURITY AND SOFTWARE INTEGRITY,
AND WEAK CONTRACT MANAGEMENT PRACTICES, HAVE INCREASED EPA'S VULNERABILITY TO
WASTE,  FRAUD  AND ABUSE  IN ITS

HIGHLY SENSITIVE ADP SYSTEMS.  ALSO,  EPA COULD RECOVER/USE NEARLY S2.2M WORTH
OF DISK STORAGE SPACE.

  - EXPLANATION OF THE REASONS MUNACDOtT DECISION HAS NOT BEEN HADE:  OIG
REQUESTED ADDITIONAL INFORMATION FROM OARM'S INITIAL  RESPONSE TO THE AUDIT
RECOMMENDATIONS.

  = DESIRED TIMETABLE FOR ACHIEVING A NANACPOT DECISION:  FINAL DETERMINATION
EXPECTED ON APRIL 15, 1993.

 IG FOJUTMP STATUS  AS OF 3/31/93   [2]
                                                OFFICE OF GENERAL COUNSEL

                                                 E1JBF1-05-0175-2100M3 EM. DUJUTH               HM  7/7/92
                                                  Sumy: EPA DID NOT ENSURE THAT $21 MILLION IN CONTRACTS TO SUPPORT THE
                                                AGENCY'S DULUTH ENVIRONMENTAL RESEARCH LABORATORY WERE AWARDED AND MONITORED I*
                                                THE BEST INTERESTS OF THE GOVERNMENT.

                                                  - EXPLANATION OF THE REASONS NANACDCNT DECISION HAS NOT BEEN HADE:  OIG
                                                ACCEPTED THE OFFICE OF ADMINISTRATION AND RESOURCES MANAGEMENT AND THE OFFICE
                                                OF RESEARCH AND DEVELOPMENT'S RESPONSE TO THE AUDIT RECOMMENDATIONS.  THE
                                                OFFICE OF  GENERAL COUNSEL WILL ADDRESS THE ONLY OUTSTANDING ISSUES RELATED T(
                                                THIS AUDIT.

                                                  = DESIRED TIHETABLE FOR ACHIEVING A HANACPCNT DECISION: RESOLUTION IS
                                                EXPECTED BY SEPTEMBER 30, 1993.
                                                 IG FOLLCUP STATUS AS OF 3/31/93  0

                                                GRANTS ADMINISTRATION DIVISION

                                                 E3BST2-03-0452-2400059  CERHA EARLY WARNING              7/ 9/92
                                                  Suimary:   WE DISCLOSED A POSSIBLE CONFLICT  OF INTEREST IN  THE
                                                AWARDING  OF  AN EPA COOPERATIVE  AGREEMENT TO A NON-PROFIT FIRM.
                                                A  REVIEW  IS  IN PROCESS.  INTERIM FINDINGS HAVE RESULTED IN AN
                                                INVESTIGATIVE REFERRAL.

                                                  - EXPLANATION OF THE REASONS  MANAGEMENT DECISION HAS NOT BEEN
                                                HADE:   THE GRANTS ADMINISTRATION DIVISION REVIEWED EARLY WARNINC
                                                REPORT  AND REQUESTED  OIG TO PERFORM A FULL AUDIT.  THIS AUDIT IS
                                                STILL   PENDING.

                                                  = DESIRED  TIHETABLE FOR  ACHIEVING A MANAGEMENT DECISION:

                                                 IG FOLLOWUP STATUS AS OF   3/31/93   [1]  (Requested audit is in process am
                                                draft report expected by end of May 1993.)

                                                E5BKN1-04-0290-2300045 NORTH CAROLINA STATE  UNIV.   NC  3/26/92
                                                  Sunnary:   THIRTY-NINE PROJECTS DID NOT RELATE TO THE GRANT.
                                                OER QUESTIONED 12 PROJECTS  AS UNSUPPORTED.  EXCESS  OVERHEAD WAS
                                                CLAIMED.  CENTER DIRECTOR MISCHARGED TIME.

                                                  - EXPLANATION OF THE REASONS  NANAGEHENT DECISION  HAS NOT BEEN
                                                HADE:   THE COMPLEXITY OF THIS AUDIT HAS REQUIRED NUMEROUS
                                                MEETINGS  WITH OIG, PROGRAM  OFFICE, AND NC STATE.   THE PROGRAM
                                                OFFICE  DOES  NOT AGREE WITH  THE  PROPOSED RESOLUTION.

                                                  = DESIRED  TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION:

                                                IG FOLLOUUP STATUS AS OF   3/31/93   [1]
  OCTOBER 1, 1992 THROUGH MARCH 31, 1993
                                                                                                                                     49

-------
   Assignment Control
   Number
Title
                                Final Report
                                     Issued
Assignment Control
Number
                     Title
Final Report
     Issued
   N3HVJ1-04-0432-2500251 TENNESSEE STATE OF
   *Suimary:
                               TN   12/18/91
    - EXPLANATION OF THE REASONS  MANAGEMENT DECISION HAS NOT BEEN
  MADE:  THE AUDIT REPORT WAS ORIGINALLY ASSIGNED TO REGION 4 FOR
  RESOLUTION. THE GRANT ADMINISTRATION DIVISION IS AWAITING
  ADDITIONAL INFORMATION FROM RECIPIENT IN RESPONSE TO AUDIT
  FINDINGS.

    = DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION:
  RESOLUTION IS EXPECTED BY JULY  15,  1993.

   IG FOLLOUUP STATUS AS OF  3/31/93    [1]

  DIRECTOR OF ADMINISTRATION. RESEARCH TRIANGLE PARK

   E8BHL2-03-0179-2100667 E. H. PECHAN                VA  9/30/92
    Suimary:  WE FOUND NUMEROUS WEAKNESSES SUCH AS AWARDING A
  CONTRACT TO AN   INEXPERIENCED  CONTRACTOR, NUMEROUS AMENDMENTS
  WITH LITTLE OR NO JUSTIFICATION AND POTENTIAL CONFLICT OF
  INTEREST BETWEEN CONTRACTOR AND EPA GRANTEE.   WE QUESTIONED
  $441,768 IN INELIGIBLE CONSULTANT,  DIRECT LABOR & OTHER COSTS.

    - EXPLANATION OF THE REASONS  MANAGEMENT DECISION HAS NOT BEEN
  MADE:  OFFICE SENT ITS RESPONSE TO  THE OIG ON MARCH 31, 1993.
  DIG DID NOT ACCEPT RESPONSE.  CONTRACTOR MUST PROVIDE ADDITIONAL
  INFORMATION TO CONTRACTING OFFICER.   INFORMATION WILL BE
  FURNISHED ON 5/31/93.

    = DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION:

   IG FOLLOUUP STATUS AS OF  3/31/93    [21

  OFFICE OF ACQUISITION MANAGEMENT

  Cost Review and Rate Negotiation  Section

   D9EFL2-03-0299-2100309 COMPUTER  SCIENCE CORP       VA  4/ 6/92
    Suimary:  RESTATEMENT OF TWO  PRIOR FINDINGS (1) VOLUMINOUS

  LABOR TRANSFERS  (2) INADEQUATE SUPPORTING DOCUMENTATION FOR
  LABOR ADJUSTMENTS AND VERBAL AUTHORIZATIONS.

    - EXPLANATION OF THE REASONS  MANAGEMENT DECISION HAS NOT BEEN
  MADE:  A DELAY IN THE RESOLUTION  OF THIS AUDIT WAS CAUSED BY THE
  DEPARTMENT OF DEFENSE BEING THE COGNIZANT AGENCY FOR CSC, RATHER
  THAN EPA.  THE CORRECTIVE ACTION  PLAN FOR THE RECOMMENDATIONS TO
  THIS AUDIT HAVE BEEN APPROVED.

    = DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION:

   IG FOLLOWUP STATUS AS OF  3/31/93    [1]  (Additional audits have been
  requested and completed by DCAA. When the  requested reports are resolved the issues of these
  reports will be resolved also.)

   D9EFL2-03-0300-2100310 COMPUTER  SCIENCE CORP       VA  4/ 6/92
    Sunmary:  SIX INTERNAL CONTROL  WEAKNESSES WERE REPORTED:
  PAYROLL PROCEDURES, RECORDS,  SEGREGATION OF DUTIES, BILLING AND
  TIMEKEEPING RECORDS.

    - EXPLANATION OF THE REASONS  MANAGEMENT DECISION HAS NOT BEEN
  HADE:  A DELAY IN THE RESOLUTION  OF THIS AUDIT WAS CAUSED BY THE
  DEPARTMENT OF DEFENSE BEING  THE COGNIZANT AGENCY FOR CSC, RATHER
  THAN EPA. A REVIEW OF THE  LABOR CHARGING PRACTICES MUST STILL BE
  COMPLETED.  THE CORRECTIVE ACTION PLAN  FOR THE RECOMMENDATIONS TO
  THIS AUDIT HAVE BEEN APPROVED.

    = DESIRED TIMETABLE FOR  ACHIEVING A MANAGEMENT DECISION:

 IG FOLLOUUP STATUS AS OF  3/31/93    11]   (Additional audits have been
requested and completed by DCAA. When the requested reports are resolved the issues of these
reports will be resolved also.)
  D8DML2-02-0121-2100404 MALCOLM PIRNIE
   *Sumary:
                                                                                                               INC
                                                                                                                             NY   6/10/92
                                                 - EXPLANATION  OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN
                                               MADE:  THE DEPARTMENT OF LABOR HAS TAKEN ISSUE  WITH SOME OF THE
                                               COSTS ASSOCIATED WITH THIS AUDIT. NEGOTIATIONS  ARE PENDING. THIS
                                               AUDIT CANNOT BE  RESOLVED UNTIL THE DEPARTMENT OF  LABOR LAW SUIT
                                               IS SETTLED.

                                                 = DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT  DECISION:

                                                IG FOLLOWUP STATUS AS OF  3/31/93   [1]  (OIG agrees with the above status
                                               and does not expect a response until the litigation has been completed.)
                                                D8DML2-02-0122-2100405 MALCOLM PIRNIE  INC
                                                 *Sumary:
                                                      NY  6/10/92
                                                 - EXPLANATION OF  THE REASONS MANAGEMENT DECISION HAS NOT BEEN
                                               MADE:  THE DEPARTMENT  OF LABOR HAS TAKEN ISSUE  WITH SOME OF THE
                                               COSTS ASSOCIATED WITH  THIS AUDIT. NEGOTIATIONS  ARE PENDING. THIS
                                               AUDIT CANNOT BE RESOLVED UNTIL THE DEPARTMENT OF  LABOR LAW SUIT
                                               IS SETTLED.

                                                 = DESIRED TIMETABLE  FOR ACHIEVING A MANAGEMENT  DECISION:

                                                IG FOLLOUUP STATUS AS OF  3/31/93   [1]  (OIG agrees with the above status
                                               and does not expect a response until the litigation has been completed.)

                                                P2DU*8-03-0174-1300105 PHILADELPHIA CITY OF        PA  9/12/91
                                                 Suimary:  PWD CLAIMED THAT OPERATING COSTS WERE ALLOCABLE TO
                                               EPA GRANTS, BUT ALSO CHARGED THESE SAME COSTS TO  THEIR CUSTOMERS
                                               THROUGH THEIR  WATER AND SEWER RATES.

                                                 - EXPLANATION OF  THE REASONS MANAGEMENT DECISION HAS NOT BEEN
                                               MADE:  THE OIG IS RESEARCHING INTERNAL EPA  APPEAL PROCEDURES
                                               BECAUSE OF LEGAL  ISSUES INVOLVED.  RESOLUTION OF  THIS AUDIT IS
                                               PENDING REVIEW OF THESE LEGAL ISSUES.  ONCE THESE ISSUES ARE
                                               RESOLVED, STEPS TO  CLOSE THIS AUDIT WILL CONTINUE.

                                                 = DESIRED TIMETABLE  FOR ACHIEVING A MANAGEMENT  DECISION:
                                                 IG FOLLOUUP  STATUS AS OF  3/31/93    [1]

                                                 P8AAL2-03-0072-2100087 ICF CORP
                                                 Sunnary:  (PREAWARD AUDIT UNDER NEGOTIATION)
                                                      VA 12/ 4/91
                                                 - EXPLANATION OF THE REASONS MANAGEMENT  DECISION HAS NOT BEEN
                                               MADE:  THIS  CONTRACT HAS NOT BEEN AWARDED.

                                                 = DESIRED  TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION:  THE
                                               CONTRACT  IS  EXPECTED TO BE AWARDED BY APRIL  30,  1993.
                                                 IG  FOLLOUUP  STATUS AS OF  3/31/93    [1]

                                                 P9AKN2-03-0547-2300092 ICF CORP
                                                 Sunnary:  (PREAWARD AUDIT UNDER NEGOTIATION)
                                                       VA  9/30/92
                                                  - EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN
                                               MADE:   CONTRACT AWARD DETERMINATION  HAS  NOT BEEN MADE.

                                                  = DESIRED  TIMETABLE FOR ACHIEVING  A MANAGEMENT DECISION:

                                                 IG FOLLOUUP STATUS AS OF  3/31/93    [1]   (An explanation was not provided
                                               by EPA relating to the reasons a management decision  had. not been made at 3/31 /93.  A desired
                                               timetable for achieving a management decision was also not provided.)

                                                 D8EML2-03-0302-2100315 GILBERT ASSOCIATES INC      PA  4/ 7/92
                                                  Sunnary:   DCAA DETERMINED THAT GILBERT  COMMONWEALTH OWES THE
                                               FEDERAL GOVERNMENT $2,538,438 AS A CREDIT REFUND DUE TO THE
                                               TERMINATION  OF A DEFINED BENEFIT PENSION  PLAN  AND EPA HAS A
                                               PORTION OF $1,285.

                                                  - EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN
                                               MADE:
    50
                                                 = DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION:

                                                 IG FOLLOUUP STATUS AS OF  3/31/93    11]   (An explanation was not provided
                                               by EPA relating to the reasons a management decision had not been made at 3/31 /93.  A desired
                                               timetable for achieving a management decision was also not provided.)

                                                                              OFFICE OF THE INSPECTOR GENEFSAl

-------
    Assignment Control
    Number
Title
Final Report
     Issued
Assignment Control
Number              Title
Final Report
     Issued
 P8ASL2-03-0329-2100390 ICF CORP                      VA  5/27/92
  Summary:  (PREAWARD AUDIT UNDER NEGOTIATION)

  - EXPLANATION OF  THE REASONS MANAGEMENT DECISION  HAS NOT BEEN
4ADE:  THE CONTRACT HAS NOT BEEN AWARDED.

  = DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION:

 IG FOLLOUUP STATUS AS OF  3/31/93    [1]   (An explanation was not provided
>y EPA relating to the reasons a management decision had not been made at 3/31/93. A desired
metabto for achieving a management decision was also not provided)
 P8AML2-03-0357-2100419 ICF CORP
  Sunmary:  (PREAUARD AUDIT UNDER  NEGOTIATION)
                             VA  6/16/92
  - EXPLANATION OF  THE REASONS MANAGEMENT DECISION  HAS NOT BEEN
 ADE:   CONTRACT AWARD  DETERMINATION  HAS NOT BEEN MADE.

  = DESIRED TIMETABLE  FOR ACHIEVING  A MANAGEMENT DECISION:

  IG FOLLOUUP STATUS AS OF  3/31/93    [1]  (An explanation was not provided by
 EPA relating to the reasons a management decision had not been made at 3/31/93. A desired
 timetable for achieving a management decision was also not provided.)

  D8DML2-03-0549-2100536 VIGYAN  INC                   VA  8/31/92
   Senary:  DCAA AUDITED THE DIRECT AND INDIRECT  COSTS FOR
 CY1988.  THE AUDIT OF DIRECT COSTS DISCLOSED NO EXCEPTIONS.  DCAA
 DID NOT  QUESTION ANY COSTS  IN  THE OH EXPENSE  POOLS.  DCAA
 QUESTIONED  .1% OF  THE G&E EXPENSE POOL RELATED TO DIRECT LABOR  IN
 THE ALLOCATION BASE.

   - EXPLANATION OF THE REASONS MANAGEMENT  DECISION HAS NOT BEEN
 MADE:  NEGOTIATIONS COMPLETE.   AWAITING CONTRACTOR TO SIGN
 AGREEMENT AND  RETURN.

   = DESIRED TIMETABLE  FOR  ACHIEVING A MANAGEMENT DECISION:
 EXPECT CLOSURE BY APRIL  30,  1993.

   IG FOLLOUUP STATUS AS OF   3/31/93    [1]

  D8EML2-03-0563-2100619  ROY F  UESTON                 PA  9/16/92
   Suoaary:   DCAA FOUND THAT THE CONTRACTOR'S  INTERNAL CONTROLS
 PERTAINING  TO  THE ACCOUNTING  SEGREGATION AND  DELETION OF
 UNALLOWABLE COSTS AS REQUIRED  BY FAR  31.201-6 AND CAS 405 ARE
 INADEQUATE.

   - EXPLANATION OF THE REASONS MANAGEMENT  DECISION HAS NOT BEEN
 MADE:

   = DESIRED TIMETABLE  FOR  ACHIEVING A MANAGEMENT DECISION:

   IG FOLLOUUP STATUS AS OF  3/31/93    11]  (An explanation was not provided by
 EPA relating to the reasons a management decision had not been made at 3/31/83. A desired
 timetable for achieving a management decision was also not provided.)

  P8AAN2-03-0445-2300059  ICF CORP                     VA   7/16/92
   Suonry:   (PREAUARD  AUDIT UNDER NEGOTIATION)

   - EXPLANATION OF THE REASONS MANAGEMENT  DECISION HAS NOT BEEN
 MADE:  THE  CONTRACTOR  MUST REVISE  ITS POLICY  AND PROCEDURES AND
 SEND TO  EPA FOR  EVALUATION.  ONCE THIS IS RECEIVED, PROCEDURES  TO
 CLOSE THIS  AUDIT WILL  CONTINUE.

