cf ice of the
 ispector General
(A/350/
(92/002
United States
Environmental Protection
Agency
Office of the
Inspector Ge
November 1992

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                                        350R92002
Office of the Inspector General
Semiannual Report
to the Congress
April 1,1992 Through
September 30,1992
                                          Recycled/Recyclable
                                          Printed on paper that contains
                                          at least 50% recycled fiber

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                 On the cover:
    Mount Rainier National Park
        in Ashford,  Washington,
          (photo courtesy of the
          National Park Service,
U.S. Department of the Interior).

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      During this semiannual period, our focus on EPA's
      contract management activities received
      considerable attention from the Agency, Congress
and the Office of Management and Budget (OMB). The
government-wide implications of our findings and the
Agency's comprehensive response to them became the
subject of several congressional hearings and led to the
establishment of an OMB task force and an interagency
SWAT Team which both dealt with contract audit matters.
OMB will issue a "Report on the Federal Audit Contract
Process." We participated as a member of the Office of
Federal Procurement Policy (OFPP) inter-agency team
which reviewed civilian agencies' contract management
practices and will issue a report. These reports make
major recommendations for improving contract
management and  strengthening the Federal Acquisition
Regulation.  OFPP and civilian agencies are currently in
the process of implementing these  recommendations.
    We also continued our audit and investigative work
on the integrity of data from our contract laboratories
which is used to make important regulatory, permitting,
and licensing decisions.  Our investigative work showed
vulnerability to fraud and abuse by laboratories
participating in the Superfund Contract Laboratory
Program relating to analyses of soil and water samples.
    We recommended that EPA include six areas as
material weaknesses in its fiscal 1992 Federal Managers'
Financial Integrity Act assurance letter to the President
and Congress: Contract Management,  Financial and
Management Integrity, Scientific  Data Integrity,
Information Resources Management, Enforcement, and
Audit Followup and Implementation of Corrective Actions.
The Agency has demonstrated a willingness to  resolve
these problems and develop a climate of anticipating and
preventing future material weaknesses.
    We are encouraged by the Agency's cooperative
efforts to address  the management problems which it
faces, including what we consider to be the root causes
of its contract management problems.  We look forward to
working with the Administrator, Congress, and other
agencies in the future to improve the way Federal
contracts are managed and to help EPA achieve its
mission.
John C. Martin
Inspector General

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Executive Summary 	1
EPA High Risk Areas of Significant Concern to the OIG	3
Profile of Activities and Results	6
Establishment of the OIG in EPA—Its Role and Authority  	7
Organization and Resources	7
Purpose and Requirements of the Office of the Inspector General
  Semiannual Report  	7
Overview of EPA's Current Challenges	9

Section 1—Significant  Problems, Abuses, and Recommendations
Summary of Audit Activities and Results	  11
Agency Management 	  12
Construction Grants  	  16
Superfund Program	  19
Special and Early Warning Reviews	  23

Section 2—Report Resolution
Status Report on Perpetual  Inventory of Reports in  Resolution Process
  for the Semiannual Period  Ending September 30, 1992  	  26
Audit Followup  	  27
Status of Management Decisions on IG Audit Reports	  28
Resolution of Significant Reports	  30

Section 3—Prosecutive Actions
Summary of Investigative Activity	  31
Description of Selected Prosecutive Actions  	  32
Description of Selected Prosecutive and Administrative Actions
  Concerning EPA Employees	  34
Civil and Administrative Actions to Recover EPA Funds	34

Section 4—Fraud Prevention and Management Improvements
Review of Legislation and Regulations	36
Suspension and Debarment Activities	  38
Congressional Testimony by the Inspector General	  39
OIG Management Initiatives	  40
Personnel Security Program  	  40
President's Council on Integrity and Efficiency  	  41
Committee on Integrity and Management Improvement	41
Hotline Activities	  42
Professional and Organizational Development	  42

Appendices
Appendix 1—Reports Issued 	  44
Appendix 2—Reports Without Management Decisions	  60

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The soap tree yucca grows sparsely throughout the gypsum dunes at White Sands National Monument.

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

1. Inadequate Procurement
and Contract  Monitoring at
Duluth Laboratory.

EPA did not ensure that $21
million in contracts to support
the Agency's Duluth,
Minnesota, Environmental
Research Laboratory were
awarded  and monitored in the
best interests of the
Government (page 12).

2. California Used Leaking
Underground  Storage Tank
(LUST) Funds On Lower
Priority Cleanups.

California used about $4.5
million of LUST grant funds to
oversee cleanups of lower
priority sites, rather than sites
posing the greatest threat to
human health and the
environment.  Further,
aggressive enforcement
actions were not being taken
against recalcitrant tank
owners or operators (page 13).

3. After 12 Years, EPA's
Information Resources
Management Problems
Continue.

Despite statutory requirements
and repeated criticism from 50
previous reports and
testimonies, fragmented
management, lack of  an
integrated long-range planning
process, and inadequate
internal controls still keep EPA
from developing and operating
reliable, cost effective, and
secure information
management systems for
effective program
administration, critical decision
making, and compliance with
Federal requirements
(page 13).

4. Access to EPA Computer
Information Systems Not
Adequately Controlled.

Although  agreeing over the
past 2 years to our
recommendations in four prior
1udit reports, EPA still did not
adequately control access to
its computer files. As a result,
the Agency's highly sensitive
financial payment systems are
unnecessarily exposed to fraud
and abuse from unauthorized
access, modification, or
destruction. In addition, the
Agency could recover nearly
$2.2 million worth of disk
storage space for reuse
(page 14).

5. Improvements Needed in
the Review of Precautionary
Statements on Pesticide
Labels.

EPA cannot assure the public
that precautionary statements
on many pesticide labels are
adequate  (page 15).

6. Actions Needed to Better
Ensure the Integrity of Data
Supporting Pesticides
Registrations.

EPA was  not effectively
implementing its Good
Laboratory Practices Program.
As a result, the Agency lacked
assurance that the data
submitted by independent
laboratories in support of
pesticide registrations and
regulatory decisions was
accurate and reliable
(page 15).

7. Nearly  $63 Million of
Questioned Costs Claimed
for Philadelphia,
Pennsylvania, Project.

The City of Philadelphia
claimed $20,603,639 of
ineligible force account,
engineering, construction and
indirect costs. An additional
$42,355,847 of unsupported
costs were also questioned
(page 17).

8. Over $26.5 Million of
Ineligible  and Unnecessary
Costs Claimed for
Underutilized Russian River
Project.

The Russian River County
Sanitation District, Guerneville,
California, claimed $8,344,066
of ineligible construction,
engineering, legal and
administrative costs.  An
additional $18,247,400 of
unnecessary costs were
questioned, primarily because
the facility was significantly
underutilized (page 17).

9. Oregon Grantee's $15.6
Million Project Claim
Questioned.

Newberg, Oregon, claimed
$15,641,057 of costs for a
wastewater treatment facility
that has been discharging
effluent without a valid
National Pollutant Discharge
Elimination System permit
(page 18).

10. New York City Claimed
Over $16.9 Million of
Questioned Costs.

New York City claimed
$3,067,609 of ineligible
construction, engineering,  and
force account costs. An
additional $13,885,728 of
unsupported costs were
questioned (page 18).

11. Operational Problems at
$12.2 Million North Dakota
Facility.

The City of Grand Forks, North
Dakota, claimed $3,433,767 of
ineligible  and unnecessary/
ureasonable costs, primarily
for failed  liners and molding
intended to protect against
erosion at treatment lagoons
(page 18).

12. Milwaukee, Wisconsin,
Claimed Almost $5.8 Million
in Questioned Costs.

The Milwaukee Metropolitan
Sewer District claimed
$3,060,908 of ineligible
administrative, engineering,
inspection and construction
costs. An additional
$2,720,064 of unsupported
administrative, engineering and
inspection costs were
questioned (page 19).

13. Better Administration
Needed of Superfund
Contractor-Operated Sample
Management Office.

EPA's ineffective monitoring of
its contractor resulted in
inadequate consideration of
performance histories in
selecting laboratories to
analyze samples. Further,
lack of competition increased
EPA's vulnerability to how the
contractor controls samples,
cost inefficiencies, and
confusion over the respective
roles of the Agency and the
contractor (page 20).

14. More Effective
Monitoring of Contract
Laboratories  Needed.

EPA's Las Vegas, Nevada,
Environmental Monitoring
Systems Laboratory did not
always identify poor performing
CLP laboratories and initiate
timely followup actions to
assure high quality analytical
data for Superfund site
investigations  (page 20).

15. Region 2 Not Fully
Recovering Hazardous
Waste Site Cleanup Costs
from Responsible Parties
(RP).

Region 2's negotiations
process for recovery of  costs
incurred in cleaning up
hazardous waste sites did not
always identify and attempt to
collect interest and Department
of Justice costs or convince
the RPs that all work was
properly performed and
contractor costs were not
excessive (page 21).

16. Delays and Cost
Increases at the Stringfellow,
California, Superfund Site.

EPA Region 9's and the State
of California's cleanup of
Stringfellow hazardous waste
site has been hampered by (1)
incomplete evaluation of the
impact of laboratory
groundwater sample analyses
problems on data  reliability, (2)
the extension of the Remedial
Investigation/Feasibility Study's
estimated completion by more
than 6 years at an increased
cost of $9.6 million, and (3)
delays in constructing and
starting up a contaminated
groundwater pretreatment
facility with excess capacity
increasing costs by $3.5
million (page 21).
APRIL 1,1992 THROUGH SEPTEMBER 30,1992

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17. EPA Lacks Controls Over
Responsible Parties' (RP)
Response Claims.

Internal control weaknesses
hindered EPA's ability to
properly manage RPs' claims
for cleanup of Superfund
hazardous waste sites
(page 22).

18. EPA Fails to Comply
with Printing and
Photocopying Regulations.

EPA program offices continued
to use contractors to print
Agency documents and
allowed contractors to exceed
photocopying limitations in
violation of Government
printing and photocopying
regulations (page 23).

19. Proper Permitting
Procedures  Not Followed
For Ohio Incinerator.

The validity of the Resource
Conservation and Recovery
Act permit issued for operation
of a hazardous waste
incinerator being constructed
by Waste Technologies
Industries (WTI) and WTI's
obligation to  comply with
financial assurance
requirements are clouded by
changes in ownership
(page 24).

20. $4.4 Million of Duplicate
Costs Claimed for
Philadelphia, Pennsylvania,
Project.

The City of Philadelphia,
Pennsylvania, submitted an
interim claim for an estimated
$4,415,014 of construction
management costs charged  as
both direct and indirect costs
(page 25).
Section  2—
Report Resolution

At the beginning of the
semiannual period, there were
282 reports for which no
management decision had
been made. During the
second half of fiscal  1992, the
Office of Inspector General
issued 918  new reports  and
closed 239.  At the end of the
reporting period, 339 reports
remained in the Agency
followup system for which no
management decision had
been made.  Of the 339
reports,  102  reports remained
in the Agency followup system
for which no  management
decision was made within 6
months of issuance (page 26).
    In two followup reviews,
the Office of  Inspector General
found that some problems
identified in previous reports
continued (page 27).
However, we have nothing to
report this period with respect
to significant  management
decisions with which  we
disagree as required by the
1988 Inspector General Act
Amendments.
    For the  239 reports
closed, EPA  management
disallowed $47.6 million of
questioned costs for  recovery
and agreed with our
recommendations that $1.1
million be put to better use
(page 26). In addition, cost
recoveries in current and  prior
periods included $3.7 million in
cash collections, and at least
$30.8 million  in offsets against
billings (page 6).
Section 3—
Prosecutive Actions

During this semiannual
reporting period, our
investigative efforts resulted in
21 convictions and 13
indictments.  Also, this
semiannual period our
investigative work led to $3.6
million in fines and recoveries
(page 31).
     Results of continuing
investigations of EPA's
contract laboratory program
included the conviction of the
president and a supervisor of a
New York lab company for
mail fraud and submitting false
statements; a guilty plea from
a lab company vice president
to a false statement charge;
and the  banning of two lab
employees from EPA-related
work for 3 years.
     In other cases, EPA's
former supplier of computer
equipment pled guilty to four
counts of making false claims,
was fined $600,000 and
ordered to make restitution of
$1.11  million; a lab company
president received a 6-month
sentence for providing false
water quality data; a Michigan
man pled guilty to
impersonating an EPA official;
a West Virginia city clerk
received a 4 month sentence
for embezzling funds related to
an EPA grant; an EPA
employee pled guilty to making
false declarations about his
educational background; and
another EPA employee has
been charged with stealing an
EPA computer (page 32).
Section 4—Fraud
Prevention and
Management
Improvements

Review of Proposed
Legislation and Regulations

During this semiannual period,
we reviewed 17 legislative and
67 regulatory items.  The most
significant were proposed
revisions to OMB Circular A-
130, regarding data integrity of
sensitive application systems;
the Contractor Licensing
Reform Act of 1992; proposed
rulemaking to implement the
Cash Management
Improvement Act of 1990; the
Environmental Crimes Act of
1992; and a  draft EPA
Comptroller policy
announcement on security
policy and procedures of the
EPA financial management
system (page 36).

Suspension and Debarment
Activities

We completed 55 cases during
this reporting period, resulting
in 35 debarments, 15
suspensions, and 5 settlement
agreements (page 32).

Congressional Testimony by
the Inspector General

The  Inspector General testified
five times before congressional
committees during this
reporting period on (1) EPA's
contract management and
oversight, (2) Superfund, (3)
inert ingredients in pesticides,
and (4) efforts with the
Defense Contract Audit
Agency to strengthen the
Office of Inspector's General
contract audit process at EPA
(page 39).

Personnel Security Program

During this reporting period,
the Personnel Security Staff
reviewed 489 investigations.
Among the actions taken,
based on these reviews, were
the issuance of written
reprimands to three employees
for failure to  list previous
terminations  and convictions
on the SF-171, Application for
Federal Employment; and the
termination of the access of
four contractor employees to
Confidential Business
Information for failing to list on
the SF-86, Questionnaire for
Sensitive Positions previous
drug usage, continuous use of
controlled substances,  and a
conviction for assault
(page 40).

Committee on Integrity and
Management Improvement

The EPA Committee on
Integrity and Management
Improvement, chaired by the
Inspector General, published
employee awareness bulletins
on hotel/motel tax exemptions,
political activity, and  leave
policies, and sponsored a
series of special events during
Public Service  Recognition
Week (page  41).

Hotline Activities

The OIG toll-free Hotline
opened 50 new cases and
closed 46 cases during the
reporting period. Of the closed
cases eight resulted  in
environmental, prosecutive, or
administrative corrective action
(page 42).

