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United States
Environmental Protection
Agency
T
Office of
Inspector General (2441)
Washington DC 20460
November 1994
350R94003
of Inspector General
smiannual Report
Congress
X
April 1, 1994 through
September 30, 1994
If
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Foreword
During this semiannual reporting period, the EPA Office of
Inspector General has been a leader among the Inspector General
community in implementing the recommendations of the National
Performance Review (NPR). I was one of the Inspectors General
who participated through the President's Council on Integrity
and Efficiency in the creation of the "Inspectors General Vision
Statement," which states how the IG's can best carry out their
duties in harmony with the spirit of the NPR. We are continuing
to demonstrate that leadership through changes in our work with
the Agency and initiatives to streamline our organization.
Our relationship with Agency managers and staff has been
further strengthened by our work in support of the Agency's strategic
themes, and by focusing attention on the underlying causes of some
of the most severe problems which have affected the Agency for
years. In particular, we have worked on cooperative projects with
Agency managers to improve the integrity of scientific and financial
information, and Superfund accounting. We believe that the Agency is generally taking appropriate
corrective action in response to our work, especially in the areas of contract management and Superfund
administrative initiatives. However, as presented in this report, areas still remain requiring continued
Agency attention as will many new areas we are just beginning to explore, such as the use of cooperative
agreements, grants and subcontractors.
We have ambitiously applied the concepts of reinvention in the OIG by restructuring our
organization and work processes for greater staff empowerment, operational efficiency and diversity. In
fiscal 1994, the EPA OIG implemented a policy supporting our Affirmative Action Plan resulting in
minorities and women accounting for 75 percent of all new hires and promotions, and 76 percent in
grades 13 to 15.
I am encouraged that a new organizational culture, along with cooperative efforts between the
Office of Inspector General and Agency management will be the foundation for continuing improvement
in EPA.
John C. Martin
Inspector General
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EPA's Progress in Improving High Risk Areas 1
Executive Summary 5
Profile of Activities and Results 7
Establishment of the OIG in EPA-lts Role and Authority 8
Purpose and Requirements of the Office of Inspector General
Semiannual Report 8
Who's Who in the Office of Inspector General 9
Section 1-Significant Findings and Recommendations
Cost and Benefits 10
Agency Management 11
Extramural Resources Management 17
Construction Grants 23
Superfund 27
Section 2-Report Resolution
Status Report on Perpetual Inventory of Reports in Resolution Process
for the Semiannual Period Ending September 30, 1994 34
Audit Followup 34
Status of Management Decisions on IG Reports 36
Resolution of Significant Reports 39
Section 3-Prosecutive Actions
Summary of Investigative Activity 40
Description of Selected Prosecutive and Administrative Actions 41
Section 4-Fraud Prevention and Management Improvements
Review of Legislation and Regulations 43
Suspension and Debarment Activities 45
OIG Management Initiatives 47
President's Council on Integrity and Efficiency 49
Committee on Integrity and Management Improvement 50
Hotline Activities 50
Appendices
Appendix 1—Reports Issued 51
Appendix 2-Reports Issued Without Management Decisions 65
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EPA's Progress in Improving High Risk Areas
This section of our report presents
the Office of Inspector General's
(OIG) perspective on significant
problems which the Agency must
continue to address to ensure its
programs are conducted in an
effective, efficient, and economical
manner. OIG and EPA personnel
have cooperated extensively to
address these problems. The
Agency has also taken a number
of actions either independently or
in response to our reports to
improve its operations. However,
EPA's most significant problems
were created over a long period of
time, and resolution will require
long term commitments and
constant attention throughout the
Agency. Therefore, it is too soon
to determine whether EPA
management's corrective actions
will fully solve these problems.
The following presents the areas of
significant current concern to the
OIG, and some of EPA's actions
taken during this semiannual
reporting period to address them
Financial Management
OIG Concerns
The Agency team that recently
completed a National Performance
Review (NPR) of EPA's financial
management reported three
weaknesses: insufficient time and
funds; the complexity of the
various financial management
systems and processes; and a
wide disparity in expertise and
attention paid to financial
management among EPA
managers. In addition, the OIG
has repeatedly reported that EPA's
accounting systems do not provide
complete, consistent, reliable and
timely data. Although the Agency
has made ~a number of significant
improvements in financial
management, additional actions
are needed to ensure EPA
individuals responsible for financial
management have the necessary
trained staff, policies, procedures
and systems to effectively carry out
these responsibilities.
Our broad, top-level review of
EPA's financial management
program found that historically,
EPA did not give financial
management the attention it
needed. While appropriate initial
steps were taken, EPA officials did
not follow through to ensure
successful completion. Many
employees did not consider
financial management to be as
important as program
management, and users of EPA's
financial systems were concerned
with their limited capabilities and
the lack of integration between
finance and reporting systems. An
OIG audit identified over 100 EPA
contracts, closed as many as 11
years ago, with $7 million still
obligated on them, and found that
the Agency had not requested
refunds from contractors which
could potentially amount to $2
million. An audit of EPA's handling
of Superfund bankruptcy
settlements found that during fiscal
1992 and 1993, the Agency
received $22.4 million worth of
marketable securities, but had not
restricted access to or assigned
custodial responsibility for them;
and as the OIG has historically
found for other types of accounts
receivable, those for bankruptcy
settlements were not recorded
timely in EPA's accounting system.
In the Superfund Program,
problems have been reported in
cost documentation, data
accuracy, and accounting for all
past cleanup and recovery costs.
An OIG review showed problems
continue to exist in the area of
response claims against the
Superfund. Our recent follow-up
review of these response claims
showed that EPA has made
tangible efforts to address our
1992 recommendations, but that
some corrective actions have
either not been implemented or
have not corrected the problems in
areas such as reconciliations of
commitment and obligation
information, and billings for
oversight costs.
Agency Actions
In response to these reports,
EPA is taking a number of
actions. For example, EPA is
developing performance
measures for financial
management activities, setting
annual goals for closing
contracts, and improving
controls over the receipt of and
accounting for marketable
securities.
The Agency is also using OIG
consultative services in ways
other than audits in resolving
EPA's financial management
problems. The Comptroller
thanked the OIG for the
"excellent analysis . . .
performed ... to identify
unrecorded Superfund accounts
receivable balances," and stated
she is taking prompt action.
Officials in another office
thanked the OIG for helping
reconcile one of their revolving
funds allowing them to complete
a difficult task in a short period
of time.
Information Resources
Management (IRM)
OIG Concerns
IRM is critical to the success of all
program activities. For a number
of years, EPA's IRM program has
been hampered by serious
problems such as data quality
deficiencies, significant cost
overruns and delays in developing
APRIL 1, 1994 THROUGH SEPTEMBER 30, 1994
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information systems, development
of duplicate information systems,
and difficulties in addressing cross-
media pollution problems. These
problems materially impact the
effectiveness of EPA's programs.
While EPA has been taking actions
to improve its IRM program, and
we believe the Agency is generally
proceeding in the right direction,
we still have concerns about EPA's
ability and commitment to address
its long-standing IRM problems.
Our broad, top-level review of
EPA's IRM program found that
historically the Agency had not
treated information as a valuable,
strategic resource. Major systemic
deficiencies existed in four key
areas: IRM management and
organizational structure; resource
planning and performance
measurement; information system
development; and data
management. Although EPA has
taken significant steps to
implement the Integrated Financial
Management System (IFMS) such
as completing a strategy and
master work plan, and
implementing some functional
modules and a single general
ledger, further steps are needed
to achieve an integrated,
comprehensive financial
management system. During this
period we reported that the costs
to fully implement IFMS have
escalated from $7.7 million to
$17.2 million, and that target dates
for completing implementation
have slipped more than 6.5 years
to at least fiscal 1995. In addition,
EPA is spending an estimated
$11.2 million to operate its older
systems during this delay.
Agency Actions
EPA officials continue to take a
number of far-reaching actions
in response to our March 1994
report on our broad, top-level
review of EPA's IRM program.
For example, EPA has
established a new decision-
making Executive Steering
Committee for IRM made up
primarily of EPA's top
executives; is finalizing an IRM
Strategic Plan; and plans to pilot
test a working capital fund in
fiscal 1995 to help provide
stable, multi-year funding for
major IRM initiatives. In
response to our draft report on
IFMS, EPA officials stated they
had fully implemented 5 of our
16 recommendations and either
had started or were planning to
begin action on the remaining
ones.
Integrity Act
Implementation
OIG Concerns
DIG reports issued between 1992
and 1994 highlighted problems
with the Agency's ability to
effectively carry out its Integrity Act
responsibilities. We found that
many managers segregated the
Integrity Act process from other
management activities, did not
relate the process to management
control system improvements, and
knew neither what control systems
were nor how to operate them
effectively. While senior
management was committed to
identifying material weaknesses, in
our opinion the Agency did not
effectively identify them through
the lower management levels and
implement corrective actions
before they became material and
took years and significant
resources to correct. While the
Agency is implementing a new
process, we are concerned that
some EPA managers'
misperceptions about management
integrity concepts may jeopardize
its success. Managers must
understand and integrate integrity
concepts into their daily
management and accept
responsibility for implementing
sound management practices.
Agency Actions
7"Ai/s year the OIG worked with
EPA to reengineer its Integrity
Act process, making managers
more accountable for evaluating
and improving their programs
and for the integrity of their
programs and resources. The
reengineered process builds on
Agency-wide Management
Integrity Principles, which
managers are expected to
incorporate into existing
management processes and
program strategies.
Management of Extramural
Resources
OIG Concerns
EPA relies extensively on
contractors and other outside
entities to assist in cleaning up
pollution, developing national
policy, and setting the
environmental agenda for the
future. In response to past
criticism of EPA's contract
management practices, the Agency
has made significant progress in
correcting systemic deficiencies.
However, in our view, EPA
management needs to continue
improving their management of
extramural resources and to
emphasize that Agency officials
are accountable for their actions.
The pervasive nature of EPA's
resource management problems,
which detract from the
effectiveness of EPA's programs,
continues to be shown by the
following significant issues
identified by our recent work.
OFFICE OF INSPECTOR GENERAL
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• Grants and Cooperative
Agreements (CAs)
OIG audits of major conferences
coordinated by University of
Kansas and Temple University
found that EPA circumvented
assistance regulations and
misused CA funds when it
organized the conferences to be
what senior managers called "first
class event[s]." EPA did not
properly award or administer the
CAs and participated in the
unauthorized expenditure of
Federal funds for items such as
participant travel, alcohol and
entertainment. Another OIG
special review reported that over
the past 20 years EPA has not
consistently adhered to statutory
prohibitions against paying for
non-Federal attendance at
meetings and conferences with
Agency travel funds. In addition,
some EPA offices were improperly
paying travel-related expenses for
advisory committee members
through contracts and interagency
agreements. As a result of these
reports, the Inspector General
formally advised the Administrator
of concerns related to planning and
funding conferences, and
suggested that she communicate
her commitment to proper
accountability for Federal funds to
all EPA executives and managers.
An OIG special review of
assistance agreements awarded to
the Center for Earth Resource
Management Applications, Inc.,
questioned 99 percent of the costs
claimed for reasons including
conflict of interest and excessive
expenditures. Finally, an OIG
audit of CAs awarded to Montana
State University (MSU) questioned
all project costs that MSU claimed
because the CAs funded an EPA
employee's advanced education,
contrary to the stated purpose of
the CAs and the Intergovernmental
Personnel Act (IPA) Assignment
Agreement.
• Competition in Awarding
Contracts
EPA generally awarded its
competitive procurements in
accordance with Government
requirements. However, an OIG
audit found that a significant
percentage of EPA's contracts
were awarded after receipt of only
one competitive proposal, giving
EPA less assurance that it
received the benefits of
competition for these contracts. In
another audit, we found that there
was, at most, limited competition in
the award of five of the eight prime
contracts valued at over $10
million awarded to a major EPA
contractor.
• Superfund Contracting
An OIG audit of EPA's
management of Emergency
Response Cleanup Services
(ERCS) contracts showed that
EPA's plan to correct contract
management deficiencies identified
in prior OIG audits was not always
effective. EPA continues to allow
ERCS contractor non-compliance
with Federal Acquisition Regulation
and contract accounting system
requirements. Despite a decade of
doing business with EPA, the
ERCS contractors reviewed still do
not have approved accounting
systems for cost type contracts.
Without adequate independent
contractor accounting system
support, there are no assurances
that contractor billings reflect
actual, allowable incurred costs.
With one exception, sanctions for
contractor non-compliance were
not exercised because
Headquarters and regional
contracting personnel believed this
would drive away ERCS
contractors and limit future
competition.
Agency Actions
The Agency is working to
implement the 40
recommendations in its June
1992 report on EPA's contracts
management. To date, EPA has
implemented 16 of the 40 and is
in various stages on the
remaining 24, but it will be at
least one year before we can
determine the effectiveness of
these actions. In response to
our recent reports, the Agency
is taking a number of positive
corrective actions. On our
audits of conference and travel
Issues, the Agency is issuing
clarifying guidance and
providing additional training and
oversight in certain areas. The
Agency agreed that the
cooperative agreements used to
pay University of Kansas and
Temple University for their
conference management
activities should have been
contracts, but declined to
disallow all costs due to their
belief this would pose
inequitable impacts on the
universities. Finally, in
response to our audit of ERCS
contracts, EPA has begun
withholding some award fees for
contractors which are not in
compliance with Federal
accounting system
requirements, and will also be
trying a different contracting
mechanism to help address this
problem.
APRIL 1, 1994 THROUGH SEPTEMBER 30, 1994
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Major Laws Administered by EPA
Statute
Pollution Prevention Act
Toxic Substances Control Act
Federal Insecticide, Fungicide,
and Rodenticide Act
Federal Food, Drug and Cosmetic Act
Resource Conservation and Recovery Act
and Solid Waste Disposal Act
Comprehensive Environmental Response,
Compensation, and Liability Act
Clean Air Act
Clean Water Act
Safe Drinking Water Act
Marine Protection, Research and
Sanctuaries Act
Asbestos School Hazard Abatement Act
and Asbestos Hazard Emergency
Response Act
Emergency Planning and Community
Right-to-Know Act
Oil Pollution Act of 1990
Environmental Research, Development,
and Demonstration Authorization Act
National Environmental Education Act
Provisions
Provides that pollution should be prevented or reduced at the source,
recycled safely when not preventable, treated safely when not
preventable or recyclable, and as a last resort, disposed of or
otherwise released into the environment in a safe manner.
Requires EPA notification of any new chemical prior to its
manufacture and authorizes EPA to regulate production, use, or
disposal of a chemical.
Authorizes EPA to register all pesticides, specify the terms and
conditions of their use, and remove unreasonably hazardous
pesticides from the marketplace.
Authorizes EPA in cooperation with FDA to establish tolerance levels
for pesticide residues on food.
Authorizes EPA to identify hazardous wastes and regulate their
generation, transportation, treatment, storage, and disposal.
Requires EPA to designate hazardous substances that can present
substantial danger and authorizes the cleanup of sites contaminated
with such substances.
Authorizes EPA to set emission standards to limit the release of
criteria pollutants and hazardous air pollutants.
Requires EPA to establish a list of toxic water pollutants and set
standards.
Requires EPA to set drinking water standards to protect public health
from hazardous substances.
Regulates ocean dumping of toxic contaminants.
Authorizes EPA to provide loans and grants to schools for abatement
of asbestos hazards and 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.
Authorizes all EPA research and development programs.
Provides for a program of education on the environment through
activities in schools, institutions of higher education and related
OFFICE OF INSPECTOR GENERAL
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Executive Summary
Section 1-
Significant Findings
and
Recommendations
1. LUST Program on
American Indian Lands
Needs Improvements
EPA has not effectively
implemented a nationwide
program to clean up leaking
underground storage tanks on
American Indian lands, some
of which are contaminating
drinking water (page 11)
2. Improvements Needed
in Idaho's Leaking
Underground Storage Tank
(LUST) Program
The State of Idaho did not
have adequate personnel time
or other accounting
documentation to support
$711,905 in costs claimed to
the LUST program. The State
also needed to improve its
oversight of high priority LUST
sites, cost recoveries, and
reporting procedures (page
12)
3. Streamlined Integrity Act
Process Stresses
Accountability
The Agency previously
segregated the Federal
Managers' Financial Integrity
Act (Integrity Act) process
from other management
activities. Most managers
responded to the paper-
intensive requirements without
using it to measure progress
or to detect and correct
weaknesses. In addition,
managers had not received
adequate training and
guidance (page 13)
4. Over $200 Million in
Unliquidated and Excess
Contract Obligations
EPA did not close or obtain
refunds on almost 2,000
inactive contracts or
deobligate $7 million in excess
funds on over 100 closed
contracts. This left over $200
million in unliquidated
obligations that could have
used for other environmental
purposes or returned to the
U.S. Treasury (page 14)
5. Further Actions Needed
on EPA'S Integrated
Financial Management
System (IFMS)
After years of problems and
cost overruns, continued
Agency top management
attention is required to make
the IFMS reliable, usable, and
cost effective (page 15)
6. Centralized
Administrative Management
Needed to Improve
Technology Program
Although EPA is successfully
publicizing the concept of the
Federal Technology Transfer
Act (FTTA) and encouraging
the creation of public-private
partnerships, the program can
be enhanced with centralized
oversight of the Cooperative
Research and Development
Agreement (CRADA) process,
including stronger internal
control of the funds the
Agency receives from outside
organizations (page 16)
7. Additional Improvements
Needed in Contracting With
Small and Disadvantaged
Businesses
EPA complied with laws and
regulations in awarding and
amending contracts to small
and disadvantaged business
firms during fiscal 1993.
However, contrary to the
objectives of the program,
awards were made just days
before the firms' program
eligibility expired (page 17).
8. Improperly Procured
Services Included Inherently
Governmental Functions
EPA inappropriately procured
$150,000 of program
management services,
including inherently
governmental functions, under
a sole source cooperative
agreement rather than a
competitive process (page
18)
9. Conflict of Interest
Increases Questioned Costs
The Center for Earth
Resource Management
Applications, Inc. (CERMA)
violated EPA's conflict of
interest regulations, failed to
maintain an adequate financial
management system, and
their internal control structure
contained significant
deficiencies. In addition,
nearly all costs claimed by
CERMA were questioned
(page 18)
10. Cooperative
Agreements Misused for
Graduate Courses
Two cooperative agreements
(CA) awarded to evaluate and
refine techniques to identify
and measure environmentally
significant chemicals, were
used to provide graduate
course work at Montana State
University (MSU) for an
Agency employee. In
addition, other costs claimed
under the cooperative
agreements could not be
supported (page 19)
11. EPA Improperly
Awarded Cooperative
Agreements and Approved
Excessive Expenditures for
Two Conferences
• 1989 Award to the
University of Kansas
EPA circumvented assistance
regulations and misused
Federal funds by awarding a
cooperative agreement to the
University of Kansas (KU)
which included ineligible and
unnecessary costs such as
travel, alcohol, and
entertainment (page 20)
• 1991 Award to Temple
University
EPA erroneously awarded a
cooperative agreement to
Temple University and
mismanaged the agreement
by not controlling expenditures
and allowing unauthorized
travel (page 21)
12. Non-Federal Employee
Travel Expenses Improperly
Paid
EPA misused Agency travel
funds, contracts, and
interagency and cooperative
agreements to pay travel-
related expenses for non-
Federal employee attendance
at conferences and meetings
(page 22)
13. Almost $9.4 Million of
Costs Questioned for
Vallejo, California, Project
Vallejo, California, claimed
$5,525,458 of ineligible
administration, engineering
and construction costs for the
Vallejo Sanitation and Flood
Control District project An
additional $3,874,497 of
unreasonable project costs
were questioned (page 24)
14. Over $8.2 Million of
Ineligible Costs Claimed for
Houston, Texas, Project
Houston, Texas, claimed
$6,159,937 of ineligible
engineering and construction
costs for the construction of a
wastewater treatment facility
An additional $991,174 of
unsupported costs and
$1,063,235 of unnecessary or
unreasonable costs were
questioned (page 24).
15. Fairfax County, Virginia,
Claimed Nearly $4.3 Million
of Questioned Costs
The County of Fairfax,
Virginia, claimed $3,533,822
of ineligible architectural
engineering and construction
costs for wastewater treatment
APRIL 1, 1994 THROUGH SEPTEMBER 30, 1994
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facility improvements An
additional $752,097 of
unsupported costs were
questioned (page 25).
16. Onondaga County, New
York, Claimed Nearly $5.8
Million of Questioned Costs
for Sewers
Onondaga County, New York,
claimed $1,888,500 of •
ineligible architectural
engineering and construction
for the design and
construction of Ley Creek
service area improvements,
and $3,863,733 of costs that
exceeded the grant ceiling
(page 25)
17. Over $4.5 Million of
Questioned Costs Claimed
for Ocean County, New
Jersey, Project
The Ocean County Utilities
Authority, New Jersey claimed
$3,057,931 of ineligible
architectural engineering,
construction, force account,
administrative, and innovative
and alternative technology
costs for the construction of
wastewater treatment facilities.
An additional $1,455,727 of
unsupported costs were
questioned (page 26)
18. Contractors Still Lack
Adequate Accounting
Systems
Emergency Response
Cleanup Services (ERGS)
contractor accounting system
deficiencies noted in past OIG
reports still exist because of
inadequate enforcement by
EPA personnel In addition,
EPA rarely exercised
sanctions for contractor non-
compliance (page 28).
19. Better Controls Needed
to Protect Over $22 Million
in Securities in Bankruptcy
Cases
EPA had limited controls in
place to safeguard marketable
securities received as a result
of Superfund cost recovery
efforts. Also, current
bankruptcy laws hinder EPA's
cost recovery efforts (page
29)
20. Over $227,000 of
Ineligible Claims for
Minnesota Superfund Site
The Minnesota Pollution
Control Agency (MPCA) had
weak internal controls over
personnel and contractor
costs, and did not comply with
procurement laws and
regulations As a result, we
questioned $227,584 of the
costs claimed for the Ritari
Post and Pole site under a
Superfund multi-site
cooperative agreement
(page 30).
21. Over $278,000 of
Questioned Costs Claimed
for Georgia Superfund
Activities
The Georgia Department of
Natural Resources,
Environmental Protection
Division (GDNR), did not
properly account for labor
costs or fund use in
compliance with EPA
regulations. We questioned
$278,756 of the costs claimed
for three Superfund
Cooperative Agreements
(page 30).
22. Superfund
Administrative Initiatives
Reduce Time and Save
Money
EPA conducted a variety of
successful initiatives which
demonstrated the potential for
reducing the time and cost of
cleanups, and for making the
process more equitable.
However, improvements were
needed in analyzing,
measuring, and publicizing the
results of pilot projects to
replicate successful
techniques nationwide
(page 32).
Section 2~Report
Resolution
At the beginning of the
semiannual period; there were
248 reports for which no
management decision had
been made. During the
second half of fiscal 1994, the
Office of Inspector General
issued 796 new reports and
closed 813. At the end of the
reporting period, 231 reports
remained in the Agency
followup system for which no
management decision had
been made. Of the 231
reports, 73 reports remained
in the Agency followup system
for which no management
decision was made within 6
months of issuance (page 33).
For the 245 reports closed
that required Agency action,
EPA management disallowed
$35.3 million of questioned
costs for recovery and agreed
with our recommendations
that $2.5 million be put to
better use (page 34). In
addition, cost recoveries in
current and prior periods
included $2 06 million in cash
collections, and at least
$34.78 million in offsets
against billings (page 7).
Section 3-
Prosecutive Actions
During this semiannual
reporting period, our
investigative efforts resulted in
7 convictions and 11
indictments Also, during this
semiannual period, our
investigative work led to $0.2
million in fines and recoveries
(page 40).
Section 4-Fraud
Prevention and
Resources
Management
During this semiannual period,
we reviewed 3 legislative and
70 regulatory items. The most
significant were comments on
the proposed Inspector
General Reform Act of 1994
(H.R 4679) and OMB's
request for views on S. 1782,
the Electronic Freedom of
Information Improvement Act
(page 43).
The Office of Grants and
Debarment completed action
on 37 OIG generated
suspension and debarment
cases during this reporting
period, resulting in 20
suspensions, 12 debarments,
and 5 compliance agreements
(page 45).
The EPA Committee on
Integrity and Management
Improvement (CIMI), chaired
by the Inspector General,
developed and distributed a
bulletin to EPA personnel with
a brief synopsis of the
activities permitted under the
revisions to the Hatch Act,
which became effective on
February 3, 1994 (page 50).
Twenty-four Hotline cases
were opened and 32 were
closed during the reporting
period. Of the closed cases, 5
resulted in environmental,
prosecutive, or administrative
corrective action (page 50).
OFFICE OF INSPECTOR GENERAL
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Profile of Activities and Results
Office of Inspector General
April 1, 1994, to
September 30, 1994 Fiscal 1994
(dollars in millions)
Audit Operations
OIG Managed Reviews:
- Reviews Performed by EPA, Independent
Public Accountants and State Auditors
- Questioned Costs*
- Total $65.8
- Federal Share $48 8
Recommended Efficiencies*
(Funds be Put to Better Use)
- Total $0 3
- Federal Share $0 3
Cost Disallowed to be Recovered
- Federal Share (costs which EPA
management agrees are unallowable
and is committed to recover or
offset against future payments) $34.4
Cost Disallowed as Cost Efficiency
Federal Share (funds made available
by EPA management's commitment to
implement recommendations in OIG
performance and preaward audits) $0.0
$156.5
$114.6
$24
$2.4
$773
$00
April 1, 1994, to
September 30, 1994 Fiscal 1994
(dollars in millions)
Agency Recoveries:
- Recoveries from Audit Resolutions of
Current and Prior Periods (cash collections
or offsets to future payments.)** $36.8 $67 2
Reports Issued:
- OIG Managed Reviews:
- EPA Reviews Performed by the OIG 98 164
- EPA Reviews Performed by Independent
Public Accountants 29 69
- EPA Reviews Performed by State Auditors 2 10
- Other Reviews:
- EPA Reviews Performed by
another Federal Agency 292 500
- Single Audit Act Reviews 375 783
Total Reports Issued 796 1,526
Reports Resolved (Agreement by
Agency officials to take satisfactory
corrective action)*** 245 517
Other Reviews:
Reviews Performed by another
Federal Agency or Single Audit Act Auditors
- Questioned Costs*
- Total $3.8 $8.6
- Federal Share $3.8 $8.6
- Recommended Efficiencies*
- Total $9.4 $15.4
- Federal Share $9.4 $154
- Cost Disallowed to be Recovered
- Federal Share $0.9 $2.8
- Cost Disallowed as Cost Efficiency
- Federal Share $2.5 $3.8
Investigative Operations
- Fines and Recoveries (including civil) $0.2
- Investigations Opened 96
- Investigation Closed 128
- Indictments of Persons or Firms 11
- Convictions of Persons or Firms 7
- Administrative Actions Against EPA
Employees 8
$1.8
233
272
19
14
27
Fraud Detection and Prevention Operations
• Debarments, Suspensions, and
Compliance Agreements 37
• Hotline Cases Opened 24
Hotline Cases Processed and Closed 32
Personnel Security Investigations
Adjudicated 1012
81
4J
61
167C
'Questioned Costs (Ineligible, Unsupported, and Unnecessary/Unreasonable) and Recommended Efficiencies (Funds be Put to Better Use) are
subject to change pending further review in the audit resolution process
"Information on recoveries from audit resolution is provided from the EPA Financial Management Division and is unaudited.
'"Reports resolved are subject to change pending further review.
APRIL 1,1994 THROUGH SEPTEMBER 30,1994
-------
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 1994, the Agency
was appropriated
$6,658,927,000 and
authorized 18,625 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 $44.6 million to carry
out the provisions of the
Inspector General Act of
1978, as amended. Nearly
$16.3 million of the OIG's
appropriation was derived
from the Hazardous
Substance Superfund trust
fund and $669,100 was
derived from the Leaking
Underground Storage Tank
trust fund. The OIG has a
funded staffing level of 449
FTE positions. The funding
and FTE available to the OIG
represent 0.7 percent and
2.4 percent, respectively, of
the Agency's totals.
Purpose and
Requirements of the
Office of Inspector
General Semiannual
Report
The Inspector General Act of
1978 (Public Law 95-452), as
amended, requires the
Inspector General to keep the
Administrator and Congress
fully and currently informed of
problems and deficiencies in
the Agency's operations and
to recommend corrective
action.
The IG Act further specifies
that semiannual reports will
be provided to the
Administrator by each April 31
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)
Section 5(a)(1)
Section 5(a)(2)
Section 5(a)(3)
Section 5(a)(4)
Section 5(a)(5)
Section 5(a)(6)
Section 5(a)(7)
Section 5(a)(8)
Section 5(a)(9)
Review of Legislation and Regulations
Significant Problems, Abuses, and
Deficiencies
Recommendations with Respect to
Significant Problems, Abuses, and
Deficiencies
1
Prior Significant Recommendations on
Which Corrective Action Has Not
Been Completed Appendix 2
Matters Referred to Prosecutive
Authorities 3
Summary of Instances
Where Information Was Refused
List of Audit Reports Appendix 1
Summary of Significant Reports 1
Statistical Table 1-Reports With
Questioned Costs 2
Statistical Table 2-Reports With
Recommendations That Funds Be Put
To Better Use 2
Section 5(a)(10) Summary of Previous Audit
Reports Without Management
Decisions
Appendix 2
Section 5(a)(11) Description and Explanation of Revised
Management Decisions Appendix 2
43
10
10
65
40
*
51
10
37
38
65
65
Section 5(a)(12) Management Decisions with Which the
Inspector General Is in Disagreement **
* There were no instances where information or ass/stance requested
by the Inspector General was refused during this reporting period.
" There were no instances of management decisions with which the
Inspector General was in disagreement.
OFFICE OF INSPECTOR GENERAL
-------
Headquarters
Office of Inspector General-Who's Who
Inspector General
John C. Martin
Deputy Inspector General
Anna Hopkins Virbick
Office of Audit
Kenneth A. Konz
Assistant Inspector General
Janes 0. Rauch
De
uty
Office of Management
John C. Jones
Assistant Inspector General
Office of Investigations
Daniel S. Sweeney
Assistant Inspector General
Michael J. Fitzsiunions
Deputy
Acquisition & Assistance
Audits
Elissa R. Karpf
Internal and Performance
Audits
Michael D. Simmons
Program Management Division
John T. Walsh
Resources Management Division
Michael J. Binder
Planning and Resources Management
Kenneth D. Hockman
Engineeering & Science
Walter 6. Gilbert
ADP Audits & Support
Craig Silverthorne
Divisional Inspectors General
10
x^
Regions 9 & 10
Truman R Beeler,
Audit
GUAM
HAWAII
Region 5
Anthony C. Carrollo, Audit
Region 4, 5, 6, 7, 8, 9, & 10
Allen P. Fallin, Investigations
Regions 7 & 8
Nikki Tinsley, Audit
Regions 4 & 6
Mary Boyer, Audit
Region 1, 2
Paul McKechnie, Audit
Region 1, 2, & 3
Thomas Papineau,
Investigations
Region 3
Paul R. Gandolfo, Audit
Headquarters
Edward Gekosky
HQs Audit Division
Melissa M. Heist
Financial Audit Div.
Emmett D Dashiell
Procurement Fraud
Div., Investigations
APRIL 1,1994 THROUGH SEPTEMBER 30, 1994
-------
Section 1 -- Significant Findings 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. Audit
findings are open to further
review but are the final position
of the Office of Inspector
General. This section is divided
into four areas: Agency
Management, Extramural
Resources Management,
Construction Grants, and
Superfund.
Photo by Steve Deianey
FISCAL 1994 COST BENEFITS OF AUDIT EFFORTS
(IG AUDIT BUDGET, AUDIT RESULTS, AND EPA MANAGEMENT DECISIONS)
140
120
100
80
60
40
20
FEDERAL COSTS
QUESTIONED
$123.2 MILLION
EPA DECISIONS TO
RECOVER FUNDS
FY 94 AUDIT BUDGET
10
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 performance 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 audit,
performance audit, and special
review findings and
recommendations pertaining to
Agency management resulting
from our efforts during this
semiannual reporting period.
LUST Program on
American Indian Lands
Needs Improvements
Findings In Brief
EPA has not effectively
implemented a nationwide
program to clean up leaking
underground storage tanks on
American Indian lands, some of
which are contaminating
drinking water.
Background
In 1986, Congress established
what has become a $1.1 billion
Leaking Underground Storage
Tank (LUST) trust fund for cleaning
up leaking tanks, about $475
million of which had been
appropriated as of fiscal 1994.
Indian tribes are particularly
vulnerable to the health risks
posed by leaking underground
storage tanks due to their heavy
reliance on groundwater for
drinking water. In general, EPA
and the tribes share responsibility
for operating the underground
storage tank program on Indian
lands, because Indian tribes are
not treated as states and cannot
legally be regulated by states.
We Found That
EPA had not established many of
the management controls needed
to operate the LUST program, and
had not devoted the resources
necessary to fully implement the
program on American Indian lands.
Due to the lack of resources,
implementation on Indian lands by
some EPA regions was less than
that by some states on non-Indian
lands.
EPA has not developed a reliable
national inventory of underground
tanks or leaking tanks on American
Indian lands. Although most of the
regions have attempted to develop
inventories, we found one of the
largest regional inventories may be
understated by as much as 61
percent. An accurate inventory is
the critical, first step to identifying
leaking tanks and controlling the
leaking tank problem. The need
for a national inventory of
underground storage tanks on
Indian lands was previously
APRIL 1, 1994 THROUGH SEPTEMBER 30, 1994
11
-------
identified by the EPA OIG in a
March 1992 audit report.
Slow progress has been made in
cleaning up leaking underground
tanks which contaminated drinking
water, groundwater, and the soil on
American Indian lands. At least 75
percent of the leaking underground
tank sites on American Indian
lands had not been cleaned up,
including those contaminating
drinking water.
EPA's enforcement program for
LUST sites on American Indian
lands was insufficient to foster full
compliance with laws, and resulted
in only two administrative
complaints for leaking tank sites
since inception of the LUST
program in 1988.
We Recommended That
The Assistant Administrator for
Solid Waste and Emergency
Response:
• Establish a consistent nationwide
LUST program on Indian lands,
which includes national goals,
priorities, policies, performance
measures, and uniform
management information reporting
requirements.
• Revise EPA's implementation
strategy to address a way of
overcoming barriers such as the
lack of resources.
• Require the development of an
accurate, up-to-date inventory of
underground tanks and leaking
tanks to be a top priority action
item.
• Coordinate with the Office of
Enforcement and Compliance
Assurance to establish a strong
enforcement program on Indian
lands as a priority action item.
What Action Was Taken
In responding to the draft report,
the Assistant Administrator for
Solid Waste and Emergency
Response (OSWER) concurred
with our audit recommendations
and agreed to take appropriate
actions to resolve the audit issues.
Although the Assistant
Administrator for Enforcement and
Compliance Assurance (OECA) did
not formally respond to the draft
report, prior discussions with
representatives from OECA
indicate general agreement with
OSWER's response. On
September 29, 1994, the final
report (4100573) was issued to the
Assistant Administrators for Solid
Waste and Emergency Response
and Enforcement and Compliance
Assurance. A response to the final
report is due by December 28,
1994.
Improvements Needed in
Idaho's Leaking
Underground Storage Tank
(LUST) Program
Findings In Brief
The State of Idaho did not have
adequate personnel time or
other accounting documentation
to support $711,905 in costs
claimed to the LUST program.
The State also needed to
improve its oversight of high
priority LUST sites, cost
recoveries, and reporting
procedures.
Background
The LUST Trust Fund was
established to finance the cleanup
of petroleum releases from leaking
underground storage tanks EPA
provided funds to the State of
Idaho through cooperative
agreements to pay for the cleanup
of LUST sites, oversight of
responsible party cleanups,
recovery of Trust Fund
expenditures, and administrative
expenditures directly related to
these activities.
We Found That
EPA awarded $835,008 to the
State of Idaho through a LUST
cooperative agreement. Claimed
costs of $711,905 were questioned
as unsupported because claimed
payroll costs were based upon
budget allocations instead of actual
time worked on the program, and
non-personnel costs were not
supported with sufficient evidence
to show that the costs were
allocable to the program.
The State did not give sufficient
attention to some LUST sites that
posed the greatest threat to human
health and the environment. A
sample of 23 sites designated
either as high priority or as
contaminating groundwater
disclosed that remediation for nine
of the sites either was not
conducted or needed improvement.
The State's procedures used for
the recovery of LUST Trust Fund
expenditures needed improvement
to ensure that recoveries of all
LUST trust funds expended on
sites were obtained from
responsible parties. Recoveries for
four sites did not cover all of the
costs related to the sites, the
settlements were not adequately
documented, and the State did not
charge interest on the amounts to
be recovered.
Quarterly reports from the State of
Idaho did not accurately report
LUST program activity during fiscal
1993. The number of confirmed
releases were understated by 16
percent, cleanups initiated were
overstated by 18 percent, and
cleanups completed were
understated by 57 percent. In
12
OFFICE OF INSPECTOR GENERAL
-------
addition, the quarterly reports ,
included activity that had occurred
prior to the reporting periods.
We Recommended That
The Regional Administrator,
Region 10, require the State of
Idaho to:
• Either provide support for costs
claimed and make a financial
adjustment for costs not supported,
or seek a deviation from the
Federal requirements for such
supporting documentation.
• Claim costs based on actual
costs and establish procedures
which ensure that amounts claimed
are allowable and allocable.
• Ensure that oversight activities
are based on assigned priorities
and that priorities are assigned to
all sites.
• Ensure that each cost recovery
claim includes all costs associated
with the site and that settlements
are documented.
• Assess interest charges on cost
recovery amounts.