   = DESIRED TIMETABLE  FOR  ACHIEVING A MANAGEMENT DECISION:

   IG FOLLOUUP STATUS AS OF   3/31/93    [1]   (A desired timetable for achieving a
 management decision was not provided by EPA.)
                 D8DML2-04-0182-2100420 CLAUDE TERRY & ASSOCIATES   GA  6/17/92
                  *Sumnary:

                  - EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN
                MADE:  THIS CONTRACT IS IN ACTIVE NEGOTIATIONS.

                  = DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION:

                 IG FOLLOUUP  STATUS AS OF  3/31/93   [1]  (An explanation was not provide.
                by EPA relating to the reasons a management decision had not been made at 3/31 /93. A desirec
                timetable for achieving a management decision was also not provided.)

                 D8DML2-04-0136-2100422 CLAUDE TERRY & ASSOCIATES   GA  6/17/92
                  •Summary:

                  - EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEI
                MADE:  THIS CONTRACT IS IN ACTIVE NEGOTIATIONS.

                  = DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION:

                 IG FOLLOUUP  STATUS AS OF  3/31/93   [1]  (An explanation was not provide.
                by EPA relating to the reasons a management decision had not been made at 3/31 /93. A desirec
                timetable for achieving a management decision was also not provided.)

                 D8DML2-04-0181-2100423 CLAUDE TERRY & ASSOCIATES   GA  6/17/92
                  •Sumnary:

                  - EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEI
                MADE:  THIS CONTRACT IS IN ACTIVE NEGOTIATIONS.

                  = DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION:

                 IG FOLLOUUP  STATUS AS OF  3/31/93   [1]  (An explanation was not provide.
                by EPA relating to the reasons a management decision had not been made at
                3/31/93. A desired timetable for achieving a management decision was also not provided.)

                 D9BGL2-04-0368-2100587 VESTA TECHNOLOGY LTD         FL  9/ 9/92
                 Summary:  VESTA PROVIDED INCINERATION SERVICES TO  REIDEL
                ENVIRONMENTAL  SERVICES. DELAY  CLAIM DUE TO FAILED TEST BURNS &
                DEMOBILIZATION.   $113 THOUSAND QUESTIONED ON DELAY.   $129
                THOUSAND QUESTIONED ON EXTENDED OVERHEAD.  $264  THOUSAND
                UNAUDITED SUB  CONTRACTOR (FLINT).   $88 THOUSAND  PROFIT
                QUESTIONED.

                 - EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN
                MADE:

                 = DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION:

                 IG FOLLOUUP STATUS AS OF   3/31/93    [1]   (An explanation was not provide,
                by EPA relating to the reasons a management decision had not been made at 3/31/93. A desirec
                timetable for achieving a management decision was also not provided.)

                 P8DMLO-05-0421-2100376 PEI ASSOC FY 90              OH  5/20/92
                 Sunmary:  THE  AUDIT QUESTIONED  ABOUT  $100,000  AS INELIGIBLE
                AND  $248,000 AS  UNSUPPORTED.    IN ADDITION,  $980,000  IS UNAUDITE
                PENDING RECEIPT  OF  A  REPORT FROM DCAA.

                 -  EXPLANATION  OF  THE  REASONS MANAGEMENT DECISION HAS NOT BEEN
                MADE:  THE AUDIT  IS AWAITING  REVIEW OF  GENERAL AND
                ADMINISTRATIVE COSTS.   ONCE DCAA AUDIT  COMPLETES REVIEW OF
                CORPORATE ALLOCATION  IS COMPLETE, THE AUDIT  WILL BE  CLOSED.

                 =  DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION:

                 IG FOLLOUUP STATUS AS OF   3/31/93    [1]   (A desired timetable for achievin;
                a management decision was not provided by EPA.)
     OCTOBER 1, 1992 THROUGH MARCH 31, 1993
                                                                                                                51

-------
 Assignment Control
 Number
Title
                                Final Report
                                     Issued
 Assignment Control
 Number
Title
Final Report
     Issued
 P8DML1-05-0189-2100528 PEI ASSOC FY 85             OH  8/20/92
  Suimary:  WE HAVE QUESTIONED $130,000 INELIGIBLE  AND $362,546
IN UNSUPPORTED THE PROPOSED INDIRECT RATES WERE  ADJUSTED
ACCORDINGLY.
  - EXPLANATION  OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN
HADE:  PEI  HAS PROVIDED CONTRACTING OFFICER  WITH ADDITIONAL
DOCUMENTATION  FOR REVIEW.  A SUPPLEMENTAL AUDIT  HAS BEEN
REQUESTED.  THE OIG WILL PERFORM THE AUDIT AND  ISSUE SUPPLEMENTAL
REPORT.  ONCE SUPPLEMENTAL AUDIT  IS RECEIVED, PROCEDURES TO CLOSE
AUDIT  WILL  CONTINUE.

  = DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION:

  IG FOLLOUUP STATUS AS OF  3/31/93   [1]  (The OIG received the above March
1, 1993 request for a supplemental audit. We reviewed the response submitted to EPA by PEI and
determined that no further audit work was necessary or appropriate. We responded to EPA on March
17,1993 with recommended adjustments. We considered this letter satisfactory to respond to EPA's
request.  EPA still has to respond to the initial audit report above.)

  P8BMP1-05-0335-2400073 PEI ASSOC  (FY 85)            OH  9/ 9/92
  SuMary:   THE  REVIEW FOUND $224,781 OF INELIGIBLE AND $195,886
OF UNSUPPORTED COSTS.

  - EXPLANATION  OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN
MADE:  PEI HAS  PROVIDED CONTRACTING OFFICER WITH  ADDITIONAL
DOCUMENTATION. A SUPPLEMENTAL AUDIT HAS BEEN REQUESTED. THE OIG
WILL   PERFORM  THE AUDIT AND ISSUE SUPPLEMENTAL REPORT.  ONCE
SUPPLEMENTAL AUDIT IS RECEIVED, PROCEDURES TO CLOSE AUDIT WILL
CONTINUE.

  = DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION:
  IG FOLLOUUP STATUS AS OF  3/31/93   [1]   (The OK3 received the above March
 1,1993 request for a supplemental audit. We reviewed the response submitted to EPA by PEI and
 determined that no further audit work was necessary or appropriate. We responded to EPA on March
 17, 1993 with recommended adjustments. We considered this letter satisfactory to respond to EPA's
 request. EPA still has to respond to the initial audit report above.)
  P9DHL9-10-0110-1100108 RES FY86 INDIRECT COSTS
   •Suoaary:
                                 OR  1/24/91
 P9DHL9-10-0174-2100504 CH2M 88 OH                   OR  7/30/92
  Suraiary:  COSTS  QUESTIONED OF $17,150,592  ARE UNALLOWABLE  FOR
FEDERAL PARTICIPATION.    SIGNIFICANT  INTERNAL CONTROL AND
COMPLIANCE WEAKNESSES WERE ALSO NOTED.

  - EXPLANATION OF THE REASONS MANAGEMENT  DECISION HAS NOT BEEN
MADE:

  = DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION:
NEGOTIATIONS ARE EXPECTED TO BE COMPLETED  ON APRIL 21, 1993.
POST NEGOTIATION MEMORANDUMS WILL BE  FORWARDED TO THE OIG.

 IG FOLLOUUP STATUS AS OF  3/31/93    II]

 P9DHLO-10-0085-2100505 CH2M 89 OH                   OR  7/30/92
  Suimary:  COSTS  QUESTIONED OF $16,474,583  ARE UNALLOWABLE  FOR
FEDERAL PARTICIPATION SIGNIFICANT INTERNAL CONTROL AND
COMPLIANCE WEAKNESSES WERE ALSO NOTED.

  - EXPLANATION OF THE REASONS MANAGEMENT  DECISION HAS NOT BEEN
MADE:

  = DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION:
NEGOTIATIONS ARE EXPECTED TO BE COMPLETED  ON APRIL 21, 1993.
POST NEGOTIATION MEMORANDUMS WILL BE  FORWARDED TO THE OIG.

 IG FOLLOUUP STATUS AS OF  3/31/93    [1]

 P9DHL9-10-0148-2100642 RES 88 OH                    OR  9/28/92
  Suimary:  RES INCLUDED INELIGIBLE COSTS  IN ITS PROPOSED 1988
FINAL INDIRECT COST RATES.  AS A RESULT RES  MAY HAVE BEEN
REIMBURSED FOR UNALLOWABLE COSTS UNDER EPA CONTRACTS.

  - EXPLANATION OF THE REASONS MANAGEMENT  DECISION HAS NOT BEEN
MADE:  THE OIG ASKED THAT NEGOTIATIONS BE  SUSPENDED PENDING  THE
RESOLUTION OF OTHER ISSUES THAT MAY IMPACT THE OUTCOME OF THIS
AUDIT. OIG WILL ISSUE REVISED AUDIT REPORTS.  ONCE THESE ISSUES
ARE RESOLVED, STEPS TO CLOSE THIS AUDIT WILL CONTINUE.

  = DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION:
   - EXPLANATION OF  THE REASONS MANAGEMENT DECISION HAS NOT BEEN
 MADE:  THE OIG ASKED  THAT NEGOTIATIONS BE SUSPENDED PENDING THE   IG FOLLOUUP STATUS AS OF   3/31/93   [1]  (OIG agrees with the above status
 RESOLUTION OF OTHER ISSUES THAT MAY IMPACT  THE  OUTCOME OF THIS   ^Jo" not expert a r«Hx«1se mill tf» review ha. b«m compl««l. The OIG doe. not issue
 AUDIT.  ONCE THESE  ISSUES ARE RESOLVED,  STEPS TO CLOSE THIS AUDIT revl   repo '
 UILL CONTINUE
               '                                                     OFFICE OF ACQUISITION MANAGEMENT
   = DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION:

  IG FOLLOUUP  STATUS AS OF  3/31/93   [1]  (OK3 agree, with the above status
 and does not expect a response until the review has been completed.)
                                              Durham Contracts Management Division

                                               D8AML2-03-0399-2100603 EXPERIMENTAL PATHOLOGY LABS
                                                Suwary:  (PREAUARD AUDIT UNDER NEGOTIATION)
                                                          9/10/92
  P9DHLO-10-0096-2100304 RES 87 OH
   •SuMary:
                                 OR  3/31/92
   - EXPLANATION  OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN
 MADE:  THE OIG ASKED THAT NEGOTIATIONS BE SUSPENDED PENDING THE
 RESOLUTION OF OTHER ISSUES THAT MAY IMPACT  THE  OUTCOME OF THIS
 AUDIT.  ONCE THESE  ISSUES  ARE RESOLVED,  STEPS TO CLOSE THIS AUDIT
 WILL CONTINUE.
   = DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION:

  IG FOLLOUUP STATUS AS OF  3/31/93   [1]  (OIG agrees with the above status
 and does not expect a response until the review has been completed.)

  P9DH*8-10-0080-2100503 CH2M 87 OH                   OR  7/30/92
   Suimary:   COSTS QUESTIONED OF $7,126,600  ARE UNALLOWABLE  FOR
 FEDERAL  PARTICIPATION.   SIGNIFICANT INTERNAL CONTROL AND
 COMPLIANCE WEAKNESSES WERE ALSO NOTED.

   - EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT  BEEN
 MADE:

   = DESIRED  TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION:
 NEGOTIATIONS ARE EXPECTED TO BE COMPLETED ON APRIL 21, 1993.
 POST  NEGOTIATION MEMORANDUMS WILL BE FORWARDED TO THE OIG.

   IG FOLLOUUP STATUS AS OF  3/31/93   [1]
                                                - EXPLANATION OF  THE REASONS MANAGEMENT DECISION HAS NOT BEEN
                                              HADE:  NEGOTIATIONS HAVE  BEEN CONCLUDED AND A  SOURCE SELECTED.
                                              THE CONTRACT FILE IS UNDER REVIEW.

                                                = DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION:  AN
                                              AWARD TO ANOTHER FIRM IS  EXPECTED BY MAY 1,  1993.

                                                IG  FOLLOUUP  STATUS AS OF  3/31/93    HI

                                                D8CAL2-03-0433-2100604 ENERGY AND ENVIRONMENTAL    VA  9/10/92
                                                 SuHary:  THE CONTRACTOR'S FINAL VOUCHER INCLUDED COSTS  IN
                                               EXCESS OF CONTRACT LIMITATIONS TOTALING $51,622.

                                                 -  EXPLANATION OF THE REASONS MANAGEMENT  DECISION HAS NOT BEEN
                                               MADE:  THIS CONTRACT CLOSE OUT HAS COST QUESTIONED DUE TO
                                               CONTRACT OVERRUN.  IN ADDITION, THE FEE MUST BE ADJUSTED SINCE
                                               LEVEL OF EFFORT WAS NOT  MET.  THE  CONTRACTOR HAS BEEN REQUESTED TO
                                               PROVIDE DATA  FOR CONTRACTOR OFFICER DECISION ON BOTH ISSUES.

                                                 =  DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION:
                                               RESOLUTION IS EXPECTED BY MAY 15, 1993.

                                                IG  FOLLOUUP  STATUS AS OF  3/31/93    [11
  52
                                                                                OFFICE OF THE INSPECTOR GENERAL

-------
  Assignment Control
  Number
Title
Final Report
     Issued
                                              Assignment Control
                                              Number
Title
Final Report
     Issued
 D8CPL2-03-0432-2100620 MIRANDA ASSOCIATES  INC      DC  9/16/92
  SuMary:  DCAA QUESTIONED $278,979 DUE TO  1) THE  LIMITATIONS OF
FUNDS CLAUSE, 2) OVERSTATED OVERHEAD COSTS, AND 3) A
COMPUTATIONAL ERROR.

  - EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN
HADE:  THE CONTRACT HAS BEEN CLOSED  OUT.  INDIRECT COST QUESTIONED
DUE TO CLAIMS IN EXCESS OF CONTRACT CEILING.  IN ADDITION, FEE
DETERMINATION MUST BE MADE UNDER LEVEL OF EFFORT. THE CONTRACTOR
REQUESTED TO CERTIFY LEVEL OF EFFORT SO THAT A CONTRACTOR OFFICER
DECISION CAN BE MADE.

  = DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION:
RESOLUTION IS EXPECTED BY MAY 14, 1993.

 IG FOLLOUUP STATUS AS OF  3/31/93   [1]

 D8AML2-04-0335-2100440 ALPHA-GAMMA TECHNOLOGIES INCNC  6/25/92
  Summary:  (PREAWARD AUDIT UNDER NEGOTIATION)

  - EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN
MADE:  THE COMPETITIVE RANGE HAS  NOT BEEN ESTABLISHED BECAUSE THE
TECHNICAL EVALUATION PANEL HAS NOT RESPONDED TO  REVIEW  COMMENTS.
  = DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION:  THE
PROJECTED AWARD DATE IS JUNE 30, 1993.
 IG FOLLOUUP STATUS AS OF  3/31/93    [1]
 D8ANL2-04-0242-2100467 EC/R INC.
      ary:  (PREAWARD AUDIT UNDER NEGOTIATION)
                              NC  7/10/92
  - EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN
MADE:  THE COMPETITIVE RANGE HAS NOT  BEEN ESTABLISHED  BECAUSE THE
TECHNICAL EVALUATION PANEL HAS NOT RESPONDED TO REVIEW COMMENTS.

  = DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION:  THE
PROJECTED AWARD DATE IS JUNE 30,  1993.

 IG FOLLOUUP STATUS AS OF  3/31/93    [1]

 D8AML2-04-0362-2100474 ANALYTICAL TESTING  CONSULT  NC  7/15/92
  Summary:  (PREAWARD AUDIT UNDER NEGOTIATION)

  - EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN
MADE:  THE COMPETITIVE RANGE HAS NOT  BEEN ESTABLISHED  BECAUSE THE
TECHNICAL REVIEW PANEL HAS NOT RESPONDED TO REVIEW COMMENTS.

  = DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION:  THE
PROJECTED AWARD DATE IS JUNE 30,  1993.
 IG FOLLOUUP STATUS AS OF  3/31/93    [1]

 P8AHP2-05-0301-2400052 EQM (AIR)
  Suimary:  (PREAUARD AUDIT UNDER NEGOTIATION)
                              OH  7/ 2/92
  - EXPLANATION OF THE REASONS MANAGEMENT DECISION  HAS NOT  BEEN
MADE:  THE COMPETITIVE RANGE HAS NOT BEEN ESTABLISHED  BECAUSE
THE TECHNICAL EVALUATION PANEL HAS NOT RESPONDED TO REVIEW
COMMENTS.

  = DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION:   THE
PROJECTED AWARD DATE IS JUNE 30, 1993.

 IG FOLLOUUP STATUS AS OF  3/31/93    [1]

 D8AML2-09-0175-2100457 MAXWELL LABORATORIES  INC PA CA  7/  7/92
  Summary:  (PREAUARD AUDIT UNDER NEGOTIATION)

  - EXPLANATION OF THE REASONS MANAGEMENT DECISION  HAS NOT  BEEN
HADE:  THE PROCUREMENT WAS PUT ON HOLD DUE TO A DELAY  IN
APPROVAL OF THE PROCUREMENT REQUEST, WHICH WAS RECEIVED IN
NOVEMBER 1992.

  = DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION:   THE
PROJECTED AWARD DATE IS JUNE 15, 1993.

