TD194.6
.E627
1997
350R97°°6
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ANNUAL
SUPERFUND REPORT
TO THE CONGRESS
FOR FISCAL 1996
April 1997
Required by
Section 111(k)of the
Comprehensive Environmental Response, Compensation,
and Liability Act of 1980 (CERCLA),
as amended by the Superfund Amendments and
Reauthorization Act of 1986 (SARA)
OFFICE OF THE INSPECTOR GENERAL
U.S. ENVIRONMENTAL PROTECTION AGENCY
U.S. Environmental Protection Agency
J^n5'Ubrary(PL.12J)
' / west Jackson Boufevard. 12th Flo*
Chicago, ri 60604-3590
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T L
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EPA Office of the Inspector General Annual Super-fund Report to the Congress for Fiscal 1996 i
FOREWORD
This report covers fiscal 1996 activities, and is our tenth Annual Superfund Report to the
Congress. The Superfund Amendments and Reauthorization Act of 1986 (SARA) requires the
Office of the Inspector General (OIG) to audit the Superfund program annually and to report to
Congress annually on these audits.
In addition to reviewing Agency performance, we also take a proactive role to help the
Environmental Protection Agency (EPA) management prevent future problems. During fiscal
1996, we assisted EPA management in a number of ways. We actively participated in the
Agency's Superfund Senior Regional Management Acquisition Council and other meetings to
help the Agency continue to improve its contract procurement and management. We helped
the Agency improve its financial management. We also worked with the Agency as it sought to
improve its information resources management.
The beginning of the Superfund program created new and unique accounting requirements.
Although EPA resolved several previous material internal control weaknesses, it still needed to
make further efforts to complete correction of some weaknesses. In our fifth and latest audit of
the Hazardous Substance Superfund financial statements, we again had to disclaim an opinion
on the financial statements because of material weaknesses in EPA's accounting controls. We
could not determine whether the statements were fairly presented due to weaknesses in the
areas of recording reimbursable Superfund oversight costs as assets, accounting for the
components of net position, and estimating the liability resulting from unbilled grant expenses.
Our reviews of the Agency's performance in managing the Superfund program continue to
indicate that its improvements initiatives appear to help. In a review of the remedial
investigation/feasibility study process at the South Indian Bend Wash "mega-site" in Arizona,
we found the use of the presumptive remedy and plug-in Record of Decision improvements
minimized redundant investigative steps, helped EPA make more consistent site decisions, and
accelerated the cleanup process. Our historical case study of three sites showed the
seriousness of the problems the Agency's initiatives seek to address. Lengthy studies and
enforcement negotiations delayed cleanups for many years, resulting in higher cleanup costs
and continued risks to public health and the environment.
Our major review of the Agency's third largest contractor found that EPA needed to better its
performance to reduce costs and eliminate contract services of questionable value. Two of the
four contracts we reviewed were Superfund contracts. EPA paid the contractor much more in
administrative costs to promote the Local Government Reimbursement program than it paid in
reimbursements to local governments for emergency responses. EPA agreed to explore lower
cost alternatives to promote this program. In the contract for Environmental Services
Assistance Teams, we found that in one region the contractor received positive award fee
evaluations despite deficiencies in its management. In another region, the contractor charged a
high percentage of its hours to program management, including "make-work" assignments, due
to unclear objectives and ill-defined tasks. EPA restructured the follow-on contract to
strengthen its oversight and specifically define program management.
Our review of Federal cleanup activities at the Summitville, CO, Superfund site found that EPA
responded to emergency conditions there by reducing hazardous waste risks. However, EPA
Region 8 did not adequately oversee Interagency Agreements (lAGs) with the Department of
Interior's Bureau of Reclamation (Reclamation) resulting in seven cost overruns totaling nearly
$7.3 million and inefficient cleanup implementation. During our review, the Region issued new
guidance to improve IAG oversight.
Although EPA spent nearly $2 million overseeing the Aerojet General Corporation (Aerojet)
Superfund site, Region 9 had not evaluated the quality of laboratory data used for making
public health risk assessments, developing cleanup alternatives, and designing the remedy.
Aerojet, a major Department of Defense contractor, spent about $100 million on studies and
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EPA Office of the Inspector General Annual Superfund Report to the Congress for Fiscal 1996 ii
cleanup without adequately ensuring the quality of the underlying data or complying with the
data quality requirements in its consent decree with EPA and the State of California. The
Region agreed to improved oversight measures and to require appropriate revisions in Aerojet's
Quality Assurance Project Plan.
Our Superfund investigative efforts continued to produce fines, restitutions, recoveries, and
convictions for fraud and other improper actions of EPA contractors. A major analytical
services laboratory pled guilty to defrauding EPA and other Federal agencies, and was
sentenced to paying more than $1.8 million in fines, restitution, and a special assessment. Two
of the laboratory's employees were also convicted and sentenced. Two other laboratories had
convictions affirmed or settled fraud cases.
The Administration proposed in its fiscal 1998 budget to eliminate the requirement to issue this
report, along with the specific annual audits the report is required to summarize. This report is
largely duplicative of our semiannual reports. Elimination of the specific audit requirements will
allow us to focus our audit efforts each year on those areas where they can be most productive.
We hope the Congress will approve this recommendation.
We will continue to help Agency management deliver the most effective and efficient Superfund
program through a comprehensive program of audits, investigations, fraud prevention, and
cooperative efforts with Agency management.
~CoJL_
Nikki L. Tinsley \
Acting Inspector General C_y
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EPA Office of the Inspector General Annual Superfund Report to the Congress for Fiscal 1996 iii
TABLE OF CONTENTS
PURPOSE 1
BACKGROUND 2
ASSISTANCE TO EPA MANAGEMENT 3
HAZARDOUS SUBSTANCE SUPERFUND 5
EPA Made Improvements in Financial Reporting, but Some Weaknesses Remained .... 5
COOPERATIVE AGREEMENTS, CREDITS, AND GRANTS 7
City of San Bernardino's Accounting System Needed Improvement 7
Oregon Claims More than $300,000 in Ineligible Credits 8
Superfund Technical Assistance Grant Program Seldom Used 9
REMEDIAL INVESTIGATIONS AND FEASIBILITY STUDIES 11
Initiatives Proved Successful at Superfund "Mega-Site" 11
Unnecessary Planning Exercise at Waverly Site 12
CONTRACTS 13
Inadequate Management Led to Ineffective and Costly Programs 14
INTERNAL AUDITS AND SPECIAL REVIEWS 16
Major Delays in Superfund Cleanups Increased Costs and Potential Health Risks 16
Hazardous Waste Risks Reduced, But Inadequate Oversight Resulted in Cost Overruns
and Inefficient Cleanup 17
Superfund Site Laboratory Data Was Questionable 19
INVESTIGATIVE ACTIVITY 21
EXHIBIT 1: SUPERFUND REVIEW REPORTS ISSUED DURING FISCAL 1996 24
APPENDIX: ACRONYMS AND ABBREVIATIONS 29
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EPA Office of the Inspector General Annual Superfund Report to the Congress for Fiscal 1996 1
PURPOSE
We provide this report pursuant to section 111 (k) of the Comprehensive Environmental
Response, Compensation, and Liability Act (CERCLA) of 1980, as amended. The Superfund
Amendments and Reauthorization Act (SARA) of 1986 amended that section of CERCLA to
add several annual requirements for the Inspector General of each Federal agency carrying out
CERCLA authorities. These requirements include four audit areas and an annual report to
Congress about the required audit work. This report covers fiscal 1996 audits of Superfund
activities. We discuss the required four audit areas below.
This report contains chapters on the mandated audit areas, except claims. We also summarize
other significant Superfund audit work, assistance to EPA management, and Superfund
investigative work performed during fiscal 1996. We exceed the statutory requirements by
providing Congress with the significant results of Superfund work beyond that specifically
mandated in section 111 (k).
Trust Fund
CERCLA requires ". . . an annual audit of all payments, obligations, reimbursements, or other
uses of the Fund in the prior fiscal year. . . ." We now meet this requirement through the
financial statement audit required by the Government Management Reform Act.
Claims
CERCLA requires an annual audit to assure ". .. that claims are being appropriately and
expeditiously considered ..." Since SARA did not include natural resource damage claims
as allowable Fund expenditures, the only claims provided in CERCLA, as amended, are
response claims. We did not receive any final response claims to audit during fiscal 1996.
Cooperative Agreements
CERCLA requires audits ". . . of a sample of agreements with States (in accordance with the
provisions of the Single Audit Act) carrying out response actions under this title ..." We
perform financial and compliance audits of cooperative agreements with States and political
subdivisions. Some of our audits also review program performance.
Remedial Investigations/Feasibility Studies (RI/FS)
CERCLA requires our". . . examination of remedial investigations and feasibility studies
prepared for remedial actions ..." Our RI/FS examinations review the adequacy of the
studies to provide a sound technical basis for remedial action decisions. We usually perform
these examinations as special reviews by our technical staff.
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EPA Office of the Inspector General Annual Superfund Report to the Congress for Fiscal 1996 2
BACKGROUND
The Comprehensive Environmental Response, Compensation, and Liability Act of 1980
(CERCLA), Public Law 96-510, enacted on December 11, 1980, established the "Superfund"
program. The purpose of the Superfund program is to protect public health and the
environment from the release, or threat of release, of hazardous substances from abandoned
hazardous waste sites and other sources where other Federal laws do not require response.
CERCLA established a Hazardous Substance Response Trust Fund to provide funding for
responses ranging from control of emergencies to permanent remedies at uncontrolled sites.