• Ensure that quarterly report
information is reconciled to source
documentation and that LUST
program activity is reported timely.
What Action Was Taken
In responding to the draft report,
the State of Idaho agreed to
implement most of our
recommendations relating to
performance issues. The State
disagreed with our conclusions
pertaining to the questioned costs,
because it believed that its
accounting system was in
compliance with Federal
accounting requirements. On
September 28, 1994, the final audit
report (4100563) was issued to the
Regional Administrator. A
response to the final report is due
by December 29, 1994.
Streamlined Integrity Act
Process Stresses
Accountability
Findings in Brief
The Agency previously
segregated the Federal
Managers' Financial Integrity Act
(Integrity Act) process from
other management activities.
Most managers responded to
the paper-intensive
requirements without using it to
measure progress or to detect
and correct weaknesses. In
addition, managers had not
received adequate training and
guidance.
Background
Congress passed the Integrity Act
in 1982 to renew the Federal
government's focus on
strengthening internal controls by
requiring agencies to continuously
evaluate and report to Congress
and the President on the adequacy
of control systems. In fiscal 1994,
the Agency reengineered the
Integrity Act requirements to
streamline the process and make
managers more accountable for
ongoing evaluations and program
improvements.
We Found That
The Agency did not achieve
substantive results from its
Integrity Act efforts because the
Agency segregated implementation
from other management activities.
Managers usually accomplished
the steps but did not realize that
the process was a means of
establishing effective program
management. The Agency's
Integrity Act guidance and training
were deficient and did not
successfully communicate
concepts to Agency managers who
were unable to link the process to
their day-to-day operations.
Managers generally did not identify
weaknesses through control
reviews because they did not test
controls to see if programs and
functions were operating as
intended. The majority of
weaknesses were identified
externally, and managers did not
use a building block process that
enabled weaknesses they
identified to flow up through the
Agency's management structure to
the program and function offices as
contemplated by the Integrity Act.
Recently, the Agency reengineered
the Integrity Act requirements to
streamline the process and
integrate responsibilities for prompt
detection, correction, and
prevention of problems in program
planning, budgeting, operations,
fiscal management, and evaluation,
making managers more
accountable for evaluating and
improving their programs as part of
everyday operations. However,
the reengineered program will
succeed only if managers accept
responsibility for implementing
sound management practices, and
the Agency rewards managers who
identify problems and improve
control systems.
We Recommended That
The Administrator:
• Require AAs and RAs to direct
their senior managers to develop
guidance and procedures for
reporting weaknesses and
suggested corrective actions
through the organizational structure
which includes requiring managers
to report weaknesses in writing to
National Program Managers.
APRIL 1, 1994 THROUGH SEPTEMBER 30, 1994
13
-------
• Require AAs and RAs to assess
and document the overall
magnitude of weaknesses and
corrective actions reported to them
by managers throughout the
Agency.
• Direct AAs and RAs to hold their
senior managers accountable for
providing training on- the Agency's
new integrity process and to hold
all managers accountable through
the performance appraisal process
for identifying and correcting
weaknesses in the way they carry
out their programs and achieve
results.
What Action Was Taken
In responding to the draft report,
the Agency Comptroller generally
agreed with the finding and
recommendations regarding the
cumbersome and paper-intensive
nature of the Integrity Act process
and that guidance and training
were not always clear and
complete. However, the
Comptroller disagreed with the
second finding related to control
reviews and stated that annual
guidance provided sufficient criteria
for conducting proper reviews and
for reporting weaknesses through
the chain-of-command. The final
report (4100522) was issued on
September 16, 1994. A response
to the final report is due by
December 16, 1994.
Over $200 Million in
Unliquidated and Excess
Contract Obligations
Findings in Brief
EPA did not close or obtain
refunds on almost 2,000 inactive
contracts or deobligate $7
million in excess funds on over
100 closed contracts. This left
over $200 million in unliquidated
obligations that could have been
used for other environmental
purposes or returned to the U.S.
Treasury.
Background
During the past 23 years, the
Agency's contract obligations have
exceeded $12 billion for work
performed under 14,500 contracts.
With the enactment of legislation in
1990, timely contract closeout,
deobligation of unexpended
monies, and receipt of refunds due
the Agency became even more
important in helping the Agency
avoid using current financial
resources on old contractual
issues.
We Found That
Closing almost 2,000 inactive
contracts in a timely manner could
have allowed EPA to deobligate
over $200 million, over one-half of
which is Superfund money. Some
of these funds should have been
deobligated almost 12 years ago
and then used to either pay for
other Government programs or
EPA projects or initiatives. For
appropriations other than
Superfund, the Agency is required
to return funds obligated prior to
fiscal 1989 to the U.S. Treasury
causing payments needed to
finalize older contracts to be paid
from current year funds subject to
a one percent limitation.
In addition, we estimate that the
Agency has not requested refunds
from contractors which could
potentially amount to $2 million.
This occurred because refunds are
usually calculated during the
closeout process which was'a low
priority and not consistently
accomplished.
We also found over 100 contracts
were closed as many as 11 years
ago, and $7 million was not
deobligated because Agency
personnel did not prepare the
necessary documentation. The
Agency could have reprogrammed
$4.4 million for use in EPA
Superfund programs and returned
$2.6 million to the U.S. Treasury.
We Recommended That
The Assistant Administrator for
Administration and Resources
Management:
• Emphasize the importance of
timely contract closeout to all
personnel responsible for this
function.
• Close completed contracts in
accordance with the time frames
specified by the Federal
Acquisition Regulation (FAR) and
deobligate excess funds in a timely
manner.
• When closing contracts, direct
initial efforts to those contracts with
fiscal 1989 appropriations.
• Deobligate excess funds on all
closed contracts as required by
FAR.
What Action Was Taken
The final report (4100462) was
issued to the Assistant
Administrator for Administration
and Resources Management on
July 21, 1994. In responding to
our draft report, the Agency agreed
with our recommendations and
provided an acceptable action plan
to correct the identified
weaknesses, including setting
annual goals for closing contracts
and dedicating personnel to this
function to the greatest extent
possible. As a result, we closed
this audit in our tracking system
and all corrective actions will now
be tracked in the Agency's
Management Audit Tracking
System.
14
OFFICE OF INSPECTOR GENERAL
-------
Further Actions Needed on
ERA'S Integrated Financial
Management System
(IFMS)
Findings in Brief
After years of problems and cost
overruns, continued Agency top
management attention is
required to make the IFMS
reliable, usable, and cost
effective.
Background
Since the mid-1980's, EPA has
been developing a major system,
IFMS, to integrate all of its financial
systems which track and control
over $6.9 billion annually. In 1987,
EPA contracted for the software
and related services to implement
IFMS.
We Found That
EPA has taken a number of
significant steps to implement an
integrated financial management
system and to overcome previous
management problems. These
steps include: (1) implementing a
single general ledger; (2)
appointing a Chief Financial Officer
(CFO), Deputy CFO, and a
Director, IFMS Project
Management Staff; (3) completing
the IFMS Strategy and Master
Work Plan; (4) implementing the
newest off-the-shelf software
version which upgraded IFMS
capabilities; and (5) completing an
updated cost study, requirements
analysis, and charter.
Despite these accomplishments,
the Agency still needs to take
further significant actions to fully
implement an integrated,
comprehensive financial
management system. Target
dates for completing IFMS
implementation have slipped more
than 6.5 years, to at least fiscal
1995. Until full implementation is
attained, the return on the planned
IFMS investment over the
remaining system life will be
limited. Specifically, EPA has not
implemented critical modules;
eliminated dependency on the
existing financial systems which, in
part, duplicate IFMS functions and
capabilities; and fully interfaced
IFMS to financial subsystems and
other administrative systems.
As a result, EPA has incurred cost
overruns and other unexpected
operational costs, such as:
• Development and
implementation costs have
escalated from $7.7 million to
$17.2 million. These costs include
at least $148,100 EPA spent on
software and maintenance costs
for modules that the Agency
purchased but did not use;
• EPA will incur additional costs to
operate and maintain the existing
systems until IFMS is fully
implemented. We estimate these
costs could be as much as $11.2
million from 1990 to 1995; and
• EPA may incur additional
expenditures ranging from an
estimated $415,000 to several
million dollars over the next two
years to update the account code
structure and convert historical
data from older systems.
EPA did not develop, review, and
update costs throughout the IFMS
system life cycle to effectively
control the development and
operation of the system. As a
result, EPA management is not in
a position to make informed
system and budget decisions
regarding the design, development,
operation, and maintenance of the
system which will cost
approximately $202 million over an
estimated 12-year system life.
The IFMS problems were primarily
due to: (1) insufficient top
management leadership and
direction over IFMS development
and implementation; (2)
fragmented managerial authority
and unclear lines of authority; (3)
IFMS decisions made without a
comprehensive plan based on a
generally accepted system life
cycle approach; (4)
overcustomizing the off-the-shelf
software; (5) the absence of a
comprehensive system to
accumulate costs; and (6) unclear
EPA policies and guidance on life
cycle costing.
We Recommended That
The Assistant Administrator for
Administration and Resources
Management:
• Provide continued top
management involvement and
leadership in IFMS development
and implementation.
• Continue to reassess the plans,
goals, alternative solutions, costs
and benefits of the remaining IFMS
phased implementation.
• Limit customization to the off-
the-shelf software modules.
• Revise the IFMS Charter and
IFMS Strategy and Master Work
Plan to reflect the IFMS system of
accountability and establish
priorities and realistic target dates.
• Establish an accurate and
effective methodology and process
to accumulate, track, and monitor
all IFMS life cycle costs.
What Action Was Taken
Agency officials generally agreed
with our findings and
recommendations. In fact, the
Agency completed action on 5 of
our 16 recommendations and has
APRIL 1, 1994 THROUGH SEPTEMBER 30, 1994
15
-------
initiated or has plans to initiate
action on the remaining 11. For
example, during the course of the
audit top management involvement
with and oversight of IFMS
development increased
substantially. The final report
(4100561) was issued to the
Assistant Administrator for
Administration and Resources
Management on September 28,
1994. A response to the final
report is due by December 28,
1994.
Centralized Administrative
Management Needed to
Improve Technology
Program
Findings in Brief
Although EPA is successfully
publicizing the concept of the
Federal Technology Transfer Act
(FTTA) and encouraging the
creation of public-private
partnerships, the program can
be enhanced with centralized
oversight of the Cooperative
Research and Development
Agreement (CRADA) process,
including stronger internal
control of the funds the Agency
receives from outside
organizations.
Background
The FTTA, designed to speed the
transfer of patents and technology
to the private sector, authorizes
government-operated laboratories
and offices to enter into CRADAs
and licensing agreements with
other parties, under which the
government may receive and use
funds from outside parties . As an
added incentive, the Act permits
Federal laboratories and individual
inventors to collect royalties from
licensing agreements with private
companies to market government-
owned inventions.
We Found That
EPA is successfully fulfilling the
objectives of the FTTA by taking
an active role in formulating and
implementing procedures to
facilitate the development and
rapid movement of technology to
the private sector, and by
publicizing the concepts of FTTA
and encouraging the use of
CRADAs and licensing agreements
as defined by the Act.
Although the number of
agreements has nearly doubled
every year as interest has grown
and the process has become more
streamlined, we found that
CRADAs do not have the
centralized administrative
management to track payments
and monitor status that exists for
other legal documents, such as
contracts and grants. CRADAs do
not have the equivalent of a
contracting officer or grant
specialist to oversee the
administrative functions once the
agreement is in effect, and we
believe the current decentralized
oversight may lead to problems,
the most serious of which would be
that lost or misdirected funds could
go unnoticed. We noted several
instances where the Agency had
not received scheduled payments
from CRADA companies, and
internal controls were insufficient
for tracking payments.
We Recommended That
The Assistant Administrator for
Administration and Resources
Management require the Director,
Grants Administration Division, to
establish and document a process
for administrative management of
CRADAs which tracks payments
and monitors their status. The
process should include a
reconciliation of amounts due to
amounts received; a uniform
numbering system for CRADAs;
maintenance of all original signed
CRADAs; and provisions for
modifying or canceling existing
CRADAs and adequate
documentation of such events.
What Action Was Taken
The final report (4100470) was
issued to the Assistant
Administrator for Administration
and Resources Management and
the Acting Assistant Administrator
for Research and Development on
July 29, 1994. In responding to
the draft report, the Agency agreed
to track CRADA payments, monitor
their status, and initiate an Agency-
wide FTTA task force to consider
potential modifications and develop
revisions to the EPA guidance to
assure a comprehensive
management system for the FTTA
program. As a result, we closed
out this audit in our tracking
system and all corrective actions
will now be tracked in the Agency's
Management Audit Tracking
System.
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OFFICE OF INSPECTOR GENERAL
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Extramural Resources
Management
Over the past several years, the
OIG has repeatedly identified
problems in the Agency's award
and administration of contracts,
interagency agreements, and
cooperative agreements at
various EPA offices and
facilities. During this
semiannual reporting period, the
OIG conducted a major review to
examine EPA's programs for
using 8(a) contractors.
Independent audits of the
records and performance of
individual contractors and
recipients of assistance
agreements were also
conducted in accordance with
the General Accounting Office
standards for audits of
governmental organizations,
programs, activities, and
functions. These audits
determine whether costs
claimed by contractors are
eligible, supported by
documentation, necessary, and
reasonable. Reviews were also
conducted of EPA's use of
extramural resources to pay for
conference support and travel.
Summaries follow of the most
significant findings and
recommendations reported
during this semiannual period.
Additional Improvements
Needed in Contracting
With Small and
Disadvantaged Businesses
Findings in Brief
EPA complied with laws and
regulations in awarding and
amending contracts to small and
disadvantaged business firms
during fiscal 1993. However,
contrary to the objectives of the
program, awards were made just
days before the firms' program
eligibility expired.
Background
Section 8(a) of the Small Business
Act (Act) is designed to assist
small, disadvantaged businesses in
becoming financially competitive in
the open market for Government
contracts. The Office of Small and
Disadvantaged Business Utilization
(OSDBU) is the Agency's advocate
for small businesses. Firms in the
8(a) program can participate for a
maximum of nine years, known as
the "Program Term," and agencies
can set aside and award service
contracts under $3 million to these
firms without competition.
We Found That
EPA complied with applicable laws
and regulations in awarding and
amending 8(a) contracts during
fiscal 1993, and showed
improvement in detecting and
correcting historical problems such
as contract splitting, under-
valuation, or conflicts of interest.
We found fiscal 1993 awards in
which contracting officials identified
similar problems and took
corrective actions, and that fiscal
1992 and 1993 awards evidenced
a significantly improved distribution
among firms.
However, EPA awarded seven sole
source, multi-year contracts to four
8(a) firms totalling over $90 million
just days before the expiration of
the firms' program eligibility. This
practice: (1) permits firms to
benefit from sole source awards for
several years after the conclusion
of their "Program Term;" (2) does
not encourage 8(a) firms to
compete in the open marketplace;
and (3) creates a perception that
EPA favors selected contractors.
Additionally, OSDBU has faced
resistance as the Agency's
advocate for 8(a) contractors.
Problems included: (1) insufficient
and untimely contract information
being available to OSDBU; (2) a
lack of Agency-wide accountability
for meeting 8(a) contracting goals;
and (3) an inefficient organizational
structure. As a result, EPA did
not meet its fiscal 1992 or 1993
goals for contracting with 8(a)
firms.
We Recommended That
The Assistant Administrator for
Administration and Resources
Management and the Director,
OSDBU:
• Establish a policy .requiring their
offices to concur and provide
written justification for awarding
8(a) contracts whose base or
option periods extend beyond the
established "Program Term" of the
recipient 8(a) firm.
• Develop a method of setting
8(a) program goals for Assistant
Administrators, Regional
Administrators, and Office and
Division Directors, and a
mechanism for timely tracking of
actual achievements.
• Improve the coordination
between OSDBU and the Office of
Acquisition Management in
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17
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directing and supervising the Small
and Disadvantaged Business
Utilization Specialists.
• The Director, OSDBU, develop a
multi-year plan which identifies
current 8(a) contract levels and
presents a strategy for obtaining
sufficient future contracts to meet
the Agency's projected goals.
What Action Was Taken
The final report (4100452) was
issued to the Assistant
Administrator for Administration
and Resources Management and
the Director, OSDBU, on July 22,
1994. In response to our draft
report, Agency officials generally
agreed with our findings and
recommendations related to
improved planning and information
gathering within OSDBU, increased
accountability in the program
offices, and improved coordination.
However, they did not agree with
our finding or recommendations
concerning sole source contracts
awarded to 8(a) firms near the
completion of their program
eligibility. On October 13, 1994,
we received a response from the
Assistant Administrator for
Administration and Resources
Management to the final report.
However, we have not received
OSDBU's response.
Improperly Procured
Services Included
Inherently Governmental
Functions
Findings in Brief
EPA inappropriately procured
$150,000 of program
management services, including
inherently governmental
functions, under a sole source
cooperative agreement rather
than a competitive process.
Background
The Office of Small and
Disadvantaged Business Utilization
(OSDBU), in cooperation with
EPA's Risk Reduction Engineering
Laboratory (RREL), prepared and
submitted a proposal to enhance
pollution prevention research in the
small business environment by
competitively awarding grants
totaling $750,000 to various small
businesses. EPA awarded a
cooperative agreement to the
Center for Hazardous Materials
Research (CHMR) in 1990 with
potential maximum funding of
$900,000, including $150,000 for
program management services.
We Found That
CHMR's services were for the
direct benefit of the Government
and, by law, should have been
awarded under a competitive bid
contract, not a sole source
cooperative agreement. According
to CHMR's application, its role as
program manager was to
effectively and efficiently manage
the project. Although $750,000
was correctly awarded to small
businesses as grants, the
$150,000 provided to CHMR to
manage these grants was required
by the Federal Grant and
Cooperative Agreement Act
(FGCAA) to be awarded under a
contract. In addition, EPA selected
CHMR to manage the project on a
non-competitive basis by involving
them in the planning phase of the
project.
Some of the program management
services CHMR performed
included making judgmental
decisions on behalf of the
Government in violation of OMB
policy to retain inherently
governmental functions in-house.
Specifically, these services
included awarding subgrants to
small businesses, and determining
if each small business had
satisfactorily completed a sufficient
amount of work to warrant
approval of their voucher for
payment.
We Recommended That
The Director of OSDBU ensure
that all future contracts and
assistance agreements involving
OSDBU are awarded in
compliance with all applicable
laws, regulations, and EPA policies
and procedures.
What Action Was Taken
The final report (4400102) was
issued to the Director of OSDBU
on August 29, 1994. In responding
to our draft report, the Director of
OSDBU generally concurred with
the findings and recommendations.
A response to the final report is
due by November 28, 1994.
Conflict of Interest
Increases Questioned
Costs
Findings in Brief
The Center for Earth Resource
Management Applications, Inc.
(CERMA) violated EPA's conflict
of interest regulations, failed to
maintain an adequate financial
management system, and their
internal control structure
contained significant
deficiencies. In addition, nearly
all costs claimed by CERMA
were questioned.
Background
EPA awarded three assistance
agreements totaling $235,000 to
CERMA, a non-profit educational
organization located in Springfield,
Virginia, to support various
recycling initiatives. CERMA had a
management services agreement
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OFFICE OF INSPECTOR GENERAL
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with another firm, a profit-making
company and EPA contractor, in
which that firm provided CERMA
with administrative support
(including financial management
services), fund-raising, and
program support.
We Found That
A conflict of interest existed since
the president of the other firm, who
was also the Treasurer and Project
Manager of CERMA, authorized
CERMA's procurement of
unspecified management services,
including a ten percent profit, from
his own consulting firm. He
determined which services would
be provided, authorized payment
for services, and signed checks,
including payments to his own
company. He also maintained
CERMA's entire financial
management system on the other
firm's computer, established salary
rates and fringe benefits for himself
and CERMA employees, and
submitted claims to EPA for
reimbursement.
CERMA violated EPA's
requirement to properly account for
Federal funds by not having an
adequate financial management
system, and did not comply with
the annual audit requirements of
OMB Circular A-133. In addition,
there were significant deficiencies
in CERMA's internal control
structure, including the lack of: (1)
oversight by the Board of
Directors, (2) separation of duties,
(3) written policies and procedures,
and (4) adequate personnel
management which adversely
affected CERMA's ability to record,
process, summarize, and report
financial data, including claims for
reimbursement to EPA
Of the $195,785 costs claimed by
CERMA, 99 percent were
questioned, and we determined
that $91,793 were ineligible,
$1,212 were unsupported, and
$102,010 were unreasonable.
Costs were questioned for various
reasons, including conflict of
interest, lack of prior approval,
noncompliance with cost principles,
costs not included in the approved
budgets, excessive expenditures,
inadequate documentation,
inappropriate allocations, and other
violations of regulations.
Related to these deficiencies, a
separate OIG report disclosed that
EPA's Office of Solid Waste
(OSW) did not perform site visits or
request and review financial
information for two assistance
agreements awarded to CERMA.
We Recommended That
EPA recover the costs associated
with the management services
agreement and the resulting
conflict of interest, and that project
officers administer assistance
agreements in accordance with
EPA policies and procedures.
What Action Was Taken
The final report (4400106) was
issued to the Director, Grants
Administration Division, the
Director, Office of Solid Waste (in
Headquarters), and the Regional
Administrator, Region 3, on
September 12, 1994. In response
to our draft report, the Agency
concurred with the findings
identified in the report, but did not
believe it would be feasible to
attempt to recover the questioned
costs because CERMA was no
longer in business. The Agency
terminated the two awards that
were active as of our review, and
suspended CERMA, the other firm,
and its president from all Federal
procurement and nonprocurement
activities in December 1993. In
March 1994, EPA's Debarring
Official approved a Compliance
Agreement with the other firm and
its president in which he admitted
that he had engaged in a conflict
of interest and agreed to repay the
Government for any associated
costs that are disallowed. A
response to the final report is due
by December 12, 1994.
The final report (4400113) was
issued to the Director, Office of
Solid Waste, and the Director,
Grants Administration Division. In
response to the draft report, OSW
generally disagreed with the
findings but agreed with our
recommendations. A response to
the final report is due by December
27, 1994.
Cooperative Agreements
Misused for Graduate
Courses
Findings in Brief
Two cooperative agreements
(CA), awarded to evaluate and
refine techniques to identify and
measure environmentally
significant chemicals, were used
to provide graduate course work
at Montana State University
(MSU) for an Agency employee.
In addition, other costs claimed
under the cooperative
agreements could not be
supported.
Background
EPA awarded two CAs in 1989
and 1991 to fund a study which
required MSU to evaluate and
refine mass spectrometric
techniques needed to identify and
measure environmentally important
chemicals. To accomplish this
work, an EPA employee was
relocated from the EPA laboratory
in Athens, Georgia to MSU in
Bozeman, Montana under an
Intergovernmental Personnel Act
(IPA) agreement. A senior MSU
Department of Chemistry staff
APRIL 1, 1994 THROUGH SEPTEMBER 30, 1994
19
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member was to be the program
manager, and EPA was authorized
to reimburse MSU for 79 percent
of the allowable project costs.
We Found That
The CAs were actually used to
fund an employee's graduate level
training in violation of the
provisions of the agreements
involved. Although the preliminary
I PA agreement specifically
provided for the EPA employee's
formal education, this provision
was objected to by EPA
Headquarters and eliminated from
the final agreement. The EPA
employee attended MSU as a
graduate student for 24 months of
the assignment, and the final
research report submitted by MSU
to EPA was a modified version of
the employee's doctoral thesis,
indicating that the research
performed supported the
employee's education rather than
the CA purpose. Therefore, we
questioned all $191,558 claimed
under the CAs.
We Recommended That
The Director, Office of Grants and
Debarment, recover the Federal
share ($150,072) of the $191,588
questioned, costs.
What Action Was Taken
The final report (4100497) was
issued on August 23, 1994, to the
Director, Office of Grants and
Debarment. A response to the
audit report is due by November
23, 1994. In responding to a draft
report, MSU concurred with some
questioned costs but did not agree
that graduate course work was not
authorized.
EPA Improperly Awarded
Cooperative Agreements
and Approved Excessive
Expenditures for Two
Conferences
1989 Award to the University
of Kansas
Findings in Brief
EPA circumvented assistance
regulations and misused Federal
funds by awarding a
cooperative agreement to the
University of Kansas (KU) which
included ineligible and
unnecessary costs such as
travel, alcohol, and
entertainment.
Background
EPA awarded a cooperative
agreement in March 1989 to KU to
manage the logistics for EPA's
National Environmental Information
Conference. Over 700 participants
attended the conference, including
over 400 EPA employees, and
EPA paid conference-related costs
for 171 non-Federal participants.
Region 7 and Headquarters staff
participated in conference
management, with the Region 7
Assistant Regional Administrator
for Policy and Management and
the former Headquarters Deputy
Assistant Administrator (DAA) for
Administration and Resources
Management serving as co-chairs.
We Found That
KU's logistical support functions for
the conference should have been
obtained through a contract instead
of a cooperative agreement since
EPA was the beneficiary of the
services. The former DAA stated
that a cooperative agreement was
chosen to fund the conference in
order to pay the travel costs of
selected non-Federal attendees.
In funding this activity, EPA cited
improper authorities, circumvented
statutory requirements, and
potentially augmented
Congressionally appropriated
funding levels for travel.
The Region 7 Project Officer did
not eliminate ineligible or
unnecessary costs from the KU
proposal before approval or
maintain adequate records. Also,
he allowed KU to use an incorrect
indirect cost rate, increasing
indirect costs by 54 percent, and
did not resolve outstanding issues
prior to authorizing close-out of the
grant file. Of the $533,523
awarded under this cooperative
agreement, we questioned more
than $400,000 as unallowable.
All Grants Administration Section
specialists involved in the KU
assistance agreement were
intimidated into doing a less than
adequate job because of the active
involvement of their senior
managers. They did not
adequately address unallowable
costs contained in the project
proposal, and obtained less
documentation than normal to
support increases to the original
award before authorizing the
amendments or approving payment
of funds.
In four instances, Region 7 and KU
conference managers improperly
contracted for conference-related
services. Region 7 conference
managers participated in contract
negotiations and awards, without
the necessary authority, and
disregarded Federal and State
procurement policies and
procedures.
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OFFICE OF INSPECTOR GENERAL
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We Recommended That
The Assistant Administrator for
Administration and Resources
Management:
• Determine whether it is
appropriate to recover the entire
amount awarded ($506,929) and
take appropriate action with
respect to the travel-related funds
spent contrary to Federal law.
• Determine the allowability of
costs claimed by KU and recover
the ineligible, unnecessary,
unreasonable, and unsupported
costs which KU incurred, and
either ratify or recover the costs
associated with the four contracts.
• Hold Agency managers
accountable for ensuring
management controls are in place
and working to prevent
unauthorized expenditures.
What Action Was Taken
In responding to our draft report,
the Assistant Administrator for
Administration and Resources
Management indicated that he
would not disallow all the costs,
nor would he disallow KU's costs
for the non-Federal participants'
travel because such an action
would have an inequitable impact
on KU. The Agency has
developed guidance and a training
course for grants project officers
which will assist EPA officials in
determining the proper funding
instrument. The final report
(4100407) was issued on June 17,
1994, to the Assistant
Administrator for Administration
and Resources Management The
Agency response was due by
September 15, 1994, but has not
been received.
1991 Award to Temple
University
Findings In Brief
EPA erroneously awarded a
cooperative agreement to
Temple University and
mismanaged the agreement by
not controlling expenditures and
allowing unauthorized travel.
Background
A cooperative agreement was
awarded to Temple University for
helping EPA host the fourth
National Environmental Information
Conference. Under the
cooperative agreement, Temple
performed numerous administrative
and logistical tasks, paid travel-
related expenses for EPA's invited
guests, and procured goods and
services.
We Found That
EPA should have awarded a
contract for the conference
because Temple only provided
logistical services. Moreover, EPA
was the sponsor and direct
beneficiary of the services.
Despite the expenditure of
thousands of dollars, there were
virtually no records to indicate that
the Agency had reviewed: (a)
Temple's proposal; (b) the
assistance award, or (c) contracts
or invoices. Numerous
unreasonable and unnecessary
items and associated costs in the
proposal should have been
questioned or disallowed before
the assistance award was
approved.
Many procurements under the
cooperative agreement violated
either Federal or University
regulations resulting in nearly 90
percent being unauthorized.
Contrary to Agency policy, EPA
directed Temple University to use
registration fees, as well as
cooperative agreement funds, to
pay for food and entertainment.
The amounts paid for meals were
at a rate more than double the
amount allowed by Federal Travel
Regulations.
We Recommended That
The Assistant Administrator for
Administration and Resources
Management:
• Determine whether it is
appropriate to recover the entire
unauthorized assistance funds paid
to Temple University because the
Agency was required to issue a
contract to obtain Temple's
services for its direct use and
benefit, rather than award a
cooperative agreement.
• Recover the ineligible,
unreasonable and unsupported
costs which Temple incurred. The
Agency should also recoup
payments made to employees for
travel costs and managers should
be held accountable to ensure
management controls are
implemented to prevent future
unauthorized expenditures.
What Action Was Taken
In responding to the draft report,
the Assistant Administrator for
Administration and Resources
Management decided not to
disallow the costs paid to Temple,
including the travel costs of non-
Federal participants. Even though
he agreed the project should have
been funded under a contract, he
indicated that disallowing all the
costs would have an inequitable
impact on Temple. The final audit
report (4100523) was issued to the
Assistant Administrator on
September 15, 1994. A response
to the final report is due by
December 14, 1994.
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21
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Non-Federal Employee
Travel Expenses
Improperly Paid
Findings in Brief
EPA misused Agency travel
funds, contracts, and
interagency and cooperative
agreements to pay travel-related
expenses for non-Federal
employee attendance at
conferences and meetings.
Background
An agency may pay for the travel
and related expenses of non-
Federal persons to attend
meetings and conferences only
when a person is requested to
meet with Federal officials on
official business or provide direct
service to an agency.
We Found That
In 1991, the Office of
Administration and Resources
Management (OARM) used travel
funds to pay for 16 people who
were not government employees to
attend a conference in Miami,
Florida. In 1992 and 1993, Office
of Cooperative Environmental
Management (OCEM) officials
authorized use of travel funds to
pay travel-related expenses for
non-EPA personnel to attend two
international conferences and one
conference in California. On at
least three occasions, OCEM also
provided funds for a contractor to
make travel arrangements and
reimbursements for individuals to
attend international conferences
and workshops. None of these
were EPA-sponsored conferences,
or for the benefit of the Federal
government.
Contrary to law, offices within EPA
have been improperly paying
travel-related expenses for
advisory committee members
through contracts and interagency
agreements (lAGs). In fiscal 1992
and 1993, 15 out of 20 EPA
advisory committees had their
members' travel funded using three
lAGs and five contracts. From
October 1, 1991, through March
31, 1993, these 15 advisory
committees used approximately
$700,000 in contract funds for this
purpose which violated statutory
requirements and may have
improperly augmented EPA's travel
appropriation.
Region 7 improperly awarded a
cooperative agreement to the
University of Kansas (KU) to
manage the 1989 National
Environmental Information
Conference. Since travel
expenses were the primary
purpose of the award, EPA may
have circumvented Agency
authority. This problem was
discussed as the subject of a
separate audit.
We Recommended That
The Assistant Administrator for
Administration and Resources
Management provide written
guidance and instructions which
clearly delineate when travel-
related expenses may be paid to
non-Federal employees and how
these expenses are to be funded,
and establish Agency-wide
procedures to oversee payment of
travel-related expenses for non-
Federal employees.
What Action Was Taken
The final report (4400079) was
issued on July 6, 1994. The
Assistant Administrator for
Administration and Resources
Management generally concurred
with our recommendations, and the
Office of the Comptroller (OC)
issued Transmittal No. 94-22,
"Payment of Travel Expenses for
Non-Federal Personnel." The
Financial Management Division
(FMD) will perform oversight
reviews to ensure that Finance
Offices are following Agency travel
disbursement guidelines, and
incorporate this procedure into
FMD's Quality Assurance Manual
which will be revised by October
1994. These actions, if properly
implemented, should resolve the
issues in the report. As a result,
we closed this review in our
tracking system.
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OFFICE OF INSPECTOR GENERAL
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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, $152.7
million was obligated on 28 new
construction grant awards and
194 increases to existing grants.
As of September 30, 1994, there
was $12.6 billion in grants that
were potentially subject to audit.
Of this total, there were 315
active construction grants,
representing $2.8 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, $1.2 billion
was awarded for 48 continuation
SRF grants.
As of September 30, 1994, EPA
had obligated $9.8 billion to 50
States and Puerto Rico under
the State Revolving Fund
program.
One of the Agency's goals is to
substantially close out the
construction grant program by
September 30, 1997. The OIG is
committed to assisting the
Agency accomplish this goal as
expeditiously as possible within
its budget and workload
constraints. Summaries of
several audits of construction
grants with significant issues
follow.
APRIL 1, 1994 THROUGH SEPTEMBER 30, 1994
23
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Almost $9.4 Million of
Costs Questioned for
Vallejo, California, Project
Findings In Brief
Vallejo, California, claimed
$5,525,458 of ineligible
administration, engineering and
construction costs for the
Vallejo Sanitation and Flood
Control District project. An
additional $3,874,497 of
unreasonable project costs were
questioned.
We Found That
EPA awarded a grant totaling
$19,962,958 to the Vallejo
Sanitation and Flood Control
District for construction of a
wastewater treatment plant. The
grantee claimed $5,525,458 of
ineligible costs under the grant,
including:
• $3,162,957 of costs related to
interest earned by the grantee on
an overpayment of Federal funds;
• $1,589,576 of costs for the
depreciated value of abandoned
and replaced equipment and
structures, rather than for their
actual costs;
• $292,895 of engineering costs
incurred prior to the date that the
engineering subagreement was
approved by State Water
Resources Control Board;
• $254,796 of costs allocable to
the ineligible portion of the
construction project,
• $141,116 of inspection costs
incurred after the construction
project completion date,
• $84,118 of construction costs
which were not applicable to the
project, and engineering start-up
costs which were allocable to failed
and/or abandoned equipment.
We also questioned $3,874,497 of
unreasonable costs related to
facilities and equipment items
intended for a biological plant
which were being used only as a
wet weather reserve capacity.
We Recommended That
The Regional Administrator,
Region 9, not participate in the
Federal share of ineligible costs
($4,144,094), determine the
eligibility of the Federal share of
unreasonable costs ($2,905,873),
and recover the applicable amount
from the grantee.
What Action Was Taken
The final report (4300051) was
issued to the Regional
Administrator, Region 9, on
September 29, 1994. A response
to the audit report is due by
December 29, 1994.
Over $8.2 Million of
Ineligible Costs Claimed
for Houston, Texas, Project
Findings In Brief
Houston, Texas, claimed
$6,159,937 of ineligible
engineering and construction
costs for the construction of a
wastewater treatment facility.
An additional $991,174 of
unsupported costs and
$1,063,235 of unnecessary or
unreasonable costs were
questioned.
We Found That
EPA awarded eight grants totalling
$208,720,680 to Houston for the
construction of a wastewater
treatment plant including
rehabilitation of sewer lines, and
construction of a sludge storage
and loading facility. The grantee
claimed $6,159,937 of ineligible
costs under the grant, including:
• $1,617,670 of costs for removal
of deteriorated pipe and manhole
lining;
• $1,140,230 of construction costs
determined to be ineligible
because the Texas Water
Development Board made
overpayments in the final eligibility
determinations for change orders;
• $1,119,518 of costs for
abandoned facility/equipment
including an abandoned barge
loading facility under the grant;
• $1,077,620 of construction
management costs attributed to
questioned construction costs;
• $622,077 of construction change
order costs considered outside of
the scope of the approved project;
• $361,000 of construction costs
incurred after the project
completion date; and
• $221,822 of engineering costs
considered outside the scope of
the approved project or allocable to
the ineligible portion of the
construction.
We also questioned $991,174 of
unsupported costs, including a sole
source procurement'not supported
by any cost analysis and costs not
supported by a contract change
order Additionally, we questioned
$1,063,235 of unnecessary or
unreasonable costs claimed in
excess of the approved grant
amount.
We Recommended That
The Regional Administrator,
Region 6, not participate in the
Federal share of ineligible costs
24
OFFICE OF INSPECTOR GENERAL
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($4,747,066), determine the
eligibility of the Federal share of
unsupported costs ($743,381) and
unnecessary and unreasonable
costs ($796,517), and recover the
applicable amount from the
grantee.
What Action Was Taken
The final report (4300052) was
issued to the Regional
Administrator, Region 6, on
September 29, 1994. A response
to the audit report is due by
December 29, 1994
Fairfax County, Virginia,
Claimed Nearly $4.3 Million
of Questioned Costs
Findings in Brief
The County of Fairfax, Virginia,
claimed $3,533,822 of ineligible
architectural engineering and
construction costs for
waste water treatment facility
improvements. An additional
$752,097 of unsupported costs
were questioned.
We Found That
EPA awarded grants totalling
$44,351,550 to Fairfax County,
Virginia, for the design and
construction of a lime solids
handling facility, activated carbon
treatment and regeneration
facilities, and related
improvements. The grantee
claimed $3,533,822 of ineligible
costs under the grant, including:
• $2,005,166 of overpayment for
settlement costs paid to a
contractor after being reimbursed
by the insurance company and
consulting engineer;
• $479,502 of costs considered
outside the scope of the approved
project;
i
• $449,676 of legal and fiscal
costs in defense of a claim not
approved;
• $323,057 of construction costs
incurred after the approved
completion date;
• $276,421 of administrative and
engineering costs not applicable to
portions of the project, and
construction costs which exceeded
bid items and change orders.
In addition, $752,097 of
unsupported costs were
questioned because the claims
were not substantiated by
documentation.