  IG  FOLLOUUP  STATUS AS OF  3/31/93    [1]
               OFFICE  OF ACQUISITION MANAGEMENT

               Financial Analysis Branch

                 D9BFL2-03-0367-2100622 COMPUTER SCIENCE CORP       VA  9/17/92
                 Suimary:  DCAA  QUESTIONED 7,692 LABOR HOURS IN EXCESS OF THOSE
               AUTHORIZED IN  THE CONTRACT.  DCAA WAS UNABLE TO DETERMINE IF
               HOURS BILLED WERE IN  ACCORDANCE WITH THE DOPO'S MEMORANDUM.

                 -  EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN
               MADE:   THE CONTRACTING OFFICER IS AWAITING CONTRACTOR RESPONSE
               TO ISSUES IN DCAA AUDIT REPORT.

                 =  DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION:

                IG  FOLLOUUP STATUS AS OF  3/31/93   [1]  (A desired timetable for achieving
               a management decision was not provided by EPA}

                P8BMN1-03-0146-2300014 O&R MANAGEMENT CORPORATION  HD 11/ 5/91
                 Summary:   O&R MANAGEMENT CLAIMED $557,442 OF OTHER DIRECT
               COSTS.  ONE HUNDRED PERCENT OF THE CONTRACT WAS QUESTIONED
               BECAUSE O&R DID NOT MAINTAIN RECORDS.

                 -  EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN
               HADE:  THE  CONTRACTING OFFICER IS  WRITING A DECISION ON THE
               DISALLOWANCE OF COST  CLAIMED BY CONTRACTOR IN AUDIT REPORT.

                 =  DESIRED TIMETABLE  FOR ACHIEVING A  MANAGEMENT DECISION:   THIS
               AUDIT SHOULD BE CLOSED  SEPTEMBER 30,  1993.

                IG  FOLLOUUP STATUS AS OF  3/31/93   [1]

               D8EMP2-03-0309-2400071 COMPUTER SCIENCE CORP       VA  9/  9/92
                 Summary:  THE LABOR  ADJUSTMENTS  SELECTED  DURING  DCAA'S AUDIT
               WERE UNACCEPTABLE  BECAUSE  THE  CONTRACTOR  DID  NOT PROVIDE
               SUFFICIENT  CORROBORATING  EVIDENCE.

                 - EXPLANATION OF THE  REASONS MANAGEMENT DECISION HAS NOT  BEEN
              HADE:  A RESPONSE TO THE  DCAA  LABOR ADJUSTMENT AUDIT  IS BEING
              PREPARED.    SUBSEQUENT  TO  THIS  RESPONSE,  DCAA WILL  PERFORM A
               FINAL DIRECT COST AUDIT.

                = DESIRED TIMETABLE  FOR  ACHIEVING A MANAGEMENT DECISION:  ONCE
              RESOLUTION OF AUDIT #2400072 OCCURS, THIS AUDIT  WILL  BE
              RESOLVED.

                IG  FOLLOUUP STATUS AS OF  3/31/93   [3]

                D9EFP2-03-0308-2400072 COMPUTER SCIENCE CORP       VA  9/ 9/92
                 Sumary:   DCAA'S AUDIT  DISCLOSED NUMEROUS INADEQUATELY
               EXPLAINED AND  DOCUMENTED  LABOR ADJUSTMENTS FROM 68-01-6360
               68-01-3840, 68-01-6363, AND 68-01-6639.

                 -  EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN
               MADE:  DCAA WAS PROVIDED A DRAFT RESPONSE AND BEGAN CALCULATING  A
               REVISED POSITION.   ANALYSIS OF THE INITIAL IMPACTS RESULTED  IN
               UNDISCLOSED AUDIT ISSUES.   A MEETING WITH DCAA IS PLANNED.

                 =  DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION:
               RESOLUTION  IS  EXPECTED BY SEPTEMBER 30, 1993.

                IG  FOLLOUUP STATUS AS OF  3/31/93   [33

               P9AHN9-05-0347-0300036 OH MATERIALS (PR EQ RATES)  OH  3/27/90
                 Summary:   (PREAUARD  AUDIT UNDER  NEGOTIATION)

                 -  EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT  BEEN
               MADE:  NEGOTIATIONS ARE PENDING. EPA REQUESTED  FURTHER AUDITS ON
               THE CONTRACTOR'S EQUIPMENT UTILIZATION RATES FOR 1990 IN ORDER TO
               RESOLVE THESE  COSTS. RATES FROM 1987 THROUGH  1989 SHOULD BE
               RESOLVED WITHIN TWELVE  MONTHS  FROM RECEIPT  OF  THESE AUDITS.

                = DESIRED TIMETABLE  FOR ACHIEVING A MANAGEMENT DECISION:

                IG  FOLLOUUP STATUS AS  OF  3/31/93  [1]  (Ongoing aud.ts on the contractor's
               equipment utilization rates will not help in the resolution of this audit since the audits involve different
              fiscal periods.)
  OCTOBER 1, 1992 THROUGH MARCH 31, 1993
                                                                                                                                53

-------
  Assignment Control
  Number
Title
Final Report
     Issued
  P9AHNO-05-0260-0300047 OH MATERIALS (PR EQ RATES)  OH  4/27/90
   Sumary:   CPREAUARD AUDIT UNDER  NEGOTIATION)

   - EXPLANATION  OF THE REASONS MANAGEMENT DECISION HAS NOT  BEEN
 HADE:  AWAITING  CONTRACTOR PROPOSAL  TO FIX FINAL EQUIPMENT  RATES
 SINCE SEPTEMBER  1992. CONTRACTOR INFORMED THAT EPA WILL PROCEED
 TO UNILATERALLY  SET  RATES IF NO RESPONSE  IS RECEIVED BY APRIL  17,
 1993.

   = DESIRED  TIMETABLE FOR ACHIEVING  A MANAGEMENT DECISION:
  IG FOLLOUUP STATUS AS OF  3/31/93
 management decision was not provided by EPA.)
                 [1]   (A desired timetable for achieving a
  D9BGL2-05-0342-2100609 UARZYN ENG                   UI  9/14/92
   Sumary:  THE  CONTRACTOR'S FINAL VOUCHER INCLUDED $40,420  IN
 ALLOWABLE COSTS  IN EXCESS OF CONTRACT  LIMITATION.

   - EXPLANATION  OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN
 MADE:  THE CONTRACTING OFFICER HAS DETERMINED THAT CONTRACTOR  IS
 ENTITLED TO QUESTIONED COSTS IN EXCESS OF CONTRACT FUNDING
 PENDING SUPERVISORY APPROVAL.  THE PROJECT OFFICER IS IN THE
 PROCESS OF AUTHORIZING ADDITIONAL FUNDING TO PAY THE FINAL
 CLAIMED CONTRACT COST.

   = DESIRED TIMETABLE FOR ACHIEVING A  MANAGEMENT DECISION:
  IG FOLLOUUP STATUS AS OF  3/31/93
 management decision was not provided by EPA.)
                 [1]   (A desired timetable for achieving a
 P9AHN1-05-0144-2300023 OHM REM ERCS2 22 FY 89
  Smmary:   CPREAUARD AUDIT UNDER  NEGOTIATION)
                                OH 12/26/91
  - EXPLANATION  OF THE REASONS MANAGEMENT DECISION HAS  NOT BEEN
MADE:  THE CONTRACTING OFFICER HAS  BEEN AWAITING CONTRACTOR
PROPOSAL TO  FIX  FINAL EQUIPMENT  RATES SINCE SEPTEMBER 1992.
CONTRACTOR INFORMED THAT EPA WILL PROCEED TO UNILATERALLY SET
RATES  IF NO  RESPONSE IS RECEIVED BY APRIL 17, 1993.

  = DESIRED  TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION:
 IG FOLLOUUP STATUS AS OF  3/31/93
a management decision was not provided by EPA.)
                 C11  (A desired timetable for achieving
 P9AHN1-05-0143-2300024 OHM  REN ERCS2 Z1 FY 89
  Suimary:   CPREAUARD AUDIT  UNDER NEGOTIATION)
                                OH 12/27/91
  - EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN
HADE:   NEGOTIATIONS ARE STILL  PENDING. EPA REQUESTED  FURTHER
AUDITS  ON  THE CONTRACTOR'S  EQUIPMENT UTILIZATION  RATES FOR 1990
IN ORDER TO RESOLVE THESE COSTS.  RATES FROM  1987  THROUGH 1989
SHOULD  BE  RESOLVED WITHIN TWELVE  MONTHS FROM RECEIPT  OF THESE
AUDITS.

  = DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT  DECISION:

  IG FOLLOUUP STATUS AS OF   3/31/93    [1]  (Ongoing audits on the
contractor's equipment utilization rates will not help in the resolution of this audit since the audits
involve different fiscal periods.)

  P8BMPO-05-0422-2400046 PEI ASSOC FY 90             OH  6/ 2/92
  Suimary:  REVIEW OF INCURRED COSTS  IS INCOMPLETE BECAUSE
AUDITED INDIRECT RATES HAVE NOT BEEN  FINALIZED  AND APPLIED.

  - EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN
MADE:   PEI HAS PROVIDED EPA WITH ADDITIONAL  DATA/DOCUMENTATION
FOR REVIEW. A SUPPLEMENTAL  AUDIT HAS BEEN REQUESTED.  THE DIG
WILL  PERFORM AUDIT AND ISSUE SUPPLEMENTAL REPORT.

  = DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION:  THIS
AUDIT SHOULD BE RESOLVED BY JUNE 30,  1993.

  IG  FOLLOUUP STATUS AS OF   3/31/93    [1]
Assignment Control
Number
                                                                    Title
Final Report
     Issued
                D8CHL2-09-0319-2100524 GEO RESOURCE  CONSULTANTS FN   CA  8/12/92
                 •Summary:

                  - EXPLANATION OF  THE REASONS MANAGEMENT DECISION  HAS NOT BEEN
                HADE:  ORIGINAL DCAA REPORT ISSUED BY  THE OIG WAS INCOMPLETE IN
                THAT THE REPORT DID NOT ADDRESS ALL  OF THE COSTS CLAIMED UNDER
                THE CONTRACT.  A  SUPPLEMENTAL DCAA REPORT WAS ISSUED  TO ADDRESS
                THE CLAIMED COSTS.   THE CONTRACTING  OFFICER IS PREPARING
                NEGOTIATION POSITION.

                  = DESIRED TIMETABLE FOR ACHIEVING  A  MANAGEMENT DECISION:

                 IG FOLLOUUP STATUS AS OF  3/31/93    [1]   (A desired timetable for reaching a
                management decision was not provided by EPA.)

                OFFICE OF ACQUISITION MANAGEMENT

                Washington Cost Advisory Branch

                 P8AML2-03-0152-2100146 ICF CORP                     VA  12/20/91
                  Suimary:  (PREAWARD AUDIT UNDER NEGOTIATION)

                  - EXPLANATION OF  THE REASONS MANAGEMENT DECISION  HAS NOT BEEN
                MADE:  CONTRACT HAS NOT BEEN AWARDED.

                  = DESIRED TIMETABLE  FOR ACHIEVING A MANAGEMENT DECISION:

                 IG FOLLOUUP STATUS AS OF  3/31/93    [1]   (An explanation  was not provided by
                EPA relating to the reasons a management decision had not been made at 3/31 /93. A desired
                timetable for achieving a management decision was also not provided.)

                 D9AKL2-03-0115-2100169 DYNAMAC                      MD  1/ 6/92
                  Suimary:  (PREAWARD  AUDIT UNDER NEGOTIATION)

                  - EXPLANATION OF  THE REASONS MANAGEMENT DECISION  HAS NOT BEEN
                MADE:

                  = DESIRED TIMETABLE  FOR ACHIEVING A  MANAGEMENT DECISION:

                 IG FOLLOUUP STATUS AS OF  3/31/93   [1]   (An explanation was not provided by
                EPA relating to the reasons a management decision had not been made at 3/31/93. A desired
                timetable for achieving a management decision was also not provided.)
                D9AKL2-03-0120-2100181  APEX ENVIRONMENTAL
                  Sumary:  (PREAWARD AUDIT UNDER NEGOTIATION)
                                                                                                                              MD
                                                                                                                                     6/92
                                                  - EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN
                                                MADE:   CONTRACT AWARD DETERMINATION HAS NOT  BEEN MADE.

                                                  = DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION:

                                                 IG FOLLOUUP STATUS AS OF  3/31/93   [1]  (An explanation was not provided by
                                                EPA relating to the reasons a management decision had not been made at 3/31 /93. A desired
                                                timetable for achieving a management decision was also not provided.)

                                                 D8AML2-03-0124-2100185 EG&G  WASHINGTON ANALYTICAL  MD  I/ 6/92
                                                  Suqmary:   CPREAUARD AUDIT UNDER NEGOTIATION)

                                                  - EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN
                                                MADE:

                                                  = DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION:

                                                 IG FOLLOUUP STATUS AS OF  3/31/93   [1]  (An explanation was not provided by
                                                EPA relating to the reasons a management decision had not been made at 3/31 /93. A desired
                                                timetable for achieving a management decision was also not provided.)
                                                 D9AGL2-03-0305-2100490 NUS  CORP - HALLIBURTON
                                                  Summary:   (PREAWARD AUDIT  UNDER NEGOTIATION)
                                                                      PA  7/23/92
                                                  - EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN
                                                MADE:   CONTRACT AWARD DETERMINATION HAS NOT  BEEN MADE.

                                                  = DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION:

                                                 IG FOLLOUUP STATUS AS OF  3/31/93   [1]   (An explanation was not provided by
                                                EPA relating to the reasons a management decision had not been made at 3/31/93. A desired
                                                timetable for achieving a management decision was also not provided.)
   54
                                                                                  OFFICE OF THE INSPECTOR GENERAL

-------
 Assignment Control
 Number              Title
 Final Report
      Issued
Assignment Control
Number              Title
Final Report
     Issued
 D9AFL2-03-0240-2100557 UNISYS                       VA  9/ 4/92
  Sunmary:   (PREAWARD AUDIT UNDER NEGOTIATION)

  - EXPLANATION OF THE REASONS MANAGEMENT  DECISION HAS NOT BEEN
MADE:  DCAA  IS CURRENTLY PERFORMING AN  INCURRED COST AUDIT ON
THE CONTRACT.   AUDIT STATUS IS PENDING  OUTCOME.

  = DESIRED  TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION:

 IG FOLLOUUP STATUS AS OF  3/31/93    II]   (A desired timetable for achieving
a management decision was not provided by EPA.)

 D9AKN2-03-0488-2300083 BRUCE COMPANY                DC  9/29/92
  Suimary:   (PREAWARD AUDIT UNDER NEGOTIATION)

  - EXPLANATION OF THE REASONS MANAGEMENT  DECISION HAS NOT BEEN
HADE:  CONTRACT HAS NOT BEEN AWARDED.

  = DESIRED  TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION:
CONTRACT  AWARD EXPECTED SEPTEMBER 30. 1993.

 IG FOLLOUUP STATUS AS OF  3/31/93    [1]

 P9AHN1-05-0191-1300085 OHM REN ERCS3 R1             OH  7/ 9/91
  Siranary:   (PREAWARD AUDIT UNDER NEGOTIATION)

  - EXPLANATION OF THE REASONS MANAGEMENT  DECISION HAS NOT BEEN
MADE:  CONTRACT NEGOTIATIONS ARE ONGOING.

  = DESIRED  TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION:

 IG FOLLOUUP STATUS AS OF  3/31/93    [1]   (An explanation was not provided
by EPA relating to the reasons a management decision had not been made at 3/31 /93. A desired
timetable for achieving a management decision was also not provided.)

 P9AHP1-05-0313-1400035 OHM REM ERCS3 R2             OH  9/ 6/91
  Summary:   (PREAWARD AUDIT UNDER NEGOTIATION)

  - EXPLANATION OF THE REASONS MANAGEMENT  DECISION HAS NOT BEEN
MADE:  CONTRACT NEGOTIATIONS ARE ONGOING.

  = DESIRED  TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION:

 IG FOLLOUUP STATUS AS OF  3/31/93    [1]   (An explanation was not provided
by EPA relating to the reasons a management decision had not been made at 3/31/93. A desired
timetable for achieving a management decision was also not provided.)
 P9AHP1-05-0313-1400036 OHM REM ERCS3 R2            OH  9/ 6/91
  Sumnary:   (PREAWARD AUDIT UNDER NEGOTIATION)

  - EXPLANATION OF THE REASONS MANAGEMENT  DECISION HAS NOT BEEN
MADE:  CONTRACT NEGOTIATIONS ARE ONGOING.

  = DESIRED  TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION:

 IG FOLLOUUP STATUS AS OF  3/31/93   [1]   (An explanation was not provided
by EPA relating to the reasons a management decision had not been made at 3/31 /93. A desired
timetable for achieving a management decision was also not provided.)

 E9AHP2-05-0036-2400001  EQM ERCS3 R5                 OH 11/27/91
  Suimary:   (PREAUARD AUDIT UNDER NEGOTIATION)

  - EXPLANATION OF THE REASONS MANAGEMENT  DECISION HAS NOT BEEN
MADE:  CONTRACT  HAS NOT  BEEN AWARDED.

  = DESIRED  TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION:
CONTRACT AWARD  EXPECTED  SEPTEMBER 30, 1993.
                       ry:  (PREAUARD AUDIT UNDER NEGOTIATION)

                  - EXPLANATION OF THE  REASONS MANAGEMENT DECISION  HAS NOT BEEN
                MADE:  CONTRACT HAS  NOT BEEN AWARDED.

                  = DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION:
                CONTRACT AWARDED EXPECTED SEPTEMBER 30, 1993.

                 IG  FOLLOUUP  STATUS  AS  OF  3/31/93    [1]

                 P9AHP2-05-0052-2400010 SAMSEL SERVICES ERCS3 R5    OH 12/26/91
                  Sunmary:  (PREAUARD AUDIT UNDER NEGOTIATION)

                  -  EXPLANATION OF THE  REASONS MANAGEMENT DECISION HAS NOT BEEN
                MADE:  CONTRACT HAS  NOT BEEN AWARDED.