CERCLA authorized a $1.6 billion program financed by a five-year environmental tax on
industry and some general revenues. CERCLA requires EPA to seek response, or payment for
response, from those responsible for the problem, including property owners, generators, and
transporters.
The Superfund Amendments and Reauthorization Act of 1986 (SARA), Public Law 99-499,
enacted October 17, 1986, revised and expanded CERCLA. SARA reinstituted the
environmental tax and expanded the taxing mechanism available for a five-year period. It
authorized an $8.5 billion program for the 1987-1991 period. It renamed the Trust Fund the
Hazardous Substance Superfund. The Budget Reconciliation Act of 1990 reauthorized the
program for three additional years and extended the taxing mechanism for four additional years.
Congress has continued to fund Superfund after expiration of the authorization and the taxing
mechanism.
The basic regulatory blueprint for the Superfund program is the National Oil and Hazardous
Substances Contingency Plan (NCP), 40 CFR Part 300. The NCP was first published in 1968
as part of the Federal Water Pollution Control Plan, and EPA has substantially revised it three
times to meet CERCLA requirements. The NCP lays out two broad categories of response:
removals and remedial response. Removals are relatively short-term responses and modify an
earlier program under the Clean Water Act. Remedial response is long-term planning and
action to provide permanent remedies for serious abandoned or uncontrolled hazardous waste
sites.
CERCLA recognized that the Federal Government can only assume responsibility for remedial
response at a limited number of sites representing the greatest public threat. Therefore, EPA
must maintain a National Priorities List (NPL), updated at least annually. The NPL consists
primarily of sites ranked based on a standard scoring system, which evaluates their threat to
public health and the environment. In addition, CERCLA allowed each State to designate its
highest priority site, without regard to the ranking system.
CERCLA section 104(c)(3) does not allow EPA to fund remedial actions unless the State in
which the release occurs enters into a contract or cooperative agreement with EPA to provide
certain assurances, including cost sharing. At most sites, the State must pay 10 percent of the
costs of remedial action. EPA may fund 100 percent of site assessment activities (preliminary
assessments, site inspections), remedial planning (remedial investigations, feasibility studies,
remedial designs), and removals. For facilities operated by a State or political subdivision at
the time of disposal of hazardous substances, the State must pay 50 percent of all response
costs, including removals and remedial planning previously conducted.
CERCLA sections 104(c)(3) and 104(d) authorize EPA to enter into cooperative agreements
with States or political subdivisions to take, or to participate in, any necessary actions provided
under CERCLA. A cooperative agreement serves to delineate EPA and State responsibilities
for actions to be taken at the site, obtains required assurances, and commits Federal funds.
EPA uses cooperative agreements to encourage State participation in the full range of
Superfund activities - site assessment, remedial, removal, and enforcement.
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EPA Office of the Inspector General Annual Superfund Report to the Congress for Fiscal 1996 3
ASSISTANCE TO EPA MANAGEMENT
Besides performing audits and investigations, the OIG responds to EPA management requests
for OIG input in the development of regulations, manuals, directives, guidance and
procurements. These are efforts to prevent problems that might later result in negative audit
findings or investigative results. The OIG reviews and comments on draft documents prepared
by Agency offices. Sometimes OIG staff participate in conferences and EPA work groups to
provide input. Fiscal 1996 was an active year for OIG preventive assistance to EPA
management in the Superfund area. We summarize below some of our major activities
assisting management. We also responded to numerous requests for assistance from the
Agency which did not develop into major projects.
Contracts Management
We actively participated in the Agency's Superfund Senior Regional Management Acquisition
Council, which includes senior representatives of EPA Headquarters and regional program and
contract management staff. We also participated in the Agency's Project Officer/Contracting
Officer Conference. These meetings provided a forum for participants to learn from each other,
and to share success stories and good ideas. Discussions covered such issues as
standardization of user guides, evaluation of future contract needs, and Agencywide issues.
We discussed reports we issued and their effect on Superfund procurement and contract
management. We review the recommendations and programmatic impacts of their
implementation. We encourage EPA officials to give us feedback on the impact our
recommendations have on their day-to-day operations.
Financial Management
Expense Allocation Assist Project. During our audit of EPA's financial statements for fiscal
1995, we identified material weaknesses in the Agency's process for allocating expenses. To
assist the Agency in obtaining an unqualified audit opinion in future years, we helped it to
strengthen its allocation process. We reviewed the Agency's allocation procedures and
provided feedback to ensure that EPA did not double-count Superfund support costs, and that it
maintained adequate supporting documentation for its allocations of expenses. Based on our
review and comments, the Agency agreed to appropriately change the procedures and maintain
supporting documentation for allocated expenses presented on Agency financial statements for
fiscal 1996.
Capitalized Personal Property. During audits of the Agency's financial statements, we found
weaknesses related to the accountability and control of property, including capitalized personal
property. These weaknesses have contributed to our disclaiming an opinion on the Agency's
Superfund financial statements. We volunteered to assist the Agency in taking corrective
actions necessary to ensure fair presentation of Agency capitalized personal property balances
on financial statements for fiscal 1996. We observed the Agency's inventory process to verify
the existence of property items. We also took statistical samples of property items and
obtained source documents to determine if the Agency's property accounting records properly
reflected the cost of the sampled items. As a result of our work, Agency officials agreed to
appropriately adjust the property accounting records and financial statements for fiscal 1996.
Review of Resource Management Directive Material. During fiscal 1996, we reviewed Agency
drafts of two chapters in the EPA's Resources Management Directive 2550D, Financial
Management of the Superfund Program. We reviewed Chapter 11 on Preauthorized Response
Action Claims and Chapter 8 on Local Government Reimbursement for Temporary Emergency
Measures. We offered suggestions to the Agency for improvements in these chapters. Our
suggestions resulted in some changes in the final version of Chapter 11. The Agency had not
issued Chapter 8 in final form when we prepared this Report.
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EPA Office of the Inspector General Annual Superfund Report to the Congress for Fiscal 1996 4
Information Resources Management (IRM)
Several prior audits identified concerns with EPA's IRM program which provides Agency
policies and guidance for Superfund and other programs. During fiscal 1996, we participated in
the IRM Re-engineering Working Session which focused on rethinking major IRM policy areas
and linking them to EPA's Strategic Plan. We also reviewed drafts of several revisions to the
Agency's IRM policies. We reviewed several parts of Directive 2100 which establishes Agency
policies for Telecommunications, Information and Data Management, and Security. We also
reviewed draft Rules of Behavior for general support systems and major applications, as well as
Record Disposition Schedules for Directive 2160, Records Management Manual. During the
course of these reviews we met with Agency IRM officials to discuss ways to improve or
enhance the draft policy documents. We also assisted the Agency in responding to the General
Accounting Office review, SUPERFUND: System Enhancements Could Improve the Efficiency
of Cost Recovery.
During 1996, we worked with the Agency in improving and selecting information systems. We
assisted the Agency in the implementation of upgrades and enhancements to the Agency's
Integrated Financial Management System (IFMS). We provided comments on draft system test
plans, attended the regular IFMS SubRelease meetings, and performed independent integrated
and systems testing. We also introduced monitoring software to several Agency Local Area
Networks (LANs) which access and/or process sensitive Agency data (e.g., financial,
Confidential Business Information). In addition, we participated in the Agency's Travel Re-
engineering Steering Committee, tasked with implementing the best automated travel system
for EPA, integrating changes in regulations, and re-engineering and standardizing our internal
processes. OIG participation resulted in a unified, complementary approach to achieving these
goals while addressing procurement, software and accounting concerns.
Superfund Audit Requirements and Reauthorization
During fiscal 1996, several Congressional committees were considering reauthorization of
CERCLA. We analyzed several drafts of reauthorization legislation for their impact on audit
resources. Inspector General John C. Martin also testified on May 8, 1996, before the
Subcommittee on National Economic Growth, Natural Resources and Regulatory Affairs of the
House Committee on Government Reform and Oversight. The Subcommittee invited the
Inspector General to testify to provide insights into various aspects of the Superfund program to
help it in the reauthorization process.
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EPA Office of the Inspector General Annual Superfund Report to the Congress for Fiscal 1996 5
HAZARDOUS SUBSTANCE SUPERFUND
The Government Management Reform Act requires Federal agencies to prepare annual
financial statements. The Act also requires that the Office of the Inspector General audit the
Agency's financial statements. One of the major entities covered by these financial statements
is the Hazardous Substance Superfund Trust Fund. The EPA OIG's requirement to audit EPA's
financial statements also meets our CERCLA audit requirement to audit annually the Superfund
Trust Fund, which we previously referred to as our Trust Fund audit. The summary below of
our fiscal 1996 financial statement audit concentrates on findings related to the financial
statements of the Hazardous Substance Superfund.
BRA Rit&cle Improvements m Flrianf ial Reporting,
^ i
Findings in Brief
EPA made substantial improvements in its financial reporting, resolving some issues
that caused us to disclaim an opinion on prior Superfund financial statements.
However, we again had to disclaim an opinion on the fiscal 1996 statements due to
continuing material internal control weaknesses in the areas of recording reimbursable
oversight costs, accounting for the components of net position, and estimating unbilled
grant expenses.
We Found That
During fiscal 1996, EPA made substantial progress in improving its financial reporting systems
and practices. The OIG worked with the Agency on a number of projects aimed at improving
the auditability of the Agency's financial statements. As a result of these efforts, we resolved a
number of issues that caused us to disclaim an opinion on prior Superfund financial statements,
such as accounting for property, making payments for grants funded from more than one
appropriation, and allocating expenses to the Trust Fund.