We Recommended That
The Regional Administrator,
Region 3, not participate in the
Federal share of ineligible costs
($2,650,367), determine the
eligibility of the Federal share of
unsupported costs ($564,072), and
recover the applicable amount from
the grantee.
What Action Was Taken
The audit report (4300044) was
issued to the Regional
Administrator, Region 3, on
August 23, 1994. A response to
the audit report is due by
November 22, 1994.
Onondaga County, New
York, Claimed Nearly $5.8
Million of Questioned
Costs for Sewers
Findings in Brief
Onondaga County, New York,
claimed $1,888,500 of ineligible
architectural engineering and
construction for the design and
construction of Ley Creek
service area improvements, and
$3,863,733 of costs that
exceeded the grant ceiling.
APRIL 1, 1994 THROUGH SEPTEMBER 30, 1994
We Found That
EPA awarded a grant of
$10,571,420 to Onondaga County,
New York, to design and construct
Ley Creek service area
improvements. The grantee
claimed $1,888,500 of ineligible
costs under the grant, including-
• $1,324,150 of architectural and
engineering fees that exceeded the
eligible amount (principal engineer
and other consultant) allowed
under the New York State
Department of Environmental
Conservation (NYSDEC) criteria;
• $449,036 of construction costs
deemed ineligible based on
NYSDEC's determination; and
• $115,314 of design allowance
costs calculated using estimated
construction costs rather than
actual costs.
We also questioned $3,863,733 of
unsupported costs representing
amounts that exceeded the grant
ceiling.
We Recommended That
The Regional Administrator,
Region 2, not participate in the
Federal share of ineligible costs
($1,038,675), determine the
eligibility of the Federal share of
costs that exceeded the grant
ceiling ($2,125,053), and recover
the applicable amount from the
grantee
What Action Was Taken
The audit report (4100412) was
issued to the Regional
Administrator, Region 2, on
June 21, 1994. A response to the
audit report was due by September
21, 1994. However, it will be
delayed until December 1994
because NYSDEC, which is
25
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responsible for resolving the audit,
is concentrating on higher priority
OIG audits of New York City
Over $4.5 Million of
Questioned Costs Claimed
for Ocean County, New
Jersey, Project
Finding In Brief
The Ocean County Utilities
Authority, New Jersey claimed
$3,057,931 of ineligible
architectural engineering,
construction, force account,
administrative, and innovative
and alternative technology costs
for the construction of
wastewater treatment facilities.
An additional $1,455,727 of
unsupported costs were
questioned.
We Found That
EPA awarded four grants totaling
$183,432,225 to the Ocean County
Utilities Authority, New Jersey for
the construction of secondary
wastewater treatment facilities,
pumping stations, force mains,
interceptor and gravity sewers,
sewer rehabilitation, ocean outfall,
odor control facilities, septage
facilities, and innovative/alternative
technology bonuses. The grantee
claimed $3,057,931 of ineligible
costs under the grant, including:
• $1,347,567 of construction cost
change orders were outside the
scope of the approved project, bid
item overruns/underruns were not
covered by final quantity change
orders, change order costs were
declared ineligible by the New
Jersey Department of
Environmental Protection and
Energy (NJDEPE), amounts were
claimed in excess of approved
change order amounts, unpaid
portion of costs incurred, and
ineligible bid amounts were
claimed;
• $842,136 of architectural
engineering costs resulting from
unapproved settlement charges,
costs claimed in excess of EPA or
NJDEPE approved amount, and
costs resulting from application of
an incorrect eligibility factor;
• $573,864 of administrative and
force account costs incurred after
the grant cut-off dates, costs in
excess of the grant budget ceiling,
costs resulting from application of
an incorrect eligibility factor,
equipment costs that exceeded the
project amount approved by EPA
or NJDEPE, and items not part of
the approved grant budget;
• $165,708 of innovative and
alternative technology bonus costs
claimed for septage facilities which
were not incurred or paid; and
• $128,656 of miscellaneous costs
lacking prior approval and costs
related to site acquisition.
We also questioned $1,455,727 of
unsupported construction,
administrative and architectural
engineering costs, including
unapproved change orders,
undocumented costs, and costs
resulting from a process control
study not approved by EPA or
NJDEPE.
We Recommend That
The Regional Administrator,
Region 2, not participate in the
Federal share of ineligible costs
($2,144,016), determine the
eligibility of the Federal share of
unsupported costs ($883,511), and
recover the applicable amount from
the grantee.
What Action Was Taken
The final report (4300034) was
issued to the Regional
Administrator, Region 2, on May 4,
1994. A response to the audit
report was due by August 4, 1994.
However, it will be delayed until
December 1994 due to numerous
technical and complex issues.
26
OFFICE OF INSPECTOR GENERAL
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Superfund
The Superfund program was
created by the Comprehensive
Environmental Response,
Compensation, and Liability Act
of 1980 (CERCLA). The Act
provided a $1.6 billion trust fund
to pay for the costs associated
with the cleanup of sites
contaminated with hazardous
waste. Taxing authority for the
trust fund expired on September
30, 1985. For more than a year,
the Superfund program operated
at a reduced level from
carryover funds and temporary
funds provided by Congress.
On October 17, 1986, the
Superfund Amendments and
Reauthorization Act of 1986
(SARA) was enacted. It
provided $8.5 billion to continue
the program for 5 more years
and made many programmatic
changes. On November 5, 1990,
the Omnibus Budget
Reconciliation Act of 1990 was
enacted, authorizing
appropriations for 3 additional
years and extension of the
taxing authority for 4 years.
The parties responsible for the
hazardous substances are liable
for cleaning up the site or
reimbursing the Government for
doing so. States in which there
is a release of hazardous
materials are required to pay 10
percent of the costs of Fund-
financed remedial actions, or 50
percent if the source of the
hazard was operated by the
State or local government.
The enactment of SARA
increased the audit
requirements for the
Inspector General. In addition
to providing a much larger and
more complex program for
which the OIG needs to provide
audit coverage, SARA gave the
Inspector General a number of
specific responsibilities.
Mandatory annual audit areas
include:
• Audit of all payments,
obligations, reimbursements, or
other uses of the Fund;
• Audit of Superfund claims;
• Examination of a sample of
agreements with States carrying
out response actions; and
• Examination of remedial
investigations and feasibility
studies.
The Inspector General is
required to submit an annual
report to the Congress
regarding the required
Superfund audit work,
containing such
recommendations as the
Inspector General deems
appropriate. The seventh
annual report, covering fiscal
1993, was issued September
1994.
APRIL 1, 1994 THROUGH SEPTEMBER 30, 1994
27
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Contractors Still Lack
Adequate Accounting
Systems
Findings in Brief
Emergency Response Cleanup
Services (ERGS) contractor
accounting system deficiencies
noted in past OIG reports still
exist because of inadequate
enforcement by EPA personnel.
In addition, EPA rarely exercised
sanctions for contractor non-
compliance.
Background
Prior audits of EPA's management
of ERCS contracts reported that
ERCS contractors generally did not
have adequate accounting systems
to provide accurate cost and
equipment utilization data. ERCS
contracts awarded after March 31,
1992, include a specific
requirement clause to establish
and maintain an acceptable cost
accounting system.
We Found That
EPA's Office of Acquisition
Management (OAM) and its
regional contracting officers (COs)
continued to allow contractor non-
compliance with the Federal
Acquisition Regulation and contract
accounting systems requirements
clauses because of a belief that
complete enforcement would drive
away ERCS contractors. Despite
a decade of doing business with
EPA, the ERCS contractors
reviewed still did not have
approved accounting and billing
systems needed for cost
reimbursement contracts. Except
for one instance, sanctions for
contractor non-compliance were
not exercised.
OAM and regional procurement
personnel also allowed some
ERCS contractors to use EPA's
internal Removal Cost
Management System (RCMS) as a
billing mechanism, despite
requirements for ERCS contractors
to generate invoices from, and
reconcile them to, their internal
accounting systems. Moreover,
EPA's historic reliance on the
RCMS to validate the contractors'
claims did not provide the
necessary internal controls to
reasonably assure that the
Agency's contract expenditures
were properly accounted for
because there was no assurance
that billed charges were actually
incurred and paid by the
contractor.
We Recommended That
The Assistant Administrator for
Administration and Resources
Management require:
• OAM and regional ERCS
contracting officers to enforce FAR
and contract clause accounting
system requirements for all current
and future ERCS contacts.
Significant remedies should be
pursued when contractors are not
making sufficient, timely progress
toward clause compliance.
• Contractors to correct
inadequate accounting systems
before EPA awards the contract.
• OAM to provide the needed
oversight and assistance to ensure
consistent and uniform regional
implementation and enforcement of
FAR and contract accounting
system requirements.
• Contractors to generate invoices
from, and be supported by,
contractor accounting systems.
The RCMS and EPA Form
1900-55 should not be utilized as a
substitute for required contractor
accounting systems.
The Assistant Administrator for
Solid Waste and Emergency
Response require that:
• OSC-certified EPA Form
1900-55 not be utilized in a
manner that could be reasonably
interpreted to satisfy contract
documentation requirements. To
neutralize this possible
interpretation, the historical
significance of EPA Form 1900-55
as a cost report should be
de-emphasized and affirmation of
its use as a receiving report should
be emphasized.
• The EPA Form 1900-55 be
modified by supplementing the
OSC certification language with a
clear statement of the authenticity
and acceptance of the costs
recorded thereon.
What Action Was Taken
The final audit report (4400112)
was issued to the Assistant
Administrator for Administration
and Resources Management and
the Assistant Administrator for
Solid Waste and Emergency
Response on September 29, 1994.
In responding to the draft report,
the Agency generally agreed with
our recommendations and provided
planned or initiated actions to
correct the identified weaknesses.
For example, EPA will provide
guidance for requiring contractors
to invoice EPA from their
accounting systems,'and EPA is
modifying the OSC certification
language. A response to the final
report is due by December 29,
1994.
28
OFFICE OF INSPECTOR GENERAL
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Better Controls Needed to
Protect Over $22 Million in
Securities in Bankruptcy
Cases
Findings In Brief
EPA had limited controls in
place to safeguard marketable
securities received as a result of
Superfund cost recovery efforts.
Also, current bankruptcy laws
hinder EPA's cost recovery
efforts.
Background
When EPA attempts to recover
Superfund Trust monies from those
responsible for the contamination,
some responsible parties file for
bankruptcy protection and EPA
may receive marketable securities
in the reorganized companies as
payment of debts. During fiscal
1992 and 1993, EPA received 2.4
million shares of marketable
securities worth $22.4 million from
bankruptcy settlements which were
transferred to the Treasury
Department to be sold and
proceeds returned to the
Superfund Trust Fund.
We Found That
EPA had not established central
receiving points, restricted access,
maintained records, or assigned
custodial responsibility for
securities. The Agency could not
be assured securities were
adequately safeguarded against
theft and forwarded timely to
Treasury, and there were no
procedures to follow up with
bankrupt responsible parties or
their trustees to ensure receipt of
all securities. In the two regions
we visited, accounts receivable for
Superfund bankruptcy settlements
were recorded an average of
seven months after agreements
were reached with responsible
parties, and securities received as
payment were not recorded in the
Agency's accounting system until
Treasury sold the securities.
Bankruptcy cases handled by
Headquarters attorneys were not
always entered into the
Comprehensive Environmental
Response, Compensation and
Liability Information System
(CERCLIS), the Agency's main
Superfund tracking system. We
identified six bankruptcy cases
valued at over $96.6 million that
were settled during fiscal 1992 and
1993, but were not recorded in
CERCLIS. Further, EPA was not
tracking marketable securities
transferred to the Agency, the
amount of securities received, and
the total proceeds from their sale.
Two key issues involving
bankruptcy law need to be
resolved to improve the Agency's
ability to recover Superfund
cleanup costs. First, some
reorganizing companies have
argued that EPA's claim should
include all environmental liability,
even future cleanup costs EPA
might incur, and that the
bankruptcy settlement should
discharge all of their environmental
liability. Second, it is unclear how
much information responsible
parties should include in their
bankruptcy notices to creditors,
and where the notices should be
filed, which could cause the
Agency to miss its opportunity to
participate in bankruptcy
proceedings.
We Recommended That
The Chief Financial Officer
establish central receiving points
for marketable securities,
designate employees to be
responsible for securities, and
develop procedures for properly
handling and recording marketable
securities.
The Assistant Administrator for
Enforcement and Compliance
Assurance:
• Assign responsibility for following
up with reorganized companies to
help ensure EPA receives all of the
securities it is entitled to receive,
and develop procedures to ensure
Superfund bankruptcy settlements
are recorded in CERCLIS.
• Include provisions in the
Agency's bankruptcy guidance to
follow up with the Department of
Justice when final bankruptcy
orders are not forwarded timely to
EPA; and forward bankruptcy
orders timely to the appropriate
financial management office so an
account receivable can be
established.
• Develop procedures to track
collections, including form of
payment for bankruptcy
settlements; and revise the
Superfund enforcement
performance measurement
reporting to reflect the impact
bankruptcies have on the
Superfund cost recovery program.
What Action Was Taken
In responding to our draft report,
the Agency generally agreed with
our findings and recommendations
and provided substantive planned
or already initiated actions to
correct the identified weaknesses.
These actions, if properly
implemented, should substantially
resolve the issues in this report.
The final audit report (4100579)
was issued to the Chief Financial
Officer and the Assistant
Administrator for Enforcement and
Compliance Assurance on
September 30, 1994. A response
to the final report is due by
December 30, 1994.
APRIL 1, 1994 THROUGH SEPTEMBER 30, 1994
29
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Over $227,000 of Ineligible
Claims for Minnesota
Superfund Site
Findings in Brief
The Minnesota Pollution Control
Agency (MPCA) had weak
internal controls over personnel
and contractor costs, and did
not comply with procurement
laws and regulations. As a
result, we questioned $227,584
of the costs claimed for the
Ritari Post and Pole site under a
Superfund multi-site cooperative
agreement.
Background
MPCA is responsible for managing
remedial activities at selected
Superfund sites under EPA's
CERCLA authority. In 1987, the
Superfund multi-site cooperative
agreement was amended to
provide funding of $234,005 for the
Ritari Post and Pole site with
two-year budget and project
periods. Six additional
amendments increased the award
to $942,963 and extended the
budget and project periods to
September 30, 1995.
We Found That
MPCA had significant weaknesses
in internal controls in the areas of
leave allocation, contractor rate
increase approvals, contractor
indirect cost rate reviews,
contractor invoice support, and
timesheet reviews. We found that
leave allocation procedures did not
equitably distribute leave because
the distribution was based upon a
percentage of the quarterly
budgeted time allocated for
Federal and State projects, and
MPCA employees were not
consistently following leave
allocation procedures.
Contractor rate increases were
approved by MPCA in excess of
contract limits and without a
thorough cost analysis or
supporting cost documentation.
The process used to review and
approve indirect costs and
associated rate increases does not
assure that these rates are
accurate, allowable, and sufficiently
justifiable. Although this was a
cost reimbursement type contract,
MPCA permitted its contractor to
submit supporting documentation
for its invoices on an inconsistent
basis, and never examined
contractor timesheets to determine
whether labor charges were
appropriate.
MPCA did not comply with
regulations and cooperative
agreement conditions pertinent to
contract procurement and site
management. Specifically, MPCA
awarded a full scope contract to a
company that submitted only a
limited scope proposal, and
improperly changed the scope of
the cooperative agreement by
adding more tasks to it without
obtaining approval from the EPA
project officer resulting in $227,584
of ineligible costs out of $942,959
total claimed costs.
We Recommended That
The Regional Administrator,
Region 5:
• Ensure MPCA implements its
planned corrective actions to
improve internal controls.
• Clarify with MPCA that all
workplans and reports are to be
submitted to the EPA project
officer.
• Recover the questioned costs of
$227,584.
What Action Was Taken
MPCA agreed to take corrective
action for all identified weaknesses
in internal controls and disagreed
with our conclusions regarding
compliance and questioned costs.
The final report (4100488) was
issued to the Regional
Administrator, Region 5, on August
15, 1994. A response to the final
report is due November 14, 1994.
Over $278,000 of
Questioned Costs Claimed
for Georgia Superfund
Activities
Findings in Brief
The Georgia Department of
Natural Resources,
Environmental Protection
Division (GDNR), did not
properly account for labor costs
or fund use in compliance with
EPA regulations. We
questioned $278,756 of the costs
claimed for three Superfund
Cooperative Agreements.
Background
EPA awarded GDNR three
Superfund cooperative agreements
totalling $1.9 million to develop and
implement management and
administration activities needed for
a Superfund core program, to
participate in site inspection
activities, and to provide technical
review of documents associated
with Superfund remedial activities.
Each of the cooperative
agreements had been amended to
extend the project period and
increase EPA funds.
We Found That
GDNR had major weaknesses in
internal controls and did not
comply with EPA regulations and
cooperative agreement conditions
in the areas of labor charging,
30
OFFICE OF INSPECTOR GENEFtAL
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timekeeping, and letter-of-credit
drawdown procedures.
Specifically, GDNR was not
tracking costs or making
letter-of-credit drawdowns by site
as required because they were not
maintaining a recordkeeping
system that enabled site-specific
costs to be tracked. Labor costs
were frequently charged to the
wrong cooperative agreement,
supervisory reviews of timesheets
were inconsistent, and supporting
cost records were destroyed even
though the State had been
cautioned in a 1990 audit that
Superfund regulations require such
records to be retained for 10 years.
In total, GDNR claimed $251,876
of ineligible costs under the
cooperative agreements, including
personnel and fringe benefit costs
associated with mischarged labor,
and training and vehicle costs
which were not related to the
cooperative agreement.
An additional $26,880 of costs
were questioned as unsupported
due to the premature destruction of
supporting documentation on
personnel, fringe benefit, travel and
equipment costs.
We Recommended That
The Acting Assistant Regional
Administrator for Policy and
Management, Region 4, disallow
the questioned costs for grant
participation, and:
• require GDNR to develop and
implement specific policies,
procedures and controls for a
system that ensures full
documentation and proper
allocation of all personnel costs;
• require GDNR to establish
formal written timekeeping policies
and maintain timesheet
documentation in accordance with
applicable regulations, and
• obtain written assurance from
GDNR that it will comply with
applicable regulations related to
record retention.
What Action Was Taken
The final report (4100496) was
issued to the Acting Assistant
Regional Administrator for Policy
and Management, Region 4, on
August 22, 1994. In response to
our draft report, GDNR generally
agreed with our findings and
recommendations and provided
substantive planned or already
initiated actions to correct the
identified weaknesses. A response
to the final report is due November
21, 1994.
APRIL 1, 1994 THROUGH SEPTEMBER 30, 1994
31
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Superfund
Administrative Initiatives
In July 1993, the Deputy
Administrator announced the
Agency's plan to improve the
Superfund program within the
current statutory authority. This
plan, known as the "Superfund
Administrative Improvements"
(SAI), focused on enhancing the
four areas of most concern to
the Administration, Congress,
and the public:
- Enforcement fairness and
reduced transaction costs.
- Cleanup effectiveness and
consistency.
- Meaningful public
involvement.
- The States' role in the
Superfund Program.
The OIG completed five SAI
reviews during this reporting
period, summarized below.
Superfund Initiatives
Reduce Time and Save
Money
Findings in Brief
EPA conducted a variety of
successful initiatives which
demonstrated the potential for
reducing the time and cost of
cleanups, and for making the
process more equitable.
However, improvements were
needed in analyzing, measuring,
and publicizing the results of
pilot projects to replicate
successful techniques
nationwide.
We Found That
Region 3 conducted an "Innovative
Data Validation Approach" to
reduce the cost and turnaround
time associated with validating
analytical results of samples taken
at Superfund sites. The initiative
proved to be a worthwhile concept
which could be improved with
further training.
Region 5 successfully completed
three pilot projects focusing on
accelerating the Superfund cleanup
process. The pilots streamlined
the traditional Superfund process
by accelerating cleanup actions
and integrating site assessments.
However, summary reports
providing Headquarters quantitative
and qualitative results of the pilots
were not completed.
Region 5 also introduced pilot
projects under the Allocation Tools
and Mixed Funding initiatives to
promote fairer settlements. Limited
progress was achieved using
allocation tools due to contract
delays, and the Region had not
developed measures of success
for the mixed funding initiative.
Region 6 initiated two pilot
"Lightning Rod" projects designed
to reduce the time required to
complete remedy selection and
initiate remedial action.
Streamlining and accelerating the
remedial planning and remedy
selection processes were
accomplished faster than non-pilot
sites, with minimal adverse effects.
Region 7 initiated 12 pilot projects
for six different initiatives.
Although the Region completed
three projects and started work on
nine others, it could not measure
the projects' success because
measurable performance
objectives were not established.
Region 10 demonstrated the use of
non-time-critical removal actions to
accelerate site cleanups. The
removal actions achieved
permanent site remedies which
saved time and costs by
eliminating the need to perform
longer term remedial actions.
We Recommended That
• The Directors for Region 3's
Environmental Services Division
and Hazardous Waste
Management Division ensure that
all remedial project managers
(RPM) are adequately trained in
the "Innovative Data Validation
Approach."
• The Regional Administrator for
Region 5 coordinate with
Headquarters to develop
performance measures for the
mixed funding initiative.
• The Regional Administrator for
Region 7 establish measurable
performance objectives for each of
the pilot projects.
What Action Was Taken
• Region 3 agreed with the
recommendation and indicated that
a "refresher" training session to
address available data validation
levels and any RPM concerns
would be conducted.
• Region 5 agreed with the
recommendations in-both reports
and indicated that the Region
would work with Headquarters
personnel to further clarify and
strengthen the program.
• Region 7 agreed with the
recommendations and will compare
regional project results to
established objectives as part of
the individual project closeout
report.
32
OFFICE OF INSPECTOR GENERAL
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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 follow-up
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.
Current Period
As of September 30, 1994, EPA had
231 OIG reports requiring resolution-
6.9 percent fewer than the beginning
balance of 248 reports six months
ago. The total number of reports
requiring resolution was also 8.8
percent fewer. The number of
reports over 180 days from report
issue date decreased 41 percent
from 124 to 73 during this reporting
period. As of September 30, 1994,
the number of past due responses
was 31.6 percent of the reports to be
resolved compared to 50 percent of
the reports in the follow-up system
as of March 31, 1994.
The costs questioned on the OIG
reports for which management
decisions exceeded 180 days as of
September 30 represented 86.3
percent of total questioned costs to
be resolved A total of $101.5
million, or 77.1 percent, were
ineligible costs that are likely to be
sustained for recovery
These reports need to be resolved
and the misspent dollars recovered
more expeditiously It takes more
time to reach a management
decision on some complex reports.
However, monies not collected
result in large amounts of funds
being borrowed to finance Agency
operations.
COMPARISON OF UNRESOLVED REPORTS AND THE RELATED COST QUESTIONED
(PAST THE 180 TIME FRAME FOR RESOLUTION)
100
80
60
40
20
80.3%
84.0%
86.3%
70 6%
44.2%
49.8%
33.9%
30.8%
30.2%
31 6%
0
92-1
93-2
94-1
92-2 93-1
• " % OVER 180 DAYS — °/o QUESTIONED CO^TS
94-2
Agency officials provided individual
explanations why follow-up had been
delayed as well as projected
resolution dates (see Appendix 2).
These explanations raise issues of
the complexity of report resolution,
state delegation for resolution, and
the changing mix of types of OIG
reviews.
During this reporting period, most
EPA Action Officials made better
efforts in resolving reports in a timely
manner. However, Region 9 and
Region 10 were not timely resolving
reports with the large dollar issues.
Instead of improvements in audit
resolution occurring in this reporting
period, the situation has worsened in
Region 9 with the percentage of
questioned costs addressed in
management decisions decreasing
from only 10 percent to just over 1
percent this semiannual period
Region 9 believes that the six-month
timeframe set forth in EPA Directive
2750 is not sufficient to assure
quality decisions necessary to
protect auditees, avoid legal
challenges, and avoid appeals.
Therefore, Region 9 has disregarded
this timeframe for audit resolution.
However, Region 9 does not have
the authority to disregard EPA policy
Both the auditee and EPA have a
right to a timely resolution of audit
issues within the required timeframe
In March, the Inspector General
brought up this serious issue of
timely resolution of audit reports witl
the Deputy Administrator urging him
to discuss the issue during his visit
with Region 9 and have Region 9 tc
agree on a plan for improvement.
During the first six months of fiscal
1994, Region 10 resolved reports
totaling only $70,000 in ineligible
questioned costs and leaving a
balance of $10.08 million of meligibl
costs questioned on reports more
than 180 days from issue date.
During the second half of the year,
Region 10 resolved $300,000 of
ineligible questioned costs. The
unresolved overdue balance of
ineligible costs questioned at year
end was $10.04 million. For years
Region 10 did not have any
unresolved reports over 180 days
from report issue date that needed
APRIL 1, 1994 THROUGH SEPTEMBER 30, 1994
-------
Status Report On Perpetual Inventory of Reports in Resolution Process For The Semiannual Period Ending
September 30, 1994 (Dollar Values in Thousands)
Report Issuance
Questioned Recommended
Number Costs Efficiencies
Report Resolution
Costs Sustained
To Be As
Recovered Efficiencies
A. For which no management decision
has been made by,the commencement
of the reporting period*
B. Which were issued during the
reporting period
C. Which were issued during the reporting
period that required no resolution
Subtotals (A + B - C)
D. For which a management decision was
made during the reporting period
E. For which no management decision has
been made by the end of the reporting
period
Reports for which no management
decision was made within six months of
issuance
248 $410,738 $29,131
796 52,095 9,665
568 305 0
476 462,528 38,796
245 90,996 12,066 $35,251 $2,545
231 371,532 26,730
73 321,478 17,723
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.
resolution. Now, extra effort needs
to be taken to once again resolve the
audit reports in a timely manner.
Trends
Our analysis of the Agency's
unresolved reports from
March 31, 1992 (92-1) through
September 30, 1994 (94-2), shows
that the Agency's percentage of
reports 180 days past the report
issue date were not proportionate to
the percentage of questioned costs
on these reports. The above chart
shows this comparison.
The number of reports over six
months old requiring resolution
should correlate more closely with
the related dollars questioned. At
the end of each fiscal year the
Agency has made good progress in
reducing the total number of reports
over six months old. Currently, these
reports represent 31.6 percent of
reports needing resolution. However,
the dollar value of these reports has
steadily risen to an all-time, high of
86.3 percent as of September 30,
1994.
It is imperative that EPA take steps
to resolve those reports with large
dollar issues in a timely manner so
that monies can be recovered more
quickly. This prevents the
Government from having to borrow
funds to finance day-to-day
operations.
Audit Followup
The Inspector General Act
Amendments of 1988 requires
Agency management to report
semiannually, in a separate report to
Congress, the corrective actions
taken in response to the OIG's
reviews. The Office of Inspector
General reviews the Agency's
followup actions on selected reviews.
Through other means, the OIG also
learns of Agency actions taken in
response to IG work which go
34
OFFICE OF INSPECTOR GENERAL
-------
beyond implementing those specific
recommendations made in review
reports.
Agency Needs to Improve
Efforts in Administering
Response Claims Against
the Superfund
Previous Problems and Findings
Our September 1992 report
concluded that there were serious
problems in EPA's handling of
response claims against the
Superfund. We reported that
significant internal control
weaknesses resulted in about
$35 million of commitments and
obligations not being properly
recorded, or not being recorded.
Also, EPA paid $2.8 million for the
first preauthorized response claim
(for the MOTCO site in Texas)
without adequate assurance that
all reimbursed costs were eligible
and that the potentially
responsible party (PRP) complied
with the settlement agreement.
Finally, EPA did not bill PRPs for
costs associated with the MOTCO
site in accordance with the
Consent Decree, so EPA did not
collect about $1.1 million for
oversight work performed by EPA
and its contractors.
Followup Findings
While EPA had made efforts to
implement some of our previous
recommendations, some corrective
actions agreed to in the Agency's
action plan had either not been
implemented or had not corrected
the deficiencies noted in our 1992
report.
All six EPA regions with
preauthorized mixed funding sites
were from one month to two years
late in their billings for oversight
costs. Four of the regions made
their billings current before we began
our review, but Regions 3 and 6
were still not current at the time of
our review.
The Agency continued to experience
difficulties in ensuring that
commitment and obligation
information for these sites was
entered into IFMS. The responsible
officials did not notice that two sites
were missing from IFMS because
periodic reviews of preauthorized
mixed funding site information
covered only information from the
prior month, rather than all prior
information.
Finally, two separate guidance
documents on the commitment and
obligation of funds that the Agency
had agreed to finalize by
December 31, 1993, continued to be
in draft. The Agency advised us that
both would be finalized by December
31, 1994. a year later than the
original plan
Correcting these areas takes on
more significance because this type
of Superfund cleanup financing
arrangement is expected to grow
significantly in the future.
Followup Recommendations
We recommended that the Assistant
Administrator for Solid Waste and
Emergency Response direct the
Office of Emergency and Remedial
Response to:
Continue its efforts to finalize and
issue procedures for the timely
commitment and obligation of funds.
Ensure that the missing
obligations for the two preauthorized
mixed funding sites are recorded in
IFMS, and review financial reports for
past as well as present status of
obligations.
Modify guidance to require
Offices of Regional Counsel to
ensure that PRP compliance with the
Consent Decree includes timely
payment of any billed oversight
costs.
• Work with the Office of
Enforcement and Compliance
Assurance to provide for an offset
provision (reimbursements to PRPs
against monies owed to the Agency)
in the consent decrees for
preauthorized mixed funding sites.
We also recommended that the
Assistant Administrator for
Administration and Resources
Management direct the Office of the
Comptroller to continue its efforts to
finalize and issue Resources
Management Directive System
Chapter 11 on response claims.
We further recommended that the
Assistant Administrators for
Administration and Resources
Management, Enforcement and
Compliance Assurance, and Solid
Waste and Emergency Response
direct all regions to ensure PRPs an
sent current and accurate oversight
cost billings before any PRP claims
are paid at preauthorized mixed
funding sites.
What Action Was Taken
In responding to the draft report, the
Agency generally agreed with our
findings and recommendations and
agreed to implement corrective
action. The final special review
report (4400091) was issued to the
Assistant Administrator for Solid
Waste and Emergency Response
and the Assistant Administrator for
Administration and Resources
Management on July 29, 1994. A
response to the final report is due t
October 27, 1994.
APRIL 1, 1994 THROUGH SEPTEMBER 30, 1994
-------
Improvements Made in
Penalty Assessments
Previous Problems and Findings
Our 1989 report on penalty
computation and assessment
concluded that the Agency needed
to take more assertive actions
regarding the (1) calculation,
assessment and documentation of
penalties; (2) collection of the
economic benefit gained by
noncompliance; and
(3) accumulation of penalty
information.
Followup Findings
In Headquarters, the Office of
Enforcement and Compliance
Assurance (OECA) had taken
successful steps to: (1) issue
penalty guidance, (2) oversee
regional activities, and (3) monitor
penalties assessed and collected,
which promoted consistency in
calculating, documenting, and
collecting penalties, and fair and
consistent treatment of the regulated
community. Region 5 had
successfully: (1) documented
penalty calculations and reductions,
(2) reduced penalties within penalty
policy limits, and (3) recovered
economic benefits, when applicable.
Followup Recommendations
We made additional
recommendations to the Assistant
Administrator for Enforcement and
Compliance Assurance on minor
issues involving the training of
attorneys involved in negotiations
and documentation for supplemental
environmental projects.
What Action Was Taken
The final report (4400107) was
issued to the Assistant Administrator
for Enforcement and Compliance
Assurance on September 15, 1994.
In responding to the draft report, the
Agency agreed to take action to
address the issues involving training
of attorneys and documentation. As
a result, we closed out this follow-up
review in our tracking system and all
corrective actions will now be tracked
in the Agency's Management Audit
Tracking System.
Actions In Response To
Other OIG Reports
The OIG's reports and cooperative
efforts with program officials
frequently have positive impacts that
reach beyond the implementation of
specific report recommendations.
These impacts are not normally
verified by formal OIG followup
reviews. For example, during this
reporting period the OIG learned that
because of our recent audit of
Region 7's oversight of State grants,
Region 7 officials formed a
workgroup to improve and streamline
their grant oversight procedures. At
their request, OIG staff are
participating in the workgroup. The
workgroup's goals are to define staff
roles and responsibilities and to
develop standard operating
procedures incorporating EPA's
reengineered Federal Managers'
Financial Integrity Act process. In
addition, project officers in other
Regions have requested copies of
the audit report for use in developing
or improving their grant oversight
procedures.
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 or,
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 contro
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 $54.6
million being sustained out of $63.4
million considered ineligible in reports
under OIG control. This is an 86
percent sustained rate.
36
OFFICE OF INSPECTOR GENERAL
-------
Table 1 -- Inspector General Issued Reports With Questioned Costs
Semiannual Period Ending: September 30, 1994
Dollar Values(thousands)
A. For which no management decision has been made by
B.
C.
D.
the commencement of the reporting period**
New Reports issued during period
Subtotals (A + B)
For which a management decision was made during
the reporting period
(i) Dollar value of disallowed costs
(ii) Dollar value of costs not disallowed
For which no management decision has been
made by the end of the reporting period
Reports for which no management decision was
made within six months of issuance
116
85
201
81
54
59***
120
55
$410,738
51,790
462,528
90,996
35,251
55,745
371,532
321,478
$120,218
15,637
135,855
35,127
5,085
30,042
100,728
86,216
* Questioned costs include 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.
** One report had the entire costs questioned sustained. In 27 reports, management did not sustain any of the
$22,442,648 questioned costs. Thirty-one reports are also included in C(ii) because they were only partially
sustained. Only the costs questioned that were not sustained in C(i) are included in this category.
APRIL 1, 1994 THROUGH SEPTEMBER 30, 1994
-------
Table 2 - Inspector General Issued Reports With Recommendations That Funds Be Put To Better Use
Semiannual Period Ending: September 30, 1994
Number Dollar Value
(in thousands)
A.
B
C.
D.
For which no management decision has been made by
the commencement of the reporting period*
Which were issued during the reporting period
Subtotals (A + B)
For which a management decision was made during
the reporting period
(i) Dollar value of recommendations that
were agreed to by management
- based on proposed management action
- based on proposed legislative action
(ii) Dollar value of recommendations that were
not Agreed to by Management
(iii) Dollar value of non-awards or unsuccessful
bidders
For which no management decision has been made by
the end of the reporting period
Reports for which no management decision was
made within six months of issuance
31
28
59
27
6
n/a
n/a
5"
18
32
9
$29,131
9,665
38,796
12,066
2,545
n/a
n/a
5,879
3,641***
26,730
17,723
* 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.
** Two reports were included in C(i) and C(ii). Only the related dollars disallowed were included in C(i), whereas the
dollars which were not disallowed were included in C(ii).
*** This amount represents the dollar value of recommendations that funds be put to better use.
_0 OFFICE OF INSPECTOR GENERAL
oo
-------
Resolution of Significant Reports
Report Number
Report Date
S2BWL1-01-0234
4100202
REPORT DATE
3/ 4/94
P2CWLO-02-0230
4100203
REPORT DATE
3/ 4/94
P2CWL3-02-0012
4100191
REPORT DATE
2/24/94
P2CWL3-02-0103
4100209
REPORT DATE
3/11/94
P2CWL9-02-0135
4100093
REPORT DATE
11/26/93
P2CWL9-02-0176
4100051
REPORT DATE
ll/ 1/93
D9AKL3-03-0292
4100024
REPORT DATE
10/19/93
P2CWM1-03-0155
4200009
REPORT DATE
2/15/94
P2CWM2-03-0026
4200008
REPORT DATE
2/10/94
P2CWM2-03-0029
4200005
REPORT DATE
2/ 1/94
]
Grantee/
Contractor
LYNN WATER
& SEWER MA
EAST HANOVER
NJ
WESTCHESTER-
PORT CHESTER
SD NJ
WOODSTOCK NY
KEANSBURG NJ
FRANKLIN NJ
BOOZ ALLEN
& HAMILTON
MD
OAKLAND MD
ANNE ARUNDEL
COUNTY MD
CHARLES
COUNTY MD
R t
I
FS Questioned/
Recommended
Efficiency
INEL
UNSP
UNUR
RCOM
INEL
UNSP
UNUR
RCOM
INEL
UNSP
UNUR
RCOM
INEL
UNSP
UNUR
RCOM
INEL
UNSP
UNUR
RCOM
INEL
UNSP
UNUR
RCOM
INEL
UNSP
UNUR
RCOM
INEL
UNSP
UNUR
RCOM
INEL
UNSP
UNUR
RCOM
INEL
UNSP
UNUR
RCOM
540,
1,758,
2, 959,
160,
2,408,
984,
1, 862,
1, 872,
393,
65,
1, 661,
1, 164,
521,
77,
709
0
0
0
305
0
0
0
471
652
0
0
042
0
0
0
939
0
0
0
924
0
0
0
0
0
0
085
078
373
0
0
558
480
0
0
533
410
0
0
teport Resolution
Federal Share
to be Recovered/
Sustained
Efficiency
INEL
UNSP
UNUR
SUST
INEL
UNSP
UNUR
SUST
INEL
UNSP
UNUR
SUST
INEL
UNSP
UNUR
SUST
INEL
UNSP
UNUR
SUST
INEL
UNSP
UNUR
SUST
INEL
UNSP
UNUR
SUST
INEL
UNSP
UNUR
SUST
INEL
UNSP
UNUR
SUST
INEL
UNSP
UNUR
SUST
540,
1,630,
2,954,
160,
2,408,
984,
1,452,
1,872,
393,
10,
1,655,
513,
77,
709
0
0
0
563
0
0
0
907
652
0
0
042
0
0
0
939
0
0
0
762
0
0
0
0
0
0
085
078
454
0
0
873
0
0
0
960
410
0
0
P2CWN1-03-0123 PHILADELPHIA INEL 15,396,996 INEL 14,764,638
2300062 PA UNSP 13,596,473 UNSP 2,285,611
REPORT DATE UNUR 0 UNUR 0
7/23/92 RCOM 0 SUST 0
P2CWN8-03-0220 ELK PINCH INEL 684,189
3300041 UNSP 1,871,305
REPORT DATE UNUR 0
5/ 6/93 RCOM 0
P2CWP2-23-0323 DECATUR SD INEL 407,990
4400009 IL UNSP 367,833
REPORT DATE UNUR 0
12/ 3/93 RCOM 0
INEL 684,189
UNSP 1,343,329
UNUR 0
SUST 0
INEL
UNSP
UNUR
SUST
407,546
366,810
0
0
NOTE: INEL = INELIGIBLE COST
UNSP = UNSUPPORTED COST
UNUR = UNNECESSARY/UNREASONABLE COST
RCOM = RECOMMENDED EFFICIENCIES
SUST = RECOMMENDED EFFICIENCIES SUSTAINED
APRIL 1, 1994 THROUGH SEPTEMBER 30, 1994
39
-------
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 March 31, 1994 189
New Investigations
Opened This Period 96
Investigations Closed
This Period 128
Pending Investigations as
of September 30, 1994 157
Prosecutive and
Administrative Actions
In this period, investigative efforts
resulted in 7 convictions and 11*
indictments. Fines and recoveries,
including those associated with civil
actions, amounted to $0.2 million.