                  =  DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION:
                CONTRACT AWARD EXPECTED SEPTEMBER 30,  1993.
                 IG FOLLOUUP  STATUS AS OF  3/31/93    [1]

                 P9AHP2-05-0306-2400058 OHM REM ERCS3 R
                  Sunmary:  (PREAWARD AUDIT UNDER NEGOTIATION)
                                                       OH  7/23/92
                  - EXPLANATION  OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN
                MADE:  CONTRACT  NEGOTIATIONS ARE ONGOING.

                  = DESIRED  TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION:

                 IG FOLLOUUP STATUS AS OF  3/31/93    [1]  (An explanation was not provided by
                EPA relating to the reasons a management decision had not been made at 3/31/93. A desired
                timetable for achieving a management decision was also not provided.)

                 P9AHP2-05-0350-2400063 MAECORP ERCS3 R5             IL  8/11/92
                  Sunnary:   (PREAWARD AUDIT UNDER NEGOTIATION)

                  - EXPLANATION  OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN
                MADE:  CONTRACT  HAS NOT  BEEN AWARDED.

                  = DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION:
                CONTRACT AWARD EXPECTED  SEPTEMBER 30, 1993.
                 IG FOLLOUUP STATUS AS OF  3/31/93    [1]

                 P9AGL2-10-0079-2100607 RES PRE-AUARD
                  Sunmary:  (PREAWARD  AUDIT UNDER NEGOTIATION)
                                                       OR  9/11/92
 IG FOLLOUUP STATUS AS OF   3/31/93   [1]

 P9AHP2-05-0054-2400007 MARS E/S ERCS3 R5
IL 12/18/91
                  - EXPLANATION OF  THE REASONS MANAGEMENT DECISION  HAS NOT BEEN
                MADE:  CONTRACT HAS NOT BEEN AWARDED.

                  = DESIRED TIMETABLE  FOR ACHIEVING A MANAGEMENT DECISION:
                CONTRACT AWARD EXPECTED SEPTEMBER 30, 1993.

                 IG FOLLOUUP STATUS AS OF  3/31/93   [1]

                REGION 1. REGIONAL  ADMINISTRATOR
                 E3BUL1-01-0178-2100522 RI ESTUARY PROGRAM GRANTS    RI  8/11/92
                  Sunmary:  A TOTAL OF $198,111 IS QUESTIONED; VARIOUS
                WEAKNESSES IN THE GRANTEE'S INTERNAL CONTROLS ARE ALSO REPORTED.

                  - EXPLANATION OF  THE REASONS MANAGEMENT DECISION  HAS NOT BEEN
                HADE:  THE REGION AND  THE DIG HAVE REACHED AGREEMENT ON MOST
                ISSUES IN THIS INTERIM AUDIT.  DISCUSSION AND AGREEMENT BETWEEN
                THE REGION, STATE AND  DIG WILL BE COMPLETE BY APRIL 30, 1993.

                  = DESIRED TIMETABLE  FOR ACHIEVING A MANAGEMENT DECISION:
                RESOLUTION OF THIS  AUDIT IS EXPECTED BY MAY 31, 1993.

                 IG FOLLOUUP STATUS AS OF  3/31/93    [2]
   OCTOBER 1, 1992 THROUGH MARCH 31, 1993
                                                                                                                                     55

-------
   Assignment Control
   Number
Title
Final Report
     Issued
Assignment Control
Number
Title
Final Report
     Issued
  REGION 2. REGIONAL ADMINISTRATOR

   P5BGLO-02-0278-2100134 EQB                         PR 12/19/91
    Summary:  THE TOTAL CLAIM OF $248,063 WAS NOT SUPPORTED BY
  ADEQUATE SOURCE DOCUMENTATION FOR US TO AUDIT THE CLAIM.

    - EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN
  MADE:  AUDITOR QUESTIONED ALL GRANTEE COSTS AS UNSUPPORTED FOR
  LACK OF RECORDS, REPORTEDLY DESTROYED IN HURRICANE.  EQB
  SUBSEQUENTLY FOUND SOME DOCUMENTATION.  REGION AND OIG ARE
  HAVING CPA TO EVALUATE THE DOCUMENTATION.

    = DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION:  THE
  FINAL DETERMINATION LETTER IS EXPECTED TO BE ISSUED BY SEPTEMBER
  30, 1993.

   IG FOLLOUUP STATUS AS OF  3/31/93   [2]

   P2CWL9-02-0231-2100399 TONAUANDA                   NY  6/ 9/92
    Suimary:  THE GRANTEE CLAIMED $409,391 OF INELIGIBLE COST AND
  $566,507 OF UNSUPPORTED COST FOR CONSTRUCTION OF A PUMPING
  STATION, FORCE MAIN AND INTERCEPTOR SEWER LINE.

    - EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN
  MADE:  THE NEW YORK STATE DEPARTMENT OF ENVIRONMENTAL
  CONSERVATION IS THE DELEGATED AGENCY RESPONSIBLE FOR DRAFTING
  THIS AUDIT RESOLUTION FOR THE REGION.  A HIGH VOLUME OF AUDITS
  AND VERY LIMITED STAFF AT NYSDEC HAS CAUSED A DELAY IN THE
  RESOLUTION OF THIS AUDIT.

    = DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION:  THE
  FINAL DETERMINATION LETTER IS EXPECTED TO BE ISSUED BY JUNE 30,
  1993.
   IG FOLLOUUP STATUS AS OF  3/31/93   [1]

   P2CUL9-02-02047-2100400 ERIE COUNTY - SOUTHTOWNS   NY  6/ 9/92
    Summary:  THE GRANTEE CLAIMED $171,699 OF INELIGIBLE COST AND
  $90,190 OF UNSUPPORTED COST FOR CONSTRUCTION OF AN ADVANCED
  WASTEWATER TREATMENT PLANT, INTERCEPTOR SEWERS AND PUMP
  STATIONS.

    - EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN
  MADE:   THE NEW YORK STATE DEPARTMENT OF ENVIRONMENTAL
  CONSERVATION IS THE DELEGATED AGENCY RESPONSIBLE FOR DRAFTING
  THIS AUDIT RESOLUTION FOR THE REGION.  A HIGH VOLUME OF AUDITS
  AND VERY LIMITED STAFF AT NYSDEC HAS CAUSED A DELAY IN THE
  RESOLUTION OF THIS AUDIT.

    = DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION:  THE
  FINAL DETERMINATION LETTER IS EXPECTED TO BE ISSUED BY JUNE 30,
  1993.

   IG FOLLOUUP STATUS AS OF  3/31/93   [1]

 P2CUL9-02-0341-2100402 SARATOGA COUNTY SEWER       NY  6/ 9/92
  SUMHfy:  THE GRANTEE CLAIMED $266,624 OF INELIGIBLE COST AND
$29,906 OF UNSUPPORTED COST FOR CONSTRUCTION OF AN INTERCEPTOR
AND COLLECTION SYSTEM AND CONSTRUCTION OF A MAINTENANCE AND
FACILITY BUILDING.

  - EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN
HADE:  THE NEW YORK STATE DEPARTMENT OF ENVIRONMENTAL
CONSERVATION  IS THE DELEGATED AGENCY RESPONSIBLE FOR DRAFTING
THIS AUDIT RESOLUTION FOR THE REGION.  A HIGH VOLUME OF
AUDITSOOOOOOO AND VERY LIMITED STAFF AT NYSDEC HAS CAUSED A DELAY
IN THE RESOLUTION OF THIS AUDIT.

  = DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION:  THE
FINAL DETERMINATION LETTER  IS EXPECTED TO BE  ISSUED BY JUNE 30,
1993.

  IG FOLLOUUP STATUS AS OF  3/31/93    [1]
    56
                                               P2CULO-02-0149-2100448 NIAGARA COUNTY SD1          NY  7/ 5/92
                                                Smmary:   THE GRANTEE CLAIMED $75,549 OF INELIGIBLE COST AND
                                              $938,238 OF  UNSUPPORTED COST FOR CONSTRUCTION OF A WASTEWATER
                                              TREATMENT PLANT,  INTERCEPTOR SEWERS AND PUMP STATIONS.

                                                -  EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN
                                              MADE:   THE NEW YORK STATE DEPARTMENT OF ENVIRONMENTAL
                                              CONSERVATION IS THE DELEGATED AGENCY RESPONSIBLE FOR DRAFTING
                                              THIS AUDIT RESOLUTION FOR THE REGION.  A HIGH VOLUME OF AUDITS
                                              AND  VERY LIMITED  STAFF AT NYSDEC HAS CAUSED A DELAY IN THE
                                              RESOLUTION OF  THIS AUDIT.

                                                =  DESIRED  TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION:  THE
                                              FINAL  DETERMINATION LETTER IS EXPECTED TO BE ISSUED BY JUNE 30,
                                              1993.

                                               IG  FOLLOUUP STATUS AS OF  3/31/93   [1]

                                               P2BU*8-02-0017-2100449 NYC - NORTH RIVER           NY  7/ 5/92
                                                Sunnary:   THE GRANTEE CLAIMED $2,661,322 OF INELIGIBLE COSTS
                                              AND  $11,814,277 OF UNSUPPORTED COSTS FOR THE CONSTRUCTION OF THE
                                              NORTH  RIVER  WASTEWATER  WATER  TREATMENT PLANT AND A SLUDGE VESSEL.

                                                -  EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN
                                              MADE:   THE NEW YORK STATE DEPARTMENT OF ENVIRONMENTAL
                                              CONSERVATION IS THE DELEGATED AGENCY RESPONSIBLE FOR DRAFTING
                                              THIS AUDIT RESOLUTION FOR THE REGION.  A HIGH VOLUME OF AUDITS
                                              AND  A  HIGH AMOUNT  OF QUESTIONED COSTS CAUSED A DELAY IN THE
                                              RESOLUTION OF  THIS AUDIT.

                                                =  DESIRED  TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION:  THE
                                              FINAL  DETERMINATION LETTER IS EXPECTED TO BE ISSUED BY JUNE 30,
                                              1993.
                                               IG  FOLLOUUP STATUS AS OF  3/31/93   [4]

                                               E9BHL1-02-0114-2100586 ERCS - SAD ENVIRONMENTAL    NJ  9/ 9/92
                                                Suimary:   THE MINI-ERCS CONTRACTOR CLAIMED $561,118 OF
                                              QUESTIONED  COSTS CONSISTING OF $30,241 OF  INELIGIBLE AND
                                              $539,877 OF  UNSUPPORTED COSTS  IN PERFORMANCE SUPERFUND CLEANUP
                                              ACTIVITIES.

                                                -  EXPLANATION OF THE REASONS MANAGEMENT DECISION  HAS NOT BEEN
                                              MADE:   THE  REGION SUBMITTED A DRAFT  RESOLUTION  TO OIG ON
                                              FEBRUARY 25, 1993. THE OIG RAISED QUESTIONS AND  IS  PREPARING
                                              MEMORANDUM  TO THE REGION LISTING ADDITIONAL  INFORMATION REQUIRE
                                              FOR  FINAL RESOLUTION.

                                                = DESIRED TIMETABLE  FOR ACHIEVING  A MANAGEMENT DECISION:   THE
                                              FINAL  DETERMINATION  IS EXPECTED TO BE ISSUED BY JUNE 30,  1993.

                                                IG FOLLOUUP STATUS AS OF  3/31/93    [1]

                                              REGION 3. REGIONAL ADMINISTRATOR

                                                P2CUMO-03-0270-2200023  LEESBURG                     VA  7/23/92
                                                Summary:   TOWN OF  LEESBURG,  VA CLAIMED $395,602 OF  COSTS  IN
                                              EXCESS OF THE GRANTS AMOUNTS.

                                                - EXPLANATION OF  THE REASONS MANAGEMENT  DECISION  HAS NOT  BEEN
                                              HADE:  REGION  ISSUED FINAL DETERMINATION LETTER TO  GRANTEE  ON
                                              FEBRUARY 2, 1993.

                                                = DESIRED TIMETABLE  FOR ACHIEVING A MANAGEMENT DECISION:

                                                IG FOLLOUUP  STATUS AS OF  3/31/93    C3]   (The audit was closed on April 5
                                              1993.)

                                                P2CUMO-03-0114-2200041  BERKELEY  COUNTY PSD         UV  9/50/9J
                                                Suimary:  COSTS  OF $517,956 WERE  INELIGIBLE  PRIMARILY  BECAUSE
                                              THE GRANTEE CLAIMED  $219,488 OF  INELIGIBLE CHANGE  ORDERS AND
                                              $169,091 OF COSTS  INCURRED BEYOND  THE CUT-OFF  DATE.

                                                - EXPLANATION OF THE REASONS MANAGEMENT  DECISION HAS NOT BEEI
                                              MADE:   THIS AUDIT  WAS  ISSUED ON SEPTEMBER  30,  1992 AND CLOSED (
                                              APRIL  1, 1993.

                                                = DESIRED TIMETABLE  FOR ACHIEVING A MANAGEMENT DECISION:

                                                  IG FOLLOUUP STATUS AS OF  3/31/93  [5]   (The OIG received the manag.
                                                decision on March 30, 1993 and closed the report on April 1, 1993.)
                                                                              OFFICE OF THE INSPECTOR GENERAL

-------
Assignment Control
Number
                     Title
                                                    Final Report
                                                         Issued
Assignment Control
Number
Title
Final Report
     Issued
  P6DUNO-03-0261-2300046 DC  GOVERNMENT                DC  3/31/92
   Sunmary:   REVIEW OF THE WASHINGTON TIMES  ALLEGATIONS
 CONCERNING  THE  BLUE PLAINS  TREATMENT PLANT  DISCLOSED CONTRACT
 OVERRUNS  OF $21 MILLION.   IN ADDITION,  EXCESSIVE  DELAYS  OCCURRED
 BECAUSE OF  PROCUREMENT POLICIES AND PRACTICES.

   -  EXPLANATION OF THE REASONS MANAGEMENT DECISION  HAS NOT  BEEN
 MADE:  A  MULTITUDE OF ISSUES TOTALING $8.5  MILLION  REQUIRED
 EXTRAORDINARY TIME TO REVIEW AND RESOLVE.   THE OIG  DISAGREED
 WITH MANAGEMENT'S PROPOSED  FINAL DETERMINATION AND  REQUESTS
 ADDITIONAL  DOCUMENTATION FROM THE  CORPS OF  ENGINEERS.

   = DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT  DECISION:  THE
 FINAL DETERMINATION LETTER  IS EXPECTED  TO BE  ISSUED BY MAY  15,
 1993.

  IG  FOLLOWUP STATUS AS OF   3/31/93  [2]  (The OIG determined the response
 to be inadequate)

  P2CWN1-03-0123-2300062 PHILADELPHIA CITY OF         PA  7/23/92
   Suimary:  THE CITY OF PHILADELPHIA WATER DEPARTMENT CLAIMED
 MORE THAN $20 MILLION OF INELIGIBLE COSTS INCLUDING $8.7 MILLION
 OF COSTS ASSOCIATED WITH ABANDONED SYSTEMS  AND EQUIPMENT.

   -  EXPLANATION OF THE REASONS MANAGEMENT DECISION  HAS NOT  BEEN
 MADE:  THE  SIZE AND COMPLEXITY OF  THIS  MEGA-AUDIT,  INVOLVING
 SEVERAL GRANTS, WILL REQUIRE MUCH  TIME  TO RESOLVE.  MEETINGS AND
 CORRESPONDENCE WITH GRANTEE ARE ONGOING.

   = DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT  DECISION:  THE
 FINAL DETERMINATION LETTER  IS EXPECTED  TO BE  ISSUED BY SEPTEMBER
 30,  1993.

  IG  FOLLOUUP STATUS AS OF   3/31/93  [1]

 REGION 4. REGIONAL ADMINISTRATOR

  E2CUN1-04-0052-1300086 HILLSBOROUGH CTY             FL  7/17/91
   Suwary:   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:   JUSTIFICATION FOR THE EXPANSION OF  THE  TREATMENT PLANT
 IS DEPENDENT UPON THE OUTCOME OF THE CORRECTIVE ACTION PLAN FOR
 THE RUSKIN/WIMAUMA PROJECT.  THE REGION AND OIG CONCUR THAT A
 FINAL DETERMINATION IS PREMATURE.

   = DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT  DECISION:

  IG FOLLOUUP STATUS AS OF  3/31/93   [2]  (OIG agrees with the above status.)

 REGION 5. REGIONAL ADMINISTRATOR

 P2CUN9-05-0336-0300076 UELLSVILLE                   OH 8/ 6/90
  Sunary:  WE  QUESTIONED AS INELIGIBLE  OVER $1.9  MILLION BECAUSE
 OF THE GRANTEE'S FAILURE TO REHABILITATE ITS SEWERS.

  - EXPLANATION OF THE REASONS MANAGEMENT DECISION  HAS NOT BEEN
MADE:  GRANTEE  RESOLVED ALL COMPLIANCE  FINDINGS ON  DECEMBER 23,
 1992, AS INSTRUCTED UNDER 1988 CONSENT  DECREE.  OIG AGREED TO
REGION'S FINAL  DETERMINATION LETTER DATED MARCH 26,  1993, BUT
WILL  NOT  CLOSE  AUDIT UNTIL  GRANTEE COMPLIES WITH  SPECIAL
CONDITIONS OF GRANT AWARD.
                                                                   P2CUP9-05-0075-1400037 GARY SO                      IN  9/ 9/91
                                                                    SuMary:  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 ENTIRE GRANT OF $33 MILLION WAS QUESTIONED DUE TO
                                                                  ALLEGED IMPROPER PLANT OPERATION AND VIOLATION OF NPDES. GRANTEE
                                                                  PROVIDED VOLUMINOUS DOCUMENTATION TWO WEEKS BEFORE FINAL
                                                                  DETERMINATION DUE DATE.  A  CONSENT DECREE  GIVES GARY UNTIL 1994 TO
                                                                  COMPLY.