However, we again had to disclaim an opinion on the fiscal 1996 Superfund financial
statements due to material weaknesses in the areas of recording reimbursable oversight costs
as assets, accounting for the components of net position, and estimating at year-end the
amount owed grantees for costs they had incurred but for which they had not billed EPA.
Internal Control Weaknesses
Superfund Oversight Costs. EPA incurs oversight costs to monitor cleanups of hazardous
waste sites. Based on a recommendation in our fiscal 1995 audit report, the Agency attempted
during fiscal 1996 to record unbilled oversight costs as an asset. However, the methodology
developed resulted in excluding some costs that EPA should have included, while including
other costs that it should have excluded.
Superfund Net Position. The budget execution process within the Agency's accounting
system was initially set up to expend funds as though the source of all funds was appropriated
authority. However, Superfund has both appropriated and non-appropriated authority. When
finance officials recorded various transactions for non-appropriated authority, they improperly
impacted the equity, budget, and revenue accounts.
Grant Accruals. We worked with the Agency to develop an alternative approach to obtain
information from its grantees in order to estimate the amount of unbilled grant expenses at
year-end. When we attempted to confirm the information the Agency had obtained, the
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EPA Office of the Inspector General Annual Superfund Report to the Congress for Fiscal 1996 6
information grantees provided us did not agree with the information they had provided the
Agency. Therefore, we were unable to determine whether the accrued grant liability included in
the financial statements was fairly presented. However, it should also be noted that this issue
is a government-wide problem.
Compliance with Laws and Regulations
We did not identify any instances of noncompliance with laws and regulations that would result
in material misstatements to the audited financial statements. There were a number of ongoing
investigations involving EPA's grantees and contractors which could reveal violations of laws
and regulations, but no determination about these cases had yet been made.
We Recommended That
The Acting Chief Financial Officer:
Establish a working group to determine the best methodology for estimating the
amount of unbilled Superfund oversight costs to accrue at year-end.
Work with the Acting Assistant Administrator for Administration and Resources
Management to obtain information needed to fairly present the accrual for grant
expenses in the financial statements.
What Action Was Taken
We issued our final report (7100120) to the Acting CFO on March 24, 1997. We did not request
a response to the final report since the Agency's response to the draft report addressed all our
findings and recommendations.
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EPA Office of the Inspector General Annual Superfund Report to the Congress for Fiscal 1996
COOPERATIVE AGREEMENTS, CREDITS, AND GRANTS
In fiscal 1996, we issued two review reports on Superfund cost share credits and one report on
a cooperative agreement with the Puyallup Indian Tribe. We also issued a performance report
on the Technical Assistance Grants (TAG) program. The combined financial results of these
reviews were as follows:
FINANCIAL RESULTS OF FISCAL 1996 SUPERFUND
COOPERATIVE AGREEMENT AND CREDITS REPORTS
Amount audited
Ineligible costs2
Unsupported costs3
Unnecessary/unreasonable costs4
Federal Share1
$53,000
26,313
0
0
Total Costs
$8,537,931
424,818
132,724
0
1 . Federal share applies only to the Puyallup Indian Tribe cooperative agreement.
2. Costs questioned because of an alleged violation of a provision of a law, regulation, contract, grant,
cooperative agreement or other agreement or document governing the expenditure of funds.
3. Costs questioned because, at the time of the audit, they were not supported by adequate
documentation and/or had not been approved by responsible program officials.
4. Costs questioned because they were not necessary or not reasonable.
We summarize the two State credit reviews and the TAG program perforance review below.
City of San Bernardino's Accounting System Needed Improvement
Findings in Brief
We questioned costs of $61,933 relating to air stripping system pilot tests which Region
9's technical review found ineligible, and "on call" force account costs directly charged
to the project. In addition, we questioned $132,724 of costs as unsupported.
Background
EPA Region 9 requested we audit the costs claimed by the California Department of Toxic
Substance Control (CDTSC) for State cost share credit for the Newmark Ground Water
Contamination Superfund site for the period November 7, 1987 through March 3, 1994.
CDTSC claimed a credit of $5,169,943. The CDTSC credit claim was for costs the City of San
Bernardino Municipal Water Department (City) incurred under an agreement with CDTSC. EPA
added the Newmark site to the National Priorities List on March 31, 1989.
We Found That
We found the system used by the City to account for credit period costs was not adequate, in
all respects, to account for costs incurred under Federally supported programs. We based our
conclusion on (a) errors we detected during our testing of force account labor, (b) inconsistent
treatment of labor costs, and (c) unsupported fringe benefit costs. The City's accounting
system did not adequately support costs as required by Federal regulation. During our audit
fieldwork, the City told us they planned to install an updated computerized accounting system.
Since they had not yet installed it, we were unable to determine its adequacy for accumulating
costs associated with a Federally-funded project.
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EPA Office of the Inspector General Annual Superfund Report to the Congress for Fiscal 1996 8
EPA's technical review of air stripping system pilot tests claimed under the credit determined
that the tests were part of the remedial design, while only remedial action costs are eligible for
credits. Based of the Region's determination, we questioned the $60,829 claimed for pilot test
costs.
We also questioned $1,104 in "On Call" time costs as ineligible. We reviewed three instances
of "Op-Call" time charges on employee time cards. We questioned the need for "On-Call" labor
for this project and found that the City inconsistently handled these charges.
We found that the City's accounting records did not adequately support an additional $132,724
it claimed. The City claimed the bulk of these costs for force account labor.
We Recommended That
The Regional Administrator, Region 9:
Disallow the $194,657 of costs questioned as ineligible and unsupported.
Advise the CDTSC that the City of San Bernardino's accounting system requires
improvement to adequately accumulate and support costs under any EPA-
sponsored program and that EPA's participation in any future project costs will
be limited to documented direct costs until the City implements its new system.
Require the City of San Bernardino to prepare and submit an allocation plan as a
condition of being reimbursed for fringe benefits and indirect costs.
What Action Was Taken
We issued our final report (6300039) to the Regional Administrator, Region 9, on
September 27, 1996. As of April 4, 1997, we had not received a final response from Region 9.
|j^
Findings in Brief
The Oregon Department of Environmental Quality (ODEQ) claimed $336,572 of contract
costs for response at the McCormick & Baxter Superfund site which we found ineligible
because they were: (i) related to investigation or design activities, as opposed to
remedial actions; or (ii) incurred after the National Priorities List (NPL) listing date but
before entering into an EPA cooperative agreement
Background
EPA Region 10 requested we audit the costs claimed by ODEQ for State cost share credit for
the McCormick & Baxter Superfund site for the period August 1, 1990 through May 31, 1994.
ODEQ claimed a credit of $3,314,988. ODEQ initiated interim remedial actions at the site
following a sudden closure of the wood treating plant in October 1991.
We Found That
Based on the EPA project officer's technical determination, we questioned as ineligible
$226,535 for activities related to investigation or design, rather than remedial action. Superfund
legislation and EPA regulations require that costs claimed for credit must be for remedial action
activities.
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EPA Office of the Inspector General Annual Superfund Report to the Congress for Fiscal 1996 £
In addition, we questioned as ineligible contract costs of $110,037 related to change orders
which ODEQ issued after the NPL listing date of May 31,1994; the cutoff date for costs to be
eligible for credit. The State had not obligated funds for these costs before the cutoff date, and
had not entered into a cooperative agreement with EPA before incurring these costs.
According to EPA regulations, a State may only receive credit for costs incurred after NPL
listing if it entered into a cooperative agreement before incurring these costs.
We Recommended That
The Regional Administrator, Region 10 disallow the $336,572 of costs questioned as ineligible
for Superfund State cost share credit.
What Action Was Taken
We issued our final report (6100256) to the Regional Administrator, Region 10 on July 31,
1996. The Regional Administrator concurred with the audit findings in his response, dated
October 17, 1996.
Superfund Technical Assistance <3rant Fi^graps S^fflOfft llseii I |
Findings in Brief
The Agency had not adequately defined Technical Assistance Grant (TAG) program
needs, goals, or performance measures. In addition, EPA inconsistently implemented
and publicized the program, resulting in the award of only a small number of TAGs since
the program's inception.
Background
The Superfund Amendments and Reauthorizatipn Act of 1986 (SARA) authorized the TAG
program to encourage community involvement in the Superfund decision-making process.
Grants of $50,000 are available to local community groups affected by Superfund site activities
to hire technical advisors who monitor and interpret site-specific technical studies. EPA is
responsible for providing information to residents who live near Superfund sites and involving
them in site cleanup decisions.
We Found That
While EPA implemented the TAG program in general compliance with program and regulatory
requirements, program managers had not developed sufficient goals and performance
measures or a long-term strategy to effectively and efficiently manage it. We also found that
the Agency had not conducted a needs survey or identified the number of communities
interested in obtaining a TAG grant.
Although the National Contingency Plan requires that EPA notify an impacted community about
the TAG program and the availability of TAG grants, we found that EPA did not consistently
communicate this information to interested groups. Further, individual regions placed different
levels of emphasis on implementing and prompting the TAG program. This directly correlated
to the number of TAGs awarded and resulted in inconsistent program implementation across
the nation.