Professional and
Organizational Development

We approved 1,312 training
enrollments for a total of 987
days of training and
participation  in professional
                                                                                          OFFICE OF THE INSPECTOR GENERAL

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                                   EPA High  Risk Areas Of Significant
                                   Concern To The OIG
 development seminars and
 conferences (page 42).

 Total Quality Management
 (TQM)

 During fiscal 1992 a Quality
 Council, chaired by the Deputy
 Inspector General, was
 established to oversee the
 implementation of TQM within
 the OIG; over 300 OIG
 employees received TQM
 awareness training; and five
 Quality Action Teams were
 established to improve OIG
 processes (page 43).
 This section of our report
presents the Office of
 Inspector General's (OIG)
perspective on significant
problems which the Agency
must address to ensure its
programs are conducted in an
effective, efficient, and
economical manner.  The
OIG's semiannual report for
the period ended March 31,
 1992, presented the OIG's
perspective on two major
areas— Contract Management
and Financial and
Management Integrity—to
closely correspond with EPA's
current priorities and future
initiatives.  These areas
continue to be of concern to
the OIG and have captured the
attention of Agency
management.  However, for
this reporting period, this
section has been expanded
and revised to present the
OIG's perspective on four
additional areas: Scientific
Data Integrity,  Information
Resources  Management,
Enforcement, and Audit
Followup and Implementation
of Corrective Actions, several
of which  were discussed in the
prior semiannual report as
subheadings under the two
principal areas mentioned
above.  The OIG
recommended that the Agency
include these six areas in its
 1992 Federal Managers'
Financial Integrity Act
assurance letter to  the
President and Congress as
material weaknesses.

Contract Management

EPA relies extensively on
contractors to assist in carrying
out its mission to clean up past
pollution problems,  develop
national policy, and set the
environmental agenda for the
future.  As a result of our
audits and the efforts of others
over the past year,  EPA senior
managers have initiated steps
to improve the Agency's
management of contracts.  In
addition to correcting  specific
contract deficiencies reported
by the OIG, EPA established a
high level standing committee
to conduct a broad-based
review of its contracting
activities. The committee
recommended corrective
actions for many of the
Agency's basic contract
management problems. We
will continue to monitor the
Agency's implementation of
these recommendations over
the next several years.  Also,
the Assistant Administrator for
Administration and Resources
Management has expended
significant effort to improve
EPA's contract management
activities.
     There are three areas
vital to effective contract
management: the
procurement process,
management of contractors,
and audit of  contractors' cost
claims.

• Procurement  Process.
There is a dangerous tendency
in EPA for the perceived
urgency of program needs to
prevail over good procurement
practices,  as illustrated by the
following examples.

—Inadequate Procurement
and Contract Monitoring at
Duluth, Minnesota,
Environmental Research
Laboratory.  EPA awarded $21
million in scientific support
services contracts for its
Duluth laboratory to AScI
Corporation (AScI) without
investigating potential conflicts
of interest between AScI and
EPA Duluth officials (see
page 12).

—Inefficient  Contracting
Practices May Cost EPA An
Extra $10.7 Million for
Automated Data Processing
(ADP) Equipment and
Services. EPA could pay (1)
up to $8.4 million over
decreasing market prices for
microcomputer workstations
and other ADP equipment and
(2) $2.3  million more than
actually incurred by the
contractor for operating
expenses (1400060,
September 30, 1991).

—EPA Continued to Negotiate
Unreasonably High Equipment
Rates on Emergency
Response Cleanup Services
Contracts. After  10 years,
EPA continued to rely on price
analysis rather than cost data
to determine the
reasonableness of negotiated
fixed equipment rates.
Unaudited cost and usage
data for two contracts showed
an average equipment rate
markup of 427 percent for 67
items (2100292, March 31,
1992).

• Management of
Contractors.  In September
1992, EPA had 790 contracts
with obligations of $3 billion.
Under these contracts, EPA
had more than 25,000 active
work assignments, including
modifications, describing the
work to be performed by its
contractors.

—Agency's Control of
Operations and Procurement
Practices Jeopardized.  A
general laissez-faire culture
that affected EPA's
management of a support
contract with a 5-year term
and a maximum value of $347
million resulted in  (1) lessened
EPA control over critical
program activities; (2) the
creation of a personal services
relationship between the
contractor and EPA; (3) the
contractor's performance of
inherently governmental
functions; (4) potential conflict
of interest situations; and  (5)
ineffective and inefficient use
of Agency resources
(2100295, March 31,  1992).

—Alternative Remedial
Contracting Strategy Fails to
Accelerate Cleanups of
Hazardous  Waste Sites.  Poor
contractor performance and
EPA management delayed the
cleanup of hazardous waste
sites under the Alternative
Remedial Contracting
Strategy (ARCS) program in
Regions  1, 3, and  5 (2100209,
February 3, 1992).

•  Audit of Contractors' Cost
Claims.  There is  a substantial
backlog of Agency requests for
audits of contractors.  In
September 1992,  EPA had
1,872 contracts with
obligations of $4.9 billion
whose performance period had
expired, but had not been
closed out.  An incurred cost
audit could be requested each
APRIL 1,1992 THROUGH SEPTEMBER 30,1992

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year each of the 1,872
contracts were in effect. As of
August 31, 1992, the Agency
had about 450 outstanding
incurred cost audit requests.
Almost 90 percent of EPA's
contracting dollars are spent
on cost-reimbursable contracts
which provide few incentives
for contractors to control costs.
To provide additional audit
coverage, the OIG has several
initiatives underway, including
assuming cognizance for major
EPA contractors, hiring
additional financial auditors,
and implementing an
expanded contract audit
strategy (see page 40 for
discussion of OIG's
management initiative to
expand the contract audit
program).

Financial Management

The OIG has repeatedly
reported that EPA's accounting
systems do not provide
complete, consistent, reliable
and timely data for Agency
decision making.  While EPA
has devoted considerable time
to improving the Agency's
overall performance in the
area, results have been less
than anticipated. Summaries
of recent audits in this area
follow.

—Fiscal 1991 Superfund Trust
Fund Audit. With respect to
accounts receivable, $18.2
million were not recorded
timely,  and $2.5 million were
not recorded in the correct
year.  Also, $1.1 million of
collections were not recorded
timely.  Further, (1) $1.9
million of personal property
was either not  recorded or was
incorrectly recorded (2) $2.4
million of allocable general
support services and
personnel costs were not
charged to Superfund because
established ceilings were
reached, (3) $8.3 million of
nonpayroll obligations were
questioned due to a lack of
documentation and recording
errors, and (4) $3.3 million of
nonpayroll disbursements were
questioned due to a lack of
approval and inadequate
reviews (2100660, September
30, 1992).
—Superfund Contractor-
Operated Sample
Management Office and
Related Contract Laboratory
Program Issues. Because
EPA had not closed out 257
Routine Analytical Services
contracts that had expired,
almost $20 million of funds
remained unnecessarily
obligated, $341,000 of refunds
due the Agency had not
been received, and another
$250,000 of refunds had not
been received timely (see
page 20).

—Unliquidated Obligations in
Construction Grants.  Nearly
$49 million  of the $433 million
of unliquidated construction
grant obligations reviewed in
eight regions were  invalid and
should have been deobligated.
As a result, funds remained
obligated that could have been
used for additional  grants to
states (1100426, September
30,  1991).
     In response to the Chief
Financial Officers Act and our
perceived need, we will
continue emphasizing audits in
the financial management
areas.  In addition, we will
work with the Agency to
ensure that an effective
organization is established that
provides the Chief  Financial
Officer with the responsibility
and authority to correct EPA's
longstanding financial
management problems.

Scientific Data Integrity

The accuracy and reliability of
scientific data have always
been crucial to EPA's mission
as a regulatory agency
because it  forms the basis for
decisions that affect all major
American industries and
national policies to prevent
hazards and risks to health
and safety.  However, audits
and investigations show  that
EPA is not always  getting the
research for which  it pays, nor
is such  research always
accurate or objective.
     The Federal Insecticide,
Fungicide,  and Rodenticide Act
(FIFRA) requires registrants of
pesticide products  to
demonstrate that products do
not cause adverse  effects to
public health and the
environment.  The registrant
either performs the study in-
house or contracts with a
laboratory.  Good Laboratory
Practices standards specify the
minimum practices  and
procedures which must be
followed in order to ensure the
integrity of submitted
pesticides data. Recent audits
include the following.

—Integrity of Data Supporting
Pesticide Registrations. The
Agency lacked assurance that
the data submitted by
independent laboratories in
support of pesticide
registrations was accurate and
reliable (page 15).

—Accreditation Program
Needed to Ensure Integrity of
Laboratory Data. Officials
managing larger programs
similar to EPA's generally
believed that an independent
laboratory accreditation
program would fulfill EPA's
need to better ensure data
integrity (2400032,  March 31,
1992).
    Under the Contract
Laboratory Program (CLP),
independent laboratories test
samples from Superfund sites.
Investigations have disclosed
fraudulent analyses, falsified
data, uncalibrated equipment,
and backdated analyses which
could  call into question
cleanup decisions and hamper
the recovery of EPA's  cleanup
costs from responsible parties.
Recent audits in this area
include the following.

—Superfund CLP Quality
Assurance/Quality Control
(QA/QC) Program at the
Environmental Monitoring
Systems Laboratory (EMSL),
Las Vegas, Nevada.  EMSL's
controls over its QA/QC
program were not complete or
fully effective for evaluating
contract laboratories'
performance (see page 20).

—EPA's Sample Management
Office and Related CLP
Issues.  EPA used laboratories
with poor performance
histories to analyze samples
while  laboratories with superior
performance histories  were not
used to their capacity (see
page 20).

Information Resources
Management (IRM)

IRM is critical to the success
of all program activities.
Despite extensive criticism
over the last 12 years, EPA's
IRM program is still hampered
by many problems including:
(1) significant cost overruns
and delays in developing and
implementing information
systems; (2) material data
quality deficiencies; (3)
development of duplicate
information systems; (4) failure
to economically manage
mainframe storage devices; (5)
exposure of the Agency's most
sensitive  information systems
to access  by unethical users;
and (6) lack of Agency
assurance that ADP support
services contracts are being
implemented effectively,
efficiently, and at the lowest
cost to the Government.
Summaries of recent audits
identifying significant IRM
problems follow.

—Computer Systems Integrity.
EPA had not implemented
certain fundamental
management practices in its
IRM program.  A serious
absence of top  management
central direction and control
and the decentralized nature of
Agency operations have made
it extremely difficult to
effectively manage IRM
activities (see page 13).

—Software Integrity. Despite
having been previously
reported, EPA user and
contractor access to highly
sensitive payroll, contractor
payment,  and other sensitive
financial files was still not
adequately controlled.
Knowledgeable users could
access systems on the
mainframe and view, modify,
or destroy information,
programs, or other important
computer  resources with little
fear of detection (see
page  14).

—Follow-up of CERCLIS
Reporting and Post-
Implementation. Almost $1.4
                                                                                              OFFICE OF THE INSPECTOR GENERAL

-------
 billion of financial data errors
 were found in the
 Comprehensive Environmental
 Response, Compensation, and
 Liability Information System
 (CERCLIS) which supports the
 strategic decision making for
 the multi-billion dollar
 Superfund program (2400027,
 March 27, 1992).

 Enforcement

 While EPA management has
 worked diligently to improve
 EPA's enforcement program,
 additional efforts and attention
 are still needed.  During fiscal
 1991 and  1992, our audits of
 EPA's water, pesticide,
 Resource Conservation and
 Recovery  Act and Superfund
 programs  disclosed continuing
 instances  of ineffective Federal
 and  State enforcement.  EPA
 and  the States did not take
 appropriate action against
 unpermitted discharges. In
 other cases,  EPA and the
 States did not enforce consent
 agreements.  Finally, EPA was
 not making effective use of
 civil  and administrative
 penalties which punish the
 violators and deter future
 violations.  Examples follow.

 —Region  9 LUST Program.
 Although California had
 received LUST funds to
 enforce cleanups, the Stale's
 actions were largely
 ineffective. For example, at
 five sites where clean-up and
 abatement orders were issued,
 only $226,540 in penalties
 were assessed against
 recalcitrant owners, while
 penalties up to $10.4 million
 could have been assessed
 (see page 13).
—Superfund Post-Settlement
Activities.  For 15 sites in
noncompliance, EPA regions
assessed penalties against
responsible parties (RP)  for
noncompliance with post-
settlement milestones dates in
only three cases totaling
$45,000, failed to assess
potential penalties of
$4,855,500 against RPs  in
seven other cases, and did not
refer two other cases for
potential judicial sanctions
against the RPs which could
have totaled $8,125,000
(1100431, September 30,
1991).