                                                                    = DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION:

                                                                   IG FOLLOUUP STATUS AS OF  3/31/93   [3]

                                                                   P2CUP8-05-0026-1400038 GARY SO                      IN  9/  9/91
                                                                    Suimary:  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 ENTIRE GRANT OF $33 MILLION WAS QUESTIONED DUE TO
                                                                  ALLEGED IMPROPER PLANT OPERATION AND VIOLATION  OF NPDES. GRANTEE
                                                                  PROVIDED VOLUMINOUS DOCUMENTATION TWO WEEKS BEFORE FINAL
                                                                  DETERMINATION DUE DATE. A CONSENT DECREE GIVES  GARY  UNTIL 1994
                                                                  TO COMPLY.

                                                                    = DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION:

                                                                   IG FOLLOUUP STATUS AS OF  3/31/93    [3]

                                                                   P2CUNO-05-0032-2300074 UASHTENAW CO DPU             HI  9/ 4/92
                                                                    Suimary:  THE GRANTEE CLAIMED $942,874 OF INELIGIBLE COSTS
                                                                  THAT WERE NOT PROPERLY PROCURED RELATING TO LEGAL SERVICES AND
                                                                  ENGINEERING COSTS INCURRED AFTER CONSTRUCTION COMPLETION DATE.
                                                                  THE GRANTEE ALSO CLAIMED $3,742,844 OF UNSUPPORTED CONSTRUCTION
                                                                  AND ENGINEERING COSTS.

                                                                    - EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN
                                                                  MADE:   COMPLEX LEGAL ISSUES HAD TO BE RESOLVED BEFORE THE AUDIT
                                                                  COULD  BE   RESOLVED.   THE. PRELIMINARY DETERMINATION WAS ISSUED ON
                                                                  JANUARY 29,  1993.

                                                                    = DESIRED  TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION:  THE
                                                                  EXPECTED  ISSUANCE OF THE FINAL  DETERMINATION LETTER  IS APRIL 30,


                                                                   IG  FOLLOUUP  STATUS  AS OF   3/31/93    [3]

                                                                   P2CUP6-05-0298-2400004 W LAKE  SUPERIOR (DULUTH)   MN 12/12/91
                                                                   Suimary:  THE  WESTERN  LAKE SUPERIOR  SANITARY DISTRICT CLAIMED
                                                                  $8,595,588 OF  INELIGIBLE CONSTRUCTION,  ENGINEERING AND
                                                                  ADMINISTRATIVE COSTS AND $166,834 OF UNSUPPORTED COSTS.

                                                                   - EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN
                                                                  MADE:   THE DIVISIONAL  INSPECTOR GENERAL FORWARDED THIS AUDIT TO
                                                                  THE OFFICE OF ASSISTANT  INSPECTOR GENERAL FOR  AUDITS  ON JULY 24
                                                                  1992. THE REPORT QUESTIONED OVER $8 MILLION  RELATED TO THE SOLID
                                                                  WASTE PROCESSING PORTION OF THE PLANT.  OF THIS,  $7 563 075 OF
                                                                  CONSTRUCTION COSTS PLUS RELATED ARCHITECTURE AND ENGINEERING
                                                                  EXPENSES ARE AT ISSUE.

                                                                   = DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION:
                                                                  RESOLUTION OF THIS AUDIT IS EXPECTED BY SEPTEMBER 30, 1993.
                                                                  IG FOLLOUUP STATUS AS OF  3/31/93   [6]
 = DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION:
IG FOLLOUUP STATUS AS OF  3/31/93   [3]
OCTOBER 1, 1992 THROUGH MARCH 31, 1993
                                                                                                                              57

-------
   Assignment Control
   Number
Title
Final Report
     Issued
Assignment Control
Number
Title
Final Report
     Issued
   P2BWP1-05-0357-2400064  MILWAUKEE  MSD               UI  8/18/92
    Sunroary:  MILWAUKEE METROPOLITAN SEWERAGE DISTRICT CLAIMED
  $3,060,908  OF  INELIGIBLE COSTS AND $2,720,064 OF UNSUPPORTED
  COSTS.

    -  EXPLANATION OF  THE REASONS MANAGEMENT DECISION  HAS NOT BEEN
  HADE:  DUE  TO  THE LARGE  NUMBER OF  GRANTS BEING AUDITED, THE
  GRANTEE  WAS UNABLE  TO SUBMIT A COMPLETE RESPONSE UNTIL JANUARY,
  1993.

    =  DESIRED TIMETABLE FOR ACHIEVING  A MANAGEMENT DECISION:  THE
  FINAL DETERMINATION IS EXPECTED  TO BE COMPLETED BY  JUNE 30,1993.
   IG  FOLLOUUP STATUS AS OF  3/31/93   D]

   P2CWP8-05-0264-2400077  GARY SO                     IN  9/28/92
    Sumiary:  THE ENTIRE GRANT $14,860,519 IS QUESTIONED BECAUSE
  THE  WASTEWATER TREATMENT  PLANT DOES  NOT MEET ITS NPDES LIMITS
  IN ADDITION, $7,593.204  OF THE GRANT IS QUESTIONED BECAUSE THE
  TERTIARY FILTER FACILITY  HAS NOT BEEN MAINTAINED AND IS
  INOPERABLE.

    -  EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN
  MADE:  OVER $7 MILLION OF FILTER  COSTS AND ASSOCIATED ENGINEERING
  FEES WERE QUESTIONED BECAUSE THE FILTERS ARE INOPERABLE.
  CONSEQUENTLY,  THE GRANTEE IS IN VIOLATION OF ITS NPDES PERMIT   A
  CONSENT DECREE GIVES GARY UNTIL 1994 TO COMPLY.

    = DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION:

   IG  FOLLOUUP STATUS AS OF  3/31/93   D]

  N3HVJ2-05-0225-2501051  MICHIGAN DNR FY 88/89       MI  9/ 4/92
    Sumiary:  AUDITOR  QUESTIONED $618,689 DUE TO PRE-BILLING OF
 WORK NOT PAID  FOR;  NOT  MAINTAINING REQUIRED PERCENTAGE  AT  LEVEL
 OF FUNDING REQUIRED,  AND  NOT COMPLYING WITH SPECIAL CONDITIONS  ON
 COOPERATIVE AGREEMENTS.

    - EXPLANATION OF THE  REASONS MANAGEMENT DECISION HAS  NOT BEEN
 MADE:  COMPLIANCE  ISSUES  NEEDED  TO BE ADDRESSED  BEFORE
 DETERMINING THE ELIGIBILITY OF  THE QUESTIONED  COSTS.  THE
 PRELIMINARY DETERMINATION WAS  ISSUED  ON  MARCH  2,  1993.

   = DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION:  THE
 FINAL DETERMINATION  IS EXPECTED TO BE ISSUED BY APRIL 30,  1993.

  IG FOLLOUUP STATUS  AS OF  3/31/93   O]

  PZCWN4-05-0183-5100159 EUCLID                       OH  7/12/85
   Suroary:   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 ITS 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.
 CONSENT DECREE  ALLOWS GRANTEE UNTIL 1996 TO COMPLETE CORRECTIVE
 ACTIONS.

   = DESIRED  TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION:

  IG FOLLOUUP STATUS AS OF  3/31/93    [3]

  P2CUN4-05-0357-6100389 DETROIT US                  MI  8/25/86
   Sumnary:   THE CITY OF DETROIT, MI CLAIMED OVER $169,000 OF
 UNREASONABLE ENGINEERING  COSTS.

   - EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN
 MADE:  THE OIG WILL SUBMIT A PACKAGE OUTLINING THE AUDIT ISSUES
 TO  THE ASSISTANT INSPECTOR GENERAL (AIGA) FOR AUDITS BY  MAY 31
 1993.   THE AIGA  WILL  PRESENT THESE  ISSUES TO THE AUDIT RESOLUTION
 BOARD.  RESOLUTION DATE  IS DEPENDENT UPON REVIEW OF AUDIT  BY THE
ARB.

  = DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION:

 IG FOLLOUUP STATUS AS OF   3/31/93   [2]
                                               P2GUN4-05-0264-6100390 DETROIT USD                 HI  8/25/1
                                                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 BE
                                              MADE:   THE OIG  WILL SUBMIT A PACKAGE OUTLINING THE AUDIT ISSU
                                              TO THE  ASSISTANT  INSPECTOR GENERAL FOR AUDITS BY MAY 31, 1993
                                              THE AIGA WILL PRESENT  THESE ISSUES TO THE AUDIT RESOLUTION
                                              BOARD.   RESOLUTION DATE IS DEPENDENT UPON REVIEW OF AUDIT BY
                                              ARB.

                                                = DESIRED  TIMETABLE  FOR ACHIEVING A MANAGEMENT DECISION:

                                               IG FOLLOUUP STATUS AS OF  3/31/93   [21
                                               P2CUN4-05-0263-6100391  DETROIT USD                 MI  S/25/
                                                Summary:   THE  GRANTEE  CLAIMED UNREASONABLE FORCE ACCOUNT CC
                                              OF $286,000.   THE  GRANTEE  ALSO CLAIMED INELIGIBLE COSTS OF
                                              $15,000.

                                                - EXPLANATION  OF THE REASONS MANAGEMENT DECISION HAS NOT BI
                                              HADE:   THE OIG WILL SUBMIT A  PACKAGE OUTLINING THE AUDIT ISSl
                                              TO THE  ASSISTANT INSPECTOR GENERAL FOR AUDITS BY MAY 31, 1993
                                              THE AIGA WILL  PRESENT THESE ISSUES TO THE AUDIT RESOLUTION
                                              BOARD.  RESOLUTION DATE  IS DEPENDENT UPON REVIEW OF AUDIT BY
                                              ARB.

                                                = DESIRED  TIMETABLE FOR  ACHIEVING A MANAGEMENT DECISION:

                                               IG FOLLOUUP STATUS AS OF   3/31/93   [2]

                                               P2CUN4-05-0280-6100574  DETROIT USD                 MI  9/30,
                                                Summary:  WE QUESTIONED  INELIGIBLE COST OF $293,000 MOSTLY
                                              CHANGE  ORDERS.   WE ALSO  QUESTIONED UNNECESSARY COST OF $399,1
                                              FOR FORCE ACCOUNT  AND GRANTEE DELAYS.   CHANGE ORDER COSTS OF
                                              $148,00 WERE UNSUPPORTED.

                                                - EXPLANATION  OF THE REASONS MANAGEMENT DECISION HAS NOT BI
                                              HADE:   THE OIG WILL  SUBMIT A  PACKAGE OUTLINING THE AUDIT ISSl
                                              TO THE  ASSISTANT INSPECTOR GENERAL FOR AUDITS BY MAY 31, 199!
                                              THE AIGA WILL  PRESENT THESE ISSUES TO THE AUDIT RESOLUTION
                                              BOARD.  RESOLUTION DATE  IS DEPENDENT UPON REVIEW OF AUDIT BY
                                              ARB.

                                                = DESIRED TIMETABLE FOR  ACHIEVING A MANAGEMENT DECISION:

                                               IG FOLLOUUP STATUS AS OF  3/31/93   [2]

                                               P2CUN4-05-0265-6100575  DETROIT USD                 UI  9/30
                                                Suimary:  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 B
                                              HADE:   THE OIG WILL  SUBMIT A  PACKAGE OUTLINING THE AUDIT ISS
                                              TO THE  ASSISTANT INSPECTOR GENERAL FOR AUDITS BY MAY 31,  199
                                              THE AIGA WILL  PRESENT THESE ISSUES TO  THE AUDIT RESOLUTION
                                              BOARD.  RESOLUTION DATE  IS DEPENDENT UPON REVIEW OF AUDIT BY
                                              ARB.

                                                = DESIRED TIMETABLE FOR ACHIEVING A  MANAGEMENT DECISION:

                                               IG FOLLOUUP STATUS AS OF  3/31/93   [2]
    58
                                                                                                 OFFICE OF THE INSPECTOR GENEFiAL

-------
   Assignment Control
   Number
Title
Final Report
     Issued
Assignment Control
Number
Title
Final Report
     Issued
  P2CWM5-05-0242-7000034 DETROIT USD                 NI 10/ 6/86
   Sumary:  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:  THE DIG WILL SUBMIT  A PACKAGE OUTLINING THE AUDIT ISSUES
 TO THE ASSISTANT INSPECTOR  GENERAL FOR AUDITS BY MAY 31, 1993.
 THE AIGA WILL PRESENT THESE  ISSUES TO THE AUDIT RESOLUTION BOARD.
 RESOLUTION DATE IS DEPENDENT UPON REVIEW OF AUDIT BY THE ARB.

   = DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION:

  IG FOLLOUUP STATUS AS OF  3/31/93   [21

  P2CUN5-05-0246-7000044 DETROIT USD                 HI 10/ 7/86
   SUBBary:  THE GRANTEE CLAIMED UNREASONABLE FORCE ACCOUNT COSTS
 OF $336,000.

   - EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN
 MADE:  THE OIG WILL SUBMIT  A PACKAGE OUTLINING THE AUDIT ISSUES
 TO THE ASSISTANT INSPECTOR  GENERAL FOR AUDITS BY MAY 31, 1993.
 THE AIGA WILL PRESENT THESE  ISSUES TO THE AUDIT RESOLUTION BOARD.
 RESOLUTION DATE IS DEPENDENT UPON REVIEW OF AUDIT BY THE ARB.

   = DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION:

  IG FOLLOUUP STATUS AS OF  3/31/93   [2]

  P2GUN5-05-0275-7D00045 DETROIT USD                 MI 10/ 7/86
   Sunary:  WE QUESTIONED $80,000 OF INELIGIBLE ENGINEERING AND
 CONSTRUCTION COSTS.  ENGINEERING COSTS OF $112,000 INCURRED AFTER
 THE CONSTRUCTION COMPLETION DATE WERE NOT SUPPORTED.

   - EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS HOT BEEN
 MADE:  THE OIG WILL SUBMIT  A PACKAGE OUTLINING THE AUDIT ISSUES
 TO THE ASSISTANT INSPECTOR  GENERAL FOR AUDITS BY MAY 31, 1993.
 THE AIGA WILL PRESENT THESE  ISSUES TO THE AUDIT RESOLUTION BOARD.
 RESOLUTION DATE IS DEPENDENT UPON REVIEW OF AUDIT BY THE ARB.

   = DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION:

  IG FOLLOUUP STATUS AS OF  3/31/93   [2]

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

   - EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN
 MADE:  THE OIG WILL SUBMIT  A PACKAGE OUTLINING THE AUDIT ISSUES
 TO THE ASSISTANT INSPECTOR  GENERAL FOR AUDITS BY MAY 31, 1993.
 THE AIGA WILL PRESENT THESE  ISSUES TO THE AUDIT RESOLUTION BOARD.
 RESOLUTION DATE  IS DEPENDENT UPON REVIEW OF AUDIT BY THE ARB.

   = DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION:

  IG FOLLOUUP STATUS AS OF  3/31/93   [21

 P2CUN5-05-0276-7000050 DETROIT USD                 MI 10/ 8/86
  Sumary:  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 WILL SUBMIT A PACKAGE OUTLINING THE AUDIT ISSUES
TO THE ASSISTANT INSPECTOR GENERAL FOR AUDITS BY MAY 31, 1993.
THE AIGA WILL PRESENT THESE  ISSUES TO THE AUDIT RESOLUTION
BOARD.  RESOLUTION  DATE IS DEPENDENT UPON REVIEW OF AUDIT BY THE
ARB.

  = DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION:

 IG FOLLOUUP STATUS AS OF 3/31/93   [2]
                                           E2BUL5-05-0136-7000980 SAUGET                      IL  3/31/87
                                            Suimary:  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
                                          HADE:  THE REGION IS SEEKING GUIDANCE FROM REGIONAL COUNSEL AND
                                          THE WATER DIVISION REGARDING COMPLEX TECHNICAL AND LEGAL ISSUES.
                                          REGION AND OIG HAVE DISAGREEMENTS THAT WILL BE ELEVATED TO THE
                                          AUDIT RESOLUTION BOARD WHEN THE PROPOSED FINAL DETERMINATION  IS
                                          SENT.

                                            = DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION:  THE
                                          EXPECTED PRELIMINARY FINAL DETERMINATION IS APRIL 30, 1993.

                                           IG FOLLOUUP STATUS AS OF  3/31/93    12]

                                           P2GUN5-05-0132-8000464 DETROIT USD                 NI  1/20/88
                                            Suimary:  DETROIT CLAIMED INELIGIBLE COSTS OF ALMOST $2.6
                                          MILLION RESULTING FROM ITS FAILURE TO HONOR A CONTRACT.  WE ALSC
                                          QUESTIONED UNSUPPORTED COSTS OF ALMOST $2.1 MILLION.

                                            - EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN
                                          HADE:  THE OIG WILL SUBMIT A PACKAGE OUTLINING THE AUDIT ISSUES
                                          TO THE ASSISTANT INSPECTOR GENERAL FOR AUDITS BY MAY 31, 1993.
                                          THE AIGA WILL PRESENT THESE ISSUES TO THE AUDIT RESOLUTION
                                          BOARD.  RESOLUTION DATE IS DEPENDENT UPON REVIEW OF AUDIT BY  TH[
                                          ARB.

                                          = DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION:

                                           IG FOLLOUUP STATUS AS OF  3/31/93    [2]

                                           P2CUN7-05-0237-8100724 DETROIT USD                 HI  8/29/88
                                            Suimary:  DETROIT, MI CLAIMED OVER $274,000 OF INELIGIBLE
                                          CONSTRUCTION COSTS.  WE ALSO QUESTIONED UNSUPPORTED ENGINEERING
                                          AND FORCE ACCOUNT COSTS OF $662,000.