Consequently, the TAG program objective of providing local community groups access to
technical advisors at Superfund sites was generally unfulfilled during the seven years of its
existence. There had been only 151 TAGs awarded since 1988 for the more than 1,250
Superfund National Priorities List sites. EPA awarded only $8.2 million of the $33 million
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EPA Office of the Inspector General Annual Superfund Report to the Congress for Fiscal 1996 10
budgeted for TAGs since program inception, and grantees reported spending less than one-half
($3.6 million) of this amount as of the end of fiscal 1994.
We Recommended That
The Assistant Administrator for Solid Waste and Emergency Response:
Conduct a needs survey for the TAG program to determine whether there was
continuing need for the program. If not, EPA could propose elimination of the
program through the upcoming reauthorization of the Superfund statute.
If there is continuing need for the TAG program, aggressively promote the
program and track outreach efforts.
Promote consistent implementation of the TAG program through the
establishment of national program goals, performance measures, a long-term
strategy, and shared best practices.
What Action Was Taken
We issued the final report (6100160) to the Assistant Administrator for Solid Waste and
Emergency Response on March 29, 1996. In response to the final report, the Agency agreed
to publicize the TAG program on the Internet, explore alternative outreach methods, develop a
detailed long-term strategy, and develop performance measures.
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EPA Office of the Inspector General Annual Superfund Report to the Congress for Fiscal 1996 11
REMEDIAL INVESTIGATIONS AND FEASIBILITY STUDIES
In fiscal 1996, we issued two technical reports on remedial investigation/feasibility study (RI/FS)
activities at Superfund sites. The OIG Engineering and Science Staff conducted these reviews.
The reports contained no recommendations, and required no response from the Agency. We
summarize these reviews below.
/'.-,;.': ' ..j
Findings in Brief
Region 9 accelerated the cleanup process and made more consistent site decisions at
the South Indian Bend Wash (SIBW) Superfund site by using the Agency's Presumptive
Remedy and Plug-in ROD Superfund reform initiatives.
Background
The Traditional Superfund Process: The traditional procedure for cleaning up Superfund
hazardous waste sites involves a series of steps, including a feasibility study to evaluate
alternative cleanup remedies and costs, and issuance of a record of decision (ROD) detailing
the selected remedy for the site.
South Indian Bend Wash Site: SIBW covers a three square mile area in Tempe, Arizona.
Ground water was contaminated with volatile organic compounds (VOCs) from contaminated
soil at several businesses.
Presumptive Remedy: Presumptive remedies are the result of EPA analyses showing the
same remedies have been repeatedly selected for certain categories of sites. The Agency has
identified presumptive remedies for several site categories, including landfills, wood-treating
facilities, and soils contaminated with VOCs. If a site currently under investigation falls within
one of these categories, then the Agency presumes what the appropriate remedy will be.
Plug-in ROD: Plug-in ROD is a technique developed by Region 9 for use at Superfund sites
that contain many contamination sources ("mega-sites"), such as SIBW. Each source is
considered a "subsite." Under the Plug-in approach, EPA selects a specific remedy for the
entire site regardless of the number of subsites. If a subsite meets predetermined
contamination and risk related criteria established in the ROD, then it plugs in to the remedy
selected in the ROD for immediate cleanup.
We Found That
Using the Presumptive Remedy of Soil Vapor Extraction for VOCs-contaminated soils, Region 9
minimized redundant investigative steps and made more consistent site decisions.
The Plug-in approach to mega-site remediation accelerated the cleanup process at SIBW by
eliminating the need for a feasibility study and ROD for each subsite. EPA investigated the
subsites individually and simultaneously, so no single subsite held up the overall cleanup.
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EPA Office of the Inspector General Annual Super-fund Report to the Congress for Fiscal 1996 12
Unnecessary Planning Exercise at Waverly Site ; ; :: i ' ||
Findings in Brief
Remedial planning activities at the Waverly Ground Water Contamination Superfund site
in Waverly, Nebraska, were unnecessary, merely validating an Expedited Response
Action (ERA) already in place at the site. However, EPA's actions at the site were
generally consistent with the National Contingency Plan (NCP) and Agency guidance.
Background
Sampling activities at the Waverly site beginning in 1982 revealed wells were contaminated with
several hazardous substances. In March 1987, EPA issued an Engineering Evaluation/Cost
Analysis report recommending an Expedited Response Action (ERA). The ERA included
pumping and treatment of ground water using air stripping and soil gas extraction. EPA began
operation of the ERA in February 1988. The Commodity Credit Corporation, the sole identified
responsible party at the site, took over operation and maintenance of the site in June 1988.
On July 27, 1990, EPA issued a feasibility study (FS) for the site. On September 26, 1990, the
EPA Region 7 Administrator signed a Record of Decision (ROD) for the site continuing the ERA
system with verification of its effectiveness.
We Found That
EPA's actions at the site were generally consistent with the NCP and relevant Agency
guidance. However, the FS only evaluated a no further action alternative and two variations on
continuation of the ERA. Since it only validated the existing treatment system as the
appropriate final remedy, we found the planning exercise to be unnecessary. Furthermore, we
found insufficient information in the Administrative Record and site files to fully explain the
Agency's actions at the site, especially the timing of remedial planning and ROD issuance.
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EPA Office of the Inspector General Annual Superfund Report to the Congress for Fiscal 1996 13
CONTRACTS
The OIG is responsible for conducting and supervising independent and objective audits of
Superfund programs and operations. To carry out this responsibility, the OIG performs financial
and compliance audits and special reviews of EPA contractors. Each Public Law authorizing
EPA to award contracts provides the Agency authority to audit and examine the books and
records of the contractors and subcontractors receiving Federal funds. Each EPA contract also
contains audit provisions. Our primary audit objectives are to determine (1) whether the
controls exercised by the contractors and subcontractors through their accounting,
procurement, contract administration, and property management systems are adequate to
account for costs claimed; and (2) costs claimed are reasonable, allowable, and allocable, in
accordance with applicable laws and regulations, to the sponsored project.
Audits of contracts not only yield financial benefits to the Agency, but also aid in improving
Agency management. These audits also play an integral part in supporting EPA's cost recovery
actions.
Of the 95 contract reports we issued in fiscal 1996, 47 covered incurred costs under EPA
contracts. The combined financial results of these reviews were as follows:
FINANCIAL RESULTS OF FISCAL 1996 SUPERFUND
INCURRED COST CONTRACT REPORTS
Amount audited
Ineligible costs1
Unsupported costs2
Unnecessary/unreasonable costs3
Federal Share
$409,803,932
3,612,197
1,754,194
0
Total Costs
$412,711,226
3,612,197
1,754,194
0
1 . Costs questioned because of an alleged violation of a provision of a law, regulation, contract, grant,
cooperative agreement or other agreement or document governing the expenditure of funds.
2. Costs questioned because, at the time of the audit, they were not supported by adequate
documentation and/or had not been approved by responsible program officials.
3. Costs questioned because they were not necessary or not reasonable.
Another 26 of our reports were initial pricing reviews in which we reviewed costs proposed by
offerers or bidders seeking EPA contract awards. Because these are only proposed costs, our
reviews do not question costs but rather recommend as efficiencies costs that we believe EPA
should not incur. The combined financial results of the initial pricing reviews were as follows:
Total Costs Audited $1,816,533,938
Total Recommended Efficiencies $44,803,674
We also issued 7 reports on proposed indirect cost rates, 14 system survey reports, and 1
program review report on EPA contractors.
The OIG can choose to have the reviews performed by in-house staff, independent public
accounting firms or another Federal audit agency. During fiscal 1996, our Superfund contract
reviews were performed as follows:
By OIG Staff 27
By Defense Contract Audit Agency 67
By Independent Public Accountants 1
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EPA Office of the Inspector General Annual Superfund Report to the Congress for Fiscal 1996 14
Exhibit I contains a listing of all Superfund reports issued by the DIG during fiscal 1996.
We also conduct performance reviews of EPA's management of contracts and procurement.
During fiscal 1996, we issued one such report, which we summarize below.
Management of Major Contractor Neeclffil Improvement |
Findings in Brief
EPA needed to better manage performance of a major contractor to reduce costs and
eliminate contract services of questionable value.
Background
We reviewed four contracts held by the Agency's third largest contractor, of which two were
Superfund contracts. The Superfund contracts supported two programs: (1) "Local
Government Reimbursement," a program that reimburses municipalities for carrying out
temporary emergency measures; and (2) the Zone II Environmental Services Assistance
Teams (ESAT), which perform analytical services at EPA laboratories.
We Found That
The administrative costs to promote EPA's "Local Government Reimbursement" (LGR) program
were unreasonable in relation to the low response from local governments for funding. During
fiscal 1995, EPA reimbursed approximately $95,000 to four local governments, yet paid more
than $300,000 for contracts to administer the program. EPA paid the contractor to arrange
logistics and prepare audiovisual materials for workshops to promote the LGR program. The
workshops did not appear to have significantly increased the number of requests from local
governments for funding. Therefore, it may be more cost-effective for EPA to use other
alternatives, such as making the existing fact sheet (which explains the program and how to
apply for reimbursement) more available to local governments, to promote the program.
Despite deficiencies in the prime contractor's management of the Region 7 ESAT team, the
contractor received positive award fee evaluations. In addition, the Region 8 ESAT team
charged a high percentage of hours (33 percent in one fee evaluation period) to program
management, including several "make work" assignments, due to unclear objectives and ill-
defined tasks.
We Recommended That
The Assistant Administrator for Solid Waste and Emergency Response:
Curtail the use of costly workshops to promote the program and instead use
material such as the "LGR Fact Sheet" to inform local governments about the
program.