—Pesticide Consolidated
Audit. Delegated States  and
EPA regions frequently did not
take timely and appropriate
enforcement actions against
violators of pesticide laws.
Twelve of 16 States in
Regions 4, 6 and 7 had
maximum penalty authority
significantly less than provided
for in FIFRA. Under one
State's pesticide law, the
maximum fine was $500.  EPA
regions  sometimes reduced
fines below the minimum
allowed  by national guidelines
without adequate justification
or documentation (1100148,
March 26,  1991).
Audit Followup and
Implementation of Corrective
Actions

Since 1989 we have been
assessing the effectiveness of
the Agency's audit followup
responsibilities.  Our reviews
found that information in the
Agency's Management Audit
Tracking System  (MATS) was
not reliable and the Agency's
Semiannual Reports to
Congress on audit followup
activity have been inaccurate.
Our special review of three
regions (1400050, September
26, 1991) found unreported
recoveries of $7.4 million
which were almost as much as
the $8.3 million reported by the
Agency for  all 10 regions in its
Reports to Congress for fiscal
1990. As a result of our
reviews, the Agency has
reported audit followup as a
material weakness in its 1989,
1990, and 1991 Federal
Managers' Financial Integrity
Act Reports to Congress and
the President.  EPA has
elevated the issue of
implementation of corrective
action on our findings to the
highest management levels
and appears committed  to
making improvements.
APRIL 1,1992 THROUGH SEPTEMBER 30,1992

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      Profile Of  Activities And Results
Environmental Protection Agency
Office of Inspector General
Audit Operations:

CWG Managed Reviews:

Reviews Perfofmed by EPA, Independent
Public Accountants and State Auditors

- Questioned Costs
                                                    April 1,1992 to
                                                    September 30,1992
               Fiscal 1992
  * Federal Share Ineligible1
  • Total Unsupported'
  * Federal Share Unsupported'
  • Total Unnecessary/Unreasonable*
* Recommended Efficiencies (Funds be Put to Better Use)
  • Total Efficiencies'
  » Federal Share Efficiencies'

• Cost Disallowed to be Recovered
  « Federal Share Ineligible
     (costs which EPA management agrees are
     unallowable and is committed to recover
• Cost Disallowed as Cost Efficiency
  > Federal Share Recommended Efficiencies
Other Reviews:
• Questioned costs
 • 1
  • Total Unsupported*
• Recommended Efficiencies (Funds be Pet to Setter Use)
  » Total Efficiencies*
  * Federat Stare £ff tefencigs'

• Cost Disallowed to be Recovered
  • Federal Share Unnecessary/unreasonable
     (costs which EPA management agrees are
 • Cost Disallowed as Cost Efficiency
  * Federal Share Recommended Efficiencies
                              \ management's
                                          in
$50.8 Man
$77.5 Mita
$33.2 Million
$111.0 Milton
 $82.5 Minn
$104.8 Million
 $60.8 Milan
$109.0 Million
 $78.9 Miion
                                                         $64.3 Million
$85.9 Million
$91.5 Mlion
$40.7 Million
 $5.9 Miion
 $0.3 Million
                                                          $0,0 Miion      $8.0 Milton
$143.3 Mlion
 $51.2 Milton
 $16.3 Miion
  $4.5 Million
  $4 5 Milton
 $14.7 Won
 $14.3 Miion
  $03 Million
  $0.3 Million
 S3S.7 MStai
 $35.7 MMon
                                                           $0,1 Million
                                                           $0.0 Mite
  $7.5 Miion
  $7.4 Mlfon
 $15.7 Milton
 $15.3 Mlion
  $0.3 Million
  $0.3 Milton
 $50.8 Million
 $50.8 Million
                $1.2 MHIiOft
                $08 Million
                $0.0 Million
  $1.0 Milton      $6.4 Million
Agency Recoveries:

 Recoveries from Audit Resolutions of
  Current and Prior Periods
  (cash collections or offsets to future
  payments)"

Reports Issued:

• OtQ Managed Reviews;
 » EPA Reviews Performed by the 010
 * EPA Reviews Performed by Independent
   Pubte Accountants
 • EPA Reviews Performed by State Auditors

• Other Reviews:
 « EPA Reviews Performed by mother Federat Agency
 » Single Audit Act Audits
                                                                                          Total Reports Issued
                                                                       April 1,1992 to
                                                                       September 30,1992   Fiscal 1992
                                                                                         $34.5 Mliori      $59.8 Mdfon
                                   to fate satisfactory corrective acton)*"

                                 Investigative Operations

                                 * Fines and Recoveries (including civil)
»Indtetmenls of Persons or Firms
• Convictions of Persons or firms
* Administrative Actions Taken Against EPA Employees

Fraud Detection and Prevention Operations

• Oebarments, Suspensions, Voluntary Exclusions, and
                                                                                                                                                         101
                                                                                                                                                          10
                                                                                                 317
                                                                                                 429
                                                                                  918
                                                                                                                                                         239
                                                                                  $3,6
                                                                                   117
                                                                                   126
                                                                                   13
                                                                                   21
                                                                                   18
  firms from participating in EPA programs or operations
  because of misconduct or poor performance)
 * Hotline Complaints Received
 • Hotline Complaints Processed and Closed
 • Personnel Security tovesHgaliorB Adjudicated
                                                                                                                                                           S5
                                                                                                                                                           50
                                                                                                                                                           46
                    Division and is unaudited.
                    •"Reports resolved are subject to change pending further review
                                                                                                                109

                                                                                                                182
                                                                                                                 19
                                                                                                                556
                                                                              1,962
                                                                                                                                                                         493
$4.9
 255
 243
 29
 60
 29
  79
  81
  83
     DIG performance or preaward audits)
                                                                                                                                      OFFICE OF THE INSPECTOR GENERAL

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

   • Initiate and carry out
   independent and objective
   audits and investigations,
   • Issue subpoenas for
   evidence and information,
   • Obtain access to any
   materials in the Agency,
   • Report serious or flagrant
   problems to Congress,
   • Select  and appoint OIG
   employees,
   • Fill Senior Executive Service
   positions,
   • Administer oaths, and
   • Enter into contracts.

       The Inspector General is
   appointed by, and can be
   removed only by, the
   President. This independence
   protects the OIG from
   interference by Agency
   management and  allows it to
   function as the Agency's fiscal
   and operational watchdog.
Organization and
Resources

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

 The Inspector General Act of
 1978 (Public Law 95-452), as
 amended, requires the
 Inspector General to keep the
 Administrator and Congress
 fully and currently informed of
 problems and deficiencies in
 the Agency's operations and to
recommend corrective action.
The IG Act further specifies
that semiannual reports will be
provided to the Administrator
by each April 30 and October
31, and to Congress 30 days
later.  The Administrator may
transmit comments to
Congress along with the
report, but may not change
any part of it.
    The specific reporting
requirements prescribed in  the
Inspector General Act of 1978,
as amended, are listed below.
Source
Inspector General Act, as amended.
           Section and Page
Section 4(a)(2), Review of Legislation and Regulations          4         36

Section 5(a)(1), Significant Problems, Abuses, and             1         11
            Deficiencies

Section 5(a)(2), Recommendations with Respect to             1         11
            Significant Problems, Abuses, and
            Deficiencies

Section 5(a)(3), Prior Significant Recommendations on
            Which Corrective Action Has Not
            Been Completed                  Appendix 2         60

Section 5(a)(4), Matters Referred to Prosecutive Authorities       3          31

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

Section 5(a)(6), List of Audit Reports               Appendix 1          44

Section 5(a){7), Summary of Significant Reports               1          11

Section 5(a)(8), Statistical Table 1-Reports With
            Questioned Costs                         2          29

Section 5(a}(9), Statistical Table 2-Reports With
            Recommendations That Funds Be Put
            To Better Use                          2          29

Section 5(a)(10), Summary of Previous Audit Reports
            Without Management Decisions       Appendix 2          60

Section 5(a)(11), Description and Explanation of Revised
            Management Decisions             Appendix 2          60
                                Section 5(a)(12), Management Decisions with Which the
                                            Inspector General Is in Disagreement         "          —

                                * There were no instances where information or assistance requested by the Inspector
                                General was refused during this reporting period. Accordingly, we have nothing to report
                                under section 5(a)(5) of the Inspector General Act of 1978, as amended
                                " There were no instances of management decisions with which the Inspector
                                General was in disagreement
APRIL 1,1992 THROUGH SEPTEMBER 30,1992

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                       Office of  Inspector General - Who's Who
       Headquarters
                                              Inspector General

                                             John C. Martin
                                           Deputy Inspector General

                                          Anna Hopkins Virbick
        Office of Audit
        Kenneth A. Konz
        Assistant  Inspector General
        James O. Rauch
        Deputy
Office of Investigations
Daniel S. Sweeney
Assistant Inspector General
Michael J. Fitzsimmons
Deputy
            Operations Staff
            Elissa R. Karpf
            Director
            Technical Assistance Staff
            Gordon  Milbourn
            Director
             Planning and Resources
             Management Staff
             Kenneth Hockman
             Director
Office of Management
John C. Jones
Assistant  Inspector General
                                     Technical Assessment and
                                     Fraud Prevention Division
                                     Vacant
                                     Director
                                     Administration and
                                     Management Services
                                     Division
                                     Michael  Binder
                                     Director
       Divisional Inspectors General
                                               Region 5
                                               Anthony C. Carrollo, Audit

                                               Region 5, 7, & 8
                                               Vacant, Investigations
Region 9 & 10
Truman R. Beeler
Audit

H. Brooks Griffin
Investigations
                        Region 7 & 8
                        Nikki Tmsley, Audit
                                                             Mary Boyer, Audit
                                                             James F. Johnson,
                                                             Investigations
                                              Region 1 & 2
                                              Paul McKechnie, Audit
                                              Robert M. Byrnes,
                                              Investigations

                                              Region 3
                                              Paul R. Gandolfo, Audit
                                              Martin Squitieri
                                              Investigations

                                              Headquarters
                                              Edward Gekosky,
                                              Internal Audit

                                              Francis C Kiley
                                              Washington Field Office
                                              Investigations
                                                                                         OFFICE OF THE INSPECTOR GENERAL

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

  Land

  The principal sources of land
  waste are:

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

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

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

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

 Air

 The Clean Air Act
 Amendments of 1990 address
    Major Laws Administered by EPA

   •9tu»            '  .     '<   -WOKS**        •  •    ,:
    Toxic SiAstances Canlrai W     ..       Beeprts EPA noWratton ot any new ctemical •
   Ml Rodentttte Act
                            :   «teizes EPA to legtstet an pesticides, specify
   Omprertrewa Enwonmental
   Compensation,
 Reqwes EPA lo desiflriate tazafdous substances
 thai can ptesent suBsiartial dangei and authorizes
'
                               tfe retease of crteia pofctants and hazardous ait
   Clean Water Act
   Emergsrcy Ptanrtng and Commurtty RtgHt-to:,  : fteojmes Stales to tteveiop Koganis fa
                   '
   OilPo»uttonAaol1990
                             .-,<**<«»
three major threats to our
nation's environment and the
health of Americans:  urban air
pollution, acid rain, and air
toxics. The 1990 amendments
also establish a national
operating permits program and
an improved enforcement
program to foster better
compliance with the
requirements of the Act.

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

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

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

The job of cleaning and
protecting the nation's drinking
water; oceans, coastal waters,
and wetlands; and surface
waters is made complex by the
APRIL 1,1992 THROUGH SEPTEMBER 30,1992

-------
variety of sources of pollution
that affect them.

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

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

• Nonpoint Sources. Nonpoint
sources of water pollution are
multiple, diffuse sources of
pollution as opposed to a
single "point" source, such as
a discharge pipe from a
factory.  For example,
rainwater washing over
farmlands and carrying top soil
and chemical residues into
nearby  streams is a major
nonpoint source of water
pollution.

• Ocean Dumping.  Dredged
material, sewage sludge, and
industrial wastes are a major
source of ocean pollution.
Sediments dredged from
industrialized urban harbors
are often highly contaminated
with heavy metals and toxic
synthetic organic chemicals,
such as PCBs and petroleum
hydrocarbons.

Wetlands

• More  than half of the
wetlands originally in the
contiguous United States have
been lost and others have
been degraded by pollution
and hydrological changes so
that they no longer perform
many of their natural functions.
To  achieve its "no net loss"
goal, EPA is increasing
enforcement of Federal
restrictions on activities which
destroy or degrade wetlands.
10
OFFICE OF THE INSPECTOR GENERAL

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   Section  1-Significant Problems, Abuses, And  Recommendations
 As required by sections
 5(a)(1)and(2)ofthe
 Inspector General Act of
 1978, as amended, this
 section identifies significant
 problems, abuses, and
 deficiencies relating to the
 Agency's programs and
 operations along with
 recommendations for the
 current period. The findings
 described in this section
 resulted from audits and
 reviews performed by or for
 the Office of Audit and
 reviews conducted  by the
 Office of Investigations.
 Because these represent
 some of our most significant
 findings, they should not be
 considered representative of
 the overall adequacy of EPA
 management. Audit findings
 are open to further review
 but are the final position of
 the Office of Inspector
 General. This section is
 divided  into five areas:
 Summary of Audit Activities
 and Results, Agency
 Management, Construction
 Grants,  Superfund, and
 Special  and Early Warning
 Reviews.
Summary of Audit
Activities and
Results
 Questioned Costs And Recommended
 Efficiencies By Type Of Assignment

   250
  •200
  1-150
  -100
  -50
         Construction
        Federal    Non Federal
        Questioned  Questioned
Int / Mgmt
Superfund
                                                          Others
                Sources Of Reviews
                                               Areas Of Effort By Staff Days
                                                                                                   LUST-
                                                                                                   Performance
                                                                                                   207
                                           EPA 61
                                                         Superfund-
                                                         Performance
                                                         2,239
                                                             LUST-
                                                Fmancial & Compliance 11
 State Auditors
 10
               Total -918 Reviews
                                                                                 Total - 23,918 Days
APRIL 1,1992 THROUGH SEPTEMBER 30,1992
                                                                              11

-------
Agency
Management
The Inspector General Act
requires the OIG to initiate
reviews and other activities
to promote economy and
efficiency and to detect and
prevent fraud,  waste, and
mismanagement in EPA
programs and operations.
Internal and management
audits and reviews are
conducted to accomplish
these objectives largely by
evaluating the economy,
efficiency, and effectiveness
of operations.
    The following are the
most significant internal and
management audit and
review findings and
recommendations.
Inadequate
Procurement and
Contract Monitoring
at Duluth  Laboratory

Problem

EPA did not ensure that $21
million in contracts to
support the Agency's
Duluth, Minnesota,
Environmental Research
Laboratory were awarded
and monitored in the best
interests of the Government.

We Found That

A series of questionable
events involving support
contracts occurred at EPA's
Duluth laboratory.  Shortly
before leaving government
service in 1985, an EPA
scientist solicited work through
the Small Business
Administration for a company
he owned, AScI, which
provided toxicological support
services. Federal criminal law
prohibits government
employees from soliciting work
on behalf of a contractor.  EPA
contracting  officials knew of
this potential conflict of interest
but relied on Duluth's
statement that EPA's Office of
General Counsel had
approved the former
employee's contract submittal.
There was no evidence of this
approval. Eight months after
the scientist left the Agency,
AScI received a $1 million
sole-source contract from EPA.
EPA regulations prohibit non-
competitive awards to former
employees within 1 year of
leaving the  Agency.
     In 1989, at the request of
the Duluth laboratory, EPA
declined to  renew the option
years on a contract with a
local university that had been
providing chemical analysis
support to the Duluth
laboratory for years.  Instead,
the EPA Duluth Laboratory
Director initiated a request to
compete a contract for
essentially the same services
formerly provided under the
contract with the university.
AScI was awarded this
contract, with the university
acting as a major
subcontractor. This cost EPA
$300,000 more than the
original university contract.
     In 1990, EPA contracting
officials approved and
processed three sole-source
toxicological contracts, each at
slightly less than $3 million.
This action avoided the
competitive procurement that
is required when certain small
business contracts are over $3
million in value.  The Duluth
laboratory Director stated in a
memorandum that he wanted
to avoid competitive bidding
since this would be unsettling
to the staff.
     In addition to these
questionable EPA procurement
practices, AScI performed
work such as painting, laying
tile, framing and hanging
pictures, and other  remodeling
and  maintenance tasks that
were outside the contract's
scope of work for toxicological
support services. EPA
contracting officers  approved
these work assignments
without determining whether
the work was allowable under
the contract.

We Recommended That

The Assistant Administrator for
Administration and  Resources
Management and the Assistant
Administrator for Research and
Development take steps to
address the  serious
deficiencies in the conduct of
contracting officers, project
officers and others  involved in
the procurement process.
When informed of the issues
raised by the audit, EPA
officials generally agreed and
quickly took  a number of
corrective actions including:

• Instructing the Director,
Procurement and Contracts
Management Division, to (1)
develop procedures to ensure
that contract awards to former
EPA employees comply with
Government-wide and Agency
ethics requirements, (2)
complete a questionnaire that
contracting officers must use
to inquire into program
officials' potential conflicts of
interest, and (3) develop a
training course for all
contracting officers regarding
Agency conflict of interest
regulations and standards of
conduct.