Eight administrative actions** were
taken as a result of investigations:
Reprimands 2
Resignations/Removals 2
Restitutions 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 of Pending Investigations by Type
(Total-157)
General EPA Programs
Procurement Fraud
Emp.
Integrity
26
Superfund and Lust
Procurement Fraud
29
12
Constructio
30
Program
Integrity
Total Cases: 110
9
Other
2
Emp.
Integrity
14
Program
Integrity
Total Cases: 47
40
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 April 1, 1994.
Firm and President
Convicted of Making False
Claims
T. Head and Company, Inc., known
as THI, and Toney Head, Jr., the
firm's owner, president, and chief
executive officer, were convicted in
August 1994 of filing 41 false
claims.
THI of Herndon, Virginia, a
subcontractor on a prime contract
between the Small Business
Administration and EPA, was to
establish and monitor national
accounts for shipping laboratory
samples of hazardous waste and
other materials to certain contract
laboratories for analysis. Under the
cost-plus-fixed-fee subcontract, the
value of which exceeded $2 million,
EPA was to pay THI for certain
percentages of THI's direct and
indirect costs.
The investigation revealed that
Head personally directly four former
THI employees to falsify records
which showed the number of hours
that these employees worked on the
EPA contract. Head used the false
information to inflate numerous THI
invoices submitted to EPA.
Former Maryland Chief
Fiscal Officer Pleads Guilty
to Money Laundering
Rufus O. Ukaegbu, former chief
fiscal officer for the State of
Maryland Department of the
Environment, Water Quality
Financing Administration (WQFA),
pleaded guilty in July 1994 to
money laundering. Also during
July, Ukaegbu pleaded guilty to a
State of Maryland theft statute.
Utilizing a combination of state and
federal grants as well as revenues
from bonds, maintained in various
bank accounts, WQFA finances the
construction of sewage treatment
plants and other water quality
projects by local governments.
Ukaegbu, who had authority to
approve disbursements to
contractors, used his position to
cause the WQFA's bank to
generate fraudulent payment
authorizations in names the same
or similar to legitimate contractors.
The addresses, however, were
those of bank accounts or
mailboxes controlled by Ukaegbu
confederates.
Through the use of wire transfers
and monetary instruments, the
stolen funds were used to purchase:
numerous automobiles, all shipped
to Nigeria; sizeable security
investments; penicillin and other
pharmaceutical supplies which were
shipped to Nigeria for resale; home
remodeling; and to reduce personal
debt.
This case was investigated jointly
by the EPA OIG, FBI, and the
Maryland State Police.
Environmental Engineer
Sentenced for Role in
NPDES Violation
Harry Kring, an AT&T environmental
engineer, was sentenced in June
1994 to serve 6 months home
detention, 3 years probation, and
fined $5,000 and a special
assessment after pleading guilty of
negligently discharging pollutants in
violation of a National Pollutant
Discharge Elimination System
(NPDES) permit limitations and
filing false statements.
The investigation was initiated by
allegations that Kring conspired with
AT&T to falsify laboratory test
results on samples that he collected
from a wastewater treatment system
at an AT&T facility in Pennsylvania.
The allegedly falsified laboratory
test results were produced by Kring
and reported by AT&T to EPA on
Discharge Monitoring Reports as
part of AT&T's NPDES permit.
In January 1994, AT&T pleaded
guilty to the same NPDES violation
and was fined $175,000.
The case was investigated jointly by
the EPA OIG and the EPA Criminal
Investigations Division.
Region 4 Employee
Sentenced in Fraud Case
Angela Fields, a former supervisory
accountant in the EPA Region 4
office in Atlanta, was sentenced in
June 1994 to 5 months prison, 5
months home confinement, 3 years
probation, and ordered to pay
restitution of $28,049 and a $750
special assessment.
As reported in our previous
semiannual report, Fields pleaded
guilty in March 1994 to
embezzlement, wire fraud,
and mail fraud. She admitted that
she entered false information into
APRIL 1, 1994 THROUGH SEPTEMBER 30, 1994
41
-------
EPA's Integrated Financial
Management System. As a result
of her false entries, Fields received
23 U.S. Treasury checks which she
later deposited into her credit union
account After receiving the funds,
Fields then made entries into the
system that made various financial
reports appear to balance.
Fields' employment was terminated
by EPA when the fraudulent
payments were discovered in
November 1992.
New Jersey Technology
Firm Sentenced
Dantec Measurement Technology,
Inc., of Mahwah, New Jersey, was
sentenced after pleading guilty to
submitting falsified invoices to make
it appear that General Services
Administration schedule items were
sold to EPA when, in fact, non-GSA
customized items were actually
sold.
Dantec, in acknowledging and
accepting responsibility for the
improper manner in which it
administered EPA purchase orders,
entered a guilty plea for submitting
false statements. Dantec was
sentenced to pay a fine of $400 and
a $200 special assessment on each
of the four counts. In addition,
Dantec paid $10,000 for
investigative costs as a result of a
civil settlement in this matter.
Former Region 4 Attorney
Sentenced
Alvin R. Lenoir, a former EPA Office
of Regional Counsel attorney,
Region 4, was sentenced to two
years probation, 200 hours of
community service, and ordered to
pay restitution of over $3,800 to
EPA after pleading guilty to
misdemeanor theft.
Our investigation revealed that
during the period October 1991 to
March 1993 numerous phone
charges for calls made to and from
Lenoir's home and office telephone
numbers were charged to two AT&T
telephone credit cards, one issued
to the former EPA Region 4
Administrator and one to another
former Region 4 Office of Regional
Counsel attorney. Lenoir had left
EPA's employ in October 1991.
Former Contractor's
Employee Sentenced in
Credit Card Scam
Sara Lee Hinton, a former
contractor employee, was
sentenced in August 1994 to one
year probation and payment of a
special assessment after pleading
guilty to misdemeanor theft of
Government property.
The investigation was initiated after
EPA Region 3 employees reported
that credit card accounts were
opened in their names using
information that they believed to
have been accessed through the
Region's personnel office.
The investigation determined that
Hinton, who had previously been an
on-site contractor employee with
access to EPA employees' travel
vouchers, copied personal
information from the vouchers and
provided this information to a hair
stylist who, in turn, obtained credit
cards. In exchange for the
information, Hinton's hair was cut
free of charge.
This case was investigated jointly
by agents of the EPA OIG and
Postal Inspection Service.
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OFFICE OF INSPECTOR GENERAL
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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 3 legislative
and 70 regulatory items. The most
significant items reviewed are
summarized below.
H.R. 4679, The Inspector
General Reform Act of 1994
The proposed Inspector General
Reform Act of 1994 is intended to
expand the mission of Inspectors
General (IGs), provide for their
greater independence, and make
them more effective and
accountable. We reviewed this bill
at the request of its sponsors.
We supported various provisions of
the bill, including those relating to
the development of strategic plans
and performance measures; IG
term limits; the removal of Igs only
for cause; the removal of IGs from
the general supervision of the
agency head; the expanded
prohibition on interference with IG
activities to all Executive Branch
personnel; authority for IGs to
independently obtain office space,
legal counsel, and to submit initial
budgets concurrently to the agency,
OMB, and the Congress; and
authority for IGs to award bonuses
to SES employees and deal directly
with the Office of Personnel
Management on SES matters.
We also expressed serious
concerns with other aspects of the
bill. Of primary importance, we did
not agree with the expanded
requirements for reporting
information to the Congress,
particularly for ongoing
investigations and investigations
which found no wrongdoing. We
also maintained that legislative
language concerning conflicts-of-
interest for OIG employees was
unwarranted and the associated
penalties unnecessarily harsh. In
addition, we objected to the
establishment of a time frame for
coordination of investigative matters
with the Department of Justice and
to the reporting of administrative
actions against agency personnel
which the IG regarded as
insufficient. Finally, we objected to
the elimination of the authority for
an IG to disclose a whistleblower's
identity if unavoidable during the
course of an investigation. In light
of the great care and deliberations
brought to such decisions, we
considered the proposed language
to be a severe and impractical
limitation.
OMB Request for Views on
S. 1782, the Electronic
Freedom of Information
Improvement Act
We reviewed S. 1782 in response
to OMB's request. The bill, which
is designed to ensure public access
to agency records and information
and expedite the processing of
requests for such information,
redefines agency records to make ii
clear that the Freedom of
Information Act covers all
government information in any
format; requires the indexing of all
major information systems
containing agency records
regardless of form or format; and
requires agencies to provide
information in the requested format
APRIL 1, 1994 THROUGH SEPTEMBER 30, 1994
43
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including electronically, whenever
possible. While we concurred with
the general intent of this legislation,
we expressed two major concerns.
First, we maintained that it would
not be feasible to require an
agency to provide an index of all
information retrievable or stored in
an electronic form. Any such index
would have to be modified on a
daily basis as new records are
created, an onerous and virtually
impossible task to coordinate.
Furthermore, we noted that no
comparable index of non-electronic
documents is now required.
Second, the provision permitting
the court to assess the Government
for "out of pocket" expenses
incurred by the requester did not
define what constituted "out of
pocket." We recommended a
clarification of this issue.
Proposed Rule On
Electronic Mail Systems
We expressed our serious concern
about proposed standards being
developed by the National Archives
and Records Administration
(NARA) for the management of
Federal records created or received
on electronic mail (E-Mail) systems.
Overall, the proposed rule
appeared to impose extremely
pervasive document analysis and
storage requirements which would
severely impact the operation of
our local area network and the
Agency's E-Mail system.
We were particularly concerned
that the regulations would demand
a large investment of resources for
E-Mail recordkeeping, archiving and
security. Specifically, the Agency
would need to inform employees of
the rule's impact and develop
procedures for archiving required
records from its own E-mail
systems.
Some organizations would have to
modify their software to effectively
implement the rule's requirements.
In addition, the proposed
regulation's requirement that the
Agency obtain permission to
dispose of "all versions" of E-Mail
records is overly burdensome and
could even require NARA staff en-
sile to oversee records disposal.
We recommended that individuals,
with oversight by the Agency, be
allowed to make the final decision
on the majority of E-Mail records.
We were also concerned that the
requirement for backing up
transmissions from the Internet and
other information systems would
necessitate a greater investment in
security to guard against viruses.
Finally, we recommended
consideration of the special needs
of such offices as the Office of
Enforcement and Compliance
Assurance and the Office of
Inspector General for greater
security and system independence.
Reorganization Proposal
for the Gulf of Mexico
Program Office
We reviewed a proposal by the
Office of Water (OW) to transfer the
operational management and
leadership responsibilities of the
Gulf of Mexico Program Office from
OW to Regions 4 and 6 on a 2-year
rotational basis. While we agreed
that the proposed reorganization
would give the Gulf of Mexico
Program a clearer sense of
direction and increase its
effectiveness, we believed such a
system would necessitate
increased Agency oversight to
ensure program consistency.
Since the proposal failed to
address how consistency would be
monitored and who would be
responsible for this function, we
recommended that the proposal be
revised to clarify this issue.
We also recommended an
enhancement to the section
addressing management integrity
responsibilities by suggesting that
the proposal specify that the lead
region must assist OW in fulfilling
this responsibility. During the
reporting period, the proposal was
revised to our satisfaction.
Revision of EPA's Privacy
Act Manual
We commented on a draft revision
of EPA's Privacy Act Manual, which
the Office of Information Resources
Management (OIRM) updated to
include references to the Computer
Matching and Privacy Protection
Act of 1988. We recommended a
number of revisions.
The draft Manual recommended
that all denials for access issued by
OIG be coordinated with OIRM and
the Office of General Counsel
(OGC). We were concerned that
this could imply that OIRM and
OGC would "approve" all OIG
denials, including initial denials.
Although we consult with OGC on
Privacy Act issues, the ultimate
decision is the OIG's. We
suggested adding language
exempting initial OIG denials from
this procedure.
In addition, because security
procedures to protect information
systems constantly need review
and possible revision due to the
ever-changing computing and
communications environment, we
recommended that the security
controls mentioned in the
referenced documents be
continually assessed.
44
OFFICE OF INSPECTOR GENERAL
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Finally, we commented on a
section which prohibited disclosure
of EPA records subject to the
Privacy Act to a recipient agency or
non-federal agency for use in a
computer matching program without
a matching agreement approved by
the EPA Data Integrity Board.
Since the draft did not clarify
whether other agencies have
access to any of EPA's systems
from which they could perform a
match without going through the
stated process, we recommended a
clarification of this issue.
EPA Information Resources
Management Policy Manual
- Chapter 17, System Life
Cycle Management Policy
Initially, we did not concur with a
draft policy establishing the life
cycle requirements of EPA's
automated information application
systems. While we believed the
draft had many positive aspects,
we had significant concerns that
should be addressed before issuing
such an important policy document.
We recommended a more detailed
discussion of the system life cycle
process, including data
management, quality assurance,
software maintenance, evaluation
and assessment of information,
system obsolescence, development
of data dictionaries, and federally
mandated system life cycle
documentation.
Specifically, we were concerned
that the system life cycle stages
were not consistent with Federal
guidance and that the proposed
policy did not require use of a
specific system life cycle
methodology. While we agreed
that some flexibility was desirable,
we maintained that a standard
generic methodology was
necessary for consistency and
quality assurance purposes and
recommended revising the policy
accordingly. We also
recommended including an
estimate of the range of potential
life cycle costs of new system
development or enhancement and
mandating specific time frames for
reviewing and approving/
disapproving system decision
papers. Finally, we recommended
greater emphasis on user
involvement in the system life cycle
by identifying the primary and
secondary users throughout the
process. During the reporting
period, the policy was revised to
our satisfaction.
Suspension and
Debarment Activities
EPA's policy is to do business only
with contractors and assistance
recipients who are honest and
responsible. EPA enforces this
policy by suspending or debarring
contractors, assistance recipients,
or individuals within those
organizations, 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
generally do not 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 non-procurement debarment
or suspension by one agency is
effective in all agencies and
requires the General Services
Administration to publish monthly
"Lists of Parties Excluded from
Federal Procurement or Non-
procurement Programs." Formerly,
a non-procurement debarment was
effective only in the programs
administered by the debarring
agency, and each agency
maintained its own list. The EPA
Suspension and Debarment
Division in the Office of Grants and
Debarment operates the S&D
APRIL 1, 1994 THROUGH SEPTEMBER 30, 1994
45
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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.
During this period, cases with direct
OIG involvement led to 20
debarments, 12 suspensions, and 5
compliance agreements, a total of
37 actions.
The following are examples:
• On June 30, 1994, EPA sent a
Notice of Proposed Debarment to
Warren H. Berkle Jr., President of
Berkle Insurance Co., and its
affiliated companies, National
Sureco Ltd. and Associated
Insurance Inc.
Also, on September 16, 1994, EPA
debarred Kent E. Conshafter for a
period of three years
Mr. Berkle pleaded guilty to one
count of conspiracy for devising a
scheme to defraud and obtain
money and property by means of
false and fraudulent pretense. The
scheme involved issuing false
surety bonds to construction
companies working on EPA
contracts. Mr. Conshafter, a co-
conspirator in this scheme, was the
secretary of Preferred Indemnity
Insurance Company.
• On June 24, 1994, EPA
suspended T. Head and Company,
Inc. (THI), and its owner, Toney
Head, Jr., based on an indictment.
The charges against THI and Mr.
Head related to an alleged scheme
to defraud the United States by
making, and attempting to conceal,
false claims for payment on a
contract for services under the
Comprehensive Environmental
Response, Compensation, and
Liability Act.
• On April 20, 1994, EPA debarred
Rex Wilson Robinson for a period
of 3 years. Mr. Robinson pleaded
guilty to falsely impersonating an
officer and/or employee of EPA.
Mr. Robinson, while identifying
himself as an agent of EPA, made
several telephone calls to and met
with officials of Corporate Services
Inc , a subsidiary of the Michigan
Farm Bureau of Lansing, Michigan
• On June 20, 1994, EPA debarred
Robert Olcerst, owner and operator
of Brujos Scientific Inc., and
Kenneth Charles and Michael
Harris, employees of Sandag
Engineering Inc., for a period of 3
years. All were involved in a
scheme to defraud the School
Construction Authority of New York
and the public through a variety of
schemes in obtaining and
performing asbestos testing and
monitoring contracts for submitted
fictitious claims.
• On June 6, 1994, EPA issued a
Notice of Proposed Debarment
under the assistance regulations to
Martin Lesher, President of
Equitable Blueprint and Photoprint
Co. Inc., and several other
employees of the firm. The
proposed debarment was based on
a criminal conviction and a
procurement debarment under the
Federal Acquisition Regulation
imposed by the U.S. Army.
OIG Personnel Security
Program
This program is one of the first-line
defenses against fraud by using
background investigations and
National Agency Checks and
Inquiries to review the integrity of
EPA employees and contractors.
During this reporting period, there
were 1,012 investigations reviewed.
• An employee's temporary
appointment was terminated and
the employee received a 3-year
debarment from the Office of
Personnel Management (OPM) for
falsification of the SF-171, for
failing to list a criminal conviction.
• An employee was terminated
from EPA because of a conviction
for forgery of stolen U.S. Treasury
checks totaling over $27,000.
• An employee was terminated
from EPA because of a pattern of
financial irresponsibility and
delinquent debts totaling over
$7,000 and misuse of Government
property.
• After referral of post-appointment
arrest information to the supervisor,
an employee received a 14-day
suspension for being a fugitive from
justice on a previous felony charge.
• Three contractor employees were
denied access to sensitive
information and two were
terminated because of financial
irresponsibility, prior convictions for
grand larceny, assault and battery,
and possession of controlled
substances. All three contractor
employees falsified the security
questionnaire by failing to list the
prior convictions.
46
OFFICE OF INSPECTOR GENERAL
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OIG Management
Initiatives
Reinventing Offices of
Inspector General
The EPA OIG has begun the
process of reinvention, in
accordance with the following vision
statement adopted by the
Inspectors General: "We are
agents of positive change striving
for continuous improvement in our
agencies' management and
program operations and in our own
offices." In fulfilling this vision and
carrying out the mission
responsibilities set forth in the
Inspector General Act, the IGs
have pledged to:
• work with management and the
Congress to improve program
management
• use our investigative and
program compliance reviews to
improve the effectiveness of
program operations, increase
Government integrity, and
recommend improved systems to
prevent fraud, waste, and abuse.
• be innovative and question
existing procedures and suggest
improvements.
• build relationships with program
managers based on a shared
commitment to improve program
operations.
• continue to improve the quality
and usefulness of our products.
• work together to identify and
address Government-wide issues.
We believe that the OIG has
always taken a cooperative
approach with EPA management in
resolving and implementing results
of our audits and investigations. In
this regard, the OIG has begun to
place even greater emphasis on
building partnerships with Agency
program managers based on a
shared commitment to improving
operations. The OIG has taken or
planned a number of other
initiatives to enhance this
cooperation. More OIG resources
are being directed to conducting
performance audits to analyze how
well programs are meeting their
goals and recommending changes
in program design and
management techniques to
increase efficiency and improve
program results.
We will focus more on causes of
problems and provide more
balanced reporting by identifying
effective corrective actions taken by
Agency management and examples
of good management practices,
when possible.
We have begun a streamlining
process within OIG that has three
themes:
• Increased Delegation and
Decentralization of Authority
The OIG plans to delegate to the
lowest practical level the
responsibility and authority to make
managerial decisions and increase
autonomy over its audits,
investigations, and administrative
support activities.
• Increased Empowerment of
Employees with Appropriate
Accountability
We will review present
requirements for periodic reports
from field divisions to Headquarters
to streamline or eliminate
unproductive or overly burdensome
requirements.
We will continue to seek ways to
increase the use of electronic data
exchange to facilitate reporting
between field and Headquarters
offices.
We will seek to streamline the
number of specific measurements
and the narrative justification for
employee ratings, while meeting
EPA requirements.
We will examine the feasibility of
empowering the field divisions with
more authority and autonomy in
personnel matters.
• Improvement of Work Processes
and Systems
The OIG has devoted considerable
time soliciting ideas from our staff
at all levels to improve work
processes. Several major theme
areas have emerged from these
discussions. First, as stated above,
we will focus more attention on
assisting EPA managers to achieve
their program objectives. While we
will continue to conduct compliance
reviews as part of our audits, we
will work more cooperatively with
our customers to ensure that our
products meet their needs.
Internally, we will undertake a
comprehensive review of our
policies and procedures to ensure
that each requirement in the audit
process adds value to our products.
Relative to the three themes, we
have completed or currently
have in process several
streamlining initiatives.
Examples of these initiatives
follow.
• We are increasing the span of
control, reducing managerial layers,
and delegating report signature
authority to meet the EPA
Administrator's mandate and
conform to the Executive Order.
APRIL 1, 1994 THROUGH SEPTEMBER 30, 1994
47
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• We are developing performance
measures which include customer
surveys and other external
feedback.
• Senior O/G officials conducted
outreach activities with Senior
Agency officials to increase Agency
involvement in OIG planning.
• The Office of Investigations
restructured its organization by
consolidating 7 divisional offices
into 3 and reducing the number of
supervisory agents from 11 to 7.
This increased the span of control
and employee empowerment for
more investigative direction and
case development activities by
Team Leaders in the local
suboffices.
• We restructured the Semiannual
Report to Congress to achieve a
more balanced report with more
constructive images, specifically
highlighting Agency
accomplishments.
• We conducted a management
study to identify duplicative and
inefficient administrative and
oversight functions in the O/G.
• We are reviewing the O/G policy
manual to identify and eliminate
unneeded policies.
Training
OIG Developed Courses
• Statistical Sampling Training
This course was designed to
provide guidelines for the use of
statistical sampling in EPA audits.
The emphasis is on instructions for
auditors who need to carry out
elementary sampling procedures in
connection with their auditing
activities, with some additional
direction for those who encounter
more difficult sampling problems
and need references to more
complete sources. This course
was presented in Kansas City, KS.
• Effectively Selling Audit
Findings
This course, previously called
Effective Briefing Techniques, has
been restructured to emphasize
ways of building a cooperative
relationship with auditees and
agency officials through effective
communications and a participatory
approach. The course stresses the
need for gaining credibility and trust
by encouraging and recognizing
corrective actions. Most
importantly, the course presents
methods of selling change through
positive, constructive images and
by demonstrating problems as
opportunities for action. Class
participants gave several
presentations that were videotaped
and evaluated by the entire class.
This course was presented to
Headquarters staff.
• Detecting and Preventing
Fraud in EPA
This course was developed to help
independent public accountants,
OIG auditors, and EPA program
and contract managers detect,
prevent and report possible fraud to
the OIG Office of Investigations.
The purpose of the course is to
raise the consciousness of the
participants to the elements, types,
characteristics, and indicators of
fraud. During this reporting period,
the course was presented to
Northern Division staff in Chicago,
IL
• OIG New Employee
Orientation
The orientation for OIG new
employees was held twice during
this reporting period in Arlington,
Virginia, May 10-13 and in
Washington, DC, September 27-29.
The objective of the orientation was
to help new employees become
familiar with the functions and
organization of the OIG and quickly
become a part of the OIG team.
OIG Contracted Courses
• The Role of Supervisors and
Managers in Equal
Employment Opportunity
(EEO)
This course was designed to help
supervisors and managers to
understand the Federal EEO
program structure and requirements
in order to carry out the mandates
of EEO laws and regulations.
• Written Communication for
Auditors
This course was designed to
upgrade an auditor's competence ir
written communication.
• OIG Superfund Orientation
This course was developed to
provide OIG personnel with an
understanding of the Superfund
program and the overall role of the
OIG in Superfund. The course
includes a history of Superfund,
major concepts of the Superfund
program, Superfund program
organizations and resources,
auditing cooperative agreements,
auditing Superfund contracts, and
internal (management audits). This
course was presented in Chicago,
IL and Washington, DC.
48
OFFICE OF INSPECTOR GENERAL
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Kenneth Konz, Assistant Inspector General
for Audit, introducing guest speaker at a
Brown Bag gathering (photo by Dana
Sharon).
Patrick McNamee, Assistant Director of
GAO's Accounting Information and
Management Division, speaks at a Brown
Bag gathering (photo by Dana Sharon)
• Technical Writing
This workshop was designed to
help OIG engineers develop
technical documents that readers
could understand and to analyze
the data and select information
needed to fit the purpose of the
report and to serve the reader's
needs.
The Brown Bag Institute of
Learning
As part of our effort to do more in-
house training, we initiated a
lunchtime training program called
the Brown Bag Institute of
Learning. This program, hosted by
various OIG managers, features
videotapes, case studies,
discussions, and presentations by
experts on subjects pertinent to
OIG work.
During this reporting period, there
were two presentations.
Kathleen Turco, Office of
Management and Budget,
Management integrity Branch,
presented training on "Changes,
Changes, Changes: OMB Circular
A-123 and its Impact on EPA
OIG." Patrick McNamee, Assistant
Director, GAO's Accounting and
Information Management Division,
presented a training session on
"Changes to the Government
Auditing Standards."
External Quality Control
Review by Health and
Human Services OIG
Members of the IG community
conduct external quality control
reviews of each other's audit
activities every three years to
provide an independent
confirmation of the quality of audit
work. Between January and
April 1994, EPA's Office of Audit
was reviewed by representatives of
the Department of Health and
Human Services (HHS) OIG. HHS
OIG auditors evaluated the internal
quality control system, performed
testing on a sample of completed
audits, and followed up on
recommendations made in the
1991 review. The auditors
concluded that the Office of Audit's
internal quality control system was
operating effectively, and that
established policies and procedures
and applicable auditing standards
were followed. They also stated
that appropriate actions had been
taken in response to the 1991
recommendations.
President's Council on
Integrity and Efficiency
During this reporting period, the
OIG participated in two President's
Council on Integrity and Efficiency
(PCIE) financial management
improvement efforts. The
Department of Veterans Affairs led
the first initiative based on a
request from the Office of
Management and Budget for
information on the credit
management practices of Federal
government agencies. Secondly,
we participated in a Financial
Statement Audit Working Group to
discuss lessons learned in
conducting financial statement
audits.
• PCIE Performance Measures
Task Force
We participated on a special PCIE
working group to develop draft
standard performance measures for
Federal Offices of Inspector
General. The purpose of this
ongoing project is to define output
and outcome measures of OIG
efficiency and effectiveness in
relation to the recently published
APRIL 1, 1994 THROUGH SEPTEMBER 30, 1994
49
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OIG Vision Statement and
Strategies to Apply Reinvention
Principles. OIGs also must develop
and report on performance in
relation to budgetary requests and
strategic plans in compliance with
the requirements of the Chief
Financial Officers Act of 1990 and
the Government Performance
Results Act of 1993.'
Committee on Integrity
and Management
Improvement
The Committee on Integrity and
Management Improvement (CIMI)
recognized its tenth anniversary.
CIMI was established in 1984 by
EPA Order 1130.1 to coordinate
the Agency's effort to minimize the
opportunities for fraud, waste and
mismanagement in EPA programs
and activities. CIMI strives to
continually increase employee
awareness and understanding of
various Agency policies and
procedures. The Committee is
composed of senior EPA program
and regional officials and is chaired
by the Inspector General.
Awareness Bulletin 94-5 "Hatch
Act Revisions and What They
Mean to You"
For over half a century, the Hatch
Act barred most Federal Executive
Branch and postal employees from
active participation in partisan
political activities. On October 6,
1993, the President signed the
Federal Employees Political
Activities Act, eliminating many of
the prohibitions against partisan
political activity. CIMI developed
an awareness bulletin to provide an
EPA personnel with a brief
synopsis of the activities permitted
under the new law which became
effective on February 3, 1994.
The law allows most employees to
engage in partisan political
activities while off duty
Public Service Recognition Week
To communicate support and
appreciation to EPA employees at
all levels, CIMI developed and
coordinated a series of events
during Public Service Recognition
Week in May. Inspector General
John Martin was master of
ceremonies at a special ceremony
highlighted by keynote speaker
Carol Bellamy, Director of the U.S.
Peace Corps. Following the
ceremony, Administrator Carol
Browner hosted a reception for the
20 winners of the EPA Employee
Recognition Award, who, by their
actions, have made their
communities a better place.
Hotline Activities
The OIG Hotline opened 24 new
cases and completed and closed
32 cases during the reporting
period. Of the cases closed, 5
resulted in environmental,
prosecutive, or administrative
corrective action, while 27 did not
require action. Cases that did not
have immediate validity due to
insufficient information may be
used to identify trends or patterns
of potentially vulnerable areas for
future review. The Hotline also
referred 2,716 telephone callers to
the appropriate program office,
State agency, or other Federal
agency for assistance.
The following are examples of
corrective action taken as a result
of information provided by the OIG
Hotline.
• The Hotline office received a
complaint alleging that Region 9
employees had backdated site
inspection reports, misrepresented
site assessment records, and made
false entries in a Superfund
database, the Comprehensive
Environmental Response,
Compensation, and Liability
Information System (CERCLIS). A
review of the Region's Superfund
Comprehensive Accomplishments
Plan (SCAP) disclosed 212 invalid
preliminary assessments (Pas) and
63 invalid site inspections (Sis)
within three Superfund mega-sites
between 1988 and 1991 which
were entered in CERCLIS and also
claimed as SCAP accomplishments
in EPA's annual report to
Congress. Use of these Pas and
Sis significantly inflated EPA's
claimed accomplishments for those
years.
As a result of the review, the invalid
accomplishments were removed
from CERCLIS and a senior-level
EPA employee received a written
reprimand.
• The Hotline office received a
complaint alleging misuse of a
government travel card by an EPA
employee. An inquiry into the
allegation determined that misuse
had occurred. The employee was
required to pay all outstanding
charges on the card before it was
canceled and the employee
received a letter of reprimand.
50
OFFICE OF INSPECTOR GENERAL
-------
Appendix 1 - Reports Issued
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 AND THE DOLLAR VALUE OF RECOMMENDATIONS THAT FUNDS BE PUT TO BETTER USE
Questioned Costs
Assignment Control Number
Title
Final Report
Issued
Recommended
Efficiencies
Ineligible
Costs
Unsupported
Costs
Unreasonable (Funds Be Put
Costs To Better Use)
1. INTERNAL AND MANAGEMENT ASSIGNMENTS
Office of the Administrator
E1SFE3-07-0101-4100522 ERA'S INTEGRITY ACT IMPLEMENTATION 9/16/94
Office of Acquisition Management (0AM)
E1BMF4-11-0026-4100559 ADVISORY AND ASSISTANCE CONTRACTS 9/26/94
0AM Cost Advisory and Financial Analysis Division
Financial Advisory Branch
D6EML4-03-0409-4100535 TECHLAU VA 9/22/94
Assistant Administration for Administration Resources Management
E1SFF3-03-0162-4100462 CONTRACTS NOT CLOSED
E1BMF3-05-0018-4100452 8(A) CONTRACTING DC
E1JBF3-11-0030-4100470 THE FEDERAL TECHNOLOGY
TRANSFER ACT
E1SFG4-13-0063-4400076 COI POLICIES & PROCEDURES
E1SFF3-20-8004-4100579 HANDLING OF SUPERFUND
BANKRUPTCY SETTLEMENTS
E1NMF3-15-0073-4100561 INTEGRATED FINANCIAL MANAGEMENT
SYSTEMS
E1SHG3-18-0045-4400112 EPA'S MANAGEMENT OF SUPERFUND
ERCS CONTRACTS
7/21/94
7/15/94
7/29/94
6/22/94
9/30/94
9/27/94
9/29/94
6/17/94
9/30/94
9/30/94
7/ 6/94
8/10/94
E1FMF4-19-0618-4100407 UNIVERSITY OF KANSAS KS
E6EML4-07-0023-4100581 ASBESTOS REMOVAL AT SCHOOLS
IN FAIRBURY, NE
E6EML4-07-0022-4100582 ASBESTOS REMOVAL AT SCHOOLS
IN OGALALLA, NE
E6AMG3-13-0058-4400079 NON-FEDERAL TRAVEL EXPENSE
E6AMG4-13-2059-4400093 SES TRAINING
Assistant Administrator for Research and Development
E1SKF4-02-0059-4400100 RELOCATION OF EDISON LAB'S
RESPONSIBILITY FOR MANAGEMENT
OF EXTRAMURAL INSTRUMENTS TO
CINCINNATI 8/25/94
Assistant Administrator for Solid Waste and Emergency Response
E1LLF3-09-0237-4100573 LUST - NATIVE AMERICAN LANDS 9/29/94
E1SKG3-09-0021-4400115 SUPERFUND CONTRACT LAB PROGRAM -
SUPPORT CONTRACTS
E1SFG4-11-5015-4400091 RESPONSE CLAIMS FOLLOW-UP
9/29/94
7/29/94
148,100
191,974
30,822
87,842
2,966
APRIL 1, 1994 THROUGH SEPTEMBER 30, 1994
51
-------
Questioned Costs
Assignment Control Number
Title
Final Report
Issued
Recommended
Efficiencies
Ineligible
Costs
Unsupported
Costs
Unreasonable (Funds Be Put
Costs To Better Use
Assistant Administrator Office of Enforcement and Compliance Assurance
E1GMG4-05-6009-4400107 MITIGATION OF PENALTIES FOLLOW-UP 9/15/94
Regional Administrator - Region 2
E1PMG4-02-0035-4400105 EDISON LAB UTILIZATION OF
GOVERNMENT VEHICLES
Regional Administrator - Region 3
E1SKG4-03-0122-4400059 INNOVATIVE DATA VALIDATION
E6FHG4-03-0266-4400110 REGIONAL VEHICLE USAGE
Region 3 Hazardous Waste Management Division
E1SGG3-14-0013-4400070 PALMERTON ZINC RI/FS REVIEW
Regional Administrator - Region 5
E1SFG4-05-0129-4400080 SFAI SACM THRU 1/94 - REGION 5
E1SFG4-05-0175-4400092 SFAI ALLOCATION TOOLS/MIXED
FUND - REGION 5
E1HWC4-23-0009-4100540 DRINKING WATER DATA INTEGRITY -
REGION 5
Regional Administrator - Region 6
E1SGG3-14-0015-4400094 SFAI LIGHTNING ROD RI/FS
REVIEW - REGION 6
Regional Administrator - Region 7
E1SFG4-07-0047-4400103 SUPERFUND ADMINISTRATIVE
IMPROVEMENTS - REGION 7
E6ESL3-07-0146-4100424 AUDIT OF NEBRASKA'S HAZARDOUS
WASTE GRANTS
E6ESF3-07-0146-4100476 EPA'S OVERSIGHT OF NEBRASKA'S
HAZARDOUS WASTE GRANT
Regional Administrator - Region 10
E1SGG4-06-0056-4400073 SACM - REGION 10
TOTAL INTERNAL AND MANAGEMENT ASSIGNMENTS
2. CONSTRUCTION GRANT ASSIGNMENTS
E2CWL1-01-0136-4100576 MWRA
E2CWL1-01-0067-4100577 MWRA
E2CWL2-01-0029-4100578 MASS WATER RESOURCES AUTH
TOTAL OF REGION 01 = 3
E2CWL2-02-0115-4100431 NASSAU COUNTY-PT WASHINGTON NY
E2CWM3-02-0125-4200013 DELAWARE
E2CWM3-02-0168-4200015 BINGHAMTON
E2HTP3-02-0166-4400056 STATE REVOLVING FUND
P2CWLO-02-0232-4100330 CARTERET
P2CWL3-02-0177-4100412 ONONDAGA COUNTY-LEY CREEK
P2CWL1-02-0019-4100414 CAPE MAY COUNTY MUA
P2CWN1-02-0028-4300034 OCEAN COUNTY UA
P2CWN1-02-0129-4300035 NIAGARA FALLS
TOTAL OF REGION 02 = 9
E2CWM1-03-0169-4200017 CHALFONT NEW BRITAIN TWP
P2CWM2-03-0293-4200012 ANNE ARUNDEL COUNTY
P2CWN2-03-0456-4300043 HOWARD COUNTY DPW
P2CWN1-03-0098-4300044 FAIRFAX COUNTY OF
9/ 9/94
5/10/94
9/22/94
6/16/94
7/ 7/94
7/29/94
9/30/94
8/ 4/94
IS
s
=
MA
MA
MA
NY
NY
NY
NY
NJ
NY
NJ
NJ
NY
PA
MD
MD
VA
9/ 7/94
6/24/94
8/ 8/94
6/20/94
32
9/29/94
9/29/94
9/29/94
6/27/94
4/19/94
5/11/94
5/ 3/94
5/27/94
6/21/94
6/21/94
5/ 4/94
5/17/94
7/11/94
4/ 5/94
8/23/94
8/24/94
229,425
452,221
9,821
50,109
69,994
129,924
1,294,966
199,379
116,631
0
562,082
1,038,675
517,747
2,144,016
0
5,873,496
838,177
497,541
1,160,894
2,650,367
0
0
0
0
0
0
0
99,191
0
0
2,125,053
820,808
883,511
369,956
4,298,519
11,936
321,029
206,000
564,072
90,808
0
•0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
148, 10C
C
C
C
C
C
C
C
C
C
C
(
C
C
[
(
(
t
t
52
OFFICE OF INSPECTOR GENERAL
-------
Recommended
Questioned Costs
Assignment Control Number Title
P2CWN3-03-0031 -4300045 ARLINGTON COUNTY
TOTAL OF REGION 03 = 5
E2CUM4-04-0165-4200016 HELENA
E2CWM3-04-0062-4200019 KEY WEST
E2CWP3- 04 -0225 -4400096 BRUNSWICK
TOTAL OF REGION 04 = 3
E2CWL2-23-0299-4100539 ALLOUEZ TWP
TOTAL OF REGION 23 = 1
E2CWN3-06-0089-4300052 HOUSTON
TOTAL OF REGION 06 = 1
E2CWH2-09-0203-4200014 HONOLULU/KAHALUU, CITY/CO.