Eliminate all contractor efforts to promote or administer the "Local Government
Reimbursement" program.
The Assistant Administrator for Solid Waste and Emergency Response and the Acting Assistant
Administrator for Administration and Resources Management:
Revise the ESAT contracts to specifically define program management.
Monitor program management costs.
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EPA Office of the Inspector General Annual Superfund Report to the Congress for Fiscal 1996 15
Caution Regional Project Officers not to issue "make-work" assignments.
Reduce the size of the Region 8 ESAT.
What Action Was Taken
We issued the final report (6100161) to the Acting Assistant Administrator for Administration
and Resources Management, the Assistant Administrator for Solid Waste and Emergency
Response, and the Assistant Administrator for Air and Radiation on March 30, 1996. In the
Agency's January 8, 1997, response to the final report, it agreed to explore alternatives to using
workshops to promote the LGR program. However, EPA disagreed with the recommendation
to use the "Fact Sheet" as a means of informing local governments about the program because
it believed hands-on training would better serve potential applicants. EPA also disagreed with
the recommendation to eliminate contractor efforts to promote the program, stating that
contractors assist the Agency in its outreach efforts.
The Agency restructured the new ESAT contract as a work assignment contract to strengthen
oversight of contractor program management and other activities. EPA also revised the
contract statement of work to specifically define program management. In addition, EPA
reduced the size of the Region 8 ESAT Team in the follow-on contract. These actions
adequately addressed the related recommendations.
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EPA Office of the Inspector General Annual Superfund Report to the Congress for Fiscal 1996 16
INTERNAL AUDITS AND SPECIAL REVIEWS
In addition to reviews required by CERCLA, as amended, we conduct other reviews of EPA's
management of the Superfund program. We summarize below some particularly significant
internal audits and special reviews completed in fiscal 1996 not summarized elsewhere in this
Report.
Major Delays in Superfund Cleanups Increased Costs and
Health Risks ;-'. "h.!:!-.- "''; ''V :'<'='!' =;!'.. =' -\- ": ! ' '''
I
Findings in Brief
Despite identification between 12 and 15 years ago, the three Superfund sites we
reviewed were still not cleaned up. The prolonged time spent studying sites and
designing remedies resulted in higher cleanup costs and continued risks to public
health and the environment.
Background
We evaluated the history and chronology of activities at three Superfund sites to identify
examples of the barriers encountered during the cleanup process. We selected sites based
primarily on recommendations from EPA regional offices, stage of cleanup, geographic location,
and the existence of significant delays in the cleanup. We will use the information, in
conjunction with our other work, to develop a long-term audit plan for Superfund.
We Found That
In general, lengthy remedial investigation/feasibility study and enforcement negotiations
delayed actual cleanup of sites. Studying the sites and designing cleanup remedies accounted
for about 75 percent of the time since the sites were discovered. Community, state,
congressional, and potentially responsible party objections to the remedy selected also caused
delays. In addition, the requirements of the Comprehensive Environmental Response,
Compensation, and Liability Act and its 1986 amendments resulted in more focus on achieving
process steps rather than the cleanup of sites.
The Whitmoyer Laboratories site in Myerstown, PA, entered the Superfund cleanup pipeline in
1984. Although some actions had been taken to prevent further threats to public health and the
environment, others had not. For example, in 1988, EPA planned a time-critical removal of an
on-site vault containing about four million pounds of hazardous waste, due to sampling activities
which indicated extremely high concentrations of arsenic in the soil, ground water and surface
water surrounding the vault. The proposed removal action called for excavating the vault
wastes and transporting them to a secured landfill at a cost of about $3 million. However, the
removal did not take place, and the remedial program is handling the vault cleanup at an
estimated cost of around $18 million. Agency officials attributed this cost increase to the land
ban requirements, promulgated after the proposed removal. As of June 1995, when we
completed our site review, the vault and its contents were still on-site.
The Wasatch Chemical site in Salt Lake City, UT, was discovered in 1980 and estimated to
have construction completed by 1995, but was not yet fully cleaned up at the time of our review.
From 1981 to 1985, state sampling showed that the ground water at the site was contaminated
with toxic chemicals. The suspected source was an on-site evaporation pond used for
containing process wastes. In 1985, EPA proposed further investigation and possible removal
of the pond, but neither occurred. For the next ten years, EPA conducted enforcement
negotiations and two removal actions, completed the site studies, and began the remedial
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EPA Office of the Inspector General Annual Superfund Report to the Congress for Fiscal 1996 17
action. In 1994, EPA began the cleanup of the evaporation pond using innovative technology.
Because of uncertainties involved with this technology, cost estimates at the site had nearly
doubled, from $3.3 million to $6.3 million.
EPA discovered the Southern Maryland Wood Treating site in Hollywood, MD, in 1981, and
although $30 million had been spent on removal and remedial actions, the site was still not
cleaned up at the time of our review. Partially due to community and political pressure, EPA
halted work on a 95 percent completed remedial design in 1992 and the Agency was forced to
reevaluate remedial alternatives and adopt a less costly remedy. While the estimated cost for
the new remedial action was less than the original one, this change resulted in lengthening the
overall cleanup process. Although community involvement is important and necessary to
ensure acceptance of the remedy, it has the potential to increase the time and cost of site
cleanups.
We Recommended That
We made no recommendations since the case studies were designed to support a long-range
audit plan for evaluating and targeting ways of reducing future cleanup delays.
What Action Was Taken
Since no written response was required from Agency officials, we closed our report (6400016)
upon issuance to the Assistant Administrator for Solid Waste and Emergency Response and
the Assistant Administrator for Enforcement and Compliance Assurance on November 29,
1995.
Hazardous Waste iRisfcs Reduced* But Inadequate Oversight Resulted
' ^n^Jwert^ent^leari^;; '; 7. ^-rr^'rr:^,,:,:"::;-;;
Findings in Brief
EPA Region 8 responded to the Summitville, CO, Superfund site emergency in a
widespread, but remote, area by reducing hazardous waste risks. However, the Region
did not adequately oversee Interagency Agreements (lAGs) with the Department of
Interior's Bureau of Reclamation (Reclamation) resulting in seven cost overruns totaling
nearly $7.3 million and inefficient cleanup implementation.
Background
In December 1992, the Summitville Consolidated Mining Company, Inc., filed for bankruptcy
and abandoned an open-pit mining operation used to recover gold and silver from mined rock.
At the request of the Colorado Department of Health, EPA Region 8 assumed responsibility for
cleaning up the Summitville mining site and entered into an initial IAG with Reclamation to clean
up the site. By July 1995, Region 8 had obligated more than $96 million for five Reclamation
lAGs, and estimated total site cleanup costs at $120 million.
We Found That
Region 8 reduced hazardous waste risks from the Summitville site. However, the Region did
not adequately oversee and monitor Reclamation to ensure efficient cleanup:
It did not enforce IAG terms and conditions requiring Reclamation to submit current
monthly progress and cost reports. The reports were often late and did not accurately
identify costs by IAG budget categories. As a result, Reclamation overran IAG cost
ceilings seven times, once by $5.2 million.
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EPA Office of the Inspector General Annual Superfund Report to the Congress for Fiscal 1996 18
It did not properly project future Summitville funding needs or elevate funding problems
when Headquarters staff delayed funding requests.
It approved IAG payments without documentation supporting the allowability and
reasonability of costs, and routinely approved Reclamation payment requests
consisting of a single dollar figure without reviewing required monthly reports
supporting reimbursement. For example, Region 8 unknowingly reimbursed
Reclamation for an ineligible financing fee included in a single lump sum request.
It did not make sure Reclamation used contracting methods which would keep cleanup
costs down. It did not encourage Reclamation to use fixed-price contracts or delivery
orders whenever practicable, and did not document the basis for Reclamation using
time-and-materials delivery orders. Region 8 and Reclamation created an
unnecessary layer of general and administrative expenses and unnecessary profit by
allowing Reclamation's contractor to procure subcontractors for some cleanup on two
delivery orders.
It created a new contract vulnerability by allowing Reclamation to award both a fixed-
price construction contract and a related site-support time-and-materials delivery order
to the same contractor. This provided the contractor with an opportunity to avoid
losses and/or maximize profits by mischarging costs incurred on the fixed-price
contract work to the time-and-materials delivery order.
We Recommended That
The Regional Administrator, Region 8:
Instruct Regional project managers to closely monitor Reclamation's compliance with
the Summitville IAG terms and conditions and take appropriate action.
Instruct staff to elevate IAG funding delays to an appropriate management level to
ensure adequate funding availability.
Establish Regional controls over all IAG payment requests so that Regional project
managers do not approve payments without adequate supporting documentation.
Encourage Reclamation to definitize Summitville cleanup tasks, cease the use of time-
and-materials delivery orders, and establish fixed-price contracts to the extent
practicable as soon as possible.
Evaluate the adequacy of Reclamation's controls to prevent its contractor from
mischarging direct costs of the fixed-price construction contract to an open time-and-
materials delivery order.
What Action Was Taken
During our review, the Region issued new guidance to improve IAG oversight. We issued the
final report (6400019) to the Regional Administrator, Region 8, on January 22, 1996. In its final
response to our report dated February 28, 1997, the Region indicated it had closed the existing
lAGs and replaced them with new lAGs conforming to its new guidance. In this and earlier
responses, it also indicated it had taken other steps to meet the intent of the report
recommendations.