                                            - EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN
                                          MADE:  THE OIG WILL SUBMIT A PACKAGE OUTLINING THE AUDIT ISSUES
                                          TO THE ASSISTANT INSPECTOR GENERAL FOR AUDITS BY MAY 31, 1993.
                                          THE AIGA WILL PRESENT THESE ISSUES TO THE AUDIT RESOLUTION
                                          BOARD.  RESOLUTION DATE IS DEPENDENT UPON REVIEW OF AUDIT BY  THf
                                          AR8.

                                            = DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION:

                                           IG FOLLOUUP STATUS AS OF  3/31/93    [2]

                                          P2GUN5-05-0169-8100774 DETROIT USD                 MI  9/ 1/88
                                            Suimary:  WE QUESTIONED INELIGIBLE CONSTRUCTION AND
                                          ENGINEERING COSTS OF $96,520. IN ADDITION, WE QUESTIONED THAT
                                          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 WILL SUBMIT  A PACKAGE OUTLINING THE AUDIT  ISSUES
                                           TO THE  ASSISTANT INSPECTOR  GENERAL  FOR  AUDITS BY MAY  31,  1993.
                                           THE  AIGA WILL PRESENT THESE ISSUES TO THE AUDIT RESOLUTION BOARD
                                           RESOLUTION  DATE IS DEPENDENT  UPON REVIEW OF  AUDIT  BY  THE  ARB.

                                             = DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION:

                                            IG FOLLOUUP STATUS AS OF  3/31/93    [21
 OCTOBER 1, 1992 THROUGH MARCH 31, 1993
                                                                                                                                59

-------
 Assignment Control
 Number
Title
Final Report
     Issued
Assignment Control
Number
Title
Final Report
     Issued
 E2AUTO-05-0223-0400020 SELLERSBURG EUS             IN  6/14/90
  Sumary:  REGION S AWARDED A $5.5 MILLION STEP 2+3 GRANT TO
SELLERSBURG, IN FOR A PROJECT WHICH DID NOT MEET THE ELIGIBILITY
REQUIREMENTS FOR A STEP 2+3 GRANT.

  - EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN
HADE:  THE REGION AND DIVISION OIG CANNOT REACH AGREEMENT ON A
MANAGEMENT DECISION.  THE OIG HAS BEEN FORWARDED TO THE AIGA FOR
FURTHER ANALYSIS AND RESOLUTION.  THE MAIN ISSUE IS WHETHER OR
NOT THE GRANT AWARD IS INVALID.

  = DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION:
RESOLUTION IS EXPECTED BY SEPTEMBER 30, 1993.

 IG FOLLOUUP STATUS AS OF  3/31/93    [6]

 E2AWTO-05-0224-0400045 W TERRE HAUTE EUS           IN  9/28/90
  Suanary:  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:  THE REGION AND DIVISION OIG CANNOT REACH AGREEMENT ON A
MANAGEMENT DECISION.  THE OIG HAS BEEN FORWARDED TO THE AIGA FOR
FURTHER ANALYSIS AND RESOLUTION.

  = DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION:
RESOLUTION IS EXPECTED BY SEPTEMBER 30, 1993.

 IG FOLLOUUP STATUS AS OF  3/31/93    [6]

 E2AUT1-05-0134-14000070 S HENRY RSD EUS            IN  2/25/91
  Sunary:  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
HADE:  THE REGION AND DIVISION OIG CANNOT REACH AGREEMENT ON A
MANAGEMENT DECISION.  THE OIG HAS BEEN FORWARDED TO THE AIGA FOR
FURTHER ANALYSIS AND RESOLUTION.  THE MAIN ISSUE IS WHETHER OR
NOT THE GRANT AWARD IS INVALID.

  = DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION:
RESOLUTION IS EXPECTED BY SEPTEMBER 30, 1993.

 IG FOLLOUUP STATUS AS OF  3/31/93    [6]

 E2AWT1-05-0116-1400048 ENGLISH EUS                 IN  9/25/91
  Suimary:  THE GRANTEE HAS BEGUN A SIGNIFICANT REDEVELOPMENT
PROJECT WHICH RAISES QUESTIONS ABOUT THE CONCLUSIONS OF THE
FACILITIES PLANNING PROCESS. AS A RESULT THE GRANT AWARD OF
$2,676,600 WAS PREMATURE AND THE PRELIMINARY PLANNING NEEDS TO
BE REEVALUATED.

  - EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN
MADE:  THE OIG DID NOT ACCEPT MANAGEMENT'S FINAL DETERMINATION
AND IS ELEVATING THE AUDIT TO THE HEADQUARTERS OIG FOR FURTHER
ATTENTION AND ANALYSIS.  THE MAIN ISSUE IS WHETHER OR NOT THE
GRANT AWARD IS INVALID.

  = DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION:
RESOLUTION IS EXPECTED BY SEPTEMBER 30, 1993.

 IG FOLLOUUP STATUS AS OF  3/31/93   [6]
                                           REGION 8. REGIONAL ADMINISTRATOR

                                            P2CU*8-08-0052-2100634 HAYDEN, TOWN OF             CO  9/22/92
                                             Suimary:  GRANTEE CLAIMED A/E, CONSTRUCTION, AND EQUIPMENT
                                           COSTS OF $16,335.00 WHICH WERE UNSUPPORTED AND DESIGN,
                                           ENGINEERING,  AND CONSTRUCTION COSTS OF $1,382,470 WHICH WERE
                                           UNNECESSARY/UNREASONABLE BECAUSE OF UNDER UTILIZATION OF
                                           CAPACITY.

                                             - EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT  BEEN
                                           MADE:  ON DECEMBER 21. 1992, THE REGION FORWARDED A DRAFT FINAL
                                           DETERMINATION LETTER TO THE OIG.  THE OIG CODED THIS AUDIT  AS
                                           INCOMPLETE,  AND THE REGION REQUESTED REASONS FOR THIS ACTION ON
                                           MARCH 9, 1993.   THE REGION PLANS TO RESPOND QUICKLY TO THE  OIG'S
                                           CONCERNS.  NO CORRESPONDENCE HAS BEEN RECEIVED FROM THE OIG AS
                                           OF APRIL 20,  1993.

                                             = DESIRED  TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION:  THE
                                           EXPECTED DATE FOR THE FINAL DETERMINATION LETTER IS JUNE 30,
                                           1993.

                                            IG FOLLOUUP STATUS AS OF  3/31/93   [2]  (Discussions were held with the
                                           Regional representative on March 9, 1993. The report is expected to be resolved during the
                                           semiannual period ending September 30, 1993.)

                                           REGION 9. REGIONAL ADMINISTRATOR

                                            S5BG*8-09-0202-0300037 CA DEPT OF HEALTH           CA  3/30/90
                                             Sunnary:  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:  THE REGION HAS CONDUCTED EXTENSIVE WORK ON RESOLVING THE
                                           COST/PRICE ANALYSIS AND THE LAB DATA INTEGRITY COST ISSUES
                                           ASSOCIATED WITH THIS AUDIT.  RESOLUTION WAS DELAYED BY A LENGTH1
                                           NEGOTIATION  PERIOD WITH THE OIG ON HOW ISSUES NEEDED TO
                                           ADDRESSED.

                                             = DESIRED  TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION:
                                           APRIL 30, 1993.

                                            IG FOLLOUUP STATUS AS OF  3/31/93   12]

                                            P2CUM1-09-0157-2200040 SUTTER CREEK, CITY OF       CA  9/30/92
                                             Suimary:  COST QUESTIONED OF $12,916 INCLUDES $5,566 OF
                                           ENGINEERING  COST IN EXCESS OF APPROVED AMOUNT, AND $6,850 OF
                                           UNDOCUMENTED  ADMINISTRATIVE AND $500 PERMIT FEES, UNREASONABLE
                                           COSTS OF $343,467 RELATED TO FIX UP FACILITIES CONSTRUCTED  UNDEF
                                           PRIOR GRANT.

                                             - EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT  BEEN
                                           HADE:  THE STATE HAS DRAFTED A FINAL DETERMINATION LETTER WHICH
                                           IS IN ITS CONCURRENCE CYCLE.  THE REGION EXPECTS THE DRAFT  FINAI
                                           DETERMINATION LETTER SOON AND WILL REQUEST LOCAL OIG REVIEW.

                                             = DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION:  THE
                                           TARGET DATE  FOR THE FINAL DETERMINATION LETTER IS DECEMBER  31,
                                           1993.

                                            IG FOLLOUUP STATUS AS OF  3/31/93   [1]

                                            S2CUMO-09-0262-2300089 SAN FRANCISCO, CITY ft CO    CA  9/30/92
                                             SuMry:  INELIGIBLE COST INCLUDE $50,015 OF UNALLOWABLE  A/E
                                           COSTS AND $271,092 FOR COSTS ALLOCABLE TO OTHER FEDERAL
                                           FACILITIES RELATED TO UNSUPPORTED CONSTRUCTION R/E FORCE ACCOUN
                                           COSTS.
60
                                             - EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN
                                           MADE:  THE DRAFT FINAL DETERMINATION LETTER HAS BEEN DELAYED BY
                                           THE STATE'S CONCURRENCE CYCLE.

                                             = DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION:  THE
                                           TARGET DATE FOR THE FINAL DETERMINATION  IS SEPTEMBER 30,  1993.

                                            IG FOLLOUUP STATUS AS OF  3/31/93    [1]

                                                                          OFFICE OF THE INSPECTOR GENERAL

-------
  Assignment Control
  Number
Title
Final Report
     Issued
Assignment Control
Number
Title
                                                                                                Final Report
                                                                                                     Issued
  P2BWLO-09-0175-1100436 CLARK COUNTY SO             HV 9/30/91
   SuMary:  THE CLARK COUNTY SANITATION DISTRICT, NEVADA  (THE
 GRANTEE) CLAIMED INELIGIBLE COSTS OF $6,851,921, ABOUT $26
 MILLION OF UNNECESSARY/UNREASONABLE OR UNSUPPORTED COSTS  FOR A
 WASTEWATER TREATMENT PLANT USED AT ONLY ABOUT HALF OF  ITS
 CAPACITY.

   -  EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN
 MADE:   THE REGION  IS WORKING WITH  THE STATE  TO RESOLVE  THIS AUDIT
 AND  FACILITATE THE RECOVERY OF ANY OUTSTANDING RESOURCES.  THE
 REGION  REQUIRED ADDITIONAL TIME TO RESOLVE THIS  INTERIM AUDIT TO
 IDENTIFY AND ADDRESS NOT ONLY THE ISSUES HIGHLIGHTED BY THIS OIG
 REPORT  BUT ALSO OTHER  POTENTIAL ISSUES ASSOCIATED WITH THIS
 3RANT.

   =  DESIRED TIMETABLE  FOR ACHIEVING A MANAGEMENT DECISION:
 REVISED TARGET DATE FOR RESOLUTION IS SEPTEMBER 30, 1993.

  IG  FOLLOUUP STATUS AS OF  3/31/93   [1]

  S2CU*8-09-0157-1300112 LOS ANGELES, CITY OF        CA  9/25/91
   Sunwry:   INELIGIBLE COSTS OF $723,627 INCLUDED: $650,255 OF
 JNALLOWABLE  FORCE  ACCOUNT COSTS AND $73,372 FOR UNALLOWABLE
 ENGINEERING  COSTS.   UNREASONABLE COSTS INCLUDE $879,630 OF
 JNDOCUMENTED FORCE ACCOUNT AND $1,099,261.
 \RCHITECT/ENGINEERING  COSTS INCURRED UNDER PROHIBITED CONTRACT
 1ETHOD.

   -  EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN
 WDE:   THIS  IS A DELEGATED STATE.   THE  STATE HAS BEEN RESOLVING
SEVERAL OF THE TECHNICAL  ISSUES WITH THE GRANTEE.  THE GRANTEE
HAS  PROVIDED ADDITIONAL  SUPPORT DOCUMENTATION.    A FINAL
DETERMINATION  LETTER HAS  BEEN  DRAFTED  BY THE STATE AND WILL BE
SOON REVIEWED  BY THE OIG.   THIS AUDIT  IS RELATED TOY SEVERAL
OTHERS OF THE  GRANTEE.

  = DESIRED  TIMETABLE  FOR ACHIEVING A MANAGEMENT DECISION:
TARGET DATE  FOR THE  FINAL  DETERMINATION LETTER  IS SEPTEMBER 30,
1993.

  IG  FOLLOUUP STATUS  AS OF  3/31/93   [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 AND $5,275,186  FOR  INADEQUATELY
DOCUMENTED FORCE ACCOUNT  COSTS.

  - EXPLANATION OF THE REASONS  MANAGEMENT  DECISION HAS NOT BEEN
MADE:  THIS  IS A DELEGATED  STATE.  THE  STATE HAS BEEN  RESOLVING
SEVERAL OF THE TECHNICAL  ISSUES WITH THE GRANTEE.   THE GRANTEE
HAS PROVIDED ADDITIONAL SUPPORT DOCUMENTATION.    A  FINAL
DETERMINATION LETTER HAS BEEN DRAFTED BY THE STATE  AND WILL BE
SOON REVIEWED BY THE OIG.   THIS AUDIT  IS RELATED TO  SEVERAL
OTHERS OF THE GRANTEE.

  = DESIRED TIMETABLE  FOR ACHIEVING A MANAGEMENT DECISION:
TARGET DATE  FOR THE  FINAL DETERMINATION LETTER  IS SEPTEMBER 30,
1993.

 IG FOLLOUUP STATUS AS OF   3/31/93   [1]
                                             S2CUN9-09-0032-1300118 MONTEREY REG WATER POLL CON CA  9/30/91
                                              Suimary:    THE  STATE CLAIMED $7,491,007 OF INELIGIBLE
                                           CONSTRUCTION,  ENGINEERING,  ADMINISTRATIVE, AND OTHER COSTS.
                                           ADDITIONAL $51,118,958 OF UNREASONABLE PROJECT COSTS WERE
                                           QUESTIONED.

                                              - EXPLANATION OF  THE REASONS MANAGEMENT DECISION HAS NOT BEEN
                                           MADE:  THE STATE  HAS  COMPLETED WORK ON THE MANY TECHNICAL ISSUES
                                           AND DRAFTED A FINAL DETERMINATION LETTER WHICH IS CURRENTLY
                                           UNDER STATE MANAGEMENT REVIEW.  IT WILL SOON BE REVIEWED BY THE
                                           OIG.

                                              = DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION:  THE
                                           TARGET DATE FOR THE FINAL DETERMINATION LETTER IS SEPTEMBER 30,
                                           1993.

                                             IG FOLLOUUP  STATUS AS OF  3/31/93   [1]

                                             S2CU*8-09-0156-1300119 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  FORCE  ACCOUNT ALLOCABLE TO INELIGIBLE
                                           CONSTRUCTION;  UNREASONABLE  COSTS OF $68,150,598 RELATED TO
                                           EXCESSIVE LANDSCAPING, FORCE ACCOUNT AND UNUSED FACILITIES.

                                              - EXPLANATION OF  THE REASONS MANAGEMENT DECISION HAS NOT BEEN
                                           MADE:  THIS IS A  DELEGATED  STATE.  THE STATE HAS BEEN RESOLVING
                                           SEVERAL OF THE TECHNICAL ISSUES WITH THE GRANTEE.   THE GRANTEE
                                           HAS PROVIDED  ADDITIONAL SUPPORT DOCUMENTATION.   A FINAL
                                           DETERMINATION  LETTER  HAS BEEN DRAFTED BY THE STATE AND WILL BE
                                           SOON REVIEWED  BY  THE  OIG.   THIS AUDIT IS RELATED TO SEVERAL
                                           OTHERS OF THE  GRANTEE.

                                              = DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION:  THE
                                           TARGET DATE FOR THE FINAL DETERMINATION LETTER  IS SEPTEMBER 30,
                                           1993.
                                            IG FOLLOUUP STATUS AS  OF   3/31/93   [1]
                                                                                                CA  9/30/91
               S2CUN9-09-0171-1300120 TRACY, CITY OF
                Suimary:  INELIGIBLE COSTS  INCLUDED:  $11,438 FOR
              ARCHITECT/ENGINEERING COSTS;  $655,329 OF  INTEREST  EARNED;
              $2,916,214 FOR LITIGATION SETTLEMENT; UNREASONABLE COST OF
              $5,516,623 WERE RELATED TO "FIXING UP"  OF  FAILED  FACILITIES.

                - EXPLANATION OF THE REASONS MANAGEMENT  DECISION HAS NOT BEEN
              MADE:  THE CLAIMS POLICY HAS  BEEN  ISSUED.  THE  STATE SUBMITTED
              THE DRAFT FINAL DETERMINATION LETTER TO THE  OIG FOR ITS REVIEW.

                = DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION:   THE
              REVISED TARGET DATE FOR THE FINAL DETERMINATION LETTER  APRIL 30,
              1993.

               IG FOLLOUUP STATUS AS OF  3/31/93   [11

               E2AUP9-09-0189-1400006 EARLY WARNING - MONTEREY     CA   2/11/91
                Sumary:  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:   FINAL DETERMINATION LETTER IS AT  OIG FOR  REVIEW;  POSTPONED
              TO OBTAIN  LEGAL  OPINION REQUESTED BY OIG. THIS  AUDIT IS  LINKED TO
              EARLY WARNING-MARINA (#9400043).
                                                                     = DESIRED TIMETABLE  FOR ACHIEVING A MANAGEMENT DECISION:  THE
                                                                   TARGET DATE FOR THE  FINAL DETERMINATION LETTER IS SEPTEMBER 30,
                                                                   1993.