• Not exercising option years
on the three sole-source
contracts totalling  $9 million,
and competitively  recompeting
the work, and requiring future
Performance Evaluation Board
members to certify that they
have no conflicts of interest.

• Issuing guidance to stress
that all work be performed
within the contracts'
statements of work.

• Detailing  the Duluth Director
into another position.

• Issuing a policy statement
requiring laboratory employees
to identify to Headquarters any
relationship which may lead to
a conflict of interest.

The above actions should
resolve the matters raised in
the report which were  under
the control  of Office  of
Administration and Resources
Management and the Office of
Research and Development.

The Designated Agency Ethics
Official:

• Define substantive ethics
advice and require that Deputy
Ethics Officials maintain
records when they give
employees substantive ethics
advice.

• Establish interim procedures
or issue ethics advisories, if
the Office of Government
Ethics proposed regulations
were  not issued soon, to
include determinations of the
information that ethics officials
should obtain in dealing with
potential conflict of interest
situations and require  that
such  information be obtained.

• Require the Deputy  Ethics
Officials to  be trained and
certified, at least biannually, on
Government ethics laws and
regulations.

What Action Was Taken

The final audit report
(2100443) was issued to the
12
                                                                                          OFFICE OF THE INSPECTOR GENERAL

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Assistant Administrator for
Administration and Resources
Management, the Assistant
Administrator for Research and
Development, and the
Principal Deputy General
Counsel (also the Designated
Agency Ethics Official) on July
7, 1992.  A response to the
final report is due by October
5, 1992.
California Used
Leaking Underground
Storage Tank (LUST)
Funds On Lower
Priority Cleanups

Problem

California used about $4.5
million of LUST grant funds
to oversee cleanups of lower
priority sites, rather than
sites posing the greatest
threat to human health and
the environment. Further,
aggressive enforcement
actions were not being taken
against recalcitrant tank
owners or operators.

Background

EPA estimates that as many
as 40 percent of the 2 million
underground petroleum tanks
are leaking. As of December
31, 1991, California reported
16,491  leaking tank sites,
almost twice as many as any
other state. Leaking tanks
often create health and
environmental risks by
contaminating groundwater
which is the source of drinking
water for half the United
States.  Groundwater is also
used for irrigation, livestock
watering, and  industrial uses.
Leaking tanks usually contain
petroleum which is a known
carcinogen and can also cause
nausea; skin, eye, and throat
irritation; loss of reflexes; and
liver and kidney damage.

We Found That

California had not adequately
implemented a priority system
for overseeing LUST-funded
cleanups and used about $4.5
million of $15.8 million of grant
funds for cleanup of lower
priority sites, rather than those
sites posing the greatest risk
to human health and the
environment as required by the
Superfund Amendments and
Reauthorization Act of 1986
(SARA).
    Region 9 had not required
the  state to develop and
implement a meaningful
enforcement program.  As a
result enforcement actions
were inadequate for 97
percent of the sample sites
judgmentally selected for
review.  At five sites where
cleanup and abatement orders
had been issued, only
$226,540 in penalties were
assessed against recalcitrant
owners when penalties from
$1 million to $10.4 million
could  have been assessed for

Removal of an underground
storage tank in Long Beach,
California (Photo courtesy of the
State of California)
violations at those sites.
Further, the assessed
penalties did not appear to
exceed the economic benefits
to the owners of not complying
with cleanup laws and
regulations.
    State-generated cleanup
status reports overstated the
progress California was
making in cleaning up its sites.
EPA used this information to
make nationwide funding
decisions and to report the
status of the LUST program to
Congress.
    Region 9 had not made
California's receipt of LUST
funding contingent upon
progress in obtaining EPA's
approval of its underground
storage tank regulatory
program.

We Recommended That

The Regional Administrator,
Region 9:
•  Require California to revise
its priority system so  that the
most environmentally
threatening tank sites are
given the highest priority.

•  Monitor the quality and
quantity of state enforcement
actions to assure that the
enforcement program is
effective and consistent with
EPA policy and guidance.

•  Hold the state accountable
for submitting accurate
cleanup status reports.

•  Make future LUST funding
contingent upon the Region's
approval of the state's tank
regulatory program.

What Action Was Taken

The final audit report
(2100665) was issued to the
Regional Administrator, Region
9, on September 30,  1992.  A
response is due by December
29,  1992.  In responding to the
draft report, the Region
generally agreed with our
recommendations for
improving procedures for
establishing priorities for LUST
cleanups and initiating
enforcement actions.
However, the Region did not
agree that priorities should be
established on a statewide
basis.  Also, the Region
indicated that it encouraged
voluntary compliance as its
main enforcement tool.
After 12 Years, EPA's
Information
Resources
Management
Problems Continue

Problem

Despite statutory
requirements and repeated
criticism from 50 previous
reports and testimonies,
fragmented management,
lack of an integrated long-
range planning process, and
inadequate internal controls
still keep EPA from
developing and operating
reliable, cost effective, and
secure information
management systems for
effective program
administration, critical
decision making, and
compliance with Federal
requirements.

Background

EPA has over 500 information
systems as well as computer
models supporting its mission.
In fiscal 1992, EPA will spend
an estimated $287 million on
information technology.

We Found That

The absence of top
management central direction
and control over EPA's
Information  Resources
Management (IRM) program
contributed to many of the
continuing deficiencies
identified in numerous
Government reports and
congressional testimony,
including  adversely impacting
the IRM contract management
process, information system
development and operation,
and EPA's ability to
accomplish its cross-media
mission.  Contrary to
requirements of the Paperwork
Reduction Act,  EPA has not
formally designated a senior
official for IRM  and has
APRIL 1,1992 THROUGH SEPTEMBER 30,1992
                                                                                     13

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fragmented the IRM
responsibilities between four
organizations under two major
Agency components, with no
clear lines of responsibilities
between them. Actual IRM
authority has been informally
delegated too low in the
organizational structure to be
fully effective.  In addition,
EPA's IRM Steering
Committee does not provide
sufficient oversight and control
over the IRM function.
    Further, EPA had not
developed key comprehensive,
formal, and authoritative
policies, standards, and
procedures that meet  minimum
requirements and many
directives were incomplete and
outdated.  In addition, the
Agency had not established an
integrated long-range IRM
planning and budgeting
process to help acquire,
manage, and use its computer
resources.  As a result,
systems development projects
have been subjected to
funding shortages, and
duplicate  information systems
have been developed.
    Also,  the Agency  had not
instituted a comprehensive,
independent quality assurance
program for information
systems to ensure that its
mission-critical information
systems operate effectively
and accurately.  As a result,
EPA experienced serious and
costly data integrity and
software problems in its
operational information
systems.  Further, EPA had
not conducted internal control
reviews of 15 of the Agency's
28 sensitive systems to fully
comply with the Paperwork
Reduction and Computer
Security Acts regarding
sensitive system certifications
and could  not provide
reasonable assurance under
the Federal Managers'
Financial  Integrity Act that
management controls for the
systems are in place.
    Finally, the Agency  had
not completed required risk
analyses, security reviews or
met other  requirements of the
Computer Security Act of 1987
and OMB Circular A-130 for
establishing a comprehensive
Agency-wide computer security
program. As a result, EPA
had no assurance that its
valuable and mission-critical
information resources are
adequately protected from
fraud, abuse, and unauthorized
manipulation.

We Recommended That

The Administrator or Deputy
Administrator formally
designate a senior official at
the Assistant Administrator
level to provide top
management control and
oversight over IRM  activities
and establish:

• Necessary comprehensive,
formal, and authoritative IRM
policies, standards, and
procedures;

• An Agency-wide information
system planning process which
ties into the Agency's budget;

• A comprehensive  quality
assurance program to review
and evaluate information
systems;

• An internal control review
program to provide  for periodic
reviews of information system
controls; and

• A comprehensive  computer
systems security program.

What Action Was Taken

 The final audit report
(2100641) was issued to
Administrator on September
28, 1992.  A response to the
final report is due by
December 28, 1992.  In
responding to the draft report,
the Assistant Administrator for
Administration and Resources
Management fully agreed with
all findings and
recommendations and has
already taken a number of
actions to correct the
problems.
Access to EPA
Computer
Information Systems
Not Adequately
Controlled
Problem

Although agreeing over the
past 2 years to our
recommendations in four
prior audit reports, EPA still
did not adequately control
access to its computer files.
As a result, the Agency's
highly sensitive financial
payment systems are
unnecessarily exposed to
fraud and abuse from
unauthorized access,
modification, or destruction.
In addition, the Agency
could recover nearly $2.2
million worth of disk storage
space for reuse.

We Found That

EPA user and contractor
access to highly sensitive
operating system,  payroll,
contractor payment, and other
sensitive financial  payment
files was not adequately
controlled because the Agency
did not have an access control
policy and an active security
monitoring program. EPA
could not be assured of its
operating system's integrity or
control over sensitive financial
payment data. As a result, the
Agency is exposed to
unnecessary risks of fraud or
abuse because knowledgeable
perpetrators could access,
modify, or destroy EPA's
computer data and programs
with little fear of detection.
     Although EPA had
implemented an aggressive,
service-oriented direct access
storage devices management
program, opportunities existed
for EPA to recover significant
disk storage for reuse. By
enforcing existing  efficiency-
oriented procedures for all disk
storage, EPA could recover
$2.2 million worth  of disk
storage for reuse. Further, we
identified 25,956 modifications
to system software which
cannot be traced to the
change management
coordination and approval
processes at the National
Computer Center.
    These problems are due
largely to the Agency's not
having planned or provided
sufficient guidance, oversight,
and active monitoring of
contractor personnel
responsible for system
software maintenance, security
administration, and disk
management at its RTP facility
as required by OMB Circular
A-76,  entitled  Performance of
Commercial Activities.

We Recommended That

The Assistant Administrator for
Administration and Resources
Management:

• Improve information security
policies, standards, and
procedures for data protection;

• Correct the identified  system
security weaknesses;

• Develop and implement a
disk storage management
plan;

• Require that all support
services contracts incorporate
performance requirements that
meet  the intent of  the OMB
Circular A-76  performance-
oriented work statement  and
quality assurance  surveillance
plan.

What Action  Was Taken

The final audit report
(2100591) was issued to the
Assistant Administrator for
Administration and Resources
Management on September
22, 1992. A response to the
final report is due by
December 21, 1992. In
responding to our draft report,
the Assistant Administrator
generally agreed with the
findings and recommendations
and has already taken a
number of positive actions to
correct  the problems.
14
                                                             OFFICE OF THE INSPECTOR GENERAL

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Improvements
Needed in the Review
of Precautionary
Statements on
Pesticide Labels

Problem

EPA cannot assure the
public that precautionary
statements on many
pesticide labels are
adequate.

Background

Most pesticides are poisons
that kill or repel animals,
plants, or bacteria that are
considered to be pests.
However, pesticides can have
unintended effects on people,
pets, wildlife  and the
environment if improperly
used. EPA determines from
the registrant's test data what
information is needed on
labels to  use the pesticides
safely.

We Found That

The Office of Pesticide
Programs' (OPP) process for
reviewing and accepting
pesticide labels did not include
prior verification that toxicity
studies existed. In many
cases, the toxicity  studies
would not have been available
even if OPP  had attempted to
obtain them.  Due to certain
provisions of the Federal
Insecticide, Fungicide, and
Rodenticide Act, pesticides
were registered without
requiring a complete set of
toxicity studies. OPP officials
stated that supporting toxicity
data will be collected during its
pesticide reregistration process
which is not expected to be
completed until 2002.
    Further, the precautionary
statements on many pesticide
labels may not be adequate to
protect the user and the
environment.  Almost half  the
pesticide labels evaluated had
missing or inadequate
precautionary statements.
Others were missing
statements restricting usage of
the pesticide to certified
applicators.
    Until recently, OPP
placed little importance  on
incident reports which contain
important information on the
consequences of pesticide
use, including human and
animal deaths and adverse
reactions to pesticides.  For
example, OPP did not require
the registrant to make label
changes to a flea and tick
pesticide until after 200
incidents in 1  year, including
26 animal deaths.
Pesticide being prepared for aerial
spraying (photo by Earl Dotter)
What Action Was Taken

The final audit report
(2100613) was issued to the
Assistant Administrator for
Prevention, Pesticides, and
Toxic Substances on
September 30, 1992. Because
the Assistant Administrator
proposed corrective actions
which, if properly implemented,
will substantially resolve our
concerns, we closed the report
with no outstanding
recommendations.
Actions Needed to
Better Ensure the
Integrity of Data
Supporting
Pesticides
Registrations

Problem

EPA was not effectively
implementing its Good
Laboratory Practices (GLP)
Program. As a result, the
Agency lacked assurance
that the data submitted by
independent laboratories in
support of pesticide
registrations and regulatory
decisions was accurate and
reliable.

Background

In the late 1970's, EPA and
the Food and Drug
Administration (FDA) found
serious deficiencies with data
generated by independent
laboratories. These concerns
led EPA to initiate and adopt
standards of good laboratory
practices for the conduct of
laboratory studies used to
support pesticide registration
under the Federal Insecticide,
Fungicide, and Rodenticide
Act.

We Found That

The GLP Program has not
been effective in ensuring  the
integrity of data produced  by
laboratories used to support
pesticide  registrations and
regulation.  GLP inspections
have not targeted studies
which support chemicals that
are under regulatory review.
The program lacks standards
for accepting or rejecting
laboratory studies.

• Currently, GLP inspections
are generally conducted at
laboratories every 2 years, but
may not cover studies
supporting a chemical currently
under regulatory review.

• The GLP Program lacks
standards for rejecting studies
from laboratories that are in
noncompliance with GLP
regulations. As a result, a
pesticide registration
application may have been
approved based, at least in
part, on a study performed by
a laboratory that did not
conform to the GLP
regulations. As of July 1,
1992, approximately 2,247
audits had identified significant
deficiencies during GLP
inspections. Ninety-six percent
of these audits, however,  had
no  impact on the registered
status of the pesticide product,
with only .4 percent resulting in
the rejection of a study used to
support a pesticide
registration.

• In-progress reviews can
provide timely information to
resolve problems  with  a
laboratory study before the
study is completed and enable
the Agency to evaluate
whether a laboratory is
performing in accordance with
applicable regulations.
However, the future use of
such reviews was in doubt
because the Office of
Prevention, Pesticides, and
Toxic Substances (OPPTS)
had not determined whether
enforcement action may be
taken when violations of the
GLP regulations are identified
during such reviews.
Currently, enforcement action
is not taken.