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EPA Office of the Inspector General Annual Superfund Report to the Congress for Fiscal 1996 19
Superfund Site Laboratory Data Was Questionable ; | |
Findings in Brief
Although EPA spent nearly $2 million overseeing the Aerojet General Corporation
(Aerojet) Superfund site, Region 9 had not evaluated the quality of laboratory data used
for making public health risk assessments, developing cleanup alternatives, and
designing the remedy.
Background
Aerojet is a major Department of Defense contractor that develops and manufactures solid and
liquid propelled rocket motors in Rancho Cordova, California. In 1979, ground water
contamination was discovered in several private wells surrounding Aerojet's 8,500-acre facility,
and EPA listed the site on its National Priorities List in 1982 as one of the 10 highest risk sites.
In a 1989 consent decree, Aerojet agreed to complete a remedial investigation and feasibility
study, identify potential remedies and costs, and monitor contamination. Region 9 is
responsible for approving the quality assurance project plan (QAPP), monitoring compliance
with the QAPP, and verifying that work complies with the consent decree. The QAPP is the
primary vehicle for ensuring that environmental data is of sufficient quality and quantity for
decision-making.
We Found That
Aerojet spent about $100 million on studies and cleanup without adequately ensuring the quality
of the underlying data or complying with the data quality requirements in its consent decree with
EPA and the State of California. Region 9 spent nearly $2 million overseeing this site, but had
not evaluated the quality of laboratory data Aerojet collected for making public health risk
assessments, developing cleanup alternatives, and designing the remedy.
Adequate data quality objectives, which are the basis for preparing the QAPP, had not been
developed. Aerojet did not include several quality assurance activities including data validation
requirements, independent laboratory audits, frequency of performance evaluation samples,
and maintenance of magnetic media, in its QAPP. Further, the Region had not approved the
QAPP and did not ensure that Aerojet met data validation requirements for historical and recent
data, even though they are necessary for determining data quality. As a result, the database
inaccurately reflected much of the historical data, and recent data was of questionable quality.
Aerojet generally did not comply with the QAPP and related consent decree requirements. It
did not perform annual laboratory audits, submit performance evaluation samples, prepare
quarterly quality assurance reports since 1993, or conduct annual quality assurance audits.
Also, the Region and state regulatory agencies had not established responsibilities for
monitoring the quality of laboratory data, and neither state agency had taken any specific steps
to monitor data quality since they believed EPA was responsible for ensuring data quality.
We Recommended That
The Regional Administrator, Region 9, monitor the quality of laboratory data produced for the
Aerojet cleanup by:
Ensuring data quality objectives are effective.
Including key quality assurance activities in the QAPP.
Monitoring compliance with the QAPP.
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EPA Office of the Inspector General Annual Superfund Report to the Congress for Fiscal 1996 20
What Action Was Taken
We issued the final review report (6400044) to the Regional Administrator, Region 9, on
March 28, 1996. In its responses dated August 29, 1966, and September 26, 1996, the Region
agreed to improved oversight measures and to require appropriate revisions in Aerojet's QAPP.
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EPA Office of the Inspector General Annual Superfund Report to the Congress for Fiscal 1996 21
INVESTIGATIVE ACTIVITY
During fiscal 1996, pur Superfund investigative efforts resulted in one indictment and one
conviction. In addition, OIG investigations led to eleven civil/administrative actions. Monetary
fines, restitution, and recoveries totaled more than $2.5 million. At the end of fiscal 1996, we
had 49 active Superfund investigations, 31 percent of all active OIG investigations at EPA.
The OIG Office of Investigations (Ol) is continuing a major proactive investigative effort in the
Superfund program. The Ol continues to focus on all stages of the Superfund program, with a
special emphasis on contracting for removals and remediation. As a result of Ol proactive
efforts in prior years, we continue to initiate criminal investigations across the nation. We have
also seen a corresponding increase in the number of civil cases filed as a result of this
investigative activity. We expect to see an increase in significant civil actions as Ol's
investigative emphasis on major Agency contracting continues to increase.
We give examples of Superfund investigative activity with results in fiscal 1996 in the following
synopses.
Former California Lab Manager and Director Sentenced
Eureka Laboratories, Inc. (Eureka), of Sacramento, California, pled guilty in May 1995 of
conspiracy to defraud the United States and was sentenced in December 1995 to 60 months
probation, a fine of $1.5 million, restitution of $322,422, and a special assessment of $1,600.
Eureka is an analytical services laboratory hired by various government agencies, including
EPA, the Army, the Air Force, and the Navy, to test numerous water, soil, and air samples for
environmental pollutants and toxins in connection with the remediation of hazardous waste
sites. The contracts required specific laboratory procedures, such as tuning, calibration, and
performance testing of laboratory equipment, to ensure accurate and reliable data.
In November 1995, Chung Li, former Eureka Director of Laboratory Services, was sentenced to
24 months incarceration, followed by 36 months supervised probation, 250 hours of unpaid
community service, and a $400 special assessment. A special condition of probation prohibited
Li from employment involving chemical analyses for Government contracts unless the employer
has implemented a fully operational Quality Assurance/Quality Control procedure reviewed by
the probation officer. In December 1995, Kuen Lee, former Eureka laboratory manager, was
sentenced to five months incarceration, followed by 36 months supervised probation, 250 hours
of unpaid community service, 5 months' participation in a residential community correction
center, and a $400 special assessment. Lee is subject to the same special condition of
probation regarding employment as Li. The former employees had been tried and convicted of
conspiracy to falsify analytical test results and calibration of its laboratory equipment
compromising the accuracy and reliability of the test results vital to the successful identification
of hazardous substances and the remediation of hazardous waste sites.
The EPA Office of Inspector General, the U.S. Army Criminal Investigation Command, the U.S.
Air Force Office of Special Investigations, and the California Environmental Protection Agency
conducted this investigation.
Former ERCS Contractor Agreed to $589,000 Settlement
On May 6, 1996, OHM Remediation Services (OHM), an EPA Emergency Response Cleanup
Services (ERCS) contractor, agreed to pay $589,000 as part of a civil settlement with the
Government. This agreement was reached after an investigation of information that OHM and
some of its subcontractors had allegedly double-billed and over-billed costs relative to the
cleanup of the Fiske Superfund site in Nitro, West Virginia. Wastron, Inc. a subcontractor,
double-billed some costs, was paid twice in some instances and billed unsubstantiated off-
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EPA Office of the Inspector General Annual Superfund Report to the Congress for Fiscal 1996 22
specification charges for disposal of hazardous wastes. Also, OHM double-billed and over-
billed Wastron costs and other subcontractor costs to the government.
Firm and President Re-Sentenced; Consent Agreement Signed
EPA contracted with T. Head and Company, Inc. (THI), of Herndon, Virginia, to establish and
monitor national accounts for shipping laboratory samples of hazardous waste and other
materials to certain contract laboratories for analysis. The cost-plus fixed-fee contract had a
value of more than $2 million. The investigation revealed that Toney Head, Jr., the firm's
owner, president, and chief executive officer, personally directed four former THI employees to
falsify records showing the number of hours the employees worked on the EPA contract. Head
used the false information to inflate numerous THI invoices submitted to EPA. In August 1994,
THI and Head were found guilty of submitting 41 false claims to EPA. They were sentenced in
October 1994. Head appealed both convictions. On February 12, 1996, the U.S. Court of
Appeals affirmed the convictions on 39 counts, and remanded the case for re-sentencing. On
April 19, 1996, the District Court re-sentenced Head to 6 months home detention, 2 years
supervised probation, $1,950 in restitution, and a $1,950 special assessment. The Court
ordered THI to pay a $9,750 fine and a $7,800 special assessment.
In addition, a civil suit was filed against both THI and Head. In October 1995, Head signed a
consent agreement to settle the civil case for $109,750, which included $100,000 for the civil
damages and $9,750 for special assessments. Also, in February 1996, EPA, THI, and Head
entered into a 3-year compliance agreement terminating THI and Head's suspensions. The
respondents consented to a period of debarment until June 24, 1997, or the satisfactory
completion of a compliance audit of THI, whichever came first. THI further agreed to conduct
ethics training for its officers and employees, appoint an independent Ethics Compliance
Officer, and establish a hotline for complaints. The agreement also provided for EPA annual
compliance audits for three ye,ars. The terms of the agreement will apply to any successor
company THI or Head acquires or in which Head becomes an officer if that company works on
or may work on federally funded projects.
LNS Environmental Services Settled Fraud Case
LNS Services, Inc. (LNS), and Niranjan G. Shah, LNS' owner and president, entered into an
agreement with the United States Attorney's Office for the Eastern District of Texas to pay
$9,000 to settle a civil False Claims Act case. The agreement and payment resulted from an
OIG investigation relating to LNS' submission of a fraudulent invoice for testing samples from a
Superfund site. EPA paid LNS $4,687 on the fraudulent invoice.
Additional Suspensions, Debarments, or Compliance Agreements Resulting from
Investigative Activity
In November 1995, EPA suspended Pauline M. Ewald, President, Environmental Compliance
Organization (ECO). In its proposals to obtain contracts from the recipients of Superfund
Technical Assistance Grants, ECO submitted false resumes by misrepresenting degrees and
professional certification, including those for people not employed by ECO. Superfund
Technical Assistance Grants support community involvement in the cleanup of hazardous
waste sites.