                                                                    IG FOLLOUUP STATUS  AS OF  3/31/93   [1]  (OIG agrees with the above status
                                                                   The OIG had not received a draft or final determination letter as of March 31, 1993. The need for a
                                                                   legal opinion was recommended in the OIG's report in 1991. The Region has verbally suggested
                                                                   alternative action that they believe will satisfy the intent of our recommendation.  However, they have
                                                                   not yet convinced the grantee to take their alternative action. If the alternative action is not taken, a
                                                                   legal opinion may still be required.)
 OCTOBER 1, 1992 THROUGH MARCH 31,  1993
                                                                                                                                61

-------
  Assignment Control
  Number
Title
Final Report
     Issued
Assignment Control
Number
Title
                                                                                              Final Repot
                                                                                                   Issuei
  E1KAG1-09-6094-1400049 FOLLOW UP REVIEW REG.  IX AI CA  9/25/91
   Sunmary:   REGION 9  TOOK  INADEQUATE ACTION TO MONITOR AIR GRANT
 ELIGIBILITY.  AS A RESULT, $2.1 MILLION IN AIR GRANTS FROM FY
 1983  TO 1985  REMAIN QUESTIONABLE.  AN ADDITIONAL $1.9 MILLION IN
 QUESTIONABLE  GRANTS WAS AWARDED FROM FY 1986 TO 1990.

   - EXPLANATION OF THE  REASONS MANAGEMENT DECISION HAS NOT BEEN
 MADE:  A UNIQUE RESPONSE TO  THIS INTERNAL AUDIT WAS REQUIRED
 BECAUSE  CORRECTIVE ACTIONS REQUIRED FOLLOWUP WITH MULTIPLE
 EXTERNAL GRANTEES.  A DEVIATION REQUEST FOR WASHOE IS AT EPA-HQ
 (OGC).   WE  HAVE REQUESTED  IMMEDIATE ATTENTION  TO ASSIST THE
 REGION  WITH  AUDIT RESOLUTION.

   = DESIRED  TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION:

  IG FOLLOUUP  STATUS AS  OF  3/31/93   C6]

  P2CUMO-09-0294-2200036 EL MIRAGE. CITY OF          AZ  9/29/92
   Sunmary:  UNSUPPORTED ADMINISTRATIVE COSTS OF $110,285
 QUESTIONED.   INELIGIBLE COSTS INCLUDE $9,681 FOR ADMINISTRATION
 AND ARCHITECT/ENGINEERING ALLOCABLE TO INELIGIBLE CONSTRUCTION
 AND $98,019  FOR CONSTRUCTION  IN EXCESS OF APPROVED $6,280,011 OF
 UNREASONABLE  COSTS RELATED TO UNDER UTILIZED FACILITIES.

   - EXPLANATION OF THE  REASONS MANAGEMENT DECISION HAS NOT BEEN
 MADE:   THE STATE HAS  REQUESTED THAT THE GRANTEE PROVIDE
 ADDITIONAL SUPPORTING DOCUMENTATION.  ONCE RECEIVED AND REVIEWED,
 A FINAL  DETERMINATION LETTER WILL BE PREPARED  AND FORWARDED TO
 THE REGION AND LOCAL  OIG.

   = DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION:  THE
 FINAL DETERMINATION LETTER IS SEPTEMBER 30, 1993.

  IG FOLLOUUP  STATUS AS  OF  3/31/93   [1]

 P2CWNO-09-0031-2300017 PINETOP LAKESIDE SO         AZ 12/ 4/91
  Sunmary:  UNNECESSARY  COSTS OF $4,105,313 QUESTIONED RELATED
TO UNUSED AND UNDERUTILIZED FACILITIES  CONSTRUCTED UNDER THE
PROJECT.

   - EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN
MADE:   THE OIG REQUESTED ADDITIONAL INFORMATION IN OCTOBER 1992
TO SUPPORT THE REGION'S  POSITION ON ONE AUDIT  ISSUE.

  = DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION: AFTER
CONSIDERABLE EFFORT TO COLLECT THE  DOCUMENTATION,  THE REGION
REACHED AGREEMENT WITH THE OIG AND  ISSUED  THE FINAL
DETERMINATION LETTER  TO  THE GRANTEE ON  MARCH 25,  1993.
 IG FOLLOUUP STATUS AS OF
on April 5, 1993.)
   3/31/93   [5] (This audit was closed
 S5BGNO-09-0303-2300043 L.A. DEPT WATER & POWER     CA  3/13/92
  Summary:  INELIGIBLE COSTS OF $2,321,195 INCURRED;  $4,810 OF
UNALLOWABLE TRAINING AND STORAGE COST; $287,450 FOR RETENTIONS
NOT PAID; AND $1,991,131 FOR UNALLOWABLE FORCE ACCOUNT
UNREASONABLE COSTS OF $4,354,690 FOR ARCHITECT/ENGINEERING
SUBAGREEMENTS NOT CONTAINING EPA PRIVITY CLAUSE.

  - EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN
MADE:  TO FACILITATE AGREEMENT WITH THE OIG,  THE REGION HOSTED
MEETINGS WITH ALL PARTIES ON APRIL 15, 1993 TO DISCUSS AND
RESOLVE ISSUES.

  = DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION:  A
FINAL DETERMINATION LETTER IS EXPECTED BY MAY 30, 1993.

 IG FOLLOUUP STATUS AS OF  3/31/93    [2]
                                           S2CUN1-09-0228-2300044 LOS ANGELES, CITY OF        CA  3/13/9
                                            Sunmary:  INELIGIBLE COSTS INCLUDED $1,400,564  FOR UNUSED
                                          EQUIPMENT ITEMS $202,058; FOR UNALLOWABLE ARCHITECT/ENGINEERIN
                                          FEES; AND $572,354 FOR UNALLOWABLE FORCE ACCOUNT, UNREASONABLE
                                          COSTS OF $1,010,586 FOR EXCESSIVE ARCHITECT/ENGINEERING AND
                                          FORCE ACCOUNT, ADDITIONAL $11,188,321 PLANT NOT OPERATING  IN
                                          ACCORDANCE WITH GRANT CONCEPTS.

                                            - EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEE
                                          MADE:  THIS IS A DELEGATED STATE.  THE STATE HAS  BEEN RESOLVIN
                                          SEVERAL OF THE TECHNICAL ISSUES WITH THE GRANTEE.  THE GRANTEE
                                          HAS PROVIDED ADDITIONAL SUPPORT DOCUMENTATION.    A FINAL
              DETERMINATION  LETTER  HAS BEEN  DRAFTED BY THE STATE AND WILL BE
              SOON  REVIEWED  BY  THE  OIG.   THIS AUDIT IS RELATED TO SEVERAL
              OTHERS  OF  THE  GRANTEE.

                = DESIRED  TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION::
              TARGET  DATE  FOR THE FINAL  DETERMINATION  LETTER IS SEPTEMBER 30
              1993.

               IG FOLLOUUP STATUS AS OF  3/31/93   [1]

               E1SG*7-09-0219-2300063 REGION 9 MGMT OF STNGFELLOU CA  7/30/9
                Summary:   REGION 9  HAS NOT EFFECTIVELY MANAGED THE
              STRINGFELLOW SUPERFUND  COOPERATIVE AGREEMENT.   PROBLEMS WITH
              ACCURACY OF  LABORATORY  ANALYSES;  DELAY IN COMPLETION OF RI/FS;
              DELAY  IN COMPLETION AND STARTUP OF INTERIM PRETREATMENT
              FACILITY;  AND  REVIEW  OF STATES ROLE.

                - EXPLANATION OF THE  REASONS MANAGEMENT DECISION HAS NOT BEE
              MADE:   ALL CONCERNS OF  THE OIG HAVE BEEN ADDRESSED VIA
              ADDITIONAL TECHNICAL  AND LEGAL SETTLEMENT EFFORTS. A FINAL
              DETERMINATION  LETTER  WILL  SOON BE PREPARED TO  CAPTURE THESE
              RESOLUTIONS.

                = DESIRED  TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION::  TH
              TARGET  DATE  FOR THE FINAL  DETERMINATION  LETTER IS MAY 30,  1993

               IG FOLLOWUP STATUS AS OF  3/31/93   [1]

               S2CUNO-09-0124-2300076 SELMA-KINGSBURG-FOULER      CA  9/ 8/9
                Swmary:  INELIGIBLE COST OF $1,012,364 INCLUDED $4,762 OF
              UNALLOWABLE  ADMINISTRATIVE COST;  $75,115 FOR
              ARCHITECT/ENGINEERING COSTS; $409,487 OF INELIGIBLE CONSTRUCTI
              AND $525,000 OF SETTLEMENT REVENUE. UNREASONABLE COSTS OF
              $4,053,969 RELATED TO UTILIZED FACILITIES.

                - EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEE
              MADE:  THE STATE  HAS  DRAFTED A FINAL DETERMINATION LETTER WHIC
              HAS BEEN  DELAYED  BY THE STATE'S CONCURRENCE CYCLE.  IT SHOULD
              FORWARDED  TO THE  REGION SHORTLY.

                = DESIRED  TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION:  TH
              REVISED FINAL  DETERMINATION DATE IS SEPTEMBER 30, 1993.

               IG FOLLOUUP STATUS AS OF  3/31/93   [1]

               E2CUN1-09-0092-2300082 RUSSIAN RIVER CSD           CA  9/25/9
                Sunmary:  COSTS OF  $8,344,066 HAVE BEEN QUESTIONED AS
              INELIGIBLE,  INCLUDING INELIGIBLE CONSTRUCTION ENGINEERING AND
              FORCE ACCOUNT  COSTS AN  ADDITIONAL $18,297,400  HAS  BEEN QUESTION
              AS UNNECESSARY BECAUSE THE PLANT WAS NOT FULLY UTILIZED.

                - EXPLANATION  OF  THE REASONS MANAGEMENT DECISION HAS NOT BEE
              MADE:  THE STATE  HAS  BEEN DELAYED BY EXTENDED WORK ON TECHNICS
              ISSUES (E.G..SETTLEMENT COSTS).  IT WILL SOON DRAFT FINAL
              DETERMINATION  LETTER.  ONCE DRAFTED, OIG REVIEW WILL BE
              REQUESTED.

                = DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION:  Th
              TARGET DATE  FOR  THE  FINAL DETERMINATION LETTER IS DECEMBER 12,
              1993.

               IG FOLLOWUP STATUS AS OF  3/31/93   [1J
 62
                                                                                                  OFFICE OF INSPECTOR GENER/

-------
 Assignment Control
 Number
Title
Final Report
     Issued
                                            Assignment Control
                                            Number
Title
                             Final Report
                                  Issued
 P2CUN1-09-0044-2300086 NACO SAN DIST.               AZ  9/29/92
   Sumary:   INELIGIBLE COSTS OF $8,487  INCLUDES  UNALLOWABLE
 ADMINISTRATIVE AND ARCHITECT/ENGINEERING COSTS;  $43,060 RELATED
 TO COSTS NOT SUPPORTED BY ADEQUATE  SOURCE DOCUMENTATION; AND
 11,390,917 RELATED TO UNDERUTILIZED  FACILITIES.

   - EXPLANATION OF THE REASONS MANAGEMENT DECISION  HAS NOT BEEN
  IADE:  AZ DEQ IS AWAITING ADDITIONAL SUPPORT DOCUMENTS FROM THE
  3RANTEE. DELAY EXACERBATED BY EXTENSIVE CHANGE IN RECIPIENT'S
  ADMINISTRATIVE PERSONNEL.

   = DESIRED  TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION:  THE
  ARGET DATE  FOR THE  FINAL DETERMINATION LETTER IS SEPTEMBER 30,
  993.

  IG FOLLOUUP STATUS  AS OF  3/31/93    [1]

  E2AWP9-09-0065-9400025  HOMELAND  EARLY WARNING      CA  3/31/89
   Suimary:  SPECIAL REVIEW OF  CONSTRUCTION  GRANT  OF  WASTEWATER
  REATMENT PLANT  FOUND $3,737,139  IN  FEDERAL  SHARE COSTS
  UESTIONED.   AN  EARLY WARNING  LETTER ADVISED THAT COSTS FOR  THE
  OLLECTION  SYSTEM  PORTION OF  THE  PROJECT DID NOT  QUALIFY  FOR
  UNO ING BECAUSE  OF THE "2/3 RULE".

   - EXPLANATION  OF THE REASONS MANAGEMENT DECISION  HAS NOT BEEN
  ADE:   RESOLUTION OF  THIS AUDIT HAS  BEEN REFERRED TO THE  AUDIT
  ESOLUTION  GROUP.  THE REGION  IS  WORKING WITH  THE AGENCY'S AUDIT
  ESOLUTION  GROUP TO RESOLVE THE ISSUE OR PREPARE  THE PACKAGE  FOR
  N AUDIT RESOLUTION BOARD DECISION.   THE OFFICE OF WATER  ISSUED
   POLICY CLARIFICATION ON THE  2/3  RULE.  THE DIG  ASKED OFFICE  OF
  ENERAL  COUNSEL  FOR FURTHER POLICY CLARIFICATION.

   = DESIRED TIMETABLE FOR ACHIEVING  A MANAGEMENT  DECISION:   THE
  EVISED  FINAL DETERMINATION LETTER TARGET DATE  IS DECEMBER 31,
  993.

  IG FOLLOUUP  STATUS AS OF 3/31/93   [6]

  E2AUP9-09-0230-9400043 EARLY  WARNING-MARINA CUD     CA 9/26/89
  Summary:  SPECIAL REVIEW OF  GRANT  TO  BUY CAPACITY  RIGHTS FROM
  EGIONAL WASTEWATER TREATMENT  PLANT  RESULTED IN AN EARLY WARNING
 ETTER  TO EPA MANAGEMENT  THAT  THE AWARD  VIOLATED  40  CFR3S 2250
 iND THAT TOTAL COSTS  QUESTIONED OF $1,694,000  (F.S.  $931,700)
 OULD CAUSE "WINDFALL" PROFITS.

   - EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN
 IADE:  THIS AUDIT IS  LINKED TO THE MONTEREY  EARLY WARNING AUDIT
 ;#140006).  BUY-IN COSTS  FOR THE MARINA WILL BE DETERMINED AFTER
 IN DIG AUDIT OF MONTEREY  EXPANSION COSTS AND THE  RESOLUTION OF
 10NTEREY'S EARLY WARNING  AUDIT.

  = DESIRED TIMETABLE FOR ACHIEVING  A MANAGEMENT  DECISION:  THE
 ARGET DATE FOR THE FINAL DETERMINATION  LETTER IS SEPTEMBER 30
 1993.

 IG FOLLOUUP STATUS AS OF  3/31/93    15]  (OIQ agrees with the above
 status)
REGION 10. REGIONAL ADMINISTRATOR

 P5CHN9-10-0151-0300095 OREGON DEQ
 *Sunmary:
                            OR  9/27/90
  - EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN
MADE:  THE REGION REQUIRED ADDITIONAL TIME TO RESOLVE A LEAVE
ISSUE SINCE IT INVOLVED SEVERAL STATES.  THE REGION ISSUED THE
FINAL DETERMINATION LETTER TO THE GRANTEE ON MARCH 30, 1993, AND
A FAX COPY WAS SENT TO THE 01G.

  = DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION:

 IG FOLLOUUP STATUS AS OF  3/31/93   [4]  (This audit was closed on April 5,
1993.)
               P2CUL9-10-0002-2100669 PIERCE COUNTY UTILITIES DEP UA  9/30/92
                Sunmary:  THE GRANTEE CLAIMED TOTAL QUESTIONABLE COSTS OF
              $4,496,181 FOR REIMBURSEMENT UNDER EPA'S CONSTRUCTION GRANTS
              PROGRAM.  COST CLAIMED OF $2,179,647 WERE FOUND TO BE INELIGIBLE
              AND CLAIMS FOR $2,316,534 WERE UNNECESSARY AND UNREASONABLE.

                - EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN
              MADE:  THE REGION OBTAINED ADDITIONAL DOCUMENTATION FOR REVIEW
              OF GRANT  ELIGIBILITY AND LACK OF DOCUMENTATION ISSUES IN AUDIT
              REPORT.  THE REGION MUST REVIEW 16 GRANTS AND 40 LARGE BOXES OF
              DOCUMENTATION WHICH OBTAINED FROM VARIOUS SOURCES TO COMPLETE
              THIS RESOLUTION.

                 = DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION:  THE
               REGION WILL ISSUE A DRAFT FINAL DETERMINATION LETTER TO OIG BY
               JULY 30,  1993.

                IG FOLLOUUP STATUS AS OF  3/31/93   [1]

                P2CUN1-10-0042-23O0088 NEUBERG, CITY OF            OR  9/30/92
                 Suimary:  INELIGIBLE COSTS OF  $8,998  RELATED COSTS IN EXCESS OF
               APPROVAL; $151,758 FOR COSTS NOT SUPPORTED BY ADEQUATE SOURCE
               DOCUMENTATION; AND $15,480,301 UNREASONABLE RELATED TO UNUSED
               FACILITIES AND EXPIRED NPDES PERMIT.

                 - EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN
               MADE:  THE REGION HAS ENCOUNTERED A DELAY IN GETTING ADDITIONAL
               INFORMATION FROM THE AUDITEE, STATE, AND CORPS OF ENGINEERS FOR
               REVIEW AND RESOLUTION OF "UNSUPPORTED COSTS" AND "COSTS CLAIMED
               IN EXCESS OF APPROVED AMOUNTS" ISSUES CONTAINED IN THE AUDIT
               REPORT.

                 = DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION:  THE
               REGION WILL ISSUE THE  DRAFT  FINAL DETERMINATION LETTER TO THE OIG
               BY JUNE 30, 1993.