E2CWM3-09-0046-4200018 CLARK CSD
E2CWM2-09-0202-4200020 CENTRAL MARIN SAN AGENCY
S2CWN2-09-0340-4300040 SAN JOAQUIN CO EAST STOCKT
S2CWN2-09-0091 -4300051 VALLEJO SAN & FLOOD CONTROL
TOTAL OF REGION 09 = 5
P2CWN3- 10-0034-4300039 NORTH BEND, CITY OF
P2CWN3-10-0055-4300049 POST FALLS, CITY OF
P2CWN4- 10-0009-4300050 TRI-CITY/CLACKAHAS COUNTY
P2CWN3-10-0141 -4300053 MUNICIPALITY OF ANCHORAGE
TOTAL OF REGION 10 = 4
TOTAL CONSTRUCTION GRANT ASSIGNMENTS
VA
AL
FL
GA
WI
TX
HI
NV
CA
CA
CA
OR
ID
OR
AK
=
Final Report
I ssued
9/ 1/94
11 8/94
9/15/94
8/10/94
9/22/94
9/29/94
4/28/94
8/24/94
9/26/94
8/ 1/94
9/29/94
6/27/94
9/26/94
9/27/94
9/29/94
31
Ineligible
Costs
1,055,887
6,202,866
15,265
560,908
417,548
993,721
430,452
430,452
4,747,066
4,747,066
79,532
107,355
698,753
158,359
4,718,744
5,762,743
32,002
0
74,903
1,987,438
2,094,343
26,234,611
Unsupported
Costs
354,861
1,457,898
0
0
0
0
232,066
232,066
743,381
743,381
0
0
0
0
0
0
49,914
39,445
15,302
11,702
116,363
6,848,227
Efficiencies
Unreasonable (Funds Be Put
Costs To Better Use)
0
0
0
0
0
0
0
0
796,517
796,517
1,977,221
0
0
0
2,905,873
4,883,094
0
0
0
0
0
5,679,611
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
3. OTHER GRANT ASSIGNMENTS
C3HVK4-01-0146-4500718 CHICOPEE, CITY OF
G3HVK4-01-0070-4500420 MASS WATER RESOURCES AUTH
G3HVK4-01-0083-4500422 MATTABASSETT DISTRICT
G3HVK4-01-0082-4500423 RI CLEAN WATER PROTECTION
G3HVK4-01-0088-4500425 YARMOUTH, TOWN OF
G3HVK4-01-0098-4500427 KENNEBUNKPORT, TOWN OF
G3HVK4-01-0105-4500531 YORK SEWER DISTRICT
G3HVK4-01-0128-4500535 YORK SEWER DISTRICT
G3HUK4-01-0131-4500643 HEALTH EFFECTS INST. ASBES
G3HVK4-01-0141-4500695 GUILFORD SANGERVILLE SANIDSTME
G3HVK4-01-0138-4500696 METRO AREA PLANNING COUNCIL MA
G3HVK4-01-0153-4500721 MAINE MUNICIPAL BOND BANK
G3HVK4-01-0154-4500722 MONTAGUE, TOWN OF
G3HVK4-01-0152-4500723 BURLINGTON, CITY OF
G3HUK4-01-0169-4500772 VERMONT LAW SCHOOL INC.
G3HVK4-01-0181-4500787 RUTLAND, CITY OF
N3HVK4-01-0075-4500421 COMMONWEALTH OF MASS
N3HUK3-01-0228-4500533 TUFTS UNIVERSITY
N3HUK3-01-0233-4500534 UNIVERSITY OF VERMONT
N3HVK4-01-0089-4500541 PORTLAND, CITY OF
N3HVK4-01-0096-4500685 PENOBSCOT INDIAN NATION
N3HVJ3-01-0196-4500686 CONNECTICUT, STATE OF
N3HVJ4-01-0013-4500687 MAINE, STATE OF
N3HUK3-01-0231-4500688 DARTMOUTH COLLEGE
N3HVK4-01-0080-4500714 NEW HAMPSHIRE, STATE OF
N3HVK4-01-0157-4500715 MALISEET INDIANS - HOULTON
N3HVK3-01-0259-4500716 MASHANTUCKET PEQUOT TRIBE
N3HVK4-01-0139-4500754 BARNSTABLE, COUNTY OF
N3HVK4-01-0184-4500773 SPRINGFIELD, CITY OF
N3HVK4-01-0155-4500785 PLEASANT POINT PASSAMAQUODDYME
TOTAL OF REGION 01 = 30
C3HVK4-02-0197-4500796
G3HVK4-02-0145-4500475
G3HVK4-02-0161-4500617
G3HVK4-02-0163-4500633
BINGHAMTON
LONG BR SEWER AUTH
LAND IS SA
INTERSTATE SAN IT COMM
G3HVK4-02-0172-4500698 OZONE TRANSP COMM
MA
MA
CT
RI
MA
ME
ME
ME
MA
FME
MA
ME
MA
VT
VT
VT
MA
MA
VT
ME
ME
CT
ME
NH
NH
ME
CT
MA
MA
'ME
NY
NJ
NJ
NY
DC
8/ 4/94
4/ 1/94
4/ 1/94
4/ 1/94
4/ 1/94
4/ 4/94
5/25/94
5/27/94
6/30/94
7/25/94
7/25/94
8/ 8/94
8/ 8/94
8/ 9/94
9/ 8/94
9/12/94
4/ 1/94
5/27/94
5/27/94
6/ 1/94
7/18/94
7/18/94
7/18/94
7/18/94
8/ 3/94
8/ 3/94
8/ 3/94
8/23/94
9/ 8/94
9/12/94
9/21/94
5/ 5/94
6/28/94
6/28/94
7/26/94
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
APRIL 1, 1994 THROUGH SEPTEMBER 30, 1994
53
-------
Questioned Costs
Recommended
Efficiencies
Assignment Control Number Title
G3HVK4-02-0184-4500753
G3HVK4-02-0189-4500756
G3HUK4-02-0192-4500757
G3HVK4-02-01 54-4500792
N3HVK3-02-011 1-4500455
N3HVK4-02-0132-4500456
N3HVK4-02-0066-4500473
N3HUK3-02-0191 -4500474
N3HVK4-02-0149-4500532
N3HVK3-02-0198-4500542
N3HUK3-02-0199-4500554
N3HVK4-02-0058-4500555
N3HVK4-02-0032-4500556
N3HVK4-02-0042-4500579
N3HVK4-02-0019-4500584
N3HUK4-02-01 10-4500591
N3HUK4-02-0025-4500602
N3HVJ4-02-0020-4500606
N3HVK4-02-0146-4500697
N3HUK4-02-0075-4500755
N3HVK4-02-0137-4500758
N3HVK4-02-0156-4500759
N3HVK4-02-01 57-4500790
TOTAL OF
C3HVK4-03-0325-4500512
C3HVK4-03-0324-4500513
D3BML4-03-0473-4100505
E3CML3-03-0201 -4100523
E3FBG4-03-0132-4400102
E3FEP3-03-0057-4400106
E3FEG3-03-0383-4400113
G3HUK4-03-0298-4500493
G3HVK4-03-0320-4500506
G3HVK4-03-0321 -4500507
G3HVK4-03-0322-4500508
G3HVK4-03-0334-4500520
G3HUK4-03-041 1-4500616
G3HVK4-03-0418-4500624
G3HUK4-03-0417-4500628
G3HVK4-03-0421 -4500632
G3HUK4-03-0428-4500639
G3HUK4-03-0429-4500640
G3HUK4-03-0430-4500641
G3HUK4-03-0445-4500690
G3HVK4-03-0446-4500691
G3HUK4-03-0447-4500692
G3HVK4-03-0448-4500693
G3HVK4-03-0484-4500778
G3HUK4-03-0488-4500781
G3HVK4-03-0493-4500788
G3HVK4-03-0486-4500789
N3HUK4-03-0270-4500457
N3HUK4-03-0271 -4500459
N3HVH3-03-0400-4500494
N3HUK4-03-0323-4500511
N3HVK4-03-0335-4500521
N3HVK4-03-0250-4500614
N3HUK4-03-0410-4500615
N3HUK4-03-0416-4500626
N3HUK4-03-0449-4500694
N3HUK4-03-0483-4500777
N3HVK4-03-0485-4500779
N3HUK4-03-0487-4500780
N3HUK4-03-0489-4500782
N3HUK4-03-0490-4500783
N3HUK4-03-0491 -4500784
N3HUK4-03-0492-4500786
N3HUK4-03-0501 -4500793
TOTAL OF
C3HVK4-04-01 28-4500440
C3HVK4-04-0107-4500461
HIGHLAND FALLS NY
INTERSTATE SAN IT COMH NY
AMERICAN LUNG ASSN NY
CAPE MAY COUNTY MUA NJ
THOMPSON NY
BURLINGTON COUNTY NJ
ERIE COUNTY NY
RUTGERS UNIV NJ
SUNY RESEARCH FOUNDATION NY
ROCKLAND COUNTY NY
MANHATTAN COLLEGE NY
WASHINGTON COUNTY NY
ONONDAGA COUNTY NY
GLOVERSVILLE NY
GLENS FALLS NY
CLARKSON UNIVERSITY NY
NYU MEDICAL CENTER NY
NEW JERSEY STATE NJ
NEW YORK STATE NY
CORNELL UNIVERSITY NY
SENECA NATION OF INDIANS NY
ELIZABETH NJ
ST REGIS MOHAWK TRIBE NY
REGION 02 = 28
BALTIMORE COUNTY MD
CARROLL COUNTY MD
CARNEGIE MELLON UNIVERSITY PA
TEMPLE UNIVERSITY PA
OSDBU-GRANT ADMINISTRATION DC
CERMA VA
EPA MONITORING OF CERMA
SOLID WASTE ASSOCIATION NA MD
WESTMINSTER MD
INTERSTATE COM POTOMAC RIVERMD
CECIL COUNTY MD
GARRETT COUNTY MD
INT. INSTITUTE ENERGY CONSERVDC
DELMONT BOROUGH PA
NAT GEOGRAPHIC SOCIETY DC
SAINT THOMAS TOWNSHIP PA
AMERICAN COUNCIL FOR ENERG DC
EARTH CONSERVANCY DC
IZAAK WALTON LEAGUE VA
SOLID WASTE ASSOCIATION NA MD
ST. MARY'S CTY. METRO. COMM.PA
MD PUBLIC BROADCASTING FOUNDDC
ALTOONA CITY AUTHORITY PA
TALBOT COUNTY MD
AMERICAN ACADEMY ENVIRONMENTDC
UPPER MONTGOMERY JOINT AUTH.PA
PETERS TOWNSHIP PA
NAT GOVERNOR'S ASSOCIATION DC
ASSOCIATION OF SCIENCE TECH DC
PHILADELPHIA CITY PA
UNIVERSITY OF DELAWARE DE
HOWARD COUNTY MD
WEST VIRGINIA STATE WV
GEORGETOWN UNIVERSITY DC
UNIVERSITY OF MARYLAND MD
TEMPLE UNIVERSITY PA
UNIVERSITY OF PITTSBURGH PA
RICHMOND CITY OF VA
NATIONAL COUNCIL OF SENIORS DC
AMERICAN ASSN. ADV. SCIENCE DC
AMERICAN ASSN. ADV. SCIENCE DC
GEORGE WASHINGTON UNIVERSITYDC
NAT. GOVERNOR'S ASSOCIATION DC
PA STATE UNIVERSITY PA
REGION 03 = 44
TAMPA FL
GREENSBORO NC
Final Report
Issued
8/22/94
8/24/94
8/25/94
9/14/94
4/15/94
4/15/94
5/ 2/94
5/ 2/94
5/25/94
6/ 6/94
6/ 9/94
6/ 9/94
6/ 9/94
6/20/94
6/20/94
6/21/94
6/22/94
6/23/94
7/26/94
8/24/94
8/26/94
8/26/94
9/14/94
5/19/94
5/19/94
8/25/94
9/15/94
8/29/94
9/12/94
9/27/94
5/12/94
5/19/94
5/19/94
5/19/94
5/20/94
6/27/94
6/28/94
6/28/94
6/28/94
6/29/94
6/29/94
6/29/94
7/25/94
7/25/94
7/25/94
7/25/94
9/12/94
9/12/94
9/12/94
9/12/94
4/15/94
4/15/94
5/12/94
5/19/94
5/20/94
6/27/94
6/27/94
6/28/94
7/25/94
9/12/94
9/12/94
9/12/94
9/12/94
9/12/94
9/12/94
9/12/94
9/16/94
4/13/94
4/15/94
Ineligible Unsupported Unreasonable (Funds Be Put
Costs Costs 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
452,725
0
87,063
0
31,905
0
15,570
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
288,810
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
876,073
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
68,346
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
69,494
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
4,763
0
96,473
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
101,236
0
0
54
OFFICE OF INSPECTOR GENERAL
-------
Recommended
Questioned Costs
Assignment Control Number Title
C3HVK4-04-01 04-4500464
C3HVK4-04-0157-4500476
C3HVK4-04-0129-4500689
C3HVK4-04-0216-4500743
C3HVK4-04-0239-4500751
E3CBP4-04-0252-4400116
G3HVK4-04-0144-4500458
G3HVK4-04-0154-4500460
G3HVK4-04-0186-4500478
G3HVK4-04-0183-4500479
G3HVK4-04-0173-4500483
G3HVK4-04-0180-4500491
G3HVK4-04-0206-4500557
G3HVK4-04-0203-4500558
G3HVK4-04-0207-4500560
G3HVK4-04-0205-4500561
G3HVK4-04-0185-4500564
G3HVK4-04-0222-4500665
G3HVK4-04-0223-4500671
G3HVK4-04-0224-4500673
G3HVK4-04-0229-4500683
G3HVK4-04-0248-4500760
G3HVK4-04-0247-4500761
G3HVK4-04-0246-4500771
N3HUK3-04-0337-4500428
N3HVK4-04-0139-4500438
N3HVK4-04-0138-4500439
N3HUK3-04-0334-4500471
N3HVK4 - 04-0047-4500472
N3HVK4-04-0184-4500477
N3HVK4-04-0178-4500482
N3HVK4-04-0179-4500492
N3HVK4-04-0190-4500509
N3HUK4-04-0126-4500510
N3HVK4-04-0140-4500568
N3HUK4-04-0142-4500569
N3HUK4-04-0212-4500588
N3HVJ4-04-0213-4500589
N3HVK4-04-0209-4500612
N3HVJ4-04-0055-4500642
N3HVK4-04-0221 -4500644
N3HVJ3-04-0333-4500645
N3HVJ3-04-0335-4500646
N3HVK4-04-0181 -4500666
N3HVK4-04-0174-4500670
N3HVK4-04-0225-4500672
N3HVK4-04-0230-4500681
N3HVK4-04-0141 -4500699
N3HVK4-04-0259-4500794
N3HVK4-04-0269-4500797
TOTAL OF
C3HVK4-05-0228-4500504
C3HVK4-05-0266-4500608
C3HVK4-05-0276-4500674
G3HVJ4-05-0200-4500468
G3HVJ4-05-0237-4500547
G3HVJ4-05-0254-4500549
G3HVJ4-05-0255-4500550
G3HVJ4-05-0253-4500551
G3HVJ4-05-0260-4500553
G3HVK4-05-0236-4500573
G3HVK4-05-0288-4500711
G3HVK4-05-0290-4500712
G3HVJ4-05-0289-4500713
G3HVK4-05-0292-4500720
G3HVK4-05-0296-4500791
N3HUJ3-05-0206-4500429
N3HVK3-05-0191 -4500430
N3HVK4-05-01 10-4500431
N3HVJ4-05-0196-4500447
N3HVJ4-05-0197-4500448
N3HVK4-05-0193-4500462
N3HVK4-05-0032-4500463
ATLANTA GA
COLUMBIA SC
JACKSONVILLE FL
FORT LAUDERDALE FL
NASHVILLE DAVIDSON COUNTY TN
REVIEW OF CA WITH NELHA- HI
JACKSONVILLE WATER WORKS GASAL
HELENA AL
BURLINGTON NC
CAMDEN TN
LINDEN TN
SANFORD FL
MIAMI -DADE WATER & SEWER DE FL
NORTH AUGUSTA SC
LUTTRELL TN
WHITE HOUSE TN
KINGSTON SPRINGS TN
ROCKWOOD WATER WASTE WATER TN
ROCKWOOD WATER WASTE WATER TN
ROCKWOOD WATER SEWER & NATURTN
KEY WEST FL
BOYD COUNTY SANITATION DIST KY
LUTTRELL TN
CONFERENCE OF RADIATION CONTKY
MISSISSIPPI MEDICAL CENTER MS
ALACHUA COUNTY FL
KNOX COUNTY TN
MEHARRY MEDICAL COLLEGE TN
FULTON COUNTY GA
COLLIER COUNTY FL
HUNTSVILLE AL
ORLANDO FL
INDIAN RIVER COUNTY FL
MIAMI UNIVERSITY OF FL
CHATTANOOGA TN
LOUISVILLE UNIVERSITY OF KY
DUKE UNIVERSITY OF NC
DEPT. OF ENVIRONMENTAL MANAGAL
FREEPORT FL
NORTH CAROLINA STATE OF NC
MONROE COUNTY FL
MISSISSIPPI STATE OF MS
TENNESSEE STATE OF TN
JAMESTOWN TN
OKALOOSA COUNTY FL
BAILEYTON TN
SEMINOLE TRIBE OF FLORIDA FL
COUNCIL OF STATE GOVERNMENTSKY
SARASOTA FL
HILLSBOROUGH COUNTY FL
REGION 04 = 52
SPRINGFIELD FY 93 IL
LANSING FY 93 MI
GRAND RAPIDS FY 93 MI
INDIANA DEM FY 92 IN
MARKLE FY 91/92 IN
NEW CHICAGO FY 91/92 IN
GLENVILLE FY 93 MN
BURNETTSVILLE FY 92/93 IN
BROWNSDALE FY 93 MN
ILLINOIS DNS FY 92/93 IL
LYLE FY 93 MN
MN RWA FY 93 MN
SMITH-GREEN CSC FY 92/93 IN
CLEVELAND NEORSD FY 93 OH
CALUMET CTUP FY 93 MI
OHIO U OF FY 92 OH
MARIETTA FY 91 OH
WAYNE CO FY 92 MI
JONATHAN ALDER LSD FY 92 OH
PERRY LSD FY 92 OH
CHIPPEWA I NO MLB FY 92 MN
CHIPPEWA I NO RLB FY 92 MN
Final Report
Issued
4/19/94
5/ 6/94
7/21/94
8/11/94
8/18/94
9/29/94
4/15/94
4/15/94
5/10/94
5/10/94
5/10/94
5/11/94
6/ 9/94
6/ 9/94
6/ 9/94
6/ 9/94
6/10/94
71 5/94
71 7/94
71 7/94
7/14/94
8/29/94
8/29/94
9/ 7/94
4/ 5/94
4/13/94
4/13/94
4/29/94
4/29/94
5/ 6/94
5/10/94
5/11/94
5/19/94
5/19/94
6/10/94
6/13/94
6/21/94
6/21/94
6/24/94
6/29/94
6/30/94
6/30/94
6/30/94
71 5/94
71 7/94
71 7/94
7/13/94
7/26/94
9/19/94
9/30/94
5/16/94
6/23/94
7/13/94
4/25/94
6/ 6/94
6/ 6/94
6/ 6/94
6/ 7/94
6/ 8/94
6/17/94
8/ 2/94
8/ 2/94
8/ 2/94
8/ 8/94
9/14/94
4/ 5/94
4/ 5/94
4/ 5/94
4/14/94
4/14/94
4/18/94
4/19/94
I ne I i g i b I e
Costs
0
0
0
0
0
12,690
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
12,690
0
0
0
32,024
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
Efficiencies
Unsupported Unreasonable (Funds Be Put
Costs 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
37,195
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
c
APRIL 1, 1994 THROUGH SEPTEMBER 30, 1994
55
-------
Questioned Costs
Recommended
Efficiencies
Assignment Control Number Title
N3HUK3-05-0271 -4500467
N3HUK4-05-0122-4500469
N3HVK3-05-0270-4500470
N3HVJ3-05-0337-4500505
N3HVJ4-05-0185-4500518
N3HVJ4-05-0245-4500528
N3HVK3-05-0269-4500529
N3HVK3-05-0254-4500530
N3HUK4-05-0194-4500570
N3HVK4-05-0235-4500571
N3HVK3-05-0295-4500572
N3HVK3-05-0325-4500574
N3HVK3-05-0360-4500575
N3HVK3-05-0356-4500576
N3HVJ3-05-0305-4500577
N3HVK3-05-0351 -4500578
N3HUK3-05-0304-4500580
N3HVJ3-05-0296-4500581
N3HVK3-05-0352-4500582
N3HVK3-05-0324-4500583
N3HVJ3-05-0363-4500585
N3HUK3-05-0388-4500586
N3HVK3-05-0260-4500587
N3HUK3-05-0318-4500590
N3HUK3-05-0372-4500592
N3HVK4-05-0234-4500595
N3HUK3-05-0370-4500603
N3HVJ3-05-0253-4500607
N3HVJ4-05-0034-4500618
N3HVJ4-05-0024-4500619
N3HVJ4-05-0035-4500620
N3HUK4-05-0163-4500621
N3HUK3-05-0387-4500622
N3HVK3- 05 - 0248-4500623
N3HUK3-05-0346-4500625
N3HVK3-05-0310-4500627
N3HVK3-05-0365-4500629
N3HVK3-05-0326-4500630
N3HUK3-05-0246-4500631
N3HVJ4-05-0083-4500634
N3HUK4-05-0084-4500635
N3HVJ4-05-0060-4500636
N3HUJ4-05-0045-4500637
N3HUK4-05-0042-4500638
N3HVJ3-05-0251 -4500675
N3HVK4-05-01 03-4500700
N3HVK4-05-011 1-4500704
N3HUK4-05-0085-4500705
N3HVK4-05-0041 -4500706
N3HVK4-05-0104-4500707
N3HVJ4-05-0077-4500708
N3HVK4-05-0062-4500709
N3HVJ4-05-0033-4500710
TOTAL OF
C3HVK4-06-0120-4500669
C3HVK4-06-0165-4500774
G3HVK4-06-0107-4500544
G3HVK4-06-0105-4500545
G3HVK4-06-0104-4500546
G3HVK4-06-01 15-4500598
G3HVK4-06-01 18-4500667
G3HVK4-06-01 19-4500668
G3HVK4-06-0148-4500742
G3HVK4-06-0155-4500744
G3HVK4-06-0153-4500745
G3HVK4-06-0154-4500746
G3HEK4-06-0156-4500748
N3HVK4-06-0095-4500449
N3HUK4-06-0096-4500465
N3HVK4-06-0108-4500543
N3HVK4-06-0113-4500596
N3HVK4-06-01 14-4500597
N3HVK4-06-0117-4500653
MICHIGAN ST U FY 92
MICHIGAN ST U FY 93
MICHIGAN ST U FY 91
OHIO ST OF FY 92
WISCONSIN ST OF FY 92
UNITED LSD FY 92
MARIETTA FY 90
MONROE CO DC FY 92
LOYOLA U FY 93
ILLINOIS DPH FY 92/93
ILLINOIS DOC FY 91/92
NORWALK FY 90
WHITE EARTH RESERV FY 91
KEWEENAW BAY 1C FY 92
MARIETTA FY 89
CHICAGO HA FY 91
DAYTON U OF FY 91
CLARK CO FY 91
NEWARK FY 92
CHIPPEWA TRIBE FY 92
INDIANA DOH FY 92
DAYTON U FY 92
WARREN FY 91
MICHIGAN U OF FY 91/92
ILLINOIS U OF FY 91/92
COLUMBUS FY 93
LOYOLA U FY 91/92
MACOG FY 92
S BEND FY 92
SUMMIT CO FY 91
ELKHART FY 92
MICHIGAN TECH U FY 93
OAKLAND U FY 92
DEARBORN HEIGHTS FY 92
NOTRE DAME U FY 92
N HOUGHTON CWS FY 92
MENOMINEE TRIBE FY 92
NORWALK FY 91
WRIGHT ST U FY 91
LOUDON-PERRYVILLE CSD FY 92
NORTHWESTERN U FY 89
LEECH LAKE RES FY 92
NE OHIO U FY 92
CLEVELAND ST U FY 91/92
YOUNGSTOWN FY 90
GARDEN CITY FY 93
BATTLE CREEK FY 92/93
WISCONSIN MED COLL FY 93
CLEVELAND FY 92
CHICAGO FY 92
LAKE STATION FY 92
AMA FY 92
BLOOMINGTON FY 91
REGION 05 = 75
SHREVEPORT
SAN ANTONIO
OAK MANOR MUD
MI
MI
MI
OH
WI
OH
OH
MI
IL
IL
IL
OH
MN
MI
OH
IL
OH
OH
OH
MN
IN
OH
OH
MI
IL
OH
IL
IN
IN
OH
IN
MI
MI
MI
IN
MI
WI
OH
OH
OH
IL
MN
OH
OH
OH
MI
MI
WI
OH
IL
IN
IL
IN
LA
TX
TX
NEW MEXICO ENVIRONMENT DEPARNM
NEW MEXICO ENVIRONMENT DEPT
DERIDDER
SEYMOUR
BLOOMING GROVE
SANTA FE
SEYMOUR
ROCKSPRINGS
ROCKSPRINGS
NM
LA
TX
TX
NM
TX
TX
TX
SOUTHWEST RESEARCH & INFORMATX
CLEBURNE
OKLAHOMA STATE UNIVERSITY
DALLAS
OSAGE NATION
TX
OK
TX
OK
TERREBONNE PARISH CONS. GOVTLA
PUEBLO OF ACOMA
NM
Final Report
I ssued
4/25/94
4/26/94
4/26/94
5/18/94
5/19/94
5/23/94
5/24/94
5/24/94
6/13/94
6/13/94
6/17/94
6/17/94
6/17/94
6/17/94
6/17/94
6/17/94
6/20/94
6/20/94
6/20/94
6/20/94
6/21/94
6/21/94
6/21/94
6/21/94
6/21/94
6/21/94
6/22/94
6/23/94
6/28/94
6/28/94
6/28/94
6/28/94
6/28/94
6/28/94
6/28/94
6/28/94
6/28/94
6/28/94
6/28/94
6/28/94
6/28/94
6/28/94
6/28/94
6/28/94
7/13/94
7/28/94
7/28/94
7/28/94
7/28/94
7/28/94
7/28/94
7/28/94
8/ 1/94
11 6/94
9/12/94
6/ 6/94
6/ 6/94
6/ 6/94
6/22/94
11 6/94
11 6/94
8/11/94
8/12/94
8/12/94
8/12/94
8/12/94
4/14/94
4/21/94
6/ 6/94
6/22/94
6/22/94
11 5/94
Ineligible Unsupported Unreasonable (Funds Be Put
Costs Costs 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
143,394
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
175,418
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
37,195
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
c
c
c
c
c
c
c
c
c
c
c
c
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
56
OFFICE OF INSPECTOR GENERAL
-------
Recommended
Questioned Costs
Assiqnment Control Number Title
N3HUK4-06-0131 -4500724
N3HVK4-06-0132-4500725
N3HVK4-06-0133-4500726
N3HVK4-06-0134-4500727
N3HVK4-06-0135-4500728
N3HVK4-06-0136-4500729
N3HVK4-06-0137-4500730
N3HUJ4-06-0138-4500731
N3HUJ4-06-0139-4500732
N3HVK4-06-0140-4500733
N3HUK4-06-0141 -4500734
N3HUK4-06-0141 -4500735
N3HVK4-06-0143-4500736
N3HVJ4-06-0144-4500737
N3HVK4-06-0145-4500738
N3HVK4-06-0149-4500739
N3HVK4-06-0146-4500740
N3HVK4-06-0147-4500741
N3HUJ4-06-0152-4500747
N3HVK4-06-0163-4500764
N3HVJ4-06-0161 -4500765
N3HVK4-06-0160-4500766
N3HVK4-06-0159-4500767
N3HVK4-06-0167-4500775
N3HVK4-06-0166-4500776
TOTAL OF
C3HVK4-07-0070-4500655
G3HVK4-07-0062-4500498
G3HVK4-07-0063-4500552
G3HVK3-07-0138-4500719
N3HVK4-07-0049-4500426
N3HVK4-07-0054-4500466
N3HVK4-07-0064-4500497
N3HVK4-07-0055-4500609
N3HVK4-07-0069-4500610
N3HVK4-07-0051 -4500651
N3HVK4-07-0038-4500659
N3HVK4-07-0045-4500664
.N3HVK4-07-0071 -4500684
TOTAL OF
E3CBL3-08-0088-4100497
G3HVJ3-08-0098-4500418
G3HVJ3-08-0091 -4500419
G3HVJ4-08-0021 -4500424
G3HVJ4-08-0050-4500611
G3HVK4-08-0055-4500676
N3HVJ3-08-01 16-4500496
N3HVK4-08-0043-4500503
N3HVK4-08-0042-4500593
N3HVK4-08-0024-4500594
N3HVK4-08-0059-4500652
N3HVK4-08-0058-4500654
N3HVK4-08-0026-4500656
N3HVK4-08-0027-4500657
N3HUK4-08-0046-4500658
N3HVK4-08-0039-4500660
N3HVK4-08-0051 -4500661
N3HVK4-08-0052-4500662
N3HVJ4-08-0049-4500663
TOTAL OF
C3HVK4-09-0125-4500647
G3HVK4-09-0124-4500432
G3HVK3-09-0235-4500436
G3HUK3 09-0221-4500437
G3HVK3-OV-0207-4500444
G3HUK4-09-0131 -4500484
G3riUK4-09-0156-4500485
G3HVK4-09-0079-4500487
G3HVK4-09-0205-4500650
RICE UNIVERSITY TX
DALLAS CITY OF TX
GALVESTON CITY HEALTH DISTRITX
PUEBLO OF SANDIA NM
EIGHT NORTHERN INDIAN PUESLONM
JEFFERSON PARISH LA
OGLALA SIOUX TRIBE NM
ARKANSAS UNIVERSITY OF AR
ARKANSAS UNIVERSITY OF AR
ARK- TEX COG AR
OKLAHOMA UNIVERSITY OF OK
OKLAHOMA UNIVERSITY OF OK
NEW MEXICO DEPT OF ENERGY NM
LOUISIANA STATE OF LA
COASTAL BEND COG TX
CENTRAL TEXAS COG TX
EL PASO TX
FORT WORTH TX
NEW MEXICO UNIVERSITY OF NM
TEXOMA TX
ARKANASAS DEPT. OF HEALTH AR
PUEBLO OF ISSLETA NM
PUEBLO OF POJOAQUE NM
TAOS PUEBLO NM
SANTA CLARA INDIAN PUEBLO NM
REGION 06 = 44
KANSAS CITY KS
NEVADA I A
CHELSEA IA
PUXICO MO
LINCOLN NE
ST. LOUIS MO
JOPLIN MO
POLK COUNTY IA
KANSAS CITY MO
KANSAS KS
WYANDOTTE COUNTY KS
SO CENT OZARK COUNCIL OF GOVMO
UNIV OF MISSOURI - SYSTEM MO
REGION 07 = 13
MONTANA STATE UNIVERSITY MT
KAYCEE WY
KAYCEE WY
MILNOR ND
WEST FARGO ND
WY OIL & GAS CONS. COMM. WY
COLORADO CO
DENVER REG COUNCIL OF GOVTS CO
GREAT FALLS MT
TURTLE MTN BAND CHIPPEWA INDND
CITY OF WESTMINSTER CO
LOWER BRULE SIOUX TRIBE SD
OGLALA SIOUX TRIBE SD
OGLALA SIOUX TRIBE SD
UNIV OF DENVER (CO SEMINARY)CO
UTE INDIAN TRIBE UT
AM INDIAN SCIENCE & ENG SOC
CONFED SALISH & KOOTENIA TRBMT
BRIDGER MT
REGION 08 = 19
LAS VEGAS, CITY OF NV
TUCSON, CITY OF AZ
HAWAII, DEPT OF HEALTH HI
CALIF PUBLIC HLTH FOUND. CA
CLARK COUNTY NV
NATURAL HERITAGE, INST FOR CA
CALIF AGAINST WASTE FOUND CA
KAUAI, COUNTY OF HI
SAN JOAQUIN VLYWIDE AIR POL CA
Final Report
Issued
8/ 9/94
8/ 9/94
8/ 9/94
8/ 9/94
8/ 9/94
8/ 9/94
8/ 9/94
8/ 9/94
8/ 9/94
8/ 9/94
8/ 9/94
8/ 9/94
8/ 9/94
8/10/94
8/10/94
8/11/94
8/11/94
8/11/94
8/12/94
8/31/94
8/31/94
8/31/94
8/31/94
9/12/94
9/12/94
71 5/94
5/13/94
6/ 8/94
8/ 5/94
4/ 1/94
4/22/94
5/13/94
6/24/94
6/24/94
71 1/94
71 5/94
71 5/94
7/15/94
8/23/94
4/ 1/94
4/ 1/94
4/ 1/94
6/24/94
7/13/94
5/13/94
5/16/94
6/21/94
6/21/94
71 5/94
71 5/94
71 5/94
71 5/94
71 5/94
71 5/94
71 5/94
71 5/94
71 5/94
6/30/94
4/ 8/94
4/12/94
4/12/94
4/13/94
5/10/94
5/10/94
5/11/94
6/30/94
Efficiencies
Ineligible Unsupported Unreasonable (Funds Be Put
Costs Costs 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
150,072
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
150,072
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
Q
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
APRIL 1, 1994 THROUGH SEPTEMBER 30, 1994
57
-------
Questioned Costs
Recommended
Efficiencies
Assignment Control Number Title
G3HVK4-09-0204-4500702
G3HVK4-09-0203-4500703
N3HVK4-09-0139-4500441
N3HVK4-09-0140-4500442
N3HVK4-09-01 26-4500443
N3HVK4-09-0138-4500450
N3HVK4-09-0137-4500451
N3HVK4-09-0136-4500452
N3HVK4-09-0160-4500480
N3HVK4-09-0074-4500486
N3HVJ3-09-0066-4500495
N3HVJ3-09-0264-4500516
N3HVK4-09-0163-4500517
N3HVJ3-09-0225-4500519
N3HVK4-09-0174-4500522
N3HVK4-09-01 75-4500523
N3HVK4-09-0176-4500524
N3HVK4-09-0177-4500525
N3HU<4-09-0129-4500559
N3HVK4-09-0187-4500563
N3HVK4-09-0158-4500565
N3HVK4-09-0159-4500566
N3HVK4-09-0073-4500567
N3HVK4-09-0072-4500599
N3HVK4-09-0201 -4500613
N3HVK4-09-0206-4500648
N3HVK4-09-0188-4500649
N3HVK4-09-0168-4500677
N3HVK4-09-0208-4500678
N3HVK4-09-0054-4500679
N3HUK4-09-01 78-4500680
N3HVJ4-09-01 55-4500749
N3HVK4-09-0166-4500750
N3HVK4-09-0157-4500752
N3HVK4-09-0210-4500762
N3HVK4-09-021 2-4500763
N3HV<4-09-0179-4500770
N3HVK4-09-021 1-4500795
TOTAL OF
E3NLB3-10-0151-4100563
G3HVK3-10-0126-4500417
G3HVJ4-10-0004-4500435
G3HVJ3-10-0136-4500445
G3HVJ4- 10-0059-4500499
G3HVJ4-10-0064-4500500
G3HVJ4-10-0013-4500502
G3HVJ4-10-0011-4500526
G3HVK4- 10-0086-4500537
G3HVK4-10-0085-4500538
G3HUK3-10-0160-4500539
G3HUX3- 10-0161 -4500540
G3HVK4-10-0123-4500600
G3HVK3-10-0167-4500605
G3HVJ4-10-0127-4500701
N3HVK3-10-0128-4500433
N3HV<3-10-0129-4500446
N3HVK3-10-0150-4500453
N3HVK3-10-0130-4500454
N3HVK4-10-0058-4500481
N3HVK4- 10-0033-4500488
N3HVK3-10-0152-4500489
N3HVK4-10-0035-4500490
N3HVK4-10-0034-4500501
N3HVK3-10-0135-4500515
N3HVK4-10-0102-4500536
N3HVK3- 10-01 74-4500562
N3HVK4-10-0106-4500604
N3HV<4-10-0110-4500682
N3HVK4-10-0091-4500768
N3HVJ4-10-0137-4500769
SOUTH COAST AIR QTY MGMT DISCA
SAN JOAQUIN VALLEY UAPC DISTCA
SAN LUIS OBISPO, COUNTY OF CA
SAN JOAQUIN, COUNTY OF CA
PHOENIX, CITY OF AZ
SACRAMENTO, COUNTY OF CA
ASSN MONTEREY BAY AREA GOV CA
SANTA CRUZ, COUNTY OF CA
SAN DIEGO ASSN OF GOVTS CA
HOOPA VALLEY TRIBE CA
CALIFORNIA, STATE OF CA
MARICOPA COUNTY AZ
•CAMPO BAND OF MISSION IND CA
MARICOPA COUNTY AZ
VENTURA, COUNTY OF CA
MARIN, COUNTY OF CA
KERN, COUNTY OF CA
MONTEREY, COUNTY OF CA
STANFORD UNIVERSITY CA
SAN BUENAVENTURA, CITY OF CA
COCOPAH INDIAN TRIBE AZ
COCOPAH INDIAN TRIBE AZ
COCOPAH INDIAN TRIBE AZ
COCOPAH INDIAN TRIBE AZ
GILA RIVER INDIAN COMMM. AZ
ORANGE, COUNTY OF CA
PLUMAS CO COMM DEV COMM CA
SHASTA, COUNTY OF CA
SAN FRANCISCO, CITY & COUNTYCA
MORONGO BAND OF MISSION IND CA
ASSOCIATION NACIONAL PRO PERCA
CALIFORNIA, STATE OF CA
GUAM, GOVERNMENT OF FM
HAWAII, DEPT OF AGRICULTURE HI
CU OF NO MARIANA ISLANDS MP
CW OF NO MARIANA ISLANDS MP
PALAU, REPUBLIC OF PW
PALAU, REPUBLIC OF PW
REGION 09 = 47
LUST- IDAHO ID
POCATELLO, CITY OF ID
CLARK COUNTY WA
SEATTLE, CITY OF WA
TACOMA, CITY OF WA
SPOKANE COUNTY WA
KING COUNTY WA
OLYMPIA, CITY OF WA
METRO WASTEWATER MGT COMM OR
METRO WASTEWATER MGT COMM OR
NORTHWEST RENEW RES CTR WA
NORTHWEST RENEW RES CTR WA
SPRINGFIELD, CITY OF OR
NESKOWIN REG SANITARY AUTH OR
SOUTH CLE ELUM, TOWN OF WA
IDAHO OFFC. OF THE GOVERNOR ID
JAMESTOWN S'KLALLAM IND TRB.WA
POINT NO POINT TREATY COUN. WA
BOISE CITY ID
LUMMI INDIAN BUSINESS COUN. WA
STILLAGUAMISH INDIAN TRIBE WA
SPOKANE TRIBE OF INDIANS WA
SPOKANE TRIBE OF INDIANS WA
HOH INDIAN TRIBE WA
CONFED TRIBES WARM SPRS. RE OR
COLUMBIA RIVER I/T FISH COM OR
QUILEUTE TRIBAL COUNCIL WA
SKOKOMISH INDIAN TRIBE WA
MARION COUNTY OR
CON TRIBES YAKIMA IND NATIONWA
IDAHO DEPT HLTH & WELFARE ID
Final Report
Issued
7/28/94
7/28/94
4/13/94
4/13/94
4/13/94
4/14/94
4/14/94
4/14/94
5/10/94
5/11/94
5/12/94
5/19/94
5/19/94
5/19/94
5/20/94
5/20/94
5/20/94
5/20/94
6/ 9/94
6/ 9/94
6/10/94
6/10/94
6/10/94
6/22/94
6/24/94
6/30/94
6/30/94
7/13/94
7/13/94
7/13/94
7/13/94
8/18/94
8/18/94
8/19/94
8/30/94
8/30/94
9/ 1/94
9/20/94
9/28/94
4/ 1/94
4/12/94
4/13/94
5/13/94
5/13/94
5/13/94
5/20/94
5/31/94
5/31/94
5/31/94
5/31/94
6/22/94
6/22/94
7/28/94
4/12/94
4/13/94
4/14/94
4/14/94
5/10/94
5/11/94
5/11/94
5/11/94
5/13/94
5/19/94
5/31/94
6/ 9/94
6/22/94
7/13/94
9/ 1/94
9/ 1/94
Ineligible Unsupported Unreasonable (Funds Be Pu
Costs Costs Costs To Better Us
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
230
0
0
0
0
0
0
0
0
178,256
3,037
49,832
71,701
42,424
15,541
361,021
0
0
0
0
0
0
0
0
0
0
0
0
0
1,525
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
TOTAL OF REGION 10 = 31
1,525
58
OFFICE OF INSPECTOR GENERAL
-------
Assignment Control Number
Title
Questioned Costs
Recommended
Efficiencies
Final Report Ineligible Unsupported Unreasonable (Funds Be Put
Issued Costs Costs Costs To Better Use)
TOTAL OTHER GRANT ASSIGNMENTS
= 383
1,576,799
106,689
101,236
5. SUPERFUND GRANT ASSIGNMENTS
E5BGL4-04-0097-4100496 GEORGIA DEPT. NATURAL RES. GA
TOTAL OF REGION 04 = 1
E5FGF4-05-0138-4100488 CA MN RITARI R5
E5FGT4-05-0138-4400061 CA RITARI PROCUREMENT MN
E5FGS4-05-0261-4400111 CA'S ILLINOIS CORE PROGRAM R5
TOTAL OF REGION 05 = 3
E5DGL4-09-0202-4100530 ARIZONA DEQ I/C 1990 & 1991 AZ
TOTAL OF REGION 09 = 1
H5BFL4-11-0033-4100509 SF FIN ACT AT NIEHS FY92
H5BFL4-11-0034-4100514 SF FIN ACTIVITIES AT ATSDR92
M5BFL4-11-0032-4100508 FY92 SF ACTIVITIES USCG AUD
TOTAL OF HDQ - HAD AUDITS = 3
8/22/94
8/15/94
5/13/94
9/23/94
9/21/94
8/26/94
8/31/94
8/26/94
239,853
239,853
0
0
0
0
0
0
0
0
0
24,748
24,748
0
0
0
0
0
0
0
0
0
TOTAL SUPERFUND GRANT ASSIGNMENTS
239,853
24,748
8. OTHER CONTRACT ASSIGNMENTS
D8AML4-01 -0085-4100247
D8BPL2-01 -0294-4100261
D8AML4-01-0118-4100331
D8AML4-01 -0122-4100428
D8AML4-01 -0129-4100429
D8DML4-01 -0149-4100437
D8DML3-01 -0106-4100458
D8DML4-01 -0166-4100465
D8CML4-01 -0164-4100466
E8AZP4-01 -0094-4400054
EASTERN RESEARCH GROUP
ABT ASSOCIATES, INC.