In March 1996, EPA suspended the National Environmental Testing Laboratory, Santa Rosa
Division (NET-SR), pending the completion of an investigation involving the propriety of
laboratory practices on which the results of analyses were based. NET-SR performed
laboratory analyses of soil and water samples for the EPA Superfund program, and for the
Departments of the Army and Navy. In July 1996, EPA entered into a compliance agreement
with NET-SR to refrain from further debarment proceedings provided that NET-SR (1)
implements a corporate compliance program to review complaints of employee violations of
law, NET-SR's laboratory protocols, Quality Assurance Plan, and Code of Ethics, (2) conducts
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EPA Office of the Inspector General Annual Superfund Report to the Congress for Fiscal 1996 23
ethics training, (3) implements an annual certification program for all analytical/technical
employees in appropriate test methods and procedures, (4) institutes controls, including
improvements to operating procedures and conducting internal audits, to ensure the quality of
the work product, and (5) terminates from working on Federal government contracts any
employee found to have committed an improper act. Prior to the agreement, NET-SR had
taken various corrective actions, including terminating or suspending all employees who
falsified analytical data.
In May 1996, EPA issued a notice of proposed debarment to Revet Environmental & Analytical
Laboratory, Inc.; Dr. Virginia Taylor, its President; and Edward Taylor, its Laboratory Director,
for unsatisfactory performance under the Contract Laboratory Program. Revet's work did not
meet EPA standards for quality and timeliness. Revet had also misrepresented work
conducted by a subcontractor as its own on a contract with the State of Massachusetts.
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EPA Office of the Inspector General Annual Superfund Report to the Congress for Fiscal 1996 24
SUPERFUND REPORTS
ISSUED DURING FISCAL 1996
Exhibit 1
Page 1of5
Final
Report
Number Description
Date
Audit Report
Control Number Issued
Internal and Management Reports
1
Reviews Related To Statutory Requirements (other than IG Act)
6100200 Financial Statements - Fiscal 1995 - All EPA E1SFL5-20-8001
6400057 Financial Statements - Fiscal 1995 - Cincinnati E1SFP5-23-8000
6400058 Financial Statements - Fiscal 1995 - Region 5 E1SFP5-05-8000
6400008 Response Claim - Re-solve, Inc., MA E9HFP4-01-0147
6400061 RI/FS Review - South Indian Bend Wash, AZ E1SGG5-14-0010
6400054 RI/FS Review - Waverly Ground Water, NE E1SGG4-14-0019
Other Performance Audits
6100161 Management of a Major EPA Contractor
6100160 Technical Assistance Grant Program
Other Special Reviews
6400029 Billing and Collection of Oversight Costs
6400044 Data Quality Oversight - Region 9 - Aerojet, CA
6400067 Project Officer 0/S of lAGs with Army COE - Region 7
6400016 Site Cleanup Barriers - Case Studies
6400019 Summitville, CO Site Response Oversight
E1SKF5-03-0070
E1SFF5-09-0021
E1SFP6-11-0017
E1SKG5-09-0110
E1SGB6-07-0016
E1SFB5-11-0008
E1SFG5-08-0032
5/ 3/96
5/31/96
5/31/96
21 5/96
6/10/96
5/ 7/96
3/30/96
3/27/96
21 6/96
3/28/96
6/19/96
11/30/95
1/22/96
Cooperative Agreement Report
6100060 Puyallup Tribe - Commencement Bay, WA Site Assistance E5CGL5-10-0053 21 8/96
State Credit Reports ; !
6300039 CA -
6100256 OR -
Newmark Site
McCormick and
Baxter Site
E5HGN5-09-0094
E5HGL6-10-0010
\
9/27/96
7/30/96
Interagency Agreement Reports
6100072 Agency for Toxic Substances & Disease Registry - FY94
6100009 Army Corps of Engineers - Fiscal 1994
6100073 Nat'l Inst. of Env. Health Sciences- Fiscal 1994
H5BFL6-20-0015 11/30/95
M5BFL5-20-0016 10/ 4/95
H5BFL6-20-0015 11/30/95
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EPA Office of the Inspector General Annual Superfund Report to the Congress for Fiscal 1996 25
SUPERFUND REPORTS
ISSUED DURING FISCAL 1996
Exhibit 1
Page 2 of 5
i
Final
Report
Number Description
Date
Audit Report
Control Number Issued
Initial Pricing Reviews
6100064 Aneptek Corp., MA
6100225 Black & Veatch Special Projects Corp., MO
6100071 Brown and Root Environmental, TX
6100075 CH2M Hill, Inc., CO
6100119 CH2M Hill. Inc., CO
6100165 Community Relations Plus, GA
6100068 Diversified Tech Corp., CT
6400059 Ecology & Environment, Inc., NY
6100184 Foothills Engineering, Inc., CO
6100097 Foster Wheeler Environmental Corp., NJ
6100243 Kimball & Associates. PA -Accounting System Eval .
6400050 Malcolm Plrme, Inc.. NY
6100069 Metcalf and Eddy, Inc., MA
6100067 Nobis Engineering, NH
6400047 PRC Environmental Management, IL - FY96 Billing Rates
6400017 PRC Environmental Management, IL - Response Action
6400063 PRC Environmental Management, IL - Response Action
6100182 RBD, Inc. Engineering Consultants, CO
6100183 RBD. Inc. Engineering Consultants, CO
6100153 Roy F. Weston, PA
6100109 Technology & Management, MD
6100224 Tetra, CA
6100213 TN Associates, WI
6400006 TRC Environmental Consultants, Inc., CT
6100223 Tucker Young, MI
6400103 Westlnghouse Remediation Services, GA
D9AGL5-01-0185 11/22/95
D9AKL6-07-0022 5/23/96
D9AKL5-06-0054 11/29/95
D9AGL5-08-0055 127 2/95
D9AGL5-08-0055 2/27/96
D9AGL5-04-0067 47 3/96
D9AGL5-01-0186 11/28/95
E9AHP6-02-0523 6/ 5/96
D9AGL5-08-0026 4/22/96
D9AKL5-01-0184 21 5/96
D9AFL6-03-0171 11 3/96
E9AGP6-02-0409 5/ 2/96
D9AKL5-01-0181 11/29/95
D9AGL5-01-0180 11/28/95
E9AKP6-05-0098 4/26/96
E9AGP6-05-0038 127 5/95
E9AGP6-05-0118 6/18/96
D9AGL5-08-0024 4/22/96
D9AGL5-08-0024 4/22/96
D9AFL5-03-0333 3/26/96
D9AFL6-03-0103 2/16/96
D9AGL6-09-0054 5/22/96
D9AKL6-05-0111 57 9/96
E9AGP5-01-0627 10/27/95
D9AKL6-05-0110 5/20/96
E9AHP6-04-0071 9/30/96
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EPA Office of the Inspector General Annual Superfund Report to the Congress for Fiscal 1996 26
Exhibit 1
Page 3 of 5
SUPERFUND REPORTS
ISSUED DURING FISCAL 1996
Coiitr^ct Rsports (iGOfJiiyit/6Gy '. ::- . . '-. "/-'' ;.. : . .'!.. ..' :
Final
Report
Number
Interim
6300019
6100265
6300007
6100287
6100048
6100057
6100247
6100128
6100033
6100104
6100029
6100061
6300021
6100285
6100286
6100195
6100196
6100025
6400051
6400033
6100208
6100162
6100169
6100321
6100322
6100159
6300001
6100034
6100021
Description
Audits
Bechtel National, Inc., CA - ARCS - Fiscal 1994
Camp, Dresser and McKee, Inc., MA - Fiscal 1992-94
CH2M Hill, Inc., OR - Fiscal Years 1990-93
Environmental Technology, Inc., VA - ERCS - FY92
International Technology Corp., CA - Fiscal 1992
Jacobs Engineering Co., CA - Fiscal 1992
Jacobs Engineering Co., CA - Fiscal 1993
MAR, Inc., MD - 1987-89
Morrison Knudsen Corp., ID - ARCS - 1989 G&A
Morrison Knudsen Corp., ID - ARCS - 1989-93
Morrison Knudsen Corp., ID - ARCS - 1990
Morrison Knudsen Corp., ID - ARCS - 1991-92
Morrison Knudsen Corp., ID - Suppl . Allocation Base
NUS Corp. . MD - Fiscal 1989
NUS Corp., MD - Fiscal 1990
OHM Remediation, OH - ERCS Overhead Rates - FY92
OHM Remediation, OH - ERCS Overhead Rates - FY93
Peer Consultants P.C., MD - Fiscal Years 1991-94
PRC Environmental Management, IL - TES 2 - FY86/86T
PRC Environmental Management, IL - FY87 Flash Report
PRC Environmental Management, IL - Fiscal 1987
PRC Environmental Management, IL - Fiscal 1993
PRC Environmental Management, IL - Fiscal 1993
Reidel Environmental Services, OR-ERCS & Dioxin-1987
Reidel Environmental Services, OR-ERCS & Dioxin-1987
Technical Resources, Inc., MD - 4/89-3/92
URS Consultant Corp., WA - ARCS - FY90-93
URS Consultant Corp., WA - Fiscal Years 1990-93
Vigyan Research Associates. VA - Fiscal 1991