• Almost 9 years after the
establishment of the GLP
Program, poor communication
within OPPTS' Office of
Compliance Monitoring and
Office of Pesticide Programs
adversely affected the
coordination necessary to
select laboratories for
inspection and studies for
APRIL 1,1992 THROUGH SEPTEMBER 30,1992
                                                                                                                      15

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audit. As a result, many
laboratories have never been
inspected, and their
compliance with GLP
regulations is unknown.  Also,
laboratory studies were often
selected for audit for pesticides
that had already been
canceled or rejected by the
Agency during the scientific
review of the applicable
pesticide.
     Coordination problems
also slowed the review of GLP
inspection reports.  For
example, a 90-day time frame
had been established for
reviewing inspection reports.
However, review of 7 of  13
randomly selected reports
exceeded the 90-day limit, with
one review taking over 1,083
days. Delays in closing
reports have resulted in an
inspection being scheduled at
a laboratory before the prior
inspection report was closed.

We Recommended That

The Assistant Administrator for
Prevention, Pesticides, and
Toxic Substances:

• Direct that GLP inspections
be scheduled to cover
laboratories that have
conducted studies supporting
pending registrations.

• Expedite the development of
standards for accepting or
rejecting  laboratory studies
based on violations of GLP
regulations.

• Require that GLP inspections
include in-progress reviews as
a means to evaluate GLP
compliance.

• Direct that sufficient
resources and qualified staff
be provided to review and
resolve inspection reports.
What Action Was Taken

In responding to our draft
report, the Assistant
Administrator for Prevention,
Pesticides, and Toxic
Substances generally agreed
with our findings and
recommendations and
provided corrective action
plans for each of the
recommendations. The final
audit report (2100661) was
issued to the Assistant
Administrator on September
30, 1992.  A response to the
final report is due  by
December 28, 1992.
Construction
Grants
EPA's wastewater treatment
works construction grants and
State Revolving Fund (SRF)
programs are the largest
programs the Agency
administers. Under the
provisions of Public Law
92-500, as amended, the
Agency was authorized to
make construction grants
covering 55 percent and, in
some instances, up to 85
percent of the eligible costs of
constructing wastewater
treatment facilities.  During this
semiannual period, $231
million  was obligated on 28
new construction grant awards
and 235 increases to existing
grants.  As of September 30,
1992, there were 2,909 grants
involving $21 billion which
were potentially subject to
audit. Of this total, there were
641 active construction grants,
representing $4.9 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,
almost $1.5 billion was
awarded for 45 continuation
SRF grants.  As of September
30, 1992, EPA had obligated
$6.6 billion to 50 States  and
Puerto Rico under the State
Revolving Fund program.
16
                                                               OFFICE OF THE INSPECTOR GENERAL

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 Nearly $63 Million of
 Questioned Costs
 Claimed  for
 Philadelphia,
 Pennsylvania, Project
  Philadelphia, PA
  Reviewed
  Questioned

 0 50 100  150 200  250 300  350 400
 Millions of Dollars
 ^^1 Federal         Non-Federal


 Problem
 The City of Philadelphia
 claimed $20,603,639 of
 ineligible force account,
 engineering, construction
 and indirect costs. An
 additional $42,355,847 of
 unsupported costs were also
 questioned.

 We Found That

 EPA awarded twelve grants to
 the City of Philadelphia to
 modify and upgrade the
 Northeast Water Pollution
 Control Plant to meet National
 Pollutant Discharge Elimination
 System permit requirements
 and to improve sludge
 management.  The grantee
 claimed $20,603,639 of
 ineligible costs under those
 grants, including:

• $8,679,712 of costs
 associated with abandoned
 systems and equipment;

• $4,067,541 of indirect costs
 applied incorrectly;

• $3,073,096 of costs which
 exceeded the grant ceiling;

• $2,113,631 of force account
 project inspection costs
 incurred after the approved
 construction completion dates;

• $940,187 of ineligible
 construction change orders;

• $897,636 of construction
 contract costs awarded in
 excess of low bids; and

• $831,836 of engineering
 costs which  were unapproved
as outside the scope of the
project or were inadequately
documented.
     We also questioned
$42,355,847 of unsupported
costs, including engineering
and construction costs
associated with uncompleted
facilities; unaudited indirect
rates; costs of inoperable
facilities; costs of construction
deficiencies needing
inspection; construction costs;
retainages not paid; and
construction supervision
charges claimed  both as direct
and indirect costs.

We Recommended That

The Regional Administrator,
Region 3, not participate in the
Federal share of ineligible
costs ($15,396,996), determine
the eligibility of the  Federal
share of unsupported costs
($13,596,473), and recover the
applicable amount from the
grantee.

What Action  Was Taken

The final report (2300062) was
issued to the Regional
Administrator, Region 3, on
July 23, 1992. A response is
due by October 23, 1992.
Over $26.5 Million of
Ineligible and
Unnecessary Costs
Claimed for
Underutilized
Russian River Project
 Russian River CSD. CA
Questioned
0 5 10
Millions ol Dollars
^H Federal
15 20
25 30
Non-Federal I I
Problem

The Russian River County
Sanitation District (District),
Guerneville, California,
claimed $8,344,066 of
ineligible construction,
engineering, legal and
administrative costs. An
additional $18,247,400 of
unnecessary costs were
questioned, primarily
because the facility was
significantly underutilized.

We Found That

EPA awarded three grants
totalling $27,720,178 to plan,
design, and construct the
District's wastewater treatment
plant.  The grantee claimed
ineligible costs of $8,344,066,
including:

• $4,553,003 of construction
costs which exceeded
approved  amounts; were
outside the project scope; or
were for an unsubstantiated
claim for differing site
conditions other than those
indicated in the contract to
install a collection system;

• $2,072,492 for EPA's share
of a refund from  the engineer
and construction contractor for
their defective work;

• $1,064,586 of engineering
costs which were allocable to
the ineligible portion of
construction; exceeded
approved  amounts; were
incurred to correct defective
work; or were outside the
scope of the project;

• $919,593 of legal costs
allocable to the ineligible
portion of  construction;
exceeded  approved amounts;
were claimed twice; related to
ordinary operating expenses;
or were outside the project's
scope;

Aeration basin in use
• $304,219 of indirect, force
account, and administrative
costs allocable to the ineligible
portion of construction; were
incurred to correct defective
work; or exceeded approved
amounts; and

• $137,802 for costs of land,
equipment, or supplies
considered excessive or
related to the underutilized
portion of the facility.

     We identified $707,629 of
eligible costs not claimed by
the grantee which were offset
against the above questioned
costs.  We also questioned
$18,247,400 of claimed costs
as unnecessary because (1)
the facility was operating at
only 41  percent of its design
capacity and  (2) change orders
could not be reconciled to
source documents.

We Recommended That

The Regional Administrator,
Region  9, not participate in the
Federal share of the net
ineligible costs ($6,258,050);
determine the eligibility of the
Federal share of unnecessary
costs ($13,685,550); and
recover the applicable amount
from the grantee.

What Action Was Taken

The audit report (2300082)
was issued to the Regional
Administrator, Region 9, on
September 25, 1992. A
response is due by December
24,  1992.
                                                                       Unused aeration basin
APRIL 1,1992 THROUGH SEPTEMBER 30,1992
                                                                                        17

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Oregon Grantee's
$15.6  Million Project
Claim Questioned
 Newberg, OR
 Questioned
[0246  8  10  12  14  16  18
Millions of Dollars
1^1 Federal        Non-Federa


Problem
Newberg, Oregon, claimed
$15,641,057 of costs for a
wastewater treatment facility
that has been discharging
effluent without a valid
National Pollutant Discharge
Elimination System (NPDES)
permit.

We Found That

EPA awarded three grants
totaling $16,036,391 to the
City of Newberg for the design
and construction of a new
secondary wastewater
treatment facility. We
questioned all of the
$15,641,057 of costs claimed
under the grants because the
facility was discharging  without
a valid NPDES permit.
Although the city once had  a
valid permit, it  had  lapsed and
had not been renewed. The
City indicated that it had filed
an  application  for a new permit
with the Oregon Department of
Environmental Quality (DEQ)
in June 1987.  However, a  July
31, 1992, letter from the DEQ
indicated that the grantee may
be  unable to comply with
wastewater quality standards
for  chlorine. Should the
grantee eventually obtain an
NPDES permit, we still
question $3,068,537 of the
claim as follows:

• $2,907,781 of unreasonable
costs for grant funded
equipment which was not
being used;

• $151,758 for costs not
supported by accounting
records; and

• $8,998 of ineligible costs in
excess of the approved grant
amount.

We Recommended That

The Regional Administrator,
Region 10:

• Require immediate action by
the grantee to obtain the
required  NPDES permit;

• If the grantee obtains the
required  NPDES permit, not
participate in the Federal share
of ineligible costs ($6,749) and
determine the eligibility of the
Federal share of the
unsupported and unreasonable
costs ($2,383,028); and

• Recover the applicable
amount from the grantee.

What Action Was Taken

The audit report (2300088)
was issued to the Regional
Administrator, Region 10, on
September 30,  1992. A
response to the report is due
by December 30, 1992.
 New York City
 Claimed Over $16.9
 Million of Questioned
 Costs
  New York City, NY
  Reviewed
  Questioned
      100
           200   300
                     400
                           500
 Millions of Dollars
 I^H Federal        Non-Federal


 Problem
 New York City claimed
 $3,067,609 of ineligible
 construction, engineering,
 and force account costs. An
 additional $13,885,728 of
 unsupported costs were
 questioned.

 We Found That

 EPA awarded two grants to
 New York City to construct the
 North River wastewater
 treatment plant and sludge
 vessel and the Oakwood
Beach wastewater treatment
plant, outfall, interceptor sewer
and force main. We
questioned $3,067,609 of the
grantee's final claim as
ineligible, including:

• $1,323,991 of engineering
inspection fees claimed in
excess of the approved
consulting engineering contract
amount;

• $964,308 of engineering,
inspection,  and force account
costs allocable to ineligible
portions of the project or
allocable to another grant; and

• $779,310 of construction
costs claimed in excess of
payments  made to the
contractor reflecting deductions
made by the grantee from
contractor claims for assessed
liquidated damages and for
change orders to cover
additional costs resulting from
the contractor's defective work.

     We also questioned
$13,885,728 of unsupported
construction, engineering and
force account costs, consisting
mostly of construction cost
overruns for which  no change
orders were submitted for EPA
approval.

We Recommended That

The Regional Administrator,
 Region 2, not participate in the
 Federal share of ineligible
costs ($1,768,442), determine
the eligibility of the  Federal
share of the unsupported costs
 ($8,051,440), and recover the
 applicable amount from the
 grantee.

 What Action Was Taken

 The audit reports (2100449
 and 2100450) were issued to
 the Regional Administrator,
 Region 2, on July 6, 1992.
 Responses are due by
 October 4, 1992.
Operational Problems
at $12.2 Million North
Dakota Facility
 Grand Forks, ND
                   10   12
Millions of Dollars
^^B Federal        Non-Federa


Problem
The City of Grand Forks,
North Dakota, claimed
$3,433,767 of ineligible and
unnecessary/unreasonable
costs, primarily for failed
liners and molding intended
to protect against erosion at
treatment lagoons.

We Found That

EPA awarded three grants
totaling $12,246,712 to the
City of Grand Forks for
expansion and upgrade of an
existing treatment plant and
related structures. Of the
costs claimed, we questioned
$288,501 as ineligible,
including:

• $275,000 of  settlement costs
the City received from a
lawsuit which were not
credited to EPA; and

• $13,501 of project inspection
fees allocable to ineligible
construction or in  excess of a
contract ceiling.

We also  questioned
$3,131,037 as
unnecessary/unreasonable
because liners did not protect
lagoons used to treat sewage
against erosion as intended.
The City of Grand Forks
incurred  additional costs to
place molding  over the liners
which also did not provide
protection as intended. An
engineering firm's report
concluded that the molding
should not have been placed
over the liners in an area
subject to winter icing
conditions.
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We Recommended That

The Regional Administrator,
Region 8, not participate in the
Federal share of ineligible
costs ($227,048), determine
the eligibility of the Federal
share of the
unnecessary/unreasonable
costs ($2,348,278). and
recover the applicable amount
from the grantee.

What Action Was Taken

The audit report (2100668)
was issued to the Regional
Administrator, Region 8, on
September 30,  1992. A
response is due by December
29, 1992.
Milwaukee
Wisconsin, Claimed
Almost $5.8 Million in
Questioned Costs
Problem

The Milwaukee Metropolitan
Sewer District claimed
$3,060,908 of ineligible
administrative, engineering,
inspection and construction
costs. An additional
$2,720,064 of unsupported
administrative, engineering
and inspection costs were
questioned.

We Found That

EPA awarded 27 grants
totaling $232,004,102 to the
Milwaukee Metropolitan Sewer
District for constructing a deep
tunnel and for repairing and
improving existing wastewater
treatment and solids
processing systems. We
questioned  $3,060,908 of the
grantee's final claim as
ineligible, including:

• $1,294,178 of administrative,
engineering, force account and
project inspection costs
allocable to the ineligible
portion of construction;

• $1,236,387 of project
inspection and procurement
costs incurred after the
approved construction
completion dates;

• $255,158 of construction
costs claimed in excess of
eligible change orders;

• $166,762 of engineering
costs due to a design error;
and

• $108,423 of costs not
incurred or in excess of grant
ceilings.

     We also questioned as
unsupported $2,212,403 of
inadequately documented
engineering costs incurred
after the approved construction
completion dates and
$507,661 of administrative and
force account costs not
approved by EPA.

We Recommended That

The Regional Comptroller,
Region 5, not participate in the
Federal share of ineligible
costs ($2,385,191); determine
the eligibility of the Federal
share of the  unsupported costs
($2,128,006); and recover the
applicable amount from the
grantee.