EASTERN RESEARCH GROUP
INDUSTRIAL ECONOMICS INC.
ARTHUR D. LITTLE
ABB COMBUSTION ENGINEERING
SIGMA RESEARCH CORPORATION
ABB ENVIRONMENTAL SERVICES
ARTHUR D. LITTLE INC.
TRC PREAwARD SUBK TO SAIC
MA
MA
MA
MA
MA
CT
MA
ME
MA
4/13/94
4/25/94
5/27/94
6/27/94
6/27/94
6/30/94
7/18/94
7/27/94
7/27/94
4/26/94
TOTAL OF REGION 01 = 10
D8DML4-02-0115-4100248
D8DML4-02-0131 -4100258
D8DML4-02-0003-4100259
D8CML3-02-0124-4100260
D8DML4-02-0030-4100332
D8AML4-02-0139-4100430
D8CML4-02-0051 -4100454
D8EML4-02-0167-4100455
D8EML4-02-0165-4100456
D8DML4-02-0023-4100457
D8EML4-02-0164-4100459
D8EML4-02-0166-4100461
D8DML4-02-0182-4100475
D8CML4-02-0037-4100501
D8DML4-02-0186-4100516
E8AZP4-02-0094-4400058
E8AXP4-02-0127-4400063
E8AXP4-02-0103-4400071
TOTAL OF
D8AML4-03-0213-4100274
D8AML4-03-0215-4100275
D8AML4-03-0153-4100276
D8AML4-03-0214-4100277
D8AML4-03-0212-4100278
D8AML4-03-0087-41 00280
D8AML4-03-0086-4100281
D8AWL3-03-0449-41 00282
08AML4-03-0126-4100284
FOSTER WHEELER CORPORATION
ACRES INTERNATIONAL CORP
TAMS CONSULTANTS INC.
SYRACUSE RESEARCH CORP
SYRACUSE RESEARCH
ENSERCH ENVIRONMENTAL CORP.
SYRACUSE RESEARCH CORP.
SYRACUSE RESEARCH CORP.
SYRACUSE RESEARCH CORP.
CAMRODEN ASSOCIATES INC.
SYRACUSE RESEARCH CORP.
SYRACUSE RESEARCH CORP
CORNELL UNIVERSITY FY 93
EXXON RESEARCH & ENG.
MALCOLM PIRNIE INC.
ECOLOGY & ENVIR
ECOLOGY & ENVIR
ECOLOGY & ENVIR
REGION 02 = 18
VERSAR
ENERGETICS INC.
LABAT ANDERSON
NJ
NY
NY
NY
NY
NJ
NY
NY
NY
NY
NY
NY
NY
NJ
NY
NY
NY
NY
VA
MD
VA
SCIENCE AND POLICY ASSOCIATEDC
LABAT ANDERSON
SCIENCES INTERNATIONAL
TECHNOLOGY APPLICATIONS
RCG/HAGLER, BAILEY
GANNETT FLEMING
VA
VA
VA
VA
MD
4/13/94
4/25/94
4/25/94
4/25/94
5/27/94
6/27/94
7/18/94
7/18/94
7/18/94
7/18/94
7/18/94
7/19/94
8/ 8/94
8/24/94
9/ 8/94
5/ 5/94
5/20/94
6/16/94
5/10/94
5/10/94
5/10/94
5/10/94
5/10/94
5/16/94
5/16/94
5/16/94
5/16/94
*The dollar value of contract audits have not been shown.
Public disclosure of the dollar value of financial recom-
mendations could prematurely reveal the Government's
negotiating positions or release of this information is
not routinely available under the Freedom of Information
Act. The number of these reports and dollar value of the
findings have been included in the aggregate data displayed
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.
APRIL 1, 1994 THROUGH SEPTEMBER 30, 1994
59
-------
Assignment Control Number Title
D8AML4-03-0151 -4100285
D8AML4-03-0185-41 00287
D8AML4-03-0184-41 00289
D8AML4-03-021 1-4100290
D8AML4-03-0210-4100291
D8EML4-03-01 17-4100294
D8BML4-03-0308-4100298
D8BML4-03-0309-4100300
D8EML4-03-0310-4100301
D8EHL4-03-0313-4100303
D8EML4-03-0312-4100304
D8EML4-03-0314-4100305
D8EML4-03-0315-4100306
D8EML4-03-0316-4100307
D8AML4-03-0267-4100312
D8BML4-03-0327-4100313
D8BML4-03-0329-4100315
D8EML4-03-0330-4100316
D8EML4-03-0331 -4100317
D8BML4-03-0326-4100318
D8EML4-03-0332-4100319
D8DML4-03-0333-41 00320
D8EML4-03-0318-4100321
D8BML4-03-0319-4100322
D8EML4-03-0355-4100335
D8EML4-03-0354-4100336
D8EML4-03-0351 -4100338
D8CML4-03-0075-4100339
D8BML2-03-0276-4100340
D8BML4-03-0350-4100341
D8BML4-03-0346-4100342
D8BML4-03-0345-4100343
D8EML4-03-0344-4100344
D8EML4-03-0343-4100345
D8CAL3-03-0213-4100346
D8CML4-03-0342-41 00347
D8CML4-03-0341 -4100348
D8DML4-03-0340-4100349
D8BML4-03-0337-4100350
D8BML2-03-0148-4100351
D8AML4-03-0280-4100355
D8AUL4-03-0297-4100359
D8AML4-03-0278-41 00360
D8CAL4-03-0016-4100361
D8EML4-03-0348-4100363
D8BML3-03-0442-41 00366
D8BML4-03-0367-41 00367
D8BML4-03-0095-4100368
D8BML2-03-0413-4100369
D8AML4-03-0366-4100370
D8CAL3-03-0284-41 00375
D8CBL4-03-0089-41 00376
D8BML4-03-0356-41 00380
D8EML4-03-0357-4100381
D8EML4-03-0358-4100382
D8BML4-03-0349-4100383
D8BML4-03-0347-4100384
D8EML4-03-0360-4100385
D8CBL3-03-0357-4100386
D8CPL3- 03 -021 2-41 00388
D8BML4-03-0096-41 00390
D8BML2-03-0180-4100391
D8AML4-03-0272-41 00399
D8AML4-03-0296-4100405
D8BML3-03-0153-4100416
D8BML4-03-0420-4100432
D8BML4-03-0419-4100433
D8AML4-03-0282-4100434
D8AML4-03-0281 -4100438
D8BML4-03-0082-4100445
D8ABL4-03-0301 -4100446
D8AML2-03-0419-4100448
D8AAL2-03-0427-4100449
D8AML4-03-0299-4100450
D8ABL4-03-0300-4100451
DYNAMAC MD
VI CYAN VA
GEOLOGICS CORPORATION MD
AVANTI CORPORATION VA
SCIENCES INTERNATIONAL INC. VA
PACIFIC ENVIRONMENTAL SERV. VA
VERSAR VA
AMERICAN MANAGEMENT SYSTEMS VA
AMERICAN MANAGEMENT SYSTEMS VA
RESOLVE, INCORPORATED DC
RESOLVE, INCORPORATED DC
RESOLVE, INCORPORATED DC
RESOLVE, INCORPORATED DC
KENNEDY KRIEGER RESEARCH MD
BIONETICS VA
GEOMET TECHNOLOGIES, INC. MD
NAHB NATIONAL RESEARCH MD
ARTHUR D. LITTLE, INC. MA
COMPUTER SCIENCE CORP. VA
MAXIMA CORPORATION MD
COMPUTER SCIENCE CORP. VA
COMPUTER SCIENCE CORP. VA
VERSAR VA
EG&G WASHINGTON ANALYTICAL MD
COMPUTER SCIENCE CORP. VA
COMPUTER SCIENCE CORP. VA
SCIENCES INTERNATIONAL, INC.VA
PROGRAM RESOURCES, INC. VA
S. COHEN AND ASSOCIATES VA
EG&G WASHINGTON ANALYTICAL MD
COMPUTER SCIENCE CORP. VA
PRC, INC. VA
BRUCE COMPANY DC
RCG/HAGLER,BAILLY, INC. VA
DYNAMAC MD
INTERNATIONAL BUSINESS SERV.VA
INTERNATIONAL BUSINESS SERV.VA
COMPUTER SCIENCE CORP. VA
LABAT-ANDERSON, INC. VA
TECHNOLOGY APPLICATIONS INC VA
COASTAL ENVIRONMENTAL MD
VI CYAN VA
GANNETT FLEMING PA
TECHNICAL RESOURCES, INC. MD
SCIENCE AND POLICY ASSOCIATEDC
COMPUTER BASED SYSTEMS, INC.VA
DIVERSIFIED TECHNOLOGY VA
TECHNOLOGY APPLICATIONS, INC VA
LABAT-ANDERSON, INC VA
PROJECT PERFORMANCE CORP. VA
DYNAMAC MD
DYNAMAC MD
COMPUTER SCIENCE CORP. VA
GEOLOGICS CORPORATION MD
HUGHES STX CORPORATION MD
EG&G WASHINGTON ANALYTICAL MD
COMPUTER SCIENCE CORP. VA
VERSAR
VIAR VA
DYNAMAC MD
RCG INTERNATIONAL VA
SRA TECHNOLOGIES VA
BIOLOGICAL ASSOCIATES MD
WASTE POLICY INSTITUTE VA
S. COHEN AND ASSOCIATES VA
UNISYS CA
UNISYS CA
RMC ENVIRONMENTAL SERVICE PA
GREELEY-POLHEMUS GROUP PA
IRVING BURTON VA
UNIVERSAL SYSTEMS VA
PERRIN QUARLES ASSOCIATES
PERRIN QUARLES ASSOCIATES VA
VERSAR VA
VERSAR VA
Final Report
Issued
5/16/94
5/16/94
5/16/94
5/16/94
5/16/94
5/18/94
5/18/94
5/18/94
5/18/94
5/18/94
5/18/94
5/18/94
5/18/94
5/18/94
5/23/94
5/23/94
5/23/94
5/23/94
5/23/94
5/23/94
5/23/94
5/23/94
5/23/94
5/23/94
6/ 1/94
6/ 1/94
6/ 1/94
6/ 1/94
6/ 1/94
6/ 1/94
6/ 1/94
6/ 1/94
6/ 1/94
6/ 1/94
6/ 1/94
6/ 1/94
6/ 1/94
6/ 1/94
6/ 1/94
6/ 1/94
6/ 1/94
6/ 7/94
6/ 7/94
6/ 7/94
6/ 7/94
6/ 7/94
6/ 7/94
6/ 7/94
6/ 7/94
6/ 7/94
6/ 7/94
6/ 7/94
6/ 8/94
6/ 8/94
6/ 8/94
6/ 8/94
6/ 8/94
6/ 8/94
6/ 8/94
6/ 8/94
6/ 8/94
6/ 8/94
6/13/94
6/14/94
6/22/94
6/28/94
6/28/94
6/28/94
6/30/94
7/14/94
7/14/94
7/14/94
7/14/94
7/14/94
7/14/94
Recommended
Questioned Costs Efficiencies
Ineligible Unsupported Unreasonable (Funds Be PL
Costs Costs Costs To Better Us
60
OFFICE OF INSPECTOR GENERAL
-------
Questioned Costs
Assignment Control Number
Title
Final Report
Issued
Ineligible
Costs
Unsupported
Costs
Recommended
Efficiencies
Unreasonable (Funds Be Put
Costs To Better Use)
D8AHL4
D8AML4
D8AML4
08AML4
D8AAL4
D8AML4
D8AML4
D8AML4
D8BML2
D8AML4
D8CBL4
D8BHL3
D8BML4
D8BML4
D8EML4
D8BML4
D8EML4
D8EML4
D8EML4
D8AML4
D8CML4
D8EML4
D8AML4
D8AML4
D8CML4
D8EML4
D8BML3
D8BML4
D8EMP2
D8EMP2-
-03-0378-
•03-0370-
•03-0377-
-03-0408-
•03-0302-
•03-0371-
•03-0372-
•03-0279-
-03-0237-
•03-0375-
•03-0290-
-03-0437-
•03-0138-
•03-0509-
•03-0505-
-03-0374-
•03-0510-
•03-0507-
•03-0504-
•03-0404-
•03-0503-
•03-0499-
•03-0470-
•03-0379-
03-0193-
03-0498-
•03-0443-
•03-0079-
•03-0311-
•03-0310-
4100480
4100481
4100482
4100483
4100484
4100485
4100486
4100487
4100503
4100507
4100526
4100533
4100534
4100541
4100543
4100544
4100545
4100546
4100547
4100549
4100550
4100551
4100553
4100555
4100556
4100557
4100558
4100564
4400066
4400068
QUANTECH, INC. VA
DYNCORP VA
WESTAT, INC. HD
MITCHELL SYSTEMS CORPORATIONVA
KEVRIC VA
INFORMATION VENTURES, INC. PA
KEVRIC COMPANY INC. MD
COM FEDERAL PROGRAMS VA
DUAL, INCORPORATED VA
SANDERS INTERNATIONAL, INC. DC
DYNCORP/PRI VA
ENERGY & ENVIRONMENTAL ANALYVA
THE SCIENTEX CORPORATION VA
EG&G WASHINGTON ANALYTICAL MD
UNIVERSAL SYSTEMS & TECH. VA
ERM PROGRAM MANAGEMENT CO. PA
HAMPSHIRE RESEARCH ASSOCIATEVA
COMPUTER SCIENCE CORP.
COMPUTER SCIENCE CORP.
SPECTRUM CONSULTING ASSOC.
JACA CORPORATION
QUANTECH, INC.
AVANTI
SURVEY RESEARCH ASSOCIATES
DYNAMAC
QUANTECH, INC.
WALCOFF & ASSOCIATES
COMPUTER SCIENCE CORP.
COMPUTER SCIENCE CORP
COMPUTER SCIENCE CORP
VA
VA
DC
PA
VA
VA
MD
MD
VA
VA
VA
VA
VA
TOTAL OF REGION 03 = 114
E8AML4-22-0412-4100537
E8BZN4-22-0078-4300041
PRICE PROPOSAL EH PECHAN
ICF KAISER-SUBKTRA BILLINGS
D8CML4
D8BML4-
D8BML4-
D8AML4
D8BML4-
D8BML4-
D8BML2-
D8BML4-
D8BML4-
D8DML2-
D8BML4-
D8AML4-
D8AML4-
D8AML4-
D8BML4-
D8AML4-
D8BML3-
D8AML4-
D8AML4-
D8AML4-
D8AML4-
D8AML4-
D8BML4-
D8AML4-
D8DML2-
D8EML4-
D8BML4-
D8BML3-
E8DML3-
E8BML4-
E8AXP4-
H8AML4-
TOTAL OF REGION 22 = 2
•04-0087-4100241 MANTECH TECHNOLOGY NC
04-0066-4100243 SEAWARD SERVICES FL
04-0070-4100245 SEAWARD SERVICES FL
04-0132-4100249 RESEARCH & EVALUATION ASSOC.NC
04-0075-4100250 KILKELLY ENVIRON. ASSOCIATESNC
04-0076-4100256 KILKELLY ENVIRON. ASSOCIATESNC
04-0279-4100257 TRANSCONTINENTAL ENTERPRISESNC
04-0057-4100263 INTEGRATED LABORATORIES NC
04-0175-4100267 TRANSCONTINENTAL ENTERPRISESNC
04-0280-4100268 TRANSCONTINENTAL ENTERPRISESNC
04-0201-4100324 JA JONES MGMT SERVICES INC. NC
04-0166-4100327 MANTECH TECHNOLOGY NC
04-0172-4100401 RAO ENTERPRISES, INC. NC
04-0169-4100402 NOVEL PHARMACEUTICAL NC
04-0214-4100411 MANTECH TECHNOLOGY NC
04-0193-4100418 RESEARCH EVALUATION ASSOC NC
04-0315-4100420 MANTECH TECHNOLOGY NC
04-0176-4100421 BCM ENGINEERS INC. MS
04-0199-4100425 ALPHA GAMMA TECHNOLOGIES NC
04-0198-4100426 EC/R INC NC
04-0210-4100440 KBN ENGINEERING FL
04-0219-4100478 TWM SERVICES INC. NC
04-0238-4100479 LEE WAN & ASSOCIATES, INC. GA
04-0220-4100490 NOVEL PHARMACEUTICAL INC. NC
04-0135-4100491 LEE WAN & ASSOCIATES GA
04-0241-4100493 NOVEL PHARMACEUTICALS INC NC
04-0068-4100574 KILKELLY ENVIRONMENTAL ASSO NC
04-0044-4100575 ADVANCED SYSTEMS TECHNOLOGY GA
04-0260-4100357 EHRT KY
04-0271-4100580 EHRT KY
04-0158-4400069 EHRT KY
04-0197-4100494 RESEARCH TRIANGLE INST NC
TOTAL OF REGION 04 = 32
D8CML4-05-0019-4100246
D8CML3-05-0141-4100254
TRIAD ENG FY 92/93
BATTELLE FY 91
WI
OH
8/12/94
8/12/94
8/12/94
8/12/94
8/12/94
8/12/94
8/12/94
8/12/94
8/25/94
8/25/94
9/16/94
9/22/94
9/22/94
9/23/94
9/23/94
9/23/94
9/23/94
9/23/94
9/23/94
9/23/94
9/23/94
9/23/94
9/23/94
9/23/94
9/23/94
9/23/94
9/26/94
9/28/94
6/ 7/94
6/ 8/94
9/22/94
8/15/94
4/ 5/94
4/ 7/94
4/ 7/94
4/13/94
4/13/94
4/19/94
4/22/94
4/29/94
5/ 3/94
5/ 3/94
5/26/94
5/26/94
6/13/94
6/13/94
6/21/94
6/23/94
6/23/94
6/23/94
6/24/94
6/24/94
II 7/94
8/11/94
8/11/94
8/17/94
8/17/94
8/17/94
9/29/94
9/29/94
6/ 2/94
9/30/94
6/14/94
8/18/94
4/12/94
4/19/94
APRIL 1, 1994 THROUGH SEPTEMBER 30, 1994
61
-------
Questi oned Costs
Recommended
Efficiencies
Assignment Control Number Title
D8CML4-05-0115-4100255
D8AML4-05-0214-4100356
D8CML4-05-0218-4100441
D8CML4-05-0219-4100442
D8CML4-05-0220-4100443
D8CML4-05-0221 -4100444
D8CML2-05-0258-41 00460
D8CML3-05-0235-4100464
D8AML4-05-0265-41 00467
D8AML4-05-0268-4100468
D8CHL3-05-0281 -41 00477
D8CML4 - 05 - 0087- 41 00495
D8CML4-05-0086-4100511
D8AML4-05-0294-4100517
D8CML2-05-031 1-4100531
E8AXP4-05-0210-4400052
E8AXP4-05-0216-4400053
E8AXP4- 05 - 021 7-4400062
E8AUP4 - 05 - 0238-4400075
E8AXP4-05-0242-4400077
E8AMP4-05-0244-4400078
E8DXP4-05-0271 -4400095
E8EXP4- 05 -0274 -4400 108
E8AXP4- 05 -0275 -44001 14
TOTAL OF
E8EXP4-23-0014-4400072
E8CAP3-23-0016-4400085
E8CMP2-23-0184-4400086
E8CAP3-23-0018-4400087
E8CMP2-23-0182-4400089
E8AXP4-23-0019-4400098
E8CAP3-23-0017-4400099
E8CAP3-23-0015-4400101
TOTAL OF
D8CML4-06-0030-4100265
D8CML4-06-0089-4100325
D8CML4- 06- 0088-41 00326
D8CML4-06-0084-4100328
D8AML4-06-0098-4100377
D8CML4-06-0085-4100427
D8BML4-06-0168-4100524
D8BML3-06-0067-4100527
D8BHL3-06-0070-4100528
TARITAS PS
HDR ENG
AUTO TESTING LAB FY 90-92
AUTO TESTING LAB FY 90-92
AUTO TESTING LAB FY 90-92
AUTO TESTING LAB FY 90-92
AUTO TESTING LAB FY 91
AUTO TESTING LAB FY 92
GREAT LAKES ENVIRO CENTER
BATTELLE
CAS/COLUMBUS FY 89
COLEJON MECH FY 91
COLEJON MECH FY 89
AT KEARNEY
LIFE SYSTEMS INC FY 90
PRC EMI (USAEC-COE)
PRC EMI (NAVY UST)
PRC EMI (NAVY OCEAN LAB)
PRC EMI (NPDES SUPP)
PRC EMI (ANNISTON)
PRC EMI (R3-SUB-ASSESS)
PRC EMI (92/93 B&P CEILING)
PRC EMI (NAVY TIMESHEETS)
PRC EMI (NAVY CLEANS)
REGION 05 = 26
EQMI S/S
PEI ASSOC (68-02-3898)
PEI ASSOC (68-02-3919)
PEI ASSOC (68-02-3855)
PEI ASSOC (68-02-3596)
EQMI (BROOKS AFB DO #1)
PEI ASSOC (68-02-4335)
PEI ASSOC (68-02-4351)
REGION 23 = 8
RADIAN CORPORATION
RADIAN CORPORATION
RADIAN CORPORATION
RADIAN CORPORATION
RADIAN
RADIAN CORPORATION
LOCKHEED ENGINEERING
RADIAN
RADIAN CORP
MI
MN
OH
OH
OH
OH
OH
OH
MI
OH
OH
OH
OH
IL
OH
IL
IL
IL
IL
IL
IL
IL
IL
IL
OH
OH
OH
OH
OH
OH
OH
OH
TX
TX
TX
TX
TX
TX
TX
TX
TX
Final Report Ineligible Unsupported Unreasonable (Funds Be Put
Issued Costs Costs Costs To Better Use
4/19/94
6/ 1/94
7/13/94
7/13/94
7/13/94
7/13/94
7/18/94
7/26/94
7/27/94
7/27/94
8/ 9/94
8/19/94
8/30/94
9/13/94
9/21/94
4/15/94
4/26/94
5/16/94
6/21/94
6/22/94
6/22/94
8/ 9/94
9/19/94
9/28/94
6/17/94
7/20/94
7/20/94
7/20/94
7/29/94
8/19/94
8/19/94
8/26/94
4/29/94
5/26/94
5/26/94
5/26/94
6/ 7/94
6/24/94
9/13/94
9/19/94
9/19/94
TOTAL OF REGION 06 =
D8AML4-07-0077-4100499 DPRA INCORPORATED
TOTAL OF REGION 07 =
1
D8BML2-09-0130-4100240 ES CI 1990
D8CML4-09-0161-4100262 TRW-SPACE & TECH. GROUP
D8BML4-09-0061-4100270 EERC CI 1992
D8CAL4-09-0152-4100271 RI-ROCKETDYNE FC
D8CAL4-09-0171-4100323 RI-ROCKETDYNE FC
D8BWL4-09-0063-4100333 MWA CI
D8CML4-09-0191-4100334 TRW-SPACE&ELECTRONICS GRP
D8AML4-09-0170-4100378 TETRA PA
D8BWL4-09-0026-4100379 MWA CI 1992
D8CAL4-09-0173-4100394 RI ROCKETDYNE FC
D8CAL4-09-0172-4100395 RI ROCKETDYNE FC
D8BML3-09-0080-4100409 TETRA CI 1990 - 1992
D8CML4-09-0144-4100415 ACUREX FC
D8CAL4-09-0024-4100463 ES FC
D8CML4-09-0082-4100472 TETRA FC
D8CWL4-09-0083-4100473 TETRA FC
D8BBL4-09-0053-4100510 EARTH METRICS, INC FC
D8BML2-09-0351-4100519 SR CI 1991
D8BML4-09-0234-4100520 THE RAND CORP CI 1991
D8BML4-09-0235-4100521 THE RAND CORP CI 1992
D8AML4-09-0227-4100525 GUTIERREZ-PALMENBERG PA
KS
CA
CA
CA
CA
CA
CA
CA
CA
CA
CA
CA
CA
CA
CA
CA
CA
CA
CA
CA
CA
AZ
8/24/94
4/ 4/94
4/26/94
5/ 3/94
5/ 6/94
5/24/94
5/31/94
5/31/94
6/ 7/94
6/ 7/94
6/ 8/94
6/ 8/94
6/15/94
6/21/94
7/22/94
8/ 2/94
8/ 2/94
8/26/94
9/13/94
9/13/94
9/13/94
9/15/94
62
OFFICE OF INSPECTOR GENERAL
-------
Recommended
Assignment Control Number Title
D8BML4-09-0240-4100562 THE RAND CORP CI '93
D8CAN3-09-0259-4300037 IT FC
D8AMN4-09-0169-4300038 SAIC P. A.
D8AWN4-09-0219-4300046 SAIC PA
D8AMN4-09-0224-4300047 SAIC PA
D8AMN4-09-0230-4300048 SAIC PA
TOTAL OF REGION 09 = 27
D8ASL4- 10-0093-41 00408 ENVIROASSOCIATES
D8APL4-10-0118-4100469 BATTELLE PA
CA
CA
CA
CA
CA
CA
WA
WA
Final Report
Issued
9/27/94
6/13/94
6/21/94
9/ 2/94
9/14/94
9/19/94
6/15/94
7/27/94
Questioned Costs Efficiencies
Ineligible Unsupported Unreasonable (Funds Be Put
Costs Costs Costs To Better Use)
TOTAL OF REGION 10 =
TOTAL OTHER CONTRACT ASSIGNMENTS
= 249
1,159,880
885,605
118,313
8,739,617
9. SUPERFUND CONTRACT ASSIGNMENTS
E9BHP3-01 -0123-4400050
P9DGL2-01 -0247-4100292
P9DGL2-01 -0247-4100329
P9DGL2-01-0220-4100474
TOTAL OF
D9AFL4-02-0112-4100310
D9AFL4-02-0173-4100515
E9EFP4-02-0155-4400082
P9CGL2-02-0283-41 00397
P9EFP2-02-0267-4400048
P9EFP3-02-0192-4400049
P9EFP4-02-0040-4400055
TOTAL OF
D9AFL4-03-0190-4100273
D9AFL4-03-0146-4100283
D9AFL4-03-0189-4100286
D9AFL4-03-0188-4100288
D9BKL2-03-0599-4100295
D9CFL3-03-0283-4100297
D9BKL4-03-0148-4100299
D9EFL4-03-0311 -4100302
D9BFL4-03-0317-4100308
D9BFL2-03-0220-4100311
D9BFL4-03-0328-4100314
D9EFL4-03-0352-4100337
D9BFL4-03-0338-4100352
D9BFL2-03-0471 -4100353
D9BFL4-03-0339-4100354
D9DFL4-03-0368-4100362
D9AFL4-03-0273-41 00364
D9BFL2-03-0584-4100365
D9BFL4-03- 0363-41 00371
D9BFL4-03-0364-4100372
D9BFL4- 03- 0365 -41 00373
D9EFL4-03-0361 -4100374
D9EFL3-03-0230-4100387
D9EFL4-03-0154-4100389
D9EFL3- 03- 0093-41 00392
D9BFL2-03-0295-4100396
D9AKL4-03-0277-4100403
D9AFL4-03-0276-4100404
D9EFL4-03-0353-4100435
D9AJL3-03-0247-4100447
D9BFL2-03-0598-4100502
D9AFL4-03-0453-4100506
D9BFL4-03-0502-4100532
D9AKL4-03-0450-4100536
D9DFL4-03-0508-4100542
D9BFL2-03-0438-4100548
D9AKL4-03-0454-4100552
D9AFL4-03-0451 -4100554
ALLIANCE TECHNOLOGIES CORP
ALLIANCE TECH. CORP.
ALLIANCE TECH. CORP.
TRC INC.
REGION 01 = 4
FOSTER - WHEELER
FOSTER WHEELER USA CORP
ECOLOGY & ENVIR.
ECOLOGY & ENVIR
ECOLOGY & ENVIR
ECOLOGY & ENVIR
ECOLOGY & ENVIR
REGION 02 = 7
COM FEDERAL PROGRAMS
SYSTEMS RESEARCH & SYSTEMS
C.C. JOHNSON
ROY F. WESTON
KEYDATA SYSTEMS INC
ROY F. WESTON
NUS CORP.
VIAR
ENVIRONMENTAL MGMT. SUPPORT
VERSAR
COM FEDERAL PROGRAMS
ROY F. WESTON
C.C. JOHNSON & MALHOTRA
TECHNICAL RESOURCES, INC.
TECHNICAL RESOURCES, INC.
ROY F. UESTON
DYNCORP VIAR
RESOURCE APPLICATIONS INC
KENDRICK AND COMPANY
KENDRICK AND COMPANY
KENDRICK AND COMPANY
ROY F. WESTON
VIAR
BOOZ ALLEN HAMILTON
ROY F WESTON
COM FEDERAL PROGRAMS
DYNCORP
DYNCORP
RESOURCE APPLICATIONS
CACI INC/FED
WADE MILLER & ASSOCIATES
AE ENVIRONMENTAL SERVICES
DYNAMAC
ROY F. WESTON
NUS CORP.
VIGYAN RESEARCH ASSOCIATES
MA
MA
MA
CT
NJ
NJ
NY
NY
NY
NY
NY
VA
VA
MD
PA
VA
PA
MD
VA
MD
VA
MA
PA
MD
MD
MD
PA
VA
VA
DC
DC
DC
PA
VA
MD
PA
VA
VA
VA
VA
VA
VA
WV
MD
PA
MD
VA
BROWN AND ROOT ENVIRONMENTALMD
C.C. JOHNSON & MALHOLTRA
MD
4/ 4/94
5/16/94
5/26/94
8/ 3/94
5/20/94
9/ 8/94
7/20/94
6/ 9/94
4/ 1/94
4/ 4/94
4/26/94
5/10/94
5/16/94
5/16/94
5/16/94
5/18/94
5/18/94
5/18/94
5/18/94
5/18/94
5/23/94
5/23/94
6/ 1/94
6/ 1/94
6/ 1/94
6/ 1/94
6/ 7/94
6/ 7/94
6/ 7/94
6/ 7/94
6/ 7/94
6/ 7/94
6/ 7/94
6/ 8/94
6/ 8/94
6/ 8/94
6/ 9/94
6/14/94
6/14/94
6/28/94
7/14/94
8/25/94
8/25/94
9/22/94
9/22/94
9/23/94
9/23/94
9/23/94
9/23/94
APRIL 1, 1994 THROUGH SEPTEMBER 30, 1994
63
-------
Questioned Costs
Assignment Control Number
Title
Final Report
Issued
Recommended
Efficiencies
Ineligible
Costs
Unsupported
Costs
D9EFP2-03-0312-4400067 COMPUTER SCIENCE CORP VA
TOTAL OF REGION 03 = 39
E9EFN4-22-0149-4300042 ICF-CAS 405,SUBCONTRACT BIL.