Audit
Control Number
D9BGN6-09-0061
D9BGL6-01-0087
D9BGN4-10-0026
D9BFL3-03-0135
D9BGL5-09-0050
D9BGL3-09-0104
D9BGL4-09-0069
D9BFL2-03-0463
D9BKL3-10-0015
D9BKL4-10-0139
D9BKL3-10-0016
D9BKL4-10-0131
D9BKN6-10-0020
D9BFL6-03-0222
D9BFL6-03-0223
D9BHL3-23-0001
D9BHL3-23-0001
D9BFL4-03-0463
E9BKP5-05-0056
E9BKT6-05-0036
E9BKL6-05-0036
E9BKL5-05-0046
E9BKL5-05-0046
E9BHL6-10-0021
E9BHL6-10-0022
D9BFL2-03-0473
D9BGN3-10-0089
D9BGL2-10-0135
D9BFL2-03-0439
Date
Report
Issued
5/15/96
87 9/96
11/13/95
9/11/96
117 2/95
117 3/95
77 9/96
3/13/96
10/13/95
2/13/96
10/11/95
11/21/95
6/18/96
9/11/96
9/11/96
4/29/96
4/29/96
107 6/95
57 2/96
2/14/96
57 2/96
3/29/96
47 8/96
9/30/96
9/30/96
3/27/96
10/16/95
10/16/95
107 6/95
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EPA Office of the Inspector General Annual Superfund Report to the Congress for Fiscal 1996 27
SUPERFUND REPORTS
ISSUED DURING FISCAL 1996
Exhibit 1
Page 4 of 5
Contract Reports (continued)
I
Final
Report
Number Description
Date
Audit Report
Control Number Issued
Final Audits
6400092 Alliance Technologies, MA - Tech. Enforcement Support
6100123 Black & Veatch Spec. Proj. Corp., MO - ARCS - 1988
6100124 Black & Veatch Spec. Proj. Corp., MO - ARCS - 1988
6100125 Black & Veatch Spec. Proj. Corp., MO - ARCS - 1989
6100167 Black & Veatch Spec. Proj. Corp., MO - ARCS - 1989
6100168 Black & Veatch Spec. Proj. Corp., MO - ARCS - 1989
6100166 Black & Veatch Spec. Proj. Corp., MO - ARCS - 1990
6100007 Black & Veatch Spec. Proj. Corp., MO - ARCS - 1992
6100254 Black & Veatch Spec. Proj. Corp., MO - ARCS
6400104 Donohue Associates, WI - ARCS Sub. to URS - FY91-92
6100230 Earth Tech, WI - ARCS - Fiscal Years 1988-93
6100181 JF Sato & Associates - TES - Fiscal Years 1989-91
6100131 Roy F. Weston, PA - ARCS - 1989-92
6100191 Roy F. Weston. PA - Region 1 ARCS - 1989-90
6100026 Roy F. Weston, PA - Region 5 ARCS - 1988-91
6100217 Sverdrup Civil, Inc., MO - Timekeeping
6100216 Sverdrup Environmental, Inc., MO - Timekeeping
6100276 Sverdrup Corp., MO - ARCS - Fiscal 1993
6100134 Versar, Inc., VA - Hazardous Waste Incineration R&D
E9CKP6-01-0625 9/ 4/96
D9CGL4-07-0072 3/ 5/96
D9CGL5-07-0014 3/ 7/96
D9C6L4-07-0072 3/ 7/96
D9CGL5-07-0014 47 5/96
D9CGL5-07-0023 47 5/96
D9CGL5-07-0014 4/ 5/96
D9CGL3-07-0147 107 3/95
D9CKL4-07-0080 7/22/96
E9CGP6-23-0017 9/30/96
E9CGL4-23-0315 6/12/96
D9CJL4-08-0025 4/22/96
D9CFL4-03-0397 3/13/96
D9CGL4-03-0194 4/25/96
D9CFL3-03-0331 107 6/95
D9CGL5-07-0029 5/16/96
D9CGL5-07-0029 5/16/96
D9CGL4-07-0076 8/19/96
D9CFL6-03-0131 3/13/96
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EPA Office of the Inspector General Annual Superfund Report to the Congress for Fiscal 1996 28
Exhibit 1
Page 5 of 5
SUPERFUND REPORTS
ISSUED DURING FISCAL 1996
Contract Reports (continued) \ : 1 ; i ; : 1
Final
Report
Number Description
Indirect Costs
6100098 Arthur D. Little. Inc., MA - 1990
6100008 B & V Waste Science & Technology Corp., MO-ARCS-1991
6100078 Ebasco Services, Inc.. NY - ARCS - 1992
6100093 Ecology & Environment. Inc.. NY - Fiscal 1989
6100037 Foster Wheeler U.S. Corp., NJ - Fiscal 1991
6100126 ICF Kaiser International - Fiscal 1986
6100209 PRC Environmental Management, IL - Fiscal 1986/86T
System Surveys
6400010 Env. Quality Mgmt., Inc. OH - Accounting System
6400090 Env. Quality Mgmt., Inc. OH - Acct'g System Follow-up
6400095 Foster Wheeler Env. Corp.. NJ -Acct'g Change Cost Imp].
6400013 Foster Wheeler Env. Corp. , NJ - Accounting System
6400014 Foster Wheeler Env. Corp.. NJ - CAS Compliance
6400062 Guardian Environmental Services. DE-Accounting System
6400018 ICF Kaiser International - CAS 403
6400002 ICF Kaiser Int'l -Kaiser Engineers, Inc. -Disci. Statmt.
6100090 International Technology Corp., CA - Billing
6300016 International Technology Corp., CA - EDP Controls
6100035 PRC Environmental Management, IL - CAS 418/410
6300025 Reidel Environmental Services, OR - CAS 402
6100319 Reidel Environmental Services, OR - D.O. Reconcil.
6400070 Westinghouse Remediation Services, GA - Acct'g System
Audit
Control Number
D9DFL2-01-0333
D9DGL3-07-0013
D9DFL3-02-0165
P9DGL2-02-0134
D9DFL2-02-0258
E9DFL4-22-0275
E9DKL5-05-0056
E9EHP5-23-0011
E9EHP6-23-5001
D9EGP6-02-0023
D9EFP5-02-0151
D9EGP5-02-0162
E9EHP6-03-0036
E9EFP4-22-0437
E9EFP4-22-0176
D9EGL6-09-0044
D9EGN5-09-0046
E9EKL5-05-0022
E9EGN5-10-0052
E9EGL4-10-0101
E9EHP6-04-0055
Date
Report
Issued
27 5/96
107 3/95
12/11/95
1/24/96
10/30/95
3/11/96
6/17/96
117 7/95
97 3/96
9/12/96
11/22/95
11/22/95
6/12/96
127 6/95
10/18/95
1/22/96
2/20/96
10/25/95
87 8/96
9/30/96
7/25/96
Program Reviews
6400020 URS Consultant Corp., WA - FY96 Floor Check
D9FGP6-10-0089 1/22/96
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EPA Office of the Inspector General Annual Superfund Report to the Congress for Fiscal 1996 29
APPENDIX: ACRONYMS AND ABBREVIATIONS
86T Fiscal 1986 transitional accounting period
Acct'g Accounting
Aerojet Aerojet General Corporation
ARCS Alternative Remedial Contracting Strategy
AZ Arizona
CA California
CAS Cost Accounting Standards
CDTSC California Department of Toxic Substance Control
CERCLA Comprehensive Environmental Response, Compensation, and Liability Act of
1980, as amended
CFO Chief Financial Officer(s)
CO Colorado
Co. Company
COE Corps of Engineers
Corp. Corporation
CT Connecticut
DE Delaware
Disci. Disclosure
D.O. Delivery Order
ECO Environmental Compliance Organization
EDP Electronic data processing
Env. Environmental
EPA Environmental Protection Agency
ERA Expedited Response Action
ERGS Emergency Response Cleanup Services (EPA contracts)
ESAT Environmental Services Assistance Team (EPA contracts)
Eureka Eureka Laboratories, Inc.
Eval. Evaluation
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EPA Office of the Inspector General Annual Superfund Report to the Congress for Fiscal 1996 30
FS Feasibility Study
FY Fiscal Year
GA Georgia
G&A General and Administrative (accounting category)
IAG Interagency Agreement
ID Idaho
IFMS Integrated Financial Management System (EPA)
IL Illinois
Impl. Implementation
Inc. Incorporated
Inst. Institute
Int'l International
IRM Information resources management
LA Louisiana
LAN Local area network
LGR Local Government Reimbursement
LNS LNS Services, Inc.
MA Massachusetts
MD Maryland
Mgmt. Management
Ml Michigan
MO Missouri
Nat'l National
NCR National Oil and Hazardous Substances Contingency Plan, 40 CFR Part 300
NE Nebraska
NET-SR National Environmental Testing Laboratory, Santa Rosa Division
NJ New Jersey
NPL National Priorities List
NY New York
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EPA Office of the Inspector General Annual Superfund Report to the Congress for Fiscal 1996 31
ODEQ Oregon Department of Environmental Quality
OH Ohio
OHM OHM Remediation Services (EPA contractor)
Ol Office of Investigations (EPA OIG)
OIG Office of the Inspector General
OR Oregon
O/S Oversight
PA Pennsylvania
PRP Potentially Responsible Party
QAPP Quality Assurance Project Plan
Reclamation Bureau of Reclamation, U.S. Department of the Interior
Reconcil. Reconciliation
RI/FS Remedial Investigation/Feasibility Study
ROD Record of Decision
SARA Superfund Amendments and Reauthorization Act of 1986
SIBW South Indian Bend Wash (Superfund site)
Statmt. Statement
Sub. Subcontract or Subcontractor
Suppl. Supplemental
TAG Technical Assistance Grant
Tech. Technical
TES - Technical Enforcement Support (EPA contracts)
THI T. Head and Company, Inc.
TX Texas
U.S. United States
VA Virginia
VOC Volatile organic compound
WA Washington
Wl Wisconsin
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