What Action Was Taken

The audit report (2400064)
was issued to the Regional
Comptroller,  Region 5,  on
August 18, 1992. A response
is due by November 17, 1992.
 Superfund
 Program
 The Superfund program was
 created by the Comprehensive
 Environmental Response,
 Compensation, and Liability
 Act of 1980 (CERCLA). The
 Act provided a $1.6 billion trust
 fund to pay for the costs
 associated with the cleanup of
 sites contaminated with
 hazardous waste. Taxing
 authority for the trust fund
 expired on September 30,
 1985. For more  than a year,
 the Superfund program
 operated at a reduced level
 from carryover funds and
 temporary funds provided by
 Congress.
     On October 17, 1986,  the
 Superfund Amendments and
 Reauthorization Act of 1986
 (SARA) was enacted.  It
 provided $8.5 billion to
 continue the program for 5
 more years and made many
 programmatic changes. On
 November 5, 1990,  the
 Omnibus Budget
 Reconciliation Act of 1990 was
 enacted, authorizing
 appropriations  for 3 additional
 years and extension of the
 taxing authority for 4 years.
     The parties responsible
 for the hazardous substances
 are liable for cleaning up the
 site or reimbursing the
 Government for doing so.
 States in which there is a
 release of hazardous materials
 are required to pay  10 percent
 of the costs of Fund-financed
 remedial actions,  or 50 percent
 if the source of the hazard was
 operated by the State or local
 government.
     The enactment of SARA
 increased the audit
 requirements for the Inspector
 General.  In addition to
providing a much larger and
 more complex program for
 which the OIG  needs to
provide audit coverage, SARA
gave the Inspector General a
number of specific
responsibilities. Mandatory
annual audit areas include:

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

• Audit of Superfund claims;

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

• Examination of remedial
investigations and feasibility
studies.

     The Inspector General is
required to submit an annual
report to the Congress
regarding the required
Superfund audit work,
containing such
recommendations as the
Inspector General deems
appropriate. The fifth annual
report,  covering fiscal 1991,
was issued in September
1992.
    In addition, the EPA
Administrator must submit a
detailed report to Congress on
January 1 of each year on the
progress  in implementing
CERCLA during the preceding
fiscal year.  The Agency has
always taken considerably
longer to prepare the report
than the 3 months allowed by
CERCLA.  The OIG is required
to review this report for
reasonableness and accuracy,
and the Agency must attach
the result of the OIG review to
the Agency's annual report.
As of September 30, 1992,  the
OIG had not received a final
version of the Agency's fiscal
1991 report for review.
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                                                                                      19

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Better Administration
Needed of Superfund
Contractor-Operated
Sample Management
Office (SMO)

Problem

EPA's ineffective monitoring
of its contractor resulted in
inadequate consideration of
performance histories in
selecting laboratories to
analyze samples.  Further,
lack of competition
increased EPA's
vulnerability to how the
contractor controls samples,
cost inefficiencies, and
confusion over the
respective roles of the
Agency and the contractor.

Background

EPA's Office of Solid Waste
and Emergency Response
(OSWER) is responsible for
the overall management of the
Contract Laboratory Program
(CLP). The SMO contractor
assists with the management
and administration of the
program by scheduling and
tracking samples, providing
quality control of samples,
awarding subcontracts to
obtain specialized analysis,
and furnishing other related
support, such as management
reporting and assistance.  The
current contract awarded in
1989 has a potential value of
$143,800,000. Sample results
are pivotal in deciding how to
clean up a hazardous waste
site.

We Found That

• Laboratories' Previous
Performance Should Be
Considered In Allocating
Samples. EPA's SMO used
several criteria in allocating
samples to various laboratories
under the CLP.  However, no
consideration was being given
to the results of the Contract
Compliance Screening (CCS)
which assessed laboratory
results for completeness and
compliance with contract
requirements. As a result,
EPA used laboratories with
poor performance histories
under CCS to analyze samples
while laboratories with superior
performance histories were not
used to their capacity.  During
one  month, three laboratories
with  the best performance
histories received only 547
samples, or 78 percent of their
combined capacity while four
laboratories with poor
performance histories received
652  samples, or 109 percent
of their capacity.

• Unnecessary Incentives
Paid to Laboratories.  EPA
received  minimal benefit from
paying almost $400,000 in
incentives to laboratories for
providing about 18,000 sample
analyses earlier than the 35
days required by the contract.
A 1990 SMO study showed
that  39 percent of samples
were received only 1 to 3 days
early.

• Special Analytical Services
(SAS) Procurements Did Not
Comply With Requirements.
SAS were not always procured
in accordance with the  SMO
contract.  Review of a sample
of 157 SAS procurements
showed that 38 procurements
did not comply with
requirements, lacked price
reasonableness
determinations, or lacked
documentation of such
determinations.

     By continually increasing
the contract term and the
contractor's duties, the Agency
has  decreased its opportunity
to obtain competition. The
lack  of competition had
allowed the same contractor to
operate the SMO for more
than a decade, lessening the
Agency's control over
operations  and its susceptibility
to cost inefficiencies and
conflict of interest situations.
EPA sometimes improperly
influenced the contractor to
assign tasks to specific
contractor personnel,
creating the appearance that a
personnel services relationship
existed between the
Agency and the contractor or
that  the contractor performed
inherently governmental
functions.
     In addition, EPA had not
closed CLP contracts timely.
As a result, nearly $20 million
remained obligated
unnecessarily, refunds from
laboratories of about $350,000
were still owed EPA, and
another $250,000 of refunds
had not been received timely,
precluding their use for other
critical Superfund program
needs.

We Recommend That

The Assistant Administrator for
Solid Waste and Emergency
Response:

• Ensure that the SMO
considers CCS performance
when selecting laboratories to
analyze samples.

• Request that the Office of
Administration and Resources
Management eliminate
incentive clauses from future
CLP contracts.

     The Assistant
Administrator for Solid Waste
and Emergency Response and
the Assistant Administrator for
Administration and Resources
Management:

• Ensure that the SMO
contractor performs price
reasonableness determinations
before awarding SAS
procurements and documents
the basis for the
determinations.

• Intensify efforts to increase
competition during the next
solicitation for offers to operate
the SMO, including the splitting
of current requirements.

What Action Was Taken

The final audit report
(2100666) was issued to the
Assistant Administrator for
Solid Waste and Emergency
Response and the Assistant
Administrator for
Administration and Resources
Management on September
30, 1992.  A response to the
report is due by December 29,
1992.  In responding to the
draft report, the Agency
generally agreed with our
findings and recommendations.
More Effective
Monitoring of
Contract Laboratories
Needed

Problem

EPA's Las Vegas, Nevada,
Environmental Monitoring
Systems Laboratory (EMSL)
did not always identify poor
performing CLP laboratories
and initiate timely followup
actions to  assure high
quality analytical data for
Superfund site
investigations.

Background

Under the CLP.  EPA has
awarded contracts to private
laboratories to provide
analytical services to support
Superfund site investigations
and cleanups. EMSL provides
Quality Assurance/Quality
Control (QA/QC)  support to the
CLP through various audits of
CLP laboratories and
evaluations of analytical
methods.

We Found That

• EMSL did not conduct
enough audits to meet its
goals, reducing its ability to
identify deficiencies in
laboratories' performance and
initiate timely follow-up action.
For example,  EMSL had  a
goal to perform a Gas
Chromatography/Mass
Spectrometry tape audit
annually of each  laboratory to
detect deviations from
standard operating procedures
and proper analytical
protocols.  During the 3-year
period of our  review, tape
audits were not performed for
11 of the 42 (26  percent)
laboratories participating  in the
program.

• EMSL had not  established
effective tracking procedures
and systems for evaluating
QA/QC historical performance
by laboratories needed since
1983, diminishing Its ability to
monitor performance trends
and identify poor performing
laboratories.  A system under
development  since 1991  is not
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                                                            OFFICE OF THE INSPECTOR GENERAL

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 projected for full
 implementation until early
 fiscal 1995.

 •  EMSL did not adequately
 report contract compliance
 deficiencies or laboratories
 with recurring  deficiencies. In
 addition, EMSL did not have
 adequate systems for rating
 the overall  performance of
 laboratories. Improvement in
 EMSL's reporting systems
 could assist the Agency
 significantly in administering its
 CLP contracts and increase its
 assurance  that the Superfund
 program is producing analytical
 data of acceptable quality.

 We Recommended That

 The Assistant Administrator for
 Research and Development
 assure that the Director,
 EMSL-Las  Vegas:

 •  Establish clear goals for
 performing QA/QC audits on
 each laboratory in the program
 and establish controls to
 assure sufficient audit
 coverage, with increased
 emphasis on poor performing
 laboratories.

 •  Institute a laboratory based
 tracking system to accumulate
 historical QA/QC performance
 data so that QA/QC efforts can
 be directed at potentially
 vulnerable  areas.

 •  Develop and implement
 procedures for identifying and
 reporting repeat deficiencies
 and laboratory non-compliance
 with contract deliverable
 requirements.

 What Action Was Taken

 The final audit report
 (2100624)  was issued to the
 Assistant Administrator for
 Research and Development on
 September 21, 1992.  The
 Assistant Administrator
 generally agreed with our
 recommendations and cited
 several steps that will be taken
 to correct the noted
 weaknesses, A response to
 the final report is due by
 December 21, 1992.
Region 2 Not Fully
Recovering
Hazardous Waste
Site Cleanup Costs
from Responsible
Parties (RP)

Problem

Region 2's negotiations
process for recovery of
costs incurred in cleaning
up hazardous waste sites
did not always identify and
attempt to collect interest
and Department of Justice
(DOJ) costs or convince the
RPs that all work was
properly performed and
contractor costs were not
excessive.

Background

The Comprehensive
Environmental Response,
Compensation, and Liability
Act of 1980 authorized EPA to
recover from RPs all costs of
response activities incurred in
cleaning up hazardous waste
sites.  In some cases, the RPs
reimburse EPA immediately
upon being notified of their
liability.  In most situations, the
RPs seek to negotiate their
liability for the costs incurred.
If a settlement is reached, EPA
and the RPs may enter into an
agreement requiring the RPs
to reimburse the Agency. If
the RPs refuse, the Region
must decide whether to refer
the case to the DOJ.

We Found That

Region 2 was not maximizing
its recovery of costs from RPs.
In only 1 of the 6 cases
reviewed were total costs
collected.  First, the Region did
not always identify and attempt
to collect interest and DOJ
costs.  In 4 of the 6 cases
reviewed, DOJ costs were not
reimbursed (in three of these
cases such costs were not
included in cost documentation
as required). More
importantly, in 2 of the 6 cases
reviewed, the Region was not
successful in negotiating full
recovery of costs incurred
because the RPs believed that
contractor costs were
excessive or the contractors
had performed poorly. As a
result, EPA did not collect
more than $2,524,300 in
potentially recoverable costs.
     In addition, the Region
did not adequately document
pertinent negotiation activities.
There was little evidence of
negotiation meetings with RPs,
interagency meetings
conducted by Agency officials,
or EPA's negotiation strategy
for settlements.  Without
adequate documentation,
management cannot be
assured that the Agency's
ability to  recover costs has
been  maximized.

We Recommend  That

The Regional Administrator,
Region 2:

• Require close monitoring of
contractor performance  during
the site cleanup phase to
preclude poor contractor
performance as a  responsible
party  bargaining issue when
negotiating cost settlements
with EPA.

• Require the inclusion of all
Superfund costs, including
interest and DOJ costs,  in cost
recovery settlements or
provide adequate justification
for their not being  included.

• Require adequate
documentation of negotiation
activities  and strategies.

What Action Was Taken

The final audit report
(2100501) was issued to the
Regional Administrator, Region
2, on July 27,  1992. A
response to the final report is
due by October 25, 1992. In
responding to the draft report,
the Regional Administrator
generally disagreed with our
findings and recommendations.
Delays and Cost
Increases at the
Stringfellow,
California, Superfund
Site

Problem

EPA Region 9's and the
State of California's cleanup
of Stringfellow hazardous
waste site has been
hampered by (1) incomplete
evaluation of the impact of
laboratory groundwater
sample analyses problems
on data reliability,  (2) the
extension of the Remedial
Investigation/Feasibility
Study's (RI/FS) estimated
completion by more than 6
years at an increased cost of
$9.6 million, and (3) delays
in constructing and starting
up a contaminated
groundwater pretreatment
facility with excess capacity
increasing costs by $3.5
million.

We Found That

Under a cooperative
agreement, EPA Region 9
provided California's
Department of Health Services
Federal funding of
$232,027,468 for cleanup
activities at the Stringfellow
hazardous waste site in
Riverside County, California.
    The reliability of the
laboratory analyses of
groundwater samples taken for
the Stringfellow site was
questionable since the 14-day
maximum holding time for
volatile organic compounds
was exceeded for 44 percent
of the samples and  the
laboratory equipment used for
analysis of the site samples
may not have been properly
calibrated. The laboratory
performing the  sampling work
pleaded guilty to charges of
making false statements and
false claims for backdating
sample analyses results under
EPA's Contract  Laboratory
Program (CLP). While the
Stringfellow sample analyses
were not performed under the
CLP program, the same
laboratory facilities and
equipment may  have been
APRIL 1,1992 THROUGH SEPTEMBER 30,1992
                                                                                                                     21

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used. Region 9 had not
adequately determined the
impact of the laboratory
problems on the data used in
the RI/FS (the phase during
which the best alternative is
determined for cleaning up the
site).  As a result, we
questioned more than $1.2
million of claimed laboratory
sample analyses costs.
    The RI/FS process for the
Stringfellow site was not well
managed by Region 9 or the
State, contributing to the
extension of the RI/FS's
estimated completion date by
more than 6 years and the
estimated costs increasing by
more than 700 percent from
about $1.6 million to at least
$11.2 million.  The Region
was aware that California was
experiencing significant
problems with its RI/FS
subcontractor, but the Region
did not take an active role in
managing the project even
though the use of a
cooperative agreement
contemplates substantial
Federal involvement. The
delays have prolonged the
long-term environmental risks
posed by the site.
Stringfellow Pretreatment Facility

     Management problems in
constructing and starting up
operations of the pretreatment
plant at the Stringfellow site
increased costs claimed by the
State by $3.5 million.  These
increased costs were primarily
due to  a design change which
more than doubled the
pretreatment plant's capacity.
On the basis of contaminated
groundwater flows at the time
of our review, the increased
capacity exceeded
requirements.
     In 1989, the State was
designated as a potentially
responsible party (PRP) for the
Stringfellow site. Retention of
the lead role in the site's
cleanup could create the
appearance of a conflict of
interest.

We Recommended That

The  Regional Administrator,
Region 9:

• Ascertain the effect that the
laboratory sample analyses
problems have on the reliability
of the RI/FS conclusions.

• Determine the allowability of
the costs for laboratory
analyses claimed and paid
under the cooperative
agreement.

• Assure that Region 9
increases its involvement in
the cleanup activities
conducted under the
cooperative agreement.

• Develop appropriate
procedures to assure that an
effective regional construction
management capability is
established for any future
construction projects at the
Stringfellow site.

• Ascertain whether the State
should continue its lead  role
responsibility for the
Stringfellow site in view of the
State's designation as a PRP.

What Action Was Taken

The final audit report
(2300063) was issued to the
Regional Administrator, Region
9,  on July 30, 1992.  A
response to the final report is
due by October 29, 1992.  A
draft audit report was provided
to  the Regional Administrator
on March 30, 1992. Although
the Region generally
responded to the factual
matters  included in the draft
report, the Region did not
specifically address our
recommendations. As a result,
all recommendations need to
be addressed in the audit
resolution process.
EPA Lacks Controls
Over Responsible
Parties' (RP)
Response  Claims

Problem

Internal control weaknesses
hindered EPA's ability to
properly manage RPs'
claims for cleanup of
Superfund hazardous waste
sites.