TOTAL OF REGION 22 = 1
D9EKL4
D9DKL2
D9DKL2
D9DKL2
D9AJL4
D9CKL4
E9DHL3
E9BGL3
E9FKG4
•04-0110-4100242
•04-0314-4100244
•04-0375-4100400
•04-0376-4100419
•04-0237-4100500
•04-0215-4100529
04-0253-4100266
04-0234-4100538
•04-0159-4400051
MANTECH RESEARCH NC
SEAWARD SERVICES INC. FL
MANTECH TECHNOLOGY NC
MANTECH TECHNOLOGY NC
DESA, INC. SC
WILLIAMS-RUSSELL & JOHNSON GA
WESTINGHOUSE REMEDIATION GA
WESTINGHOUSE REMEDIATION SV GA
WESTINGHOUSE REMEDIATION SVCGA
TOTAL OF REGION 04 =
D9AFL4-05-0211-4100410
E9AKP4- 05 - 0241 -4400074
E9DKP4- 05 -0070-4400097
E9AKP4-05-0291-4400117
ARTHUR ANDERSON
PRC EMI (TECH SUPPORT)
PRC EMI (BONUSES 90-92)
PRC EMI (R3 SATA)
IL
IL
IL
IL
TOTAL OF REGION 05 =
E9EHT4-23-0016-4400064
E9HGP2-23-0369-4400065
OHM REM RECORDS DESTRUCTION OH
MARION BRAGG SF IN
TOTAL OF REGION 23 =
D9AKL4-06-0090-4100264
D9BKL4-06-0102-4100293
D9BKL4-06-0151-4100492
LOCKHEED ENVIRONMENTAL TX
LOS ALAMOS TECHNICAL ASSOC. NM
H&GCL INCORPORATED NM
TOTAL OF REGION 06 =
D9DGL4-07-0058-4100251
D9DGL4-07-0059-4100252
D9DGL3-07-0065-4100253
D9BJL4-07-0065-4100272
D9CGL4-07-0035-4100498
MRI
MRI
MIDWEST RESEARCH INSTITUTE
DPRA
HDR ENGINEERING, INC.
TOTAL OF REGION 07 = 5
D9AKL4-08-0048-4100279 RESOURCE TECHNOLOGY CORP
TOTAL OF REGION 08 = 1
D9AGL4-09-0153-4100296 SAIC P.A.
D9AKL4-09-0193-4100422 ACUREX PA
D9CGL4-09-0077-4100439 SAIC FC
MO
MO
KS
NE
WY
CA
CA
CA
TOTAL OF REGION 09 =
D9AGL4
D9BGL4
D9BGL3
E9EHP4
E9FGP4
H9AGN4
P9BGL4
P9EGL4
P9BGL4
P9BGL4
P9BGL4
P9BGL4
P9BGL4
P9BGL4
P9BGL4
10-0072-
10-0119-
•10-0088-
•10-0044-
•10-0074-
•10-0082-
•10-0083-
•10-0077-
-10-0107
-10-0117
-10-0124
•10-0129
-10-0132
•10-0149
-10-0147
4100269
4100413
4100471
4400060
4400109
4300036
4100309
4100393
4100398
4100417
4100436
4100489
4100512
4100560
4100566
CFS ID
SHANNON & WILSON CI 1990 WA
URS FY 1989 AC WA
RES FINANCIAL CAPABILITY OR
RES REV CAS STMT OR
UNIVERSITY OF IDAHO P.A. ID
CH2M REM IV 87-89 C.I. OR
CH2M SUBCONTRACT ADM SYSTM. OR
CH2M REM/FIT 87-89 C.I. CA
CH2M TECH 1 C.I. 1987-88 OR
CH2M ARCS V C.I. 1988 & 19890R
CH2M TECH II C.I. 1988-89 OR
CH2M ARCS WEST 1989 COSTS OR
CH2M ARCS VI 1988 & 89 COSTSOR
CH2M ARCS III 1988-89 COSTS OR
TOTAL OF REGION 10 = 15
TOTAL SUPERFUND CONTRACT ASSIGNMENTS
TOTAL REPORTS = 796
6/ 7/94
8/15/94
4/ 5/94
4/ 7/94
6/13/94
6/23/94
8/24/94
9/19/94
5/ 3/94
9/22/94
4/13/94
6/17/94
6/21/94
8/12/94
9/30/94
5/20/94
5/24/94
4/29/94
5/18/94
8/17/94
4/18/94
4/18/94
4/18/94
5/10/94
8/24/94
5/10/94
5/18/94
6/23/94
71 7/94
5/ 3/94
6/21/94
8/ 2/94
5/11/94
9/22/94
6/ 7/94
5/19/94
6/ 8/94
6/10/94
6/22/94
6/29/94
8/16/94
8/30/94
9/26/94
9/28/94
93
1,212,167
30,875,531
7,839,971
15,705,240
50,464
6,040,432
64
OFFICE OF INSPECTOR GENERAL
-------
Appendix 2 -- Reports Issued Without Management Decision
THE INSPECTOR GENERAL ACT REQUIRES A SUMMARY OF EACH REPORT ISSUED BEFORE THE COMMENCEMENT OF THE
REPORTING PERIOD FOR WHICH NO MANAGEMENT DECISION HAS BEEN MADE BY THE END OF THE REPORTING PERIOD
(INCLUDING THE DATE AND TITLE OF EACH SUCH REPORT), AN EXPLANATION OF THE REASONS SUCH MANAGEMENT DECISION
HAS NOT BEEN MADE, AND A STATEMENT CONCERNING THE DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION ON
EACH SUCH REPORT. (The IG provides the summary, the date and title of each such report. The Agency provides the explanation of the
reasons 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 9/30/94:
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 for Administration and Resources Management = DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION: RESOLUTION
IS EXPECTED BY MARCH 31, 1995.
E1SFG3-11-0026-4400042 FINANCIAL MGMT REVIEW - SF 3/31/94
Summary: THE REVIEW SHOWED THAT THE AGENCY NEEDS FURTHER
IMPROVEMENT IN AREAS THAT INCLUDE: PERCEPTIONS AND AWARENESS OF
FINANCIAL MANAGEMENT; FINANCIAL ASPECTS OF SUPERFUND COST
RECOVERY; FINANCIAL AND REPORTING SYSTEMS; FINANCIAL AND
ACCOUNTING POLICIES AND PROCEDURES; PROGRAM FINANCIAL MANAGEMENT;
AND QUALIFICATIONS AND TRAINING.
- EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN MADE
THE RESPONSE WAS PROVIDED TO THE DIG ON AUGUST 8, 1994. DIG AND
MANAGEMENT ARE MEETING TO DISCUSS REMAINING CONCERNS.
= DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION:
RESOLUTION DATE CANNOT BE DETERMINED AT THIS TIME.
IG FOLLOWUP STATUS AS OF 9/30/94 [6] A management decision was
received and this report was closed on October 6 1994
Grants Administration Division
E1FBF3-10-0069-4100214 AUDIT OF CO-OPS/IAGS ERL-C OR 3/21/94
Summary: ERL-C DIDN'T ALWAYS COMPLY WITH FGCA ACT AND EPA
GUIDANCE. SEVEN OF 18 GRANTS SHOULD HAVE BEEN CONTRACTS AND TWO
GRANTS WERE INAPPROPRIATELY USED. THREE OF SIX IAGS WERE FOR
MULTIPLE INSTEAD OF DISTINCT PROJECTS. SOME IAG COSTS WERE
OVERPAID OR UNRECOVERED.
• EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN MADE:
THE RESPONSE WAS PROVIDED TO THE OIG ON JULY 21, 1994. DIG AND
MANAGEMENT MET ON JULY 28, 1994 TO BEGIN RESOLVING THE FOUR ITEMS
THE OIG DISAGREED WITH IN MANAGEMENT'S RESPONSE. OIG AND
MANAGEMENT CONTINUE TO MEET TO DISCUSS THE REMAINING UNRESOLVED
ISSUES.
= DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION:
RESOLUTION DATE CANNOT BE DETERMINED AT THIS TIME.
IG FOLLOWUP STATUS AS OF 9/30/94 [1]
Office of Acquisition Management (0AM)
P9BGL2-04-0046-3100015 WESTINGHOUSE HAZ1ECH GA 10/28/92
Summary: COSTS QUESTIONED AS INELIGIBLE REPRESENT THE
APPLICATION OF THE INCORRECT GENERAL AND ADMINISTRATIVE RATE.
UNSUPPORTED COSTS WERE FOR MATERIALS BILLED AT A FIXED-RATE NOT
PROVIDED FOR IN THE CONTRACT AND NO OTHER DOCUMENTATION WAS
ALLOWABLE TO SUPPORT UNIT PRICE USED.
IG FOLLOWUP STATUS AS OF 9/30/94 [1]
0AM Contracts Management Division • Research Triangle Park
D8CPL2-03-0432-2100620 MIRANDA ASSOCIATES INC DC 9/16/92
Summary: 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 MADE:
QUESTIONED COSTS AND FIXED FEES EARNED ARE UNDER NEGOTIATION WITH
THE CONTRACTOR. LEGAL REVIEW OF FILE HAS BEEN REQUESTED.
= DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION: THE
CONTRACTING OFFICER'S FINAL DECISION IS EXPECTED BY NOVEMBER 1
1994.
IG FOLLOWUP STATUS AS OF 9/30/94 [1]
D8CPL2-03-0441-4100108 KENDRICK & COMPANY DC 12/ 6/93
Summary: QUESTIONED COSTS $202,352 DUE TO LIMITATIONS OF FUNDS
CLAUSE AND OVERSTATED INCURRED COSTS.
- EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN MADE:
CERTIFIED LETTER SENT TO CONTRACTOR JUNE 2, 1994. NO RESPONSE
RECEIVED.
= DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION: FINAL
CONTRACTING OFFICER DECISION WILL BE MADE BY OCTOBER 31, 1994.
IG FOLLOWUP STATUS AS OF 9/30/94 [1]
P8BML2-03-0507-4100168 ASCI CORPORATION
*Summary:
VA II 5/94
- EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN MADE:
THIS REPORT ON INCURRED COSTS FOR ASCI'S FISCAL YEAR ENDING
DECEMBER 31, 1990 WAS RECEIVED ON MAY 25, 1994. THE CONTRACTOR'S
COMPLETION VOUCHER AND CUMULATIVE CLAIM ON CONTRACT 68-D9-0094 WAS
DATED JUNE 27, 1994. THE OIG IS REVIEWING THE REQUEST FOR THE
FINAL AUDIT ON THE TOTAL CONTRACT PERIOD.
= DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION: RESOLUT ION
DATE CANNOT BE DETERMINED AT THIS TIME.
IG FOLLOWUP STATUS AS OF 9/30/94 [1]
- EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN MADE: D8BML3-04-0272-3100202
THE OIG IS CURRENTLY REVIEWING THE CONTRACTOR'S ADDITIONAL *Summary:
SUPPORTING DOCUMENTATION FOR FIXED RATE MATERIALS. THE PROGRAM
RECEIVED THE OIG SUPPLEMENTAL AUDIT REPORT DATED APRIL 13, 1994.
INTEGRATED LABORATORY SYSTEMNC 6/ 2/93
APRIL 1, 1994 THROUGH SEPTEMBER 30, 1994
65
-------
Assignment Control
Number
Title
Final Report
Issued
Assignment Control
Number Title
Final Repoi
ISSUi
- EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN MADE: IG FOLLOWUP STATUS AS OF 9/30/94 [3] The DIG expects to have th,
CONTRACTOR HAS AGREED WITH COST QUESTIONED. CREDIT WILL BE TAKEN supporting documentation, which was not available dunng our audit, reviewed by Me
ON PAYMENT DUE UNDER AN ACTIVE CONTRACT. ~^p *995 Other audit priorities have caused the delay in reviewing the data
= DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION: FINAL
ACTION IS EXPECTED IN THE FIRST QUARTER OF FY 1995.
IG FOLLOWUP STATUS AS OF 9/30/94 [1]
D8BML3-04-0282-3100207 SYSTEMS RESEARCH & DEV. NC 6/ 4/93
*Summary:
- EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN MADE
THE REPORT COVERS DIRECT AND INDIRECT COSTS FOR CALENDAR YEAR
1988. COST QUESTIONED ON TWO CONTRACTS. CONTRACTOR HAS AN
APPROVED BANKRUPTCY PLAN.. ANY RECOVERY MUST BE ESTABLISHED THROUGH
THE COURT.
= DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION: FINAL
ACTION EXPECTED BY JUNE 1, 1995.
IG FOLLOWUP STATUS AS OF 9/30/94 [2]
D8AML3-04-0299-3100311 ENVIRONMENTAL QUALITY MGMT. TN
Summary: (PREAWARD AUDIT UNDER NEGOTIATION)
8/13/93
- EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN MADE
CONTRACT AWARD HAS BEEN MADE. EPA IS PREPARING THE SUMMARY OF
NEGOTIATIONS.
= DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION:
RESOLUTION IS EXPECTED IN THE FIRST QUARTER OF FY 1995.
IG FOLLOWUP STATUS AS OF 9/30/94 [1]
H8AML3-04-0298-4100018 RTI
Summary: (PREAWARD AUDIT UNDER NEGOTIATION)
NC 10/15/93
- EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN MADE:
CONTRACT AWARD HAS BEEN MADE. EPA IS PREPARING THE SUMMARY OF
NEGOTIATIONS.
= DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION:
RESOLUTION IS EXPECTED IN THE FIRST QUARTER OF FY 1995.
IG FOLLOWUP STATUS AS OF 9/30/94 [1]
P8CMP2-23-0180-3400071 PEI ASSOC OH 8/25/93
Summary: UNSUPPORTED LABOR AND TRAVEL COSTS OF $332,746 WERE
QUESTIONED DUE TO INADEQUATE DOCUMENTATION. WE ALSO QUESTIONED AS
INELIGIBLE $513 BECAUSE OF LACK OF SUPPORT FOR INTER-COMPANY
TRANSACTIONS.
- EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN MADE:
EPA LETTER ON MARCH 1, 1994 ADVISED CONTRACTOR OF COST QUESTIONED
AND REQUESTED REFUND OR SUPPORTING DOCUMENTATION. CONTRACTOR
RESPONDED ON MARCH 29, 1994 AND ADVISED THAT SUPPORT DATA WAS
AVAILABLE. LETTER ON APRIL 12, 1994 ASKED DIG TO REVIEW NEW DATA
AND PROVIDE REVISED REPORT. AWAITING DIG RESPONSE.
= DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION:
RESOLUTION DATE CANNOT BE DETERMINED AT THIS TIME.
IG FOLLOWUP STATUS AS OF 9/30/94 [3]
P8CMP2-23-0176-3400072 PEI ASSOC OH 8/26/93
Summary: QUESTIONED $839,416 OF UNSUPPORTED LABOR AND TRAVEL
COSTS THAT COULD NOT BE SUPPORTED BY ADEQUATE DOCUMENTATION.
- EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN MADE:
EPA LETTER ON MARCH 1, 1994 ADVISED CONTRACTOR OF COST QUESTIONED
AND REQUESTED REFUND OR SUPPORTING DOCUMENTATION. CONTRACTOR
RESPONDED ON MARCH 29, 1994 AND ADVISED THAT SUPPORT DATA WAS
AVAILABLE. LETTER ON APRIL 12, 1994 ASKED DIG TO REVIEW NEW DATA
AND PROVIDE REVISED REPORT. AWAITING DIG RESPONSE.
= DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION:
RESOLUTION DATE CANNOT BE DETERMINED AT THIS TIME.
P8CMP2-23-0181-3400074 PEI ASSOC OH 8/27/
Summary: QUESTIONED UNSUPPORTED LABOR AND TRAVEL OF $40,498 i
TO MISSING DOCUMENTATION. WE ALSO QUESTIONED AS INELIGIBLE $!
DUE TO LACK OF SUPPORT FOR INTERCOMPANY TRANSACTIONS.
- EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN MA
EPA LETTER ON MARCH 1, 1994 ADVISED CONTRACTOR OF COST QUESTIOI
AND REQUESTED REFUND OR SUPPORTING DOCUMENTATION. CONTRACTOR
RESPONDED ON MARCH 29, 1994 AND ADVISED THAT SUPPORT DATA WAS
AVAILABLE. LETTER ON APRIL 12, 1994 ASKED DIG TO REVIEW NEW Dl
AND PROVIDE REVISED REPORT. AWAITING DIG RESPONSE.
= DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION: RESOLUT:
DATE CANNOT BE DETERMINED AT THIS TIME.
IG FOLLOWUP STATUS AS OF 9/30/94 [3] The DIG expects to have th<
supporting documentation, which was not available during our audit, reviewed by Mj
31. 1995 Other audit priorities have caused the delay in reviewing the data
P8CMP2-23-0177-3400077 PEI ASSOC OH 9/ I/
Summary: INADEQUATE ACCOUNTING SYSTEM RESULTED IN INELIGIBLE a
QUESTIONED OF $20,359. MISSING DOCUMENTATION RESULTED IN
$1,863,579 OF QUESTIONED UNSUPPORTED COSTS. WE ALSO QUESTIONS
$1,992 AS INELIGIBLE DUE TO LACK OF SUPPORT FOR INTERCOMPANY
TRANSACTIONS.
- EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN MAI
EPA LETTER ON MARCH 1, 1994 ADVISED CONTRACTOR OF COST QUESTIOI
AND REQUESTED REFUND OR SUPPORTING DOCUMENTATION. CONTRACTOR
RESPONDED ON MARCH 29, 1994 AND ADVISED THAT SUPPORT DATA WAS
AVAILABLE. LETTER ON APRIL 12, 1994 ASKED DIG TO REVIEW NEW D/
AND PROVIDE REVISED REPORT. AWAITING DIG RESPONSE.
= DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION: RESOLUT]
DATE CANNOT BE DETERMINED AT THIS TIME.
IG FOLLOWUP STATUS AS OF 9/30/94 [3] The DIG expects to have the
supporting documentation, which was not available during our audit, reviewed by Ma
31, 1995 Other audit priorities have caused the delay in reviewing the data
P8CMP2-23-0179-3400082 PEI ASSOC OH 9/ 3/
Summary: INADEQUATE ACCOUNTING SYSTEM RESULTED IN COST QUESTIOI>
INELIGIBLE OF $35,443. MISSING DOCUMENTATION RESULTED IN
UNSUPPORTED COSTS OF $512,794.
- EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN MAI
EPA LETTER ON MARCH 1, 1994 ADVISED CONTRACTOR OF COST QUESTIOh
AND REQUESTED REFUND OR SUPPORTING DOCUMENTATION. CONTRACTOR
RESPONDED ON MARCH 29, 1994 AND ADVISED THAT SUPPORT DATA WAS
AVAILABLE. LETTER ON APRIL 12, 1994 ASKED DIG TO REVIEW NEW Of
AND PROVIDE REVISED REPORT. AWAITING DIG RESPONSE.
= DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION:
DATE CANNOT BE DETERMINED AT THIS TIME.
RESOLUT1
IG FOLLOWUP STATUS AS OF 9/30/94 [3] The DIG expects to have the
supporting documentation, which was not available during our audit, reviewed by Ma
31, 1995 Other audit priorities have caused the delay in reviewing the data
0AM Cost Advisory and Financial Analysis Division
Cost Review and Rate Negotiation Brancfi
D9BKL3-04-0034-3100010
*Summary
EHRT
KY 107 9/
- EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN MA!
NEGOTIATIONS WERE TEMPORARILY SUSPENDED WITH THE CONTRACTOR.
NEGOTIATIONS HAVE RESUMED ON MANY COMPLEX ISSUES. IT HAS BEEI*
DIFFICULT TO CONTACT AUTHORIZED REPRESENTATIVES TO RESOLVE THE!
= DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION: RESOLUT
IS ANTICIPATED IN THE FIRST QUARTER OF FISCAL YEAR 1995.
IG FOLLOWUP STATUS AS OF 9/30/94 [1]
66
OFFICE OF INSPECTOR GENERAL
-------
Assignment Control
Number
Title
Final Report
Issued
Assignment Control
Number
Title
Final Report
Issued
S5DGN2-09-0047-4300033 CA DEPT OF HEALTH ICRP CA 3/31/94
*Summary:
- EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN MADE:
THE AUDIT CONTAINS COMPLEX ISSUES WHICH WILL TAKE MUCH DISCUSSION
TO RESOLVE. HOWEVER, A NEGOTIATED SETTLEMENT IS POSSIBLE.
= DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION: EPA
EXPECTS RESOLUTION BY DECEMBER 31, 1994.
IG FOLLOWUP STATUS AS OF 9/30/94 [1]
P8BMPO-23-0422-2400046 PEI ASSOC FY 90 OH 6/ 2/92
Summary: WE QUESTIONED AS INELIGIBLE $91,483 OF COSTS BILLED IN
EXCESS OF COSTS INCURRED UNDER VARIOUS EPA CONTRACTS.
ADDITIONALLY, THE 1990 INDIRECT RATES HAVE NOT BEEN NEGOTIATED AND
FINALIZED.
- EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN MADE:
QUESTIONED DIRECT COSTS HAVE BEEN REFERRED TO THE APPROPRIATE
CONTRACTING OFFICER. HOWEVER, THE QUESTIONED DIRECT COSTS WILL
NOT BE RESOLVED UNTIL CLOSEOUT AUDITS ARE COMPLETE. PER DIG,
CLOSE OUT AUDITS ARE IN PROGRESS.
= DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION:
RESOLUTION DATE CANNOT BE DETERMINED AT THIS TIME.
IG FOLLOWUP STATUS AS OF 9/30/94 [1]
P8BMP1-23-0335-2400073 PEI ASSOC FY 85 OH 9/ 9/92
Summary: THE REVIEW FOUND $224,781 OF INELIGIBLE AND $195,886 OF
UNSUPPORTED COSTS.
- EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN MADE:
QUESTIONED DIRECT COSTS HAVE BEEN REFERRED TO THE APPROPRIATE
CONTRACTING OFFICER. HOWEVER, THE QUESTIONED DIRECT COSTS WILL
NOT BE RESOLVED UNTIL CLOSEOUT AUDITS ARE COMPLETE. PER DIG,
CLOSE OUT AUDITS ARE IN PROGRESS.
= DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION:
RESOLUTION DATE CANNOT BE DETERMINED AT THIS TIME.
IG FOLLOWUP STATUS AS OF 9/30/94 [1]
P8BMP1-23-0339-3400050 PEI ASSOC FY 89 OH 5/13/93
Summary: THE QUESTIONED COSTS DO NOT REFLECT AN ADJUSTMENT FOR
INDIRECT COSTS. INELIGIBLE COSTS OF $284,000 ARE DUE TO AN
INADEQUATE BILLING SYSTEM. UNSUPPORTED COSTS OF $530,000 WERE DUE
TO INTER-COMPANY TRANSFERS.
- EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN MADE:
QUESTIONED DIRECT COSTS HAVE BEEN REFERRED TO THE APPROPRIATE
CONTRACTING OFFICER. HOWEVER, THE QUESTIONED DIRECT COSTS WILL
NOT BE RESOLVED UNTIL CLOSEOUT AUDITS ARE COMPLETE. PER 01G CLOSE
OUT AUDITS ARE IN PROGRESS.
= DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION:
RESOLUTION DATE CANNOT BE DETERMINED AT THIS TIME.
IG FOLLOWUP STATUS AS OF 9/30/94 [1]
P8BMPO-23-0175-3400053 PEI ASSOC FY 86 OH 5/14/93
Summary: WE HAVE QUESTIONED AS INELIGIBLE $940,755, 53% WAS DUE
TO COST BILLED IN EXCESS OF WHAT WAS INCURRED. THE REMAINING 47%
WAS THE ADJUSTMENT OF INDIRECT RATES TO ACTUAL.
P8BMPO-23-0177-3400062 PEI ASSOC FY 87/88 OH 6/14/93
Summary: WE QUESTIONED AS INELIGIBLE $759,941 OF COST BILLED BUT
NOT INCURRED. WE ALSO QUESTIONED AS UNSUPPORTED $1,224,486, 48% OF
WHICH WAS DUE TO USING CATALOG PRICES. COSTS WERE NOT ADJUSTED FOR
AUDITED INDIRECT RATES.
- EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN MADE
QUESTIONED DIRECT COSTS HAVE BEEN REFERRED TO THE APPROPRIATE
CONTRACTING OFFICER. HOWEVER, THE QUESTIONED DIRECT COSTS WILL NOT
BE RESOLVED UNTIL CLOSEOUT AUDITS ARE COMPLETE. PER OIG CLOSE OUT
AUDITS ARE IN PROGRESS.
= DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION: RESOLUTION
DATE CANNOT BE DETERMINED AT THIS TIME.
IG FOLLOWUP STATUS AS OF 9/30/94 [1]
0AM Cost Advisory and Financial Analysis Division
Financial Analysis Branch
P8BMN1-03-0146-2300014 O&R MANAGEMENT CORPORATION MD III 5/91
Summary: WE QUESTIONED $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 MADE:
RESOLUTION HAS BEEN DELAYED BECAUSE THE COMPANY IS NO LONGER IN
BUSINESS. THE CONTRACTING OFFICER IS WRITING A DECISION ON
DISALLOWANCE OF COST CLAIMED BY THE CONTRACTOR IN THE AUDIT REPORT.
FINAL DECISION IS UNDER LEGAL REVIEW.
= DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION: RESOLUTION
IS EXPECTED BY DECEMBER 31, 1994.
IG FOLLOWUP STATUS AS OF 9/30/94 [1]
D9BFL2-03-0272-4100085 ROY F WESTON
*Summary:
PA 11/19/93
- EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN MADE:
THE CONTRACTING OFFICER HAS GIVEN THE CONTRACTOR UNTIL FISCAL
YEAR-END 94 TO COMPLETE FY 1992 RECONCILIATION OF ITS BOOKS DUE TO
PERSONNEL CHANGES IN THEIR GOVERNMENT COST ACCOUNTING DEPARTMENT.
THIS RECONCILIATION HAS NOT BEEN ACCOMPLISHED.
= DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION: THE
CONTRACTING OFFICER IS PREPARING A RESPONSE AND EXPECTS RESOLUTION
BY DECEMBER 30, 1994.
IG FOLLOWUP STATUS AS OF 9/30/94 [1]
E9BHP2-10-0024-3400095 RES-SELF INSURANCE OR 9/29/93
Summary: THE CONTRACTOR BILLED THE GOVERNMENT $3,709,794 IN
EXCESS OF ACTUAL COST FOR POLLUTION LIABILITY INSURANCE UNDER
CONTRACT NO. 68-01-7334.
- EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN MADE:
DEPARTMENT OF JUSTICE IS IN LITIGATION WITH CONTRACTOR ON THIS
ISSUE. THE DEPARTMENT OF JUSTICE WILL RESOLVE THE AUDIT. THE
TRIAL IS EXPECTED DURING FY 1995.
= DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION: RESOLUTION
IS EXPECTED DURING 1995.
IG FOLLOWUP STATUS AS OF 9/30/94 [1]
- EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN MADE: P9AHN9-23-0347-0300036 OH MATERIALS (PR EQ RATES) OH 3/27/90
QUESTIONED DIRECT COSTS HAVE BEEN REFERRED TO THE APPROPRIATE Summary: (PREAWARD AUDIT UNDER NEGOTIATION)
CONTRACTING OFFICER. HOWEVER, THE QUESTIONED DIRECT COSTS WILL
NOT BE RESOLVED UNTIL CLOSEOUT AUDITS ARE COMPLETE. PER OIG CLOSE - EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN MADE:
OUT AUDITS ARE IN PROGRESS. NEGOTIATIONS ARE CONTINUING.
= DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION:
RESOLUTION DATE CANNOT BE DETERMINED AT THIS TIME.
IG FOLLOWUP STATUS AS OF 9/30/94 [1]
= DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION: RESOLUTION
EXPECTED BY OCTOBER 31, 1994.
IG FOLLOWUP STATUS AS OF 9/30/94 [1]
APRIL 1, 1994 THROUGH SEPTEMBER 30, 1994
67
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P9AHN1-23-0143-2300024 OHM REM ERCS2 Zl FY 89
Summary: (PREAWARD AUDIT UNDER NEGOTIATION)
OH 12/27/91
- EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN MADE:
THE CONTRACTING OFFICER ANTICIPATES DEFINITIZATION OF THE
EQUIPMENT UTILIZATION RATES FOR 1987-1990 BY OCTOBER 31, 1994.
NEGOTIATIONS ARE CONTINUING.
= DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION:
RESOLUTION IS EXPECTED BY OCTOBER 31, 1994.
IG FOLLOWUP STATUS AS OF 9/30/94 [1]
P9AHP2-23-0021-4400002 OHM REM ERCS2 Zl FY 90 EQ OH 10/ 7/93
Summary: (PREAWARD AUDIT UNDER NEGOTIATION)
- EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN MADE:
NEGOTIATIONS ARE CONTINUING ON THIS CONTRACT.
= DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION: THIS WILL
BE RESOLVED AND THE SUMMARY OF NEGOTIATIONS ISSUED BY OCTOBER 31,
1994.
IG FOLLOWUP STATUS AS OF 9/30/94 [1]
0AM Cost Advisory and Financial Analysis Division
Washington Cost Advisory BraTich
IG FOLLOWUP STATUS AS OF 9/30/94
Regional Administrator - Region 1
[1]
D8AMN3-01-0266-4300007 ABT ASSOCIATES MA 11/15/93
Summary: (PREAWARD AUDIT UNDER NEGOTIATION)
- EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN MADE
AWARD OF THIS CONTRACT IS PLANNED FOR OCTOBER 1994. IF
SUCCESSFUL, EPA WILL PROVIDE A SUMMARY OF NEGOTIATIONS TO THE DIG.
= DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION:
RESOLUTION IS EXPECTED BY OCTOBER 31, 1994.
IG FOLLOWUP STATUS AS OF 9/30/94 [1]
D8AML4-06-0039-4100101 FTN ASSOCIATES LTD
Summary: (PREAWARD AUDIT UNDER NEGOTIATION)
TX 121 2/93
- EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN MADE
THIS AUDIT REPORT IS CURRENTLY UNDER NEGOTIATIONS. AN AWARD OF
THIS COMPETITIVE PROCUREMENT WILL NOT OCCUR UNTIL DECEMBER 1994.
A COPY OF THE SUMMARY OF NEGOTIATIONS WILL BE SENT TO THE OIG IF
FTN IS THE SUCCESSFUL OFFEROR.
= DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION:
RESOLUTION IS EXPECTED BY DECEMBER 31, 1994.
IG FOLLOWUP STATUS AS OF 9/30/94 [1]
P9AGL2-10-0089-4100225 CH2M ARCS IV TERM STLMT
Summary: (PREAWARD AUDIT UNDER NEGOTIATION)
S2CWL1-01-0024-4100179 SPRINGFIELD MA 1/3L
Summary: THE CITY OF SPRINGFIELD, MA CLAIMED UNALLOWABLE PROJI
COSTS OF $4,059,671 FOR THE CONSTRUCTION OF A SECONDARY SEWAGE
TREATMENT PLANT, INCLUDING NEW INTERCEPTER SEWERS, PUMPING
STATIONS, FORCE MAIN SIPHON, AND OUTFALL SEWER.
- EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN MA
THE REGION IS MEETING WITH THE CITY'S CONSULTANT ON A BIWEEKL1
BASES TO REVIEW $4,060,000 IN QUESTIONED COSTS. THE PROPOSED FII
DETERMINATION LETTER WILL BE SENT TO THE OIG BY NOVEMBER 30, 19<
= DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION: RESOLUT:
DATE CANNOT BE DETERMINED AT THIS TIME.
IG FOLLOWUP STATUS AS OF 9/30/94 [1]
Regional Administrator - Region 2
P2CWL1-02-0104-3100118 NYCDEP NY 3/ 2;
Summary: THE CITY OF NEW YORK CLAIMED UNALLOWABLE PROJECT co;
OF $13,953,725 FOR DESIGN AND CONSTRUCTION OF 8 DEPARTMENT OF
ENVIRONMENTAL PROTECTION WATER POLLUTION CONTROL FACILITIES AN
APPURTENANCES
- EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN MAI
THE FINAL AUDIT COVERED EIGHT GRANTS FOR A TOTAL GRANTEE CLAIK
AMOUNT OF $560 MILLION WITH AUDIT QUESTIONED COSTS OF $14 MILLK
THE DRAFT FINAL DETERMINATION IS UNDER REVIEW.
= DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION: RESOLUT]
IS EXPECTED IN NOVEMBER 1994.
IG FOLLOWUP STATUS AS OF 9/30/94 [3]
P2CWL1-02-0104-3100169 NYCDEP NY 4/29/
Summary: THE CITY OF NEW YORK, NY CLAIMED QUESTIONED COST OF
$38,829,195 CONSISTING OF $20,431,575 INELIGIBLE COSTS,
$14,635,447 UNSUPPORTED COSTS AND $3,762,173
UNREASONABLE/UNNECESSARY COSTS FOR THE DESIGN AND CONSTRUCTION
THE REDHOOK WASTEUATER TREATMENT PLANT AND APPURTENANCES.
- EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN MAI
THE AUDIT COVERED ELEVEN GRANTS FOR A TOTAL CLAIMED AMOUNT OF $2
MILLION WITH QUESTIONED COSTS OF $33 MILLION. THE REGION SENT
DRAFT RESOLUTION LETTER TO THE OIG ALONG WITH REQUESTED ADDITIOh
DOCUMENTATION AND CLARIFICATION FOR SEVERAL ITEMS.
= DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION: THE REG]
ANTICIPATES RESOLUTION BY DECEMBER 31, 1994.
OR 3/28/94 IG FOLLOWUP STATUS AS OF 9/30/94 [3]
- EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN MADE
CORRESPONDENCE RELATING TO THE STATUS OF THIS RESPONSE WAS FAXED
AND MAILED TO OIG ON SEPTEMBER 15, 1994.
= DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION:
RESOLUTION DATE CANNOT BE DETERMINED AT THIS TIME.
IG FOLLOWUP STATUS AS OF 9/30/94 [1]
P9CGL2-10-0127-4100226 CH2M REGION IV ARCS OR 3/29/94
Summary: CH2M CLAIMED $73,895 OF UNSUPPORTED COMPUTER COSTS.
$69,559 OF UNSUPPORTED COSTS RELATED TO THE RED-PENN WORK
ASSIGNMENT, AND $6,199 OF INELIGIBLE INDIRECT COSTS.
- EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN MADE:
CORRESPONDENCE RELATING TO THE STATUS OF THIS RESPONSE WAS SENT TO
THE OIG ON SEPTEMBER 15, 1994 VIA FAX AND A COPY WAS ALSO MAILED.
NEGOTIATIONS WILL NOT BE COMPLETE UNTIL FISCAL YEAR 1996.
= DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION:
RESOLUTION DATE CANNOT BE DETERMINED AT THIS TIME.
P2CWL1-02-0104-3100374 NYCDEP NY 9/14/
Summary: THE CITY OF NEW YORK, NEW YORK CLAIMED UNALLOWABLE
PROJECT COSTS OF $65,169,354 FOR THE CONSTRUCTION OF THE NORTH
RIVER SEWAGE TREATMENT PLANT AND A RECREATIONAL PARK.
- EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN MAI
NEW YORK STATE DEPARTMENT OF ENVIRONMENTAL CONSERVATION IS THE
DELEGATED AGENCY RESPONSIBLE FOR DRAFTING THE FINAL DETERMINAT1
LETTERS FOR FOUR OIG MEGA-AUDITS OF NEW YORK CITY COVERING 26
GRANTS, $1.4 BILLION CLAIMED COSTS AND $96 MILLION QUESTIONED
COSTS.
= DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION: THE REG]
ANTICIPATES RESOLUTION IN DECEMBER 1994.
IG FOLLOWUP STATUS AS OF 9/30/94 [1]
E2AWT3-02-0016-3400002 EARLY WARNING-RED HOOK WPCP NY 10/28/
Summary: OUR REVIEW OF THE NEW YORK CITY RED HOOK WPCP DISCLO;
THAT LABORATORY FACILITIES WERE NOT IN USE AND HAD NOT BEEN
UTILIZED SINCE CONSTRUCTION WAS COMPLETED. IN ADDITION, THE
COMPUTERIZED CONTROL ROOM WAS UNFINISHED.
68
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Is_sued
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Title
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Issued
- EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN MADE: IG FOLLOWUP STATUS AS OF 9/30/94 [1]
NEW YORK STATE DEPARTMENT OF ENVIRONMENTAL CONSERVATION IS THE
DELEGATED AGENCY RESPONSIBLE FOR DRAFTING THE FINAL DETERMINATION
LETTERS FOR FOUR DIG MEGA-AUDITS OF NEW YORK CITY COVERING 26
GRANTS, $1.4 BILLION CLAIMED COSTS AND $96 MILLION QUESTIONED
COSTS.
= DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION: THE
REGION ANTICIPATES RESOLUTION IN DECEMBER 1994.
IG FOLLOWUP STATUS AS OF 9/30/94 [1]
Regional Administrator - Region 3
P2BWN3-03-0077-4300032 PHILADELPHIA CITY OF PA 3/30/94
Summary: THE CITY OF PHILADELPHIA CLAIMED $10,959,010 OF
INELIGIBLE FORCE ACCOUNT, ENGINEERING, CONSTRUCTION AND INDIRECT
COSTS. AN ADDITIONAL $32,663,495 OF UNSUPPORTED AND $794,684 OF
UNNECESSARY COSTS WERE ALSO QUESTIONED.
- EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN MADE:
THE SIZE AND COMPLEXITY OF THIS MEGA-AUDIT (WHICH INCLUDES SEVERAL
GRANTS) WILL REQUIRE SIGNIFICANT TIME TO RESOLVE.
= DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION: THE
TARGET DATE FOR ISSUANCE OF A MANAGEMENT DECISION IS SEPTEMBER 30,
1995.