                IG FOLLOUUP STATUS AS OF  3/31/93   [1]

                P2CWN9-10-0107-2300091 FED WAY WATER AND SEUER     UA  9/30/92
                 Sunmary:  INELIGIBLE COSTS OF $1,304,725 CONSISTED OF $67,387
               FOR UNALLOWABLE CONSTRUCTION COST;  $61,048 RELATED TO INELIGIBLE
               CONSTRUCTION PERCENTAGE;  $21,243 OF UNAPPROVED
               ARCHITECT/ENGINEERING FEES;  AND $1,155,147 RELATED TO EXCESS
               CAPACITY.  ALSO QUESTIONED WERE $2,242,049 AS UNSUPPORTED.

                 - EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS HOT BEEN
               MADE:  THE REGION IS OBTAINING ADDITIONAL INFORMATION  FROM THE
               GRANTEE AND THE STATE TO REVIEW\RESOLVE ISSUE OF GRANT  ELIGIBLE
               COSTS FOR A 30-YEAR PLAN VS A 20-YEAR PLAN.    THE ADDITIONAL
               DOCUMENTATION WAS TIME CONSUMING TO OBTAIN SINCE THE PROJECT IS
               15 YEARS  OLD.

                 = DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION:  THE
               REGION WILL ISSUE A DRAFT FINAL  DETERMINATION LETTER TO THE  OIG
               BY MAY 31,  1993.

                IG FOLLOUUP STATUS AS OF  3/31/93    [1]

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

                 -  EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS  NOT BEEN
               MADE:   SUPERFUND  BRANCH  IS WORKING  WITH OIG  ON  A PROCUREMENT
               ISSUE.  SUPERFUND SECTION IS IN  THE FINAL STAGE  OF REVIEWING
               ADDITIONAL  INFORMATION REQUIRED TO SETTLE THE PROCUREMENT ISSUES.
               THIS  REVIEW REQUIRED ADDITIONAL  TIME  BECAUSE WAS  THE
               DOCUMENTATION  WAS LOCATED IN  AUDITEE'S  CONTRACTOR FILES.
                 = DESIRED TIMETABLE  FOR ACHIEVING A MANAGEMENT  DECISION:   THE
               DRAFT  FINAL  DETERMINATION LETTER SHOULD BE  ISSUED BY APRIL 30,
               1993.

                IG  FOLLOUUP STATUS AS OF 3/31/93    [1]
 OCTOBER 1, 1992 THROUGH MARCH 31, 1993
                                                                                                                               63

-------
 Assignment Control
 Number
Title
Final Report
     Issued
Assignment Control
Number
Title
                              Final Report
                                   Issued
 P5CG*8-10-0084-1100156 ALASKA DEPT OF ENV CONSER   AK  3/29/91
  Sunmary:  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
HADE:  THE REGION IS NEGOTIATING WITH THE IG ON PROCUREMENT AND
LEAVE ISSUES. THE LEAVE  ISSUE HAS BEEN THE MAJOR DELAYING FACTOR
SINCE IT IS A CROSSCUTTING  ISSUE WITH SEVERAL STATES.  A DRAFT
FINAL DETERMINATION LETTER  WAS ISSUED TO THE IG ON MARCH 30,
1993.

  = DESIRED TIMETABLE  FOR ACHIEVING A MANAGEMENT DECISION:
UNLESS THE OIG DOES NOT  AGREE WITH THE DECISION, THE FINAL
DETERMINATION SHOULD BE  ISSUED BY MAY 25, 1993.
 IG FOLLOUUP STATUS AS OF
determination letter on April 6, 1993.)
    3/31/93   [1]  (The OIG received the draft final
 P2CU*7-10-0046-1200039 BRISTOL BAY, BOROUGH        AK  9/30/91
  Suimary:  BRISTOL BAY BOROUGH, NAKNEK, ALASKA (THE GRANTEE)
CLAIMED INELIGIBLE COSTS OF $1,145,973 AND UNSUPPORTED  COSTS OF
$6699.  ALSO, COSTS OF  $148,200 WERE QUESTIONED AS
UNNECESSARY/UNREASONABLE.

  - EXPLANATION OF THE  REASONS MANAGEMENT DECISION HAS  NOT  BEEN
MADE:  A DRAFT FINAL DETERMINATION LETTER WAS SENT TO THE OIG
FOR CONCURRENCE ON FEB.  24, 1993.  THE OIG HAS CODED THIS
RESPONSE AS INCOMPLETE  BUT  HAS NOT YET FORWARDED CORRESPONDENCE
TO THE REGION CONCERNING THIS DETERMINATION.  THE REGION PLANS
TO RESPOND QUICKLY TO THE OIG'S CONCERNS, BUT CANNOT ESTIMATE  A
FINAL DETERMINATION DATE UNTIL THE OIG'S POSITION IS REVIEWED.

  = DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION:

 IG FOLLOWUP STATUS AS  OF  3/31/93   C1]  (The OIG discussed the above
report with a RegionaJ Representative on March 12,1993. tn this discussion, we agreed (hat
additional discussion between the Region and OIG Western Audit Division will be needed in order to
come up with the allowable project costs.)
 P5CHN9-10-0155-1300047 WASHINGTON DEPT OF ECOLOGY
 •Suimary:
                             UA  3/26/91
  - EXPLANATION OF  THE  REASONS MANAGEMENT DECISION HAS  NOT  BEEN
MADE:  THE REGION SUBMITTED A DRAFT FINAL DETERMINATION AND
RECEIVED OIG CONCURRENCE  ON FEBRUARY 18, 1993.

  = DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION:   THE
REGION ISSUED THE FINAL DETERMINATION LETTER TO THE GRANTEE AND
SENT A COPY TO THE  OIG  ON MARCH 31, 1993.  THIS AUDIT WAS CLOSED
IN THE OIG TRACKING SYSTEM ON APRIL 20, 1993.
 IG FOLLOWUP STATUS AS OF  3/31/93
OIG and the audit was closed on April 20, 1993.)
              L3]  (The response was received by the
 P5CGNO-10-0011-1300066 WASHINGTON DEPT OF ECOLOGY  UA  5/ 7/91
  Sunmary:  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 MANAGEMENT CONTROLS. WDOE CLAIMED COSTS THAT  WERE  NOT
ALLOCABLE TO THE COOPERATIVE AGREEMENT.

  - EXPLANATION OF THE  REASONS MANAGEMENT DECISION HAS NOT BEEN
MADE:  THE REGION IS NEGOTIATING WITH THE OIG ON A PROCUREMENT
ISSUE. ADDITIONAL TIME  HAS BEEN NEEDED TO REVIEW THE COST PRICE
ANALYSIS AND APPROPRIATE AWARD ISSUES.

  = DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION: A

DRAFT  FINAL DETERMINATION LETTER SHOULD BE SUBMITTED TO  THE OIG
FOR REVIEW BY  APRIL  30, 1993.

 IG FOLLOUUP STATUS  AS  OF  3/31/93    [1]
                P5CGLO-10-0066-2100299 WASH DOE  MULTI-SITE         UA  3/30/92
                 Sumary:  GRANTEE DID NOT PROCURE  SERVICES IN A MANNER THAT
               ASSURED REASONABLE PRICE OR THAT  BEST OFFERORS WERE AWARDED
               CONTRACTS.  ALSO, MANAGEMENT CONTROLS NEED STRENGTHENING TO
               PROPERLY RECORD AND CLAIM TO GRANTS.   FINALLY, CONTRACTOR
               PERFORMANCE MONITORING NEEDS IMPROVEMENT.

                 - EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS  NOT BEEN
               MADE:  THE REGION RECENTLY RECEIVED ADDITIONAL DOCUMENTATION  FRC
               THE GRANTEE RELATED TO A COST  PLUS PERCENTAGE CONTRACT  ISSUE.
               THE AUDITEE'S DELAY IN PROVIDING  THIS INFORMATION POSTPONED  THE
               RESOLUTION OF THIS AUDIT.

                 = DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION:   A
               DRAFT FINAL DETERMINATION LETTER  WILL BE FORWARDED TO THE OIG  B
               APRIL 30, 1993.

                IG FOLLOUUP STATUS AS OF  3/31/93   [2]

                P5BGL1-10-0046-2100612  IDAHO  DHU S/F COOP AGREEM.   ID  9/15/92
                 Sumary:  COSTS QUESTIONED AS UNSUPPORTED FOR; CONTRACTUAL
               SERVICES FOR WHICH IDHW DID NOT  FOLLOW PROPER PROCUREMENT
               PROCEDURES, AND PERSONNEL COSTS BECAUSE  IDHW DID NOT ALLOCATE
               FRINGE BENEFIT COSTS  IN ACCORDANCE WITH OMB CIRCULAR A-87.

                 - EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS  NOT BEE*
               MADE:  THE REGION SENT A DRAFT FINAL DETERMINATION LETTER  TO TH
               OIG ON JANUARY 21, 1993.  THE  OIG RESPONDED TO THE REGION ON
               MARCH 22, AGREEING WITH THE REGION'S DECISIONS CONCERNING  THE
               AUDIT FINDINGS BUT STIPULATING THAT THE REGION NEEDED TO
               ARTICULATE ITS FOLLOW-UP COMMITMENTS.  THE REGION DISAGREED  IN
               PRINCIPLE.  THE GRANTEE  HAS BEEN  APPRISED OF THE DECISIONS
               REGARDING THE AUDIT FINDINGS.  THE REGION AND THE OIG HAVE BEEK
               REQUESTED TO RESOLVE  THE  FOLLOW-UP ISSUE.  THE ISSUE HAS ALSO
               BEEN REFERRED TO AN AGENCY-WIDE  TASK FORCE ON AUDIT  MANAGEMENT.

                 = DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION:

                IG FOLLOUUP STATUS AS OF  3/31/93   [2]  (OIG agrees with the above  statui

                P2CU*8-10-0021-2200029 UNALASKA, CITY OF            AK  9/10/92
                 Sumary:  FINAL AUDIT OF CONSTRUCTION  GRANT  NOS. COS0064-01,  C
               AND 03 FOR CITY OF UNALASKA, AK.   THE GRANTEE CLAIMED INELIGIBLE
               UNSUPPORTED, AND UNNECESSARY/UNREASONABLE COSTS OF $234,046,
               $52,900 AND $299,235  RESPECTIVELY.

                 - EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS  NOT BEEN
               MADE:  THE REGION SUBMITTED A DRAFT FINAL DETERMINATION  LETTER T
               OIG ON FEBRUARY 2, 1993.  AS OF 4/20/93,  THE OIG  HAS  NOT PROVIDE
               A WRITTEN RESPONSE TO THIS  DRAFT  FINAL DETERMINATION LETTER.

                 = DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION:
               DEPENDING ON IG  RESPONSE  TIME  TO DRAFT FINAL DETERMINATION
               LETTER, REGION WILL  ISSUE  THE  FINAL DETERMINATION LETTER  BY  MAY
               30, 1993.

                IG FOLLOUUP STATUS AS OF   3/31/93    [2]  (On March 17, 1993, we analyze.
               and discussed the draft final determination letter with the Regional Representative. The OIG Inforrm
               the Region of the concerns In that in four of the eleven instances, the Alaska Department of
               Environmental Conservation (ADEC) claims that the criteria used in the audit report did not exist. V
               informed the Region that the criteria did exist and that ADEC needs to address this. We agreed to
               code the response as Incomplete and that the Region would look into the matter.)
  64
                                                                             OFFICE OF INSPECTOR GENERAL

-------
 Assignment Control                                  Final Report
 Number                Title                              Issued
 E2AWP2-10-0002-2400024 NPDES PERMIT                 AK  3/12/92
  Summary:  REGION 10 MADE AN IMPROPER  AND  INADEQUATELY
DOCUMENTED DECISION TO ISSUE A NPDES  PERMIT FOR SEAFOOD WASTE
DISCHARGE INTO A RELATIVELY PRISTINE  ALASKAN BAY.   REGION 10
DELAYED IN ENFORCING OVER 170 VIOLATIONS  OF THE PERMIT
CONDITIONS, INCLUDING ILLEGAL DISCHARGE.

  - EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN
MADE:  THE REGION IS NEGOTIATING WITH OIG ON PERMIT
MODIFICATIONS.

  = DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION:  THE
REGION EXPECTS TO HAVE PUBLIC NOTICE  TO ACHIEVE THE PERMIT
MODIFICATIONS AND ISSUE A FINAL DETERMINATION LETTER TO THE
GRANTEE BY JUNE 30. 1993.

 IG FOLLOUUP STATUS AS OF  3/31/93    [21

 E3BG*6-10-0066-8100761 NOSES LAKE  IRR  &  REHAB DIST UA  8/31/88
  Summary:  INTERIM AUDIT OF DEMONSTRATION  GRANT TO RESTORE
MOSES LAKE AND 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 HEADQUARTER OIG AND THE  OFFICE OF WATER ARE REVIEWING
ISSUES THAT ARE STILL NOT RESOLVED.   THE  OFFICE OF THE GENERAL
COUNSEL ESTABLISHED A LEGAL TEST TO ADDRESS THE ISSUES UNDER
REVIEW.

  = DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION:  A
FINAL DETERMINATION LETTER SHOULD BE  ISSUED BY DECEMBER 31,
1993.
 IG FOLLOUUP STATUS AS OF  3/31/93    [6]

 P2CUL8-10-0007-2100664 LOON LAKE SEWER DIST NO 4   UA  9/30/92
  Suimary:  THE GRANTEE CLAIMED INELIGIBLE  ADMINISTRATIVE, LEGAL
SETTLEMENT, ENGINEERING AND MISCELLANEOUS AND CONSTRUCTION COSTS
TOTALING $204,089.  ALSO CLAIMED WERE $141,943 IN  UNNECESSARY
AND UNREASONABLE CONSTRUCTION COSTS RELATED TO OVER DESIGN OF
THE PLANT.

  - EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN
MADE:  A DRAFT FINAL DETERMINATION  LETTER WAS FORWARDED TO THE
OIG FOR CONCURRENCE ON JANUARY 7, 1993.   ON FEB.18, 1993 THE OIG
RESPONDED TO THE DRAFT FINAL DETERMINATION  LETTER.  THE REGION IS
GATHERING ADDITIONAL INFORMATION TO ADDRESS THE OIG'S CONCERNS
INCLUDING SUPPORTING INFORMATION ON THE 75  PERCENT  FLOW ISSUE.

  = DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION:  THE
FINAL DETERMINATION SHOULD BE ISSUED  BY APRIL 30,  1993.

 IG FOLLOUUP STATUS AS OF  3/31/93    [2]
            TOTAL AUDITS ISSUED BEFORE REPORTING PERIOD  FOR WHICH  NO MANAGEMENT DECISION WAS MADE DURING THE REPORTING
            PERIOD:     146

            * = Agency procedures do not require the IG'» approval on Agency's Management Decision on an audit (other than a preaward or an internal and
            management audit) with the Federal share of questioned costs of less than $100,000. Therefore, we have not provided a summary of the audit.
  OCTOBER 1, 1992 THROUGH MARCH 31, 1993                                                                                     65

-------
OIG Mailing Addresses and Telephone Numbers • OIG Hotline  (800) 424-4000 or (202) 260-4977
Headquarters
Enyironmental Protection Agency
Office of Inspector General
401 M Street, S.W. (A-109)
Washington, DC  20460
(202) 260-3137

Atlanta
Environmental Protection Agency
Office of Inspector General
1475 Peachtree Street, NE
11th Floor
Atlanta, GA 30309-3111
Audit: (404) 347-3623
Investigations: (404) 347-2398

Boston
Enyironmental Protection Agency
Office of Inspector General
JFK Federal Building OIG 521
Boston, MA 02203
Audit: (617)565-3160
lnvestigations:(617) 565-3928

Chicago
Environmental Protection Agency
Office of Inspector General
77 West Jackson Boulevard
13th Floor (IA-13J)
Chicago, IL 60604
Audit: (312)353-2486
Investigations: (312) 353-2507

Cincinnati
Environmental Protection Agency
Office of Inspector General
MS Norwood
Cincinnati, OH 45268
Audit: (513) 366-4360

Dallas
Enyironmental Protection Agency
Office of Inspector General
1445 Ross Avenue, Suite 1200
Dallas, TX  75202-2733
Audit: (214)655-6621
investigations: (404) 347-2398

Denver
Enyironmental Protection Agency
Office of Inspector General
999 18th Street, Suite 500
Denver, CO 80205-2405
Audit: (303) 294-7520
Investigations: (303) 236-5080
Kansas City
Enyironmental Protection Agency
Office of Inspector General
726 Minnesota Avenue
Kansas City, KS66101
Audit: (913)551-7824
Investigations: (312) 353-2507

New York
Office of Inspector General
90 Church Street, Room 802
New York, NY  10007
Audit: (212) 264-5730
Investigations: (212) 264-0399

Philadelphia
Enyironmental Protection Agency
Office of Inspector General
841 Chestnut Street, 13th Floor
Philadelphia, PA  19107
Audit: (215) 597-0497
Investigations: (215) 597-9421

Research Triangle Park, NC
Environmental Protection Agency
Office of Inspector General
EPA Administration Building
Alexander Drive, Room 113
Research Triangle Park, NC 27711
Audit: (919) 541-1028
Investigations: (919) 541-1027

Sacramento
Enyironmental Protection Agency
Office of Inspector General
801 I Street, Room 466
Sacramento, CA95814
Audit: (916) 551-1076

San Francisco
Enyironmental Protection Agency
Office of Inspector General
75 Hawthorne St (1-1)
19th Floor
San Francisco, CA 94105
Audit: (415) 744-2445
Investigations: (415) 744-2465

Seattle
Enyironmental Protection Agency
Office of Inspector General
1111 3rd Avenue, Suite  1460
Seattle, WA98101
Audit: (206) 553-1273
Investigations: (415) 744-2465
66
                                                                                OFFICE OF INSPECTOR GENERA

-------