Background

Superfund was established to
clean up the nation's worst
hazardous waste sites.  To
avoid prolonged litigation and
conserve the Superfund,
Congress authorized EPA to
enter into mixed funding
agreements with RPs.  Under
these agreements, the settling
RPs pay for the cleanup and
submit a response claim to
EPA for reimbursement of an
agreed-upon percentage of the
incurred costs.  EPA had
established 10 agreements for
cleanup costs totaling about
$160 million, with EPA to
reimburse RPs approximately
$35 million, or an average of
22 percent of the total costs.

We Found That

EPA had recorded obligations
of about $35 million to cover
RP  response claims
improperly, untimely, and in
several instances not at all.  Of
the  10 fully executed
agreements, funds had  not
been obligated in the Agency's
Integrated Financial
Management System for five
agreements which amounted
to about $10 million of the
settlements. In the remaining
five cases, the Agency took
between 112 and 429 days
from the signing of the consent
decree to obligate the funds,
despite its requirement that the
funds be obligated within 3 to
10 days.
     Further, the Agency did
not  adequately assure the
eligibility of all costs
reimbursed and the RP's
compliance with the settlement
agreement before paying $2.8
million for the first response
claim. In addition, EPA did not
collect about $1.1 million for
worked performed which the
Agency or its contractors had
performed from 1988 through
1991.

We Recommended That

The Assistant Administrator for
Solid Waste and Emergency
Response:

• Direct the Office of
Emergency and Remedial
Response (OERR) to (1)
periodically reconcile
preauthorized site
commitments and obligations
with  information in the Agency
22
                                                           OFFICE OF THE INSPECTOR GENERAL

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 financial management system;
 (2) delegate responsibility for
 ensuring that sufficient funds
 are committed and obligated to
 the OERR coordinating official;
 and (3) work with the Financial
 Management Division to
 develop proper procedures for
 the timely commitment and
 obligation of funds and correct
 inappropriate site obligations.

 • Issue guidance requiring that
 written reports for a response
 claim review include technical
 evaluations of costs and
 analyses of compliance with
 the terms and conditions of the
 settlement agreement.

 • Work with the Office  of
 Enforcement and the Office of
 General Counsel to modify the
 guidance to require the Office
 of Regional Counsel to verify
 and document, at the time of
 the claim review, that EPA has
 billed and collected costs in
 accordance with the terms of
 the consent decree.
 Furthermore, include language
 in future consent decrees
 which would allow EPA to
 offset RP claims by amounts
 owed EPA.

 • Review the remaining nine
 preauthorized mixed funding
 agreements to determine if
 EPA has billed and collected
 costs in accordance with the
 terms of the respective
 consent decrees.

     The Regional
 Administrator, Region 6, direct
 the Cost Recovery Section to
 collect costs for oversight on
 the site for which the first
 response claim was submitted
 in accordance with the consent
 decree.

 What Action Was Taken

 The final audit report
 (2100662) was issued  on
 September 30, 1992.  A
response to the final report is
due by December 30, 1992.
 In responding to the draft
report, the Agency generally
agreed with the findings and
recommendations.  However,
the Agency disagreed about
the severity of the identified
 weaknesses.
Special  And  Early
Warning Reviews
This section in our semiannual
report describes the results of
significant and potential
findings, deficiencies, and
recommendations which have
been identified through
evaluations, analyses, projects,
and audits.  These reviews are
intended to help Agency
managers correct problems
and recognize the potential for
savings before resources are
fully committed.
Special Reviews

Special reviews are narrowly
focused studies of programs or
activities providing
management a timely,
informative, independent
picture of operations.  Special
reviews are not statistical
research studies or detailed
audits. Rather, they are
information gathering studies
that identify issue areas for
management attention.
 EPA Fails to Comply
 with Printing  and
 Photocopying
 Regulations
 Problem

 EPA program offices
 continued to use contractors
 to print Agency documents
 and allowed contractors to
 exceed photocopying
 limitations in violation of
 Government printing and
 photocopying regulations.

 Background

 Government printing and
 binding regulations prohibit the
 acquisition of printing services
 under contracts unless
 approved by the Congressional
 Joint Committee on Printing.
 Also, these regulations allow
 only 5,000 copies of one page
 or an aggregate of 25,000
 copies of multiple-paged
 documents to be photocopied
 by contractors.  Requirements
 exceeding these limits are to
 be printed by an authorized
 Government Printing Office
 plant.  In 1988 and 1991, the
 Agency's Procurement and
 Contracts Management
 Division issued memoranda
 reminding Agency officials of
 these provisions.  Further,
 Agency contracts contain a
 standard provision on the
 prohibition and limitation on
 the acquisition of printing and
 duplication services.

 We Found That

 Contrary to clear guidance,
 Agency Project Officers (PO)
 and Work Assignment
 Managers (WAM) continued to
 initiate delivery orders for
 printing services (primarily
 newsletters), and Contracting
 Officers (CO) approved these
 requests.  For example, the
first three issues of the
 newsletter entitled,
 "Contaminated Sediment
 News" were printed by a
contractor at a total cost of
about $2,100. Both the PO
and WAM stated that they
were unaware of the
prohibition on contracting for
printing.  They believed that
APRIL 1,1992 THROUGH SEPTEMBER 30,1992
                                                                                      23

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contractors were permitted to
perform printing services if the
total number of pages did not
exceed 25,000, not
recognizing the difference in
duplicating and printing.
Although the contract
contained the standard clause
mentioned above, the CO
approved the work
assignments including the
printing of the newsletter.
     In one photocopying
case, a contractor was
requested to duplicate 2,000
copies of a 43 page document,
or 86,000 pages.  After
reviewing the work request,
the contractor prepared four
separate work orders in the
requestor's name so the
25,000 copy limitation would
not be exceeded.
     Also, there is no central
control or comprehensive
listing of Agency newsletters.
However, from information
provided, we estimate there
may be between 75 and 100
EPA newsletters.  Most were
apparently being published
without the knowledge of the
Office of Communication,
Education and Public Affairs
(OCEPA) because they did not
have an Agency  publication
number as required by that
office.  Further, there was no
independent review before or
after a newsletter's inception to
evaluate its cost  effectiveness
or the educational value.  As a
result, many newsletters did
not conform to Agency graphic
standards.

We Recommended That

The Assistant Administrator for
Administration and Resources
Management:

• Train COs, POs and WAMs
on the printing and
photocopying limitations under
EPA contracts.

• Include reviews to detect
illegal printing in  the
contracting quality assurance
process.

• Develop quality control
procedures to monitor and
ensure the effectiveness of the
EPA printing operations.
    The Associate
Administrator for
Communication, Education and
Public Affairs:

•  Maintain  a complete and
current listing of all Agency
newsletters.

•  Review and approve existing
newsletters and requests for
additional newsletters to
determine  whether duplication
exists, graphic  standards are
met, newsletters can be
combined or eliminated, and
costs are justified.

What Action Was Taken

The special review report
(2400068) was issued to the
Assistant Administrator for
Administration and Resources
Management, the  Assistant
Administrator for Prevention,
Pesticides and Toxic
Substances, and the Associate
Administrator for
Communication, Education and
Public Affairs on September 4,
1992. A response is due by
December 4, 1992. The
Agency generally agreed with
the report's findings and
recommendations and stated
that corrective actions would
be taken to improve its
compliance with printing and
photocopying regulations.
Proper  Permitting
Procedures Not
Followed for Ohio
Incinerator

Problem

The validity of the Resource
Conservation  and Recovery
Act (RCRA) permit issued
for operation of a hazardous
waste incinerator being
constructed by Waste
Technologies  Industries
(WTI) and WTI's obligation
to comply with financial
assurance requirements are
clouded by changes in
ownership.
Background

In 1985, EPA Region 5 issued
a RCRA permit to WTI, a
partnership, to construct and
operate a hazardous waste
incinerator in Ohio.  Over the
years, several private and
governmental organizations
have questioned the validity of
the permitting process and the
safety of the facility's
operation.  Congressman
Harley O. Staggers, Jr. (West
Virginia) requested review of:
(1) EPA's permitting  process
for WTI, (2) the potential
effects of atmospheric
inversions on air quality, (3)
the appropriateness of
technology used by WTI, and
(4) issues related to the
ownership and operation of the
facility.

We Found That

•  In 1983, EPA did not provide
the State of West Virginia with
a copy of WTI's permit
application and the draft
permit. This was corrected in
1984 by EPA's re-opening the
public comment period.

•  EPA did not include the land
owner on the permit  when it
was initially issued.   In a
subsequent modification,  EPA
added the land owner to the
permit without the owner's
consent who then appealed to
EPA's Environmental Appeals
Board.

•  Regulations did not require
EPA to consider the  effects of
atmospheric inversions on air
quality. However, the State of
Ohio conducted air modelling
studies and concluded no
adverse effects were expected.
Environmental agencies from
Pennsylvania and West
Virginia concurred.  EPA  is
currently conducting  a two-
phased risk assessment that
will include consideration of air
inversions.

•  EPA approved WTI's
proposed technology.
However, the final
determination will be  made
during the trial burn when the
technology will be judged
acceptable if the facility
operates within its prescribed
permit restrictions.

• The partners making up WTI
have changed, or changed
names, several times. The
effect on the validity of WTI's
permit or WTI's responsibility
to comply with financial
assurance requirements  is
unclear.  EPA requested that
WTI provide detailed
information related to the past
and current partnership
structure and operational
control in an effort to resolve
these issues.

We Recommend That

The Regional Administrator,
Region 5:

• Make public the schedule for
conducting  EPA's risk
assessment.

• Determine whether the WTI
partnership and all individual
partners were viable entities
and properly licensed
throughout the life of the
RCRA permit.

• Identify the entity or entities
responsible and financially
liable for the WTI incinerator.

• Establish which entity or
entities have current
operational control of the WTI
incinerator.

• Re-evaluate the validity of
WTI's RCRA permit  in light of
the determinations made about
ownership and financial
assurance issues.

What Action Was Taken

 The final report (2400056) was
issued to the Regional
Administrator, Region 5,  on
July 15, 1992. In a July 23,
 1992, memo, the Deputy
Regional Administrator
designated responsibility and
target dates for responding to
each  of our recommendations.
On July 24,  1992 the
Environmental Appeals Board
found that EPA Region 5 erred
in unilaterally modifying the
permit to include the land
owner.  The Board remanded
the matter to Region 5 for
24
                                                                                          OFFICE OF THE INSPECTOR GENERAL

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 corrective action.  In
 September, WTI purchased
 the land, thereby eliminating
 the need to modify the permit.
 In a September 9,  1992, letter
 to interested parties, the
 Region stressed that the
 preliminary risk assessment
 concluded that no adverse
 health effects were expected
 from the operation of WTI's
 hazardous waste incinerator.
 On October 1, Region 5 issued
 a determination that the permit
 correctly listed WTI as owner.
 A response to the final report
 was issued on October 15,
 1992.  The report has been of
 continuing interest to several
 members  of Congress.
What Action Was Taken

The special review report
(2400084) was issued to the
Regional Administrator, Region
3, on September 30, 1992.  A
response is due by December
30, 1992.
 $4.4 Million  of
 Duplicate Costs
 Claimed for
 Philadelphia,
 Pennsylvania, Project

 Problem

 The City of Philadelphia,
 Pennsylvania (City),
 submitted an interim claim
 for an estimated $4,415,014
 of construction  management
 costs charged as both direct
 and indirect costs.

 We Found That

 EPA awarded a grant and
 amendments totaling
 $158,264,200 to the City to
 construct various facilities at
 the City's Southwest treatment
 plant. An  accounting
 deficiency resulted in
 construction management
 costs being claimed as both
 direct and indirect costs.  We
 estimate the grantee has
 claimed ineligible costs of
 $4,415,014. The final claim for
 the Southwest plant grant has
 not yet been submitted for
 audit.

 We Recommended That

 The Regional  Administrator,
 Region 3, not  participate in the
 Federal share of the ineligible
costs ($3,311,261) and recover
the applicable amount from the
grantee.
APRIL 1,1992 THROUGH SEPTEMBER 30,1992
                                                                                                                   25

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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 summaries OIG
reviews of the Agency's
followup actions on selected
reports completed in prior
periods.  In addition,
information is presented on
the resolution of significant
reports issued by the OIG
involving monetary
recommendations.
Appendix 2 summaries the
status of each report issued
before the commencement
of the reporting period for
which no management
decision had been made by
the end of the reporting
period.


EPA Office of Inspector General Status Report On Perpetual Inventory of Reports in Resolution
Process For The Semiannual Period Ending: September 30,1992
                                             Dollar Values (in thousands)
                                      Report Issuance
                                 Questioned Recommended
                        Number     Costs    Efficiencies
                                    Report Resolution
                                    Costs Sustained
                                   To Be
                                 Recovered
                                            As
                                        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
 282   355,790
 918    173,407
 620

 580
     66

529,131
239    91,806
339   437,324
102   269,164
 382,688


 121,652



  14,129

 490,211



 256,571





 233,641





131,411
                             47,600
1,058
* 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.
 26
                                                          OFFICE OF THE INSPECTOR GENERAL

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  Audit Followup
  The Inspector General Act
  Amendments of 1988 have
  focused increased attention on
  Agency responses to the
  findings of the Inspectors
  General (IG). Agency
  management is now required
  to report semiannually, in a
  separate report to Congress,
  the corrective actions taken in
  response to the IG's reviews.
  The Office of Inspector
  General reviews the Agency's
  followup actions on selected
  reviews. Below are
  summaries of two of these
  reviews.
 Assessed  Penalties
 Against RCRA
 Violators Have
 Increased  But Should
 Be Higher

 Previous Problems and
 Findings

 Our September 1989 report
 showed that EPA had failed
 to adhere to Agency policies
 and procedures for
 assessing penalties under
 the Resource  Conservation
 and Recovery Act (RCRA).
 Monetary penalties were in
 some cases insufficient to
 eliminate the economic
 benefits of violators'
 noncompliance, were not
 sufficient for the gravity of
 the offense, were
 excessively mitigated, and
 were not properly
 documented.