IG FOLLOWUP STATUS AS OF 9/30/94 [1]
Regional Administrator - Region 5
P2CWP6-05-0298-2400004 W LAKE SUPERIOR MN 12/12/91
Summary: THE GRANTEE CLAIMED $8,595,588 OF INELIGIBLE
CONSTRUCTION, ENGINEERING AND ADMINISTRATIVE COSTS, AND $166,834
OF UNSUPPORTED COSTS.
Regional Administrator - Region 7
P2CWN1-07-0194-4300029 COLUMBIA MO 2/17/94
Summary: AUDIT IDENTIFIED $53,947 OF INELIGIBLE PROJECT
INSPECTION COSTS, $28,733 OF DUPLICATED CHARGES, $22,972 OF
INELIGIBLE CONTRACTOR CLAIM ANALYSIS COSTS, AND $16,341 OF OTHER
MINOR ITEMS.
- EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN MADE:
THE REGIONAL OFFICE SUBMITTED A FINAL DETERMINATION LETTER FOR THE
DIG TO REVIEW ON SEPTEMBER 28, 1994.
= DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION: THE REGION
EXPECTS RESOLUTION IN THE FIRST QUARTER IN FY 1995.
IG FOLLOWUP STATUS AS OF 9/30/94 [5]
Regional Administrator - Region 8
P5BGL2-08-0089-4100167 STATE OF COLORADO CO I/ 4/94
Summary: WE QUESTIONED $276,188 OF INELIGIBLE PERSONNEL COSTS AND
$33,366 OF INELIGIBLE INTERDEPARTMENTAL TRANSFERS.
- EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN MADE:
A MAP REVIEW WAS COMPLETED JUNE 28, 1994 WHICH WAS A BASIS FOR OUR
PRELIMINARY FINAL DETERMINATION LETTER SENT TO THE DIG AUGUST 10,
1994 FOR CONCURRENCE. THE DIG REJECTED IT AND THE REGION AGREED TO
MAKE CHANGES. THE NEW PRELIMINARY FINAL DETERMINATION LETTER IS
DUE IN DECEMBER 1994.
= DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION: RESOLUTION
IS EXPECTED BY DECEMBER 31, 1994.
IG FOLLOWUP STATUS AS OF 9/30/94 [1]
- EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN MADE: P2CWN1-08-0063-4300005 SOUTH VALLEY UT 10/25/93
THE REGION AND OIG HAVE AGREED ON CONDITIONS OF RESOLUTION. THE Summary: GRANTEE CLAIMED COSTS PREVIOUSLY DETERMINED INELIGIBLE
REGION IS NOW PREPARING THE FINAL DETERMINATION LETTER. FOR GRANT PARTICIPATION AND MATHEMATICAL ERRORS.
= DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION:
RESOLUTION IS EXPECTED IN THE FIRST QUARTER OF FY 1995.
IG FOLLOWUP STATUS AS OF 9/30/94 [3]
E2CWL9-05-0262-3100397 FLINT MI 9/30/93
Summary: FLINT CLAIMED $2.8 MILLION UNNECESSARY/UNREASONABLE
COSTS INCURRED TO RENEGOTIATE A CONTRACT. FLINT CLAIMED
$10,416,828 UNSUPPORTED COSTS FOR ADMINISTRATION, ENGINEERING &
CONSTRUCTION. WE QUESTIONED $415,339 INELIGIBLE ENGINEERING COSTS
INCURRED AFTER CONSTRUCTION COMPLETION DATE.
- EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN MADE
DUE TO CONGRESSIONAL INTEREST AND SINCE OVER $13 MILLION OF COSTS
WERE QUESTIONED, THE REGION PROVIDED THE CITY WITH ADDITIONAL TIME
TO PROVIDE WITH SUPPORTING DOCUMENTATION. ALSO, DUE TO RELATED
LEGAL ISSUES, ASSISTANCE WAS NECESSARY FROM THE OFFICE OF REGIONAL
COUNSEL.
= DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION:
RESOLUTION DATE CANNOT BE DETERMINED AT THIS TIME.
IG FOLLOWUP STATUS AS OF 9/30/94 [3]
E2BWL5-05-0136-7000980 SAUGET IL 3/31/87
Summary: WE QUESTIONED OVER $7 MILLION FOR INELIGIBLE AND
UNNECESSARY PROJECT COSTS.
- EXPLANATION-OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN MADE
THE REGION ISSUED A PROPOSED FINAL DETERMINATION TO THE OIG ON
MARCH 22, 1994. ON APRIL 6, 1994, THE OIG AGREED WITH THE
PROPOSED ACTIONS ON ALL MATTERS EXCEPT THE DECISION TO ACCEPT THE
COSTS ASSOCIATED WITH THE TRANSFER SEWER. THIS AUDIT WAS REFERRED
TO OIG FOR RESOLUTION.
= DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION:
RESOLUTION DATE CANNOT BE DETERMINED AT THIS TIME.
- EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN MADE:
THE MANAGEMENT DECISION WAS DELAYED BECAUSE OF A LACK OF RESOURCES
TO ADDRESS AUDIT RESOLUTION. THE REGION RECEIVED COMMENTS BACK
FROM THE GRANTEE ON QUESTIONED COSTS ON SEPTEMBER 12, 1994. THE
REGION IS REVIEWING DOCUMENTATION FOR DEVELOPMENT OF A PRELIMINARY
FINAL DETERMINATION LETTER FOR NOVEMBER 1, 1994.
= DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION: RESOLUTION
IS EXPECTED BY DECEMBER 31, 1994.
IG FOLLOWUP STATUS AS OF 9/30/94
Regional Administrator - Region 9
[1]
S2CW*8-09-0157-1300112 LOS ANGELES. CITY OF CA 9/25/91
Summary: INELIGIBLE COSTS OF $723,627 INCLUDED: $650,255 OF
UNALLOWABLE FORCE ACCOUNT COSTS AND $73,372 FOR UNALLOWABLE
ENGINEERING COSTS. UNREASONABLE COSTS INCLUDE $879,630 OF
UNDOCUMENTED FIXED ACCOUNT AND $1,099,261 ARCHITECT/ENGINEERING
COSTS INCURRED UNDER PROHIBITED CONTRACT METHOD.
- EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN MADE:
THE OIG AND STATE WATER RESOURCES CONTROL BOARD NOW AGREE ON
ELIGIBILITY DETERMINATIONS SO THAT A LETTER OF DISAGREEMENT WILL NO
LONGER BE NECESSARY. THE BOARD IS MODIFYING THE FINAL DETERMINATION
LETTER ACCORDING TO THE AGREEMENTS AND WILL FORWARD IT TO EPA FOR
SIGNATURE IN OCTOBER 1994.
= DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION: RESOLUTION
IS EXPECTED BY OCTOBER 31, 1994.
IG FOLLOWUP STATUS AS OF 9/30/94 [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
APRIL 1, 1994 THROUGH SEPTEMBER 30, 1994
69
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ELECTRIC MOTORS AND $5,275,186 FOR INADEQUATELY DOCUMENTED FORCE
ACCOUNT COSTS.
- EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN MADE:
THE 01G AND STATE WATER RESOURCES CONTROL BOARD NOW AGREE ON
ELIGIBILITY DETERMINATIONS SO THAT A LETTER OF DISAGREEMENT WILL
NO LONGER BE NECESSARY. THE BOARD IS MODIFYING THE FINAL
DETERMINATION LETTER ACCORDING TO THE AGREEMENTS AND WILL FORWARD
IT TO EPA FOR SIGNATURE IN OCTOBER 1994.
= DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION:
RESOLUTION IS EXPECTED BY OCTOBER 31, 1994.
IG FOLLOWUP STATUS AS OF 9/30/94 [1]
S2CWN9-09-0032-1300118 MONTEREY REG WATER POLL CON CA 9/30/91
Summary: 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 DIG AND THE STATE WATER RESOURCES CONTROL BOARD HAVE HELD
SEVERAL MEETINGS TO RESOLVE AUDIT ISSUES. THE BOARD IS DEALING
WITH A FEW ISSUES AT A TIME IN RESPONSE TO THE DIG. THE BOARD IS
EXPECTED TO WRITE A LETTER OF DISAGREEMENT BY THE FIRST QUARTER OF
FY 1995.
= DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION:
RESOLUTION DATE CANNOT BE DETERMINED AT THIS TIME.
IG FOLLOWUP STATUS AS OF 9/30/94 [1]
S2CW*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 (F/A) ALLOCABLE TO INELIGIBLE
CONSTRUCTION; UNREASONABLE COSTS OF $68,150,598 RELATED TO
EXCESSIVE LANDSCAPING, F/A AND UNUSED FACILITIES.
- EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN MADE:
THE DIG AND STATE WATER RESOURCES CONTROL BOARD NOW AGREE ON
ELIGIBILITY DETERMINATIONS SO THAT A LETTER OF DISAGREEMENT WILL
NO LONGER BE NECESSARY. THE BOARD IS MODIFYING THE FINAL
DETERMINATION LETTER ACCORDING TO THE AGREEMENTS AND WILL FORWARD
IT TO EPA FOR SIGNATURE IN OCTOBER 1994.
= DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION:
RESOLUTION IS EXPECTED BY OCTOBER 31, 1994.
IG FOLLOWUP STATUS AS OF 9/30/94 [1]
S2CWN1-09-0228-2300044 LOS ANGELES, CITY OF CA 3/13/92
Summary: INELIGIBLE COSTS INCLUDED $1,400,564 FOR UNUSED
EQUIPMENT ITEMS; $202,058 FOR UNALLOWABLE ARCHITECT/ENGINEERING
(A/E) FEES; AND $572,354 FOR UNALLOWABLE FORCE ACCOUNT (F/A);
UNREASONABLE COSTS OF $1,010,586 FOR EXCESSIVE A/E AND F/A;
ADDITIONAL $11,188,321 BECAUSE PLANT WAS MOT OPERATING IN
ACCORDANCE WITH PLANT CONCEPTS.
- EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN MADE:
THE 01G AND STATE WATER RESOURCES CONTROL BOARD NOW AGREE ON
ELIGIBILITY DETERMINATIONS SO THAT A LETTER OF DISAGREEMENT WILL
NO LONGER BE NECESSARY. THE BOARD IS MODIFYING THE FINAL
DETERMINATION LETTER ACCORDING TO THE AGREEMENTS AND WILL FORWARD
IT EPA FOR SIGNATURE IN OCTOBER 1994.
= DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION
RESOLUTION IS EXPECTED BY OCTOBER 31, 1994.
IG FOLLOWUP STATUS AS OF 9/30/94 [1]
E2CWN1-09-0092-2300082 RUSSIAN RIVER CSD CA 9/25/92
Summary: COSTS OF $8,344,066 HAVE BEEN QUESTIONED AS INELIGIBLE,
INCLUDING INELIGIBLE CONSTRUCTION ENGINEERING AND FORCE ACCOUNT
COSTS. AN ADDITIONAL $18,297,400 HAVE BEEN QUESTIONED AS
UNNECESSARY BECAUSE THE PLANT WAS NOT FULLY UTILIZED.
Assignment Control
Number
Title
Final Repo
Issu
- EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN M/>
THE REGION AND STATE HAVE SUBMITTED SEVERAL VERSIONS OF A DRA
FINAL DETERMINATION LETTER TO THE DIG. THE OIG SUBMITTED ITS
LATEST COMMENTS ON AUGUST 11, 1994. THE STATE WATER RESOURCE
CONTROL BOARD CONTINUES TO RESOLVE REMAINING ISSUES. THE TAR'
DATE FOR A REVISED FINAL DETERMINATION LETTER IS JUNE 30, 199'
= DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION: RESOLUT
IS EXPECTED BY JUNE 30, 1995.
IG FOLLOWUP STATUS AS OF 9/30/94 [1]
S2CWNO-09-0262-2300089 SAN FRANCISCO, CITY & CO CA 9/30
Summary: INELIGIBLE COST INCLUDE $50,015 OF UNALLOWABLE
ARCHITECT/ENGINEERING (A/E) COSTS AND $271,092 FOR COSTS ALLOCA
TO OTHER FEDERAL FACILITIES RELATED TO UNSUPPORTED CONSTRUCTION
FORCE ACCOUNT COSTS.
- EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN MA
THE OIG HAS AGREED THAT COMPUTER TAPE DATA ARE ACCEPTABLE WITI
EPA COST CURVES BUT WILL NOT ACCEPT THE DATA DESPITE PREVIOUS AUi
RESOLUTION USING SAME TYPE DATA. THE STATE WATER RESOURCES CONT
BOARD SUBMITTED A LETTER OF DISAGREEMENT WITH SUPPORTING
DOCUMENTATION.
= DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION: THE REG
EXPECTS THIS AUDIT WILL BE REFERRED TO HEADQUARTERS FOR RESOLUTI
IG FOLLOWUP STATUS AS OF 9/30/94 [1]
S2CWM9-09-0192-3200056 SAN FRANCISCO, CITY & CO CA 9/30,
Summary: THE AUDIT QUESTIONED COSTS OF $137,651 AS INELIGIBLE ,
$257,228 AS UNSUPPORTED.
- EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN MA
THE OIG HAS AGREED THAT COMPUTER TAPE DATA ARE ACCEPTABLE WITI
EPA COST CURVES BUT WILL NOT ACCEPT THE DATA DESPITE PREVIOUS AUI
RESOLUTION USING SAME TYPE DATA. THE STATE WATER RESOURCES CONTI
BOARD SUBMITTED A LETTER OF DISAGREEMENT WITH SUPPORTING
DOCUMENTATION.
= DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION: THE REG
EXPECTS THIS AUDIT WILL BE REFERRED TO HEADQUARTERS FOR RESOLUTH
IG FOLLOWUP STATUS AS OF 9/30/94 [1]
S2CWNO-09-0073-3300036 SAN FRANCISCO, CITY & CO CA 4/26,
Summary: INELIGIBLE COST OF $493,315 INCLUDES $3,112 OUTSIDE
SCOPE OF PROJECT AND $490,203 NORMAL COST OF GOVERNMENT.
UNREASONABLE COST OF $2,872,442 FOR RECONSTRUCTED FORCE ACCOUI
COSTS NOT SUPPORTED BY ACTUAL SOURCE DOCUMENTATION.
- EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN MA
THE OIG HAS AGREED THAT COMPUTER TAPE DATA ARE ACCEPTABLE WITI
EPA COST CURVES BUT WILL NOT ACCEPT THE DATA DESPITE PREVIOUS AUI
RESOLUTION USING SAME TYPE DATA. THE STATE WATER RESOURCES CONTI
BOARD SUBMITTED A LETTER OF DISAGREEMENT WITH SUPPORTING
DOCUMENTATION.
= DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION: THE REG
EXPECTS THIS AUDIT WILL BE REFERRED TO HEADQUARTERS FOR RESOLUTII
IG FOLLOWUP STATUS AS OF 9/30/94 [1]
E2CWNO-09-0247-3300063 SEWER AUTH. MIDCOASTSIDE CA 9/14,
Summary: INELIGIBLE COSTS OF $581,489 CONSISTED OF $8,405 F<
EXCESSIVE INDIRECT COSTS; $64,815 OF CONTINGENCY RELATED COST!
$187,095 FOR REDESIGN $27,425 PAST COMPLETION DATE; $286,720
ALLOCABLE TO INELIGIBLE CONSTRUCTION AND $7,029 IN EXCESS OF
APPROVAL.
- EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN MA
AS OF SEPTEMBER 19, 1994, THE OIG DISAGREED WITH TWO NOTES IN
DRAFT FINAL DETERMINATION LETTER AND WILL SEND A RESPONSE ON ISS
TO THE STATE WATER RESOURCES CONTROL BOARD. A REVISED FINAL
DETERMINATION LETTER IS TARGETED FOR JANUARY 31, 1995.
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Issued
= DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION:
RESOLUTION IS EXPECTED BY JANUARY 31, 1995.
IG FOLLOWUP STATUS AS OF 9/30/94 [1]
E2BWL3-09-0190-3300072 SAN DIEGO, CITY OF OUTFALL CA 9/29/93
Summary: CITY OF SAN DIEGO CLAIMED $9.1 MILLION OF INELIGIBLE
CONSTRUCTION, ENGINEERING, AND ADMINISTRATIVE COSTS. ANOTHER
$122,810 OF COSTS WERE NOT SUPPORTED AND WERE ALSO QUESTIONED.
- EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN MADE:
THE FINAL DETERMINATION LETTER IS ON HOLD UNTIL THE CITY EXHAUSTS
ITS APPEAL RIGHTS IN THE STATE WATER RESOURCES CONTROL BOARD'S
SECTION 124 APPEAL PROCESS. THE CITY IS APPEALING TWO BOARD
DECISIONS PERTAINING A PAYMENT REQUEST AND THE REPAYMENT OF
INSURANCE PROCEEDS. A REVISED TARGET DATE FOR A FINAL
DETERMINATION LETTER IS JUNE 30, 1995.
= DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION:
RESOLUTION IS EXPECTED BY JUNE 30, 1995.
IG FOLLOWUP STATUS AS OF 9/30/94 [1]
S2CWNO-09-0050-3300078 SAN FRANCISCO, CITY AND CO CA 9/30/93
Summary: INELIGIBLE COST OF $281,859 REPRESENT COST IN EXCESS OF
THE APPROVED AMOUNT. UNSUPPORTED COSTS OF $43,598 RELATE TO FORCE
ACCOUNT COSTS NOT SUPPORTED BY ORIGINAL SOURCE DOCUMENTATION.
- EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN MADE
THE DIG HAS AGREED THAT COMPUTER TAPE DATA ARE ACCEPTABLE WITHIN
EPA COST CURVES BUT WILL NOT ACCEPT THE DATA DESPITE PREVIOUS
AUDIT RESOLUTION USING SAME TYPE DATA. THE STATE WATER RESOURCES
CONTROL BOARD SUBMITTED A LETTER OF DISAGREEMENT WITH SUPPORTING
DOCUMENTATION.
= DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION: THE
REGION EXPECTS THIS AUDIT WILL BE REFERRED TO HEADQUARTERS FOR
RESOLUTION.
IG FOLLOWUP STATUS AS OF 9/30/94 [1]
S2CWNO-09-0076-3300080 LAS VIRGENES MWD CA 9/30/93
Summary: INELIGIBLE COSTS OF $5,091,815 INCLUDES: $42,564 FOR
CONSTRUCTION COSTS NOT INCURRED; $912,643 OF INTEREST EARNED;
$647,791 FOR UNALLOWABLE ARCHITECT/ENGINEERING (A/E) AND
ADMINISTRATIVE; $1,919,244 FOR A/E AND CONSTRUCTION OUTSIDE SCOPE
OF PROJECT $2,289,573 RELATED TO EXCESS CAPACITY AND $757,976
UNREASONABLE A/E.
- EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN MADE
THE STATE WATER RESOURCES CONTROL BOARD IS PREPARING A CASH FLOW
ANALYSIS IN RESPONSE TO AN OIG REQUEST.
Assignment Control
Number
Title
Final Report
Issued
CONSTRUCTION COSTS RELATED TO LATERALS; $140,508 OF
ARCHITECT/ENGINEERING COSTS OUTSIDE THE SCOPE OF THE APPROVED
PROJECT; AND $111,630 OF ADMINISTRATIVE AND FORCE ACCOUNT COSTS N01
SUBSTANTIATED BY ADEQUATE SOURCE DOCUMENTATION.
- EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN MADE
AS OF SEPTEMBER 19, 1994, THE OIG DID NOT ACCEPT NOTES 2B, 3A, &
38. THE REGION EXPECTS TO FORMALLY DISAGREE AND WILL ESCALATE THE
ISSUES TO THE OIG BY MID-OCTOBER 1994.
= DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION: THIS AUDI1
MAY BE REFERRED TO THE HEADQUARTER'S OIG FOR RESOLUTION.
IG FOLLOWUP STATUS AS OF 9/30/94 [1]
S2CWN2-09-0126-4300023 MODESTO, CITY OF CA 1/13/94
Summary: INELIGIBLE COSTS OF $240,784 INCLUDED $62,002 OF
UNALLOWABLE FORCE ACCOUNT AND INDIRECT COSTS; $51,752 OF
CONSTRUCTION COSTS NOT INCURRED; $127,030 OF UNALLOWABLE
ARCHITECT/ENGINEERING FEES. UNSUPPORTED COSTS OF $1,536,132
REPRESENT COST NOT APPROVED BY THE SWRCB.
- EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN MADE
AS OF SEPTEMBER 19, 1994 THE STATE WATER RESOURCES CONTROL BOARD IS
PREPARING THE FINAL DETERMINATION LETTER WHICH SHOULD BE IN THE
SIGNATURE CHAIN BY SEPTEMBER 30, 1994.
= DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION: THE REGION
EXPECTS TO RESOLVE THIS AUDIT IN THE FIRST QUARTER OF FY 1995.
IG FOLLOWUP STATUS AS OF 9/30/94 [1]
E2CWN1-09-0175-4300027 TRUCKEE SAN DISTRICT CA 2/14/94
Summary: COSTS QUESTIONED OF $1,416,122 INCLUDE $13,574 OF
CONSTRUCTION COSTS IN EXCESS OF APPROVED AMOUNT AND $1,402,548 OF
UNALLOWABLE BUY-IN COSTS.
- EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN MADE
ON SEPTEMBER 19, 1994, EPA SENT A PROPOSED FINAL DETERMINATION
LETTER TO THE OIG FOR REVIEW.
= DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION: THE REGION
EXPECTS THE OIG WILL DISAGREE AND THIS AUDIT WILL BE REFERRED TO
THE HEADQUARTER'S OIG FOR RESOLUTION.
IG FOLLOWUP STATUS AS OF 9/30/94 [4]
E2AWT3-09-0138-4400029 CALIFORNIA SRF USAGE CA 2/14/94
Summary: EPA'S FUNDING OF CALIFORNIA'S STATE REVOLVING FUND
PROGRAM EXCEEDED THE STATE'S DEMAND FOR LOANS BY $282.9 MILLION AT
SEPTEMBER 30, 1993. FURTHER, THE STATE HAD NOT AWARDED $23.5
MILLION OF LOANS WITHIN ONE YEAR AS REQUIRED BY THE ACT.
= DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION:
TARGET DATE FOR RESOLUTION IS MARCH 30, 1995.
IG FOLLOWUP STATUS AS OF 9/30/94 [1]
A REVISED - EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN MADE:
THE REGION SIGNED A SUPPLEMENTAL RESPONSE ON SEPTEMBER 16, 1994 AND
SENT IT TO THE OIG. THE REGION AWAITS OIG REVIEW AND ACCEPTANCE.
E2AWT3-09-0082-3400037 SAN DIEGO, CITY OF CA 3/29/93
Summary. THE CITY OF SAN DIEGO HAS CONSTRUCTED AN $11.8 MILLION
LAND OUTFALL WHICH WILL NOT BE USED BY THE CITY FOR THE INTENDED
PURPOSE OF THE GRANT NOR WILL IT BE USED IN THE FORESEEABLE
FUTURE.
- EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN MADE
THE REGION'S ABILITY TO RESPOND TO AUDIT RECOMMENDATIONS IS
RELATED TO COURT ACTION. THE JUDGE REJECTED THE CONSENT DECREE
AND THERE IS NO LONGER A REQUIREMENT TO BUILD SECONDARY TREATMENT.
THE COURT HAS NOT YET CONCLUDED HOW TO MAKE THE CITY COMPLY. THE
REGION IS AWAITING THE COURT OUTCOME TO RESPOND TO THE OIG.
= DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION:
RESOLUTION DATE CANNOT BE DETERMINED AT THIS TIME.
IG FOLLOWUP STATUS AS OF 9/30/94 [2]
E2CWM2-09-0068-4200004 HONOLULU. C&C OF HI 1/19/94
Summary: COST QUESTIONED OF $302,145 INCLUDES $50,007 OF
= DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION: RESOLUTION
DATE CANNOT BE DETERMINED AT THIS TIME.
IG FOLLOWUP STATUS AS OF 9/30/94 [4]
E2AWP9-09-0065-9400025 HOMELAND EARLY WARNING CA 3/31/89
Summary: SPECIAL REVIEW OF CONSTRUCTION GRANT OF WASTEWATER
TREATMENT PLANT FOUND $3,737,139 IN FEDERAL SHARE COSTS QUESTIONED
AN EARLY WARNING LETTER ADVISED THAT COSTS FOR THE COLLECTION
SYSTEM PORTION OF THE PROJECT DID NOT QUALIFY FOR FUNDING BECAUSE
OF THE "2/3 RULE".
- EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN MADE
WITH OFFICE OF WATER POLICY CLARIFICATION ISSUED IN AUGUST 1994,
THE REGION IS NOW PREPARING ITS PROPOSED DETERMINATION TO THIS
EARLY WARNING REPORT.
= DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION: RESOLUTION
DATE CANNOT BE DETERMINED AT THIS TIME.
IG FOLLOWUP STATUS AS OF 9/30/94 [5]
APRIL 1, 1994 THROUGH SEPTEMBER 30, 1994
71
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Assignment Control
Number
Title
Final Report
Issued
Assignment Control
Number
E2AWP9-09-0230-9400043 EARLY WARNING-MARINA CWD CA 9/26/89
Summary: SPECIAL REVIEW OF GRANT TO BUY CAPACITY RIGHTS FROM
REGIONAL WASTEWATER TREATMENT PLANT RESULTED IN AN EARLY WARNING
LETTER TO EPA MANAGEMENT THAT THE AWARD VIOLATED 40 CFR 35 2250
AND THAT TOTAL COSTS QUESTIONED OF $1,694,000 (FEDERAL SHARE
$931,700) WOULD CAUSE "WINDFALL".
- EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN MADE
RESOLUTION OF THIS AUDIT IS LINKED TO THE MONTEREY EARLY WARNING
AUDIT. THE REGION AND DIG ARE DISCUSSING ISSUES TO HELP REACH
RESOLUTION.
= DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION: A FINAL
DETERMINATION LETTER IS EXPECTED BY MARCH 31, 1995.
IG FOLLOWUP STATUS AS OF 9/30/94 [2]
Regional Administrator - Region 10
P2CWL9-10-0002-2100669 PIERCE COUNTY UTILITIES DEP WA 9/30/92
Summary: 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.
THIS INVOLVES REVIEWING 16 GRANTS AND 40 LARGE BOXES OF
DOCUMENTATION OBTAINED FROM VARIOUS SOURCES. THE REGION EXPECTS
TO ISSUE A DRAFT FINAL DETERMINATION LETTER BY NOVEMBER 30, 1994.
= DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION:
RESOLUTION DATE CANNOT BE DETERMINED AT THIS TIME.
IG FOLLOWUP STATUS AS OF 9/30/94 [1]
P2CWN9-10-0107-2300091 FED WAY WATER AND SEW WA 9/30/92
Summary: INELIGIBLE COSTS OF $1,304,725 CONSISTED OF $67,287 FOR
UNALLOWABLE CONSTRUCTION COST, $61,048 RELATED TO INELIGIBLE
CONST. 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 NOT BEEN MADE:
THE REGION IS OBTAINING ADDITIONAL INFORMATION FROM THE AUDITEE
AND STATE TO REVIEW\RESOLVE ISSUE OF GRANT ELIGIBLE COSTS FOR A 30
YEAR PLAN VS A 20 YEAR PLAN. OBTAINING THE ADDITIONAL DOCUMENTS
IS TIME CONSUMING BECAUSE THE PROJECT IS 15 YEARS OLD. THE REGION
WILL ISSUE A DRAFT FINAL DETERMINATION LETTER BY NOVEMBER 30,
1994.
= DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION-
RESOLUTION DATE CANNOT BE DETERMINED AT THIS TIME.
IG FOLLOWUP STATUS AS OF 9/30/94 [1]
P2CWN2-10-0016-3300067 PETERSBURG, CITY OF AK 9/21/93
Summary: INELIGIBLE COSTS OF $215,893 INCLUDES: $8,064 OF
UNALLOWABLE ADMINISTRATIVE; $43,473 OF INELIGIBLE
ARCHITECT/ENGINEERING COSTS; AND $164,356 OF INELIGIBLE
CONSTRUCTION COSTS. COSTS OF $21,877 NOT SUPPORTED BY SOURCE
DOCUMENTATION.
- EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN MADE
THIS IS THE OLDEST CONSTRUCTION SITE IN THE REGION AND THERE HAS
BEEN EXTENSIVE LITIGATION. THE STATE PROJECT FILES AND MUCH OF
THE CITY'S SUPPORTING DOCUMENTATION WERE MISPLACED. THE REGION
SENT A DRAFT FINAL DETERMINATION LETTER TO THE DIG ON MAY 5, 1994.
THE DIG BELIEVES THE RESPONSE IS INCOMPLETE. THE REGION DISAGREES
AND WILL HAVE FURTHER DISCUSSIONS WITH THE DIG.
= DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION:
RESOLUTION DATE CANNOT BE DETERMINED AT THIS TIME.
IG FOLLOWUP STATUS AS OF 9/30/94 [2]
Title
Final Repo
ISSU'
P2CWNO-10-0052-3300069 SEATTLE WA 9/29
Summary: INELIGIBLE COSTS OF $162,801 INCLUDES: $6,904 ALLOCA
TO INELIGIBLE CONSTRUCTION, $155,897 COSTS OUTSIDE SCOPE OF
APPROVED PROJECT. COSTS OF $290,076 NOT SUPPORTED BY ADEQUATI
SOURCE DOCUMENTATION.
- EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN MA
THE REGION IS OBTAINING ADDITIONAL INFORMATION FOR INCLUSION IN
DRAFT FINAL DETERMINATION LETTER. THE REGION WILL ISSUE THE DR
FINAL DETERMINATION LETTER TO THE DIG BY OCTOBER 31, 1994.
= DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION: RESOLUT
DATE CANNOT BE DETERMINED AT THIS TIME.
IG FOLLOWUP STATUS AS OF 9/30/94 [4]
P2CWN1-10-0044-3300075 PORTLAND, CITY OF OR 9/29,
Summary: INELIGIBLE COSTS OF $93,739 INCLUDES: $1,305 OF
UNALLOWABLE INTEREST COSTS; $52,434 OF ARCHITECT/ENGINEERING
ADMINISTRATIVE AND CONSTRUCTION COSTS ALLOCABLE TO INELIGIBLE
CONSTRUCTION; COSTS OF $709,917 NOT SUPPORTED BY ORIGINAL SOUI
DOCUMENTATION.
- EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN MA
THE REGION HAS BEEN GATHERING INFORMATION AND COMMENTS FROM Tl
CORPS OF ENGINEERS AND STATE. THE REGION SUBMITTED A DRAFT FII
DETERMINATION LETTER TO THE DIG ON MAY 5, 1994. THE OIG BELIE'
THAT THE RESPONSE IS INCOMPLETE. THE REGION DISAGREES AND WI1
HAVE FURTHER DISCUSSIONS WITH OIG.
=• DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION: THE REG
EXPECTS RESOLUTION ON NOVEMBER 30, 1994.
IG FOLLOWUP STATUS AS OF 9/30/94 [2]
P2CWN1-10-0049-3300076 SEASIDE, CITY OF OR 9/30/
Summary: INELIGIBLE COST OF $97,155 INCLUDES $7,889 OF
UNALLOWABLE FORCE ACCOUNT AND $89,266 OF CONSTRUCTION COSTS RELA'
TO SERVICE LATERALS, COSTS OF $188,202 NOT SUPPORTED BY SOURCE
DOCUMENTATION.
- EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN MA
THE REGION HAS BEEN OBTAINING INFORMATION, COMMENTS, AND
DOCUMENTATION FROM THE STATE AND WITHIN THE REGIONAL OFFICE. 1
REGION WILL SUBMIT A DRAFT FINAL DETERMINATION LETTER TO THE OIG
NOVEMBER 30, 1994.
= DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION: RESOLUT
DATE CANNOT BE DETERMINED AT THIS TIME.
IG FOLLOWUP STATUS AS OF 9/30/94 [1]
P2CWN1-10-0041-3300077 METROPOLITAN WASTEWTR. MGT. CA 9/30/
Summary: INELIGIBLE COSTS OF $2,511,772 INCLUDES: $26,970 OF Ml
COSTS, $107,481 OF INSURANCE PREMIUMS, $181,880 ALLOCABLE TO
INELIGIBLE PERCENT; $2,195,491 OUTSIDE SCOPE OF PROJECT.
ADDITIONALLY, WE QUESTIONED $6,657,189 WHICH WAS NOT SUPPORTED
ADEQUATE SOURCE DOCUMENTS.
• EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN MAI
THIS PROJECT HAS VERY COMPLEX ISSUES, E.G. SEGMENTATION OF GRAN'
THE REGION IS SEEKING ADDITIONAL COMMENTS AND DOCUMENTATION FR
THE STATE, THE GRANTEE, AND WITHIN THE REGIONAL OFFICE. THE REG]
WILL ISSUE A DRAFT FINAL DETERMINATION LETTER TO THE OIG BY
NOVEMBER 30, 1994.
= DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION: RESOLUT]
DATE CANNOT BE DETERMINED AT THIS TIME.
IG FOLLOWUP STATUS AS OF 9/30/94 [1]
P2CWN2-10-0068-4300013 WASILLA, CITY OF AK 12/15/
Summary: INELIGIBLE COSTS OF $306,738 INCLUDED $182,188 OF co;
ALLOCABLE TO INELIGIBLE PORTION OF CONSTRUCTION; $122,647 OF
UNALLOWABLE ARCHITECT/ENGINEERING COSTS; AND $1,730 OF COSTS
CLAIMED TWICE. COSTS OF $97,346 WERE NOT SUPPORTED BY SOURCE
DOCUMENTATION.
72
OFFICE OF INSPECTOR GENERAL
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Assignment Control Final Report
Number Title Issued
- EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN MADE:
THE REGION, STATE, AND CITY ARE GATHERING ADDITIONAL INFORMATION
AND DOCUMENTATION TO BE USED. THE REGION WILL ISSUE A DRAFT FINAL
DETERMINATION LETTER TO THE OIG ON NOVEMBER 30, 1994.
= DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION:
RESOLUTION DATE CANNOT BE DETERMINED AT THIS TIME.
IG FOLLOWUP STATUS AS OF 9/30/94 [1]
E3BG*6-10-0066-8100761 MOSES LAKE IRR & REHAB DIST WA 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 (FEDERAL SHARE $1,205,039). GRANTEE USED
STANDARD METHODOLOGY INSTEAD OF DEVELOPING NEW INNOVATIVE
TECHNIQUES.
- EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN MADE:
EPA'S AUDIT REVIEW GROUP HAS REVIEWED THE CONTESTED AUDIT ISSUES
AND IS PREPARING A RECOMMENDATION FOR THE AUDIT RESOLUTION BOARD.
= DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION:
RESOLUTION DATE CANNOT BE DETERMINED AT THIS TIME.
IG FOLLOWUP STATUS AS OF 9/30/94 [6]
TOTAL AUDITS ISSUED BEFORE REPORTING PERIOD FOR WHICH NO MANAGEMENT
DECISION WAS MADE DURING THE REPORTING PERIOD: 73
* = Agency procedures do not require the IG's approval on Agency's
Management Decision on an audit (other than a preaward or an
internal and management audit) with the Federal share of questioned
costs of less than $100,000. Therefore, we have not provided a
summary of the audit.
APRIL 1, 1994 THROUGH SEPTEMBER 30, 1994 73
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PIG MAILING ADDRESSES and TELEPHONE NUMBERS
PIG HOTLINE (800) 424-4000 or (202) 260-4977
Headquarters
Environmental Protection Agency
Office of Inspector General
401 M Street, S.W. (2441)
Washington, DC 20460
(202) 260-3137
Atlanta
Environmental Protection Agency
Office of Inspector General
1475 Peachtree Street, NE
Suite 1100
Atlanta, GA 30309-3003
Audit: (404) 347-3623
Investigations: (404) 347-2398
Boston
Environmental Protection Agency
Office of Inspector General
JFK Federal Building (OIG)
(office at 1 Congress St)
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
4411 Montgomery (MS Norwood)
Cincinnati, OH 45268-7001
Audit: (513) 366-4360
Investigations: (312) 353-2507 (Chicago)
Dallas
Environmental Protection Agency
Office of Inspector General (6OIG)
1445 Ross Avenue, Suite 1200
Dallas, TXs 75202-2733
Audit: (214) 655-6621
Investigations: (404) 347-2398 (Atlanta)
Denver
Environmental Protection Agency
Office of Inspector General
999 18th Street, Suite 500
Denver, CO 80202-2405
Audit: (303) 294-7520
Investigations: (312) 353-2507 (Chicago)
Kansas City
Environmental Protection Agency
Office of Inspector General
726 Minnesota Avenue
(office at 630 Minnesota Ave)
Kansas City, KS 66101
Audit: (913) 551-7878
Investigations: (312) 353-2507 (Chicago)
New York
Office of Inspector General
90 Church Street, Room 802
New York, NY 10007
Audit: (212) 264-5730
Investigations: (212) 264-0399
Philadelphia
Environmental 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
Catawba Building
Highway 54, Mail Drop 53
Research Triangle Park, NC 27711
Audit: (919) 541-2204
Investigations: (919) 541-1027
Sacramento
Environmental Protection Agency
Office of Inspector General
650 Capitol Mall, Suite 6309
Sacramento, CA 95814
Audit: (916) 551-1076
Investigations: (415) 744-2465 (SF)
San Francisco
Environmental 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
Environmental Protection Agency
Office of Inspector General
1111 3rd Avenue, Suite 1460
Seattle, WA 98101
Audit: (206) 553-4403
Investigations: (415) 744-2465 (SF)
74
OFFICE OF INSPECTOR GENERAL
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