 Followup Findings

 Our followup report found that
 while improvements in the
 RCRA enforcement program
 were evident (e.g., RCRA
 administrative penalties
 quadrupled in fiscal 1991 and
 1992), the Agency's actions on
 our recommendations were not
 timely or fully successful in
 correcting the previously
 reported conditions. The
 Agency had not established a
 strong oversight role in RCRA
 administrative enforcement as
 indicated in its response to our
 September  1989 report.  The
 regions were to submit penalty
 calculation worksheets with all
 final  Consent
 Agreements/Final Orders
 (CA/FO). The Office of Solid
 Waste and  Emergency
 Response (OSWER) was to
 periodically review and analyze
 these worksheets to ensure
 the regions' consistent
 implementation of the
 Agency's penally policy.
 We found the regions had not
 attached the required
 documents to 11 of 17 CA/FOs
 submitted to OSWER, and
OSWER had not always
followed up with the regions
when the required documents
were not  attached. In addition,
OSWER conducted no formal
 reviews of proposed or
 assessed penalties during
 fiscal 1991.  Further, OSWER
 had not designated an official
 to ensure these periodic
 reviews were performed.  As a
 result, conditions similar to
 those previously reported still
 existed, including:  (1) failure
 to consider the economic
 benefit of noncompliance for
 all violations cited in a
 complaint, (2) excessive
 mitigation of proposed
 penalties  (for 17 cases settled
 by EPA in fiscal 1991 .final
 penalties of $4 million were
 only 59 percent of the initially
 proposed $6.8  million), and (3)
 inadequate documentation to
 justify reductions of proposed
 penalties.
    Our review also showed
 that press  releases  issued on
 settled enforcement cases, in
 which the final penalty is
 appreciably less than the
 initially proposed amount, did
 not comply with Agency policy.
 Such releases should include
 standard text to ensure that
the general public is
 adequately informed of the
 analysis behind the final
penalty and the justification for
the penalty reduction.
                                                             Followup Recommendations

                                                             We recommended that the
                                                             Assistant Administrator for
                                                             Solid Waste and Emergency
                                                             Response:

                                                             • Provide sufficient resources
                                                             to assure adequate oversight
                                                             of regional programs;

                                                             • Re-evaluate the current
                                                             implementation plans for the
                                                             revised RCRA Civil Penalty
                                                             Policy (RCPP) to assure that
                                                             adequate training and
                                                             guidance are provided to
                                                             regional personnel.

                                                             • Assure that regional
                                                             personnel comply with the
                                                             revised RCPP regarding
                                                             consideration of the estimated
                                                             economic benefits of
                                                             noncompliance in proposed
                                                             and assessed penalties;

                                                             • Assure that regional
                                                             personnel  document all
justifications for non-inclusion
of economic benefits in
proposed and assessed
penalties; and

• Assure that regional
personnel comply with the
requirements of Agency policy
when issuing press releases
on completed enforcement
actions.

What Action Was Taken

The special review report
(2400085) was issued to the
Assistant Administrator for
Solid Waste and Emergency
Response and the Assistant
Administrator for Enforcement
on September 30, 1992. A
response to the report is due
by December 30, 1992.  In
responding  to the draft report,
the Assistant Administrator for
Solid Waste and Emergency
Response and the Assistant
Administrator for Enforcement
noted the dramatic increase in
RCRA penalties and indicated
that numerous corrective
actions have occurred since
our review.  They also agreed
that documentation supporting
proposed and assessed
penalties needed
improvement.
                              Further Action
                              Needed to Enforce
                              Polychlorinated
                              Biphenyls (PCB)
                              Transformer Fires
                              Rule

                              Previous Problems and
                              Findings

                              PCBs are a family of highly
                              toxic carcinogenic
                              compounds that were
                              primarily used as  insulating
                              fluid  in electrical
                              transformers. Since
                              frequent fires in PCB
                              transformers produced
                              dioxins and furans-
                              significantly more toxic than
                              the PCB fluid-EPA
                              published a Transformer
                              Fires Rule in July  1985. The
                              rule, designed to prevent
                              fires and limit exposure
                              during PCB transformer
                              fires, banned the further
APRIL 1,1992 THROUGH SEPTEMBER 30,1992
                                                                                     27

-------
installation of PCB
transformers in or near
commercial buildings. In
addition, the rule required
that (1) all PCB transformers
in or near commercial
buildings be registered with
the responding fire
department and commercial
buildings owners, (2) some
transformers be removed or
equipped with protective
devices that would shut a
transformer down if
electrical currents reach a
level high enough to rupture
the transformer's casing and
catch fire, and (3) PCB
transformer fire related
incidents be reported to the
National Response Center
(NRC).
    Our March 1988 report
showed that many small and
volunteer fire departments
were unaware of the rule's
requirements. We also
reported that (1) EPA
devoted  insufficient
attention to commercial
buildings where public
exposure to a PCB fire
would  likely be the greatest,
(2) the effectiveness of
inspections to monitor
compliance with the rule
was limited by the process
for  selecting facilities, and
(3) additional guidance was
needed for the rule
provision requiring
equipment safety features
(enhanced  electrical
protection) designed to limit
future fires. As a result, fire
personnel and the public
could be unnecessarily
exposed to the toxic by-
products of PCB fires.
    Our report
recommended that the
Assistant Administrator for
Prevention, Pesticides and
Toxic Substances conduct
an awareness program for
small and volunteer fire
departments and commercial
building  owners and develop
guidance to improve the
inspection  program.

Followup Findings

Our special report found that
the  Agency had improved  its
outreach  efforts to provide
commercial building owners
with information on the PCB
Transformer Fires Rule.
However, the Agency needs to
take further action to ensure
that small and volunteer fire
departments are aware of the
rule and to improve the
effectiveness of inspections
which monitor compliance with
the rule. Specifically, EPA
needs to devote additional
attention to distributing
information about the rule,
ensuring compliance with the
rule's enhanced electrical
protection provisions, and
more effectively targeting
commercial buildings for PCB
inspections.

Followup Recommendations

We recommended that
Assistant Administrator for
Prevention, Pesticides and
Toxic Substances:

• Contact State Fire Bureaus
to  arrange for the distribution
of  information on  the rule to
small and volunteer fire
department personnel and
have the Bureaus periodically
followup on the effectiveness
of  the distribution efforts.

• Distribute copies of NRC
incident reports directly to
pesticides and toxic
substances branches in
regional offices for their
discretionary use in targeting
PCB inspections.

• Follow-up periodically with
NRC to ensure receipt of all
incident reports.

• Obtain feedback from
inspectors on the use of the
enhanced electrical protection
guidelines and update these
guidelines as appropriate.

What Action Was Taken

In  responding to our draft
report,  the Assistant
Administrator for  Prevention,
Pesticides and Toxic
Substances generally agreed
with our recommendations and
cited steps already in process
to correct the problems.
Specifically,  the Assistant
Administrator stated that (1)
negotiations were in progress
for the State Fire Bureaus to
distribute information about the
rule, (2) Headquarters copies
of NRC incident reports will be
distributed to the appropriate
units of regional offices, and
(3) the inspection guidelines
will be updated to include the
enhanced electrical protection
requirements and emphasized
in future training. The final
special report (2400065) was
issued to the Assistant
Administrator on August 21,
1992, and a response is due
by November 20, 1992.
Status Of
Management
Decisions On IG
Reports

This section presents statistical
information as required by the
Inspector General Act
Amendments of 1988 on the
status of EPA management
decisions on reports issued by
the OIG involving monetary
recommendations.  In order to
provide  uniformity in reporting
between the various agencies,
the President's Council on
Integrity and Efficiency issued
guidance on reporting the
costs under required statistical
tables of sections 5(a)(8) and
(9) of the Act, as amended.
     As  presented, information
contained  in Tables I and II
cannot be used to assess
results of reviews performed or
controlled  by this office. Many
of the reports counted were
performed by other Federal
auditors or independent public
accountants under the Single
Audit Act.   EPA OIG staff does
not manage or control such
assignments.  In addition,
amounts shown as costs
questioned or recommended to
be put to better  use contain
amounts which were at the
time of the review unsupported
by adequate documentation or
records. Since auditees
frequently  provide additional
documentation to support the
allowability of such costs
subsequent to report issuance,
we expect that a high
proportion of unsupported
costs will not be sustained.
     EPA OIG controlled
reports resolved during this
period resulted in $51.2 million
being sustained out of $73.3
million considered ineligible in
reports under OIG control.
This is a 70 percent sustained
rate.
28
                                                            OFFICE OF THE INSPECTOR GENERAL

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Table 1 — Inspector General Issued Reports With Questioned Costs
Semiannual Period Ending: September 30, 1992




Dollar Values (thousands)
Questioned*
Number Costs
A. For which no management decision has been
made by the commencement of the reporting period 141 355,790
B. New Reports issued during period 110 173,341
Subtotals (A -i- B) 251 529,131
C. For which a management decision was made
during the reporting period 97 91,806
(i) Dollar value of disallowed costs 74 47,600
(ii) Dollar value of costs not disallowed 75" 44,206
D. For which no management decision has been
made by the end of the reporting period 1 54 437,324
Reports for which no management decision
was made within six months of issuance 61 269,164
'Questioned costs include the unsupported costs.
"On 23 reports management did not sustain any of the $6,375,617 questioned costs.
Unsupported
Costs

55,808
53,440
109,248

20,278
6,058
14,221

88,969

36,751

The remaining
















52 reports are included in C(ii) because they were only partially sustained. Only the costs questioned
that were not sustained in C(i) are included in this category.
Table 2— Inspector General Issued Reports With
That Funds Be Put To Better Use
Semiannual Period Ending: September 30, 1992



Recommendations


Number





Dollar Value
(in thousands)
A. For which no management decision has been made
by the commencement of the reporting period
B. Which were issued during the reporting period
Subtotals (A + B)
53
61
114
382,688
107,523
490,211
C. For which a management decision was made during
the reporting period
(i) Dollar value of recommendations that were
agreed to by management
based on proposed management action
- based on proposed legislative action
(ii) Dollar value of costs not disallowed
(iii) Dollar value of non-awards or unsuccessful
bidders
48

4*
n/a
n/a
17*

30
256,571

1,058
n/a
n/a
15,141

240,371"
D. For which no management decision has been made by the
end of the reporting period
Reports for which no management decision was
within six months of issuance
66
made
18
233,641

131,411
                              *Two of the reports were the same reports in items C(i) and C(ii). Only the related dollars disallowed
                              were included in C(i), whereas the dollars which were not disallowed were included in C(ii).
                              "This amount represents the dollar value of recommendations that funds be put to better use.
APRIL 1,1992 THROUGH SEPTEMBER 30,1992
29

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Resolution of Significant Reports
Report Issuance
Repoer Number / Grantee /
Report Date Contractor
S2CWLO-01-01 09 LOWELL MA
2100293
REPORT DATE
3/27/92

E2CWMO-02-0042 WARREN
COUNTY SD1 NY
2200018
REPORT DATE
5/6/92
E2CWM(X)2-0183 BUFFALO SA NY
2200016
REPORT DATE
4/15/92

P2CWLO-02-0039 LIBERTY NY
2100206
REPORT DATE
1/30/92

P2CWL9-02-0258 WAYNE
TOWNSHIP NJ
2100165
REPORT DATE
1/2/92

P2CWL9-02-0311 AMHERSTNY
2100155
REPORT DATE
12/31/91

P2CWNO-03-0322 PHILADELPHIA
CITY OF PA
1300116
REPORT DATE
9/26/91

P2CWN9-03-0262 PRINCE WILLIAM
CO SERV AUTH VA
2300007
REPORT DATE
10/28/91
P2GWN9-03-0015 HARRISBURG
SEWERAGE AUTH PA
2300011
REPORT DATE
10/30/91
S2CWN8-04-0309 MEMPHIS TN
1300093
REPORT DATE
8/2/91
D8AML2-05-0046 ESE (PEORIA) IL
2100517
REPORT DATE
8/7/92
P2CWP9-05-0070 INDIANAPOLIS IN
1400047
REPORT DATE
9/24/91
FS Questioned /
Recommended
Report Resolution
Federal Share
to be Recovered /
Sustained
Efficiency
INEL
UNSP
UNUR
RCOM

INEL

UNSP
UNUR
RCOM
INEL
UNSP
UNUR
RCOM

INEL
UNS
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
1,053,505
102,701
0
0

416,260

0
0
0
533,913
0
0
0

437,053
170,528
0
0

1,020,217

3,685,115
0
0

4,433,158
2,046,157
0
0

7,164,570

2,565,660
341,229
0

601,963
73,402
0
0
776,776

877,246
0
0
2,192,930
1,016,314
236,971
0
0
0
0
1,013.073
3,565,238
1,589,503
0
0
INEL
UNSP
UNUR
SUST

INEL

UNSP
UNUR
SUST
INEL
UNSP
UNUR
SUST

INEL
UNSP
UNUR
SUST

INEL

UNSP
UNUR
SUST

INEL
UNSP
UNUR
SUST

INEL

UNSP
UNUR
SUST

INEL
UNSP
UNUR
SUST
INEL

UNSP
UNUR
SUST
INEL
UNSP
UNUR
SUST
INEL
UNSP
UNUR
SUST
INEL
UNSP
UNUR
SUST
Efficiency
1,019,356
0
0
0

416,260

0
0
0
533,913
0
0
0

437,053
170,528
0
0

555,897

0
0
0

4,377,632
1,585,756
0
0

5,784,966

1,200,269
0
0

456,757
73,402
0
0
757,633

876,037
0
0
2,192,930
133,776
236,971
0
0
0
0
1,013,073
3,551,791
1,243,454
0
0
Resolution of Significant Reports
Repoer Number/ Grantee/
Report Date Contractor
P5BFNO-06-0210TX WATER
COMMISSION TX
1300080
REPORT DATE
6/19/91

P2CWN9-07-0092 OMAHA, NB
2300029
REPORT DATE
1/15/92
E2CW8-09-0024 HONOLULU CITY &
COUNTY OF HI
0300090
REPORT DATE
9/19/90

E2CW8-09-0037 HONOLULU, CITY
& COUNTY OF HI
0300092
REPORT DATE
9/19/90

E2CWN9-09-0033 HONOLULU, CITY
& COUNTY OF HI
0300091
REPORT DATE
9/19/90

S2CWN9-09-0254 SAN JOSE, CITY
OFCA
2300031
REPORT DATE
1/28/92


NOTE'
INEL = INELIGIBLE COST
UNSP > UNSUPPORTED COST
Report Issuance
FS Questioned /
Recommended
Report Resolution
Federal Share
to be Recovered /
Sustained
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





3.002,915

0
0
0

558,114
0
0
0
1,018,067

0
2,031,050
0

12,202,264

0
1,870,125
0

1,655,708

0
3,148,635
0

1,844,775

0
0
0





INEL

UNSP
UNUR
SUST

INEL
UNSP
UNUR
SUST
INEL

UNSP
UNUR
SUST

INEL

UNSP
UNUR
SUST

INEL

UNSP
UNUR
SUST

INEL

UNSP
UNUR
SUST





Efficiency
3,000,758

0
0
0

558,114
0
0
0
1,018,067

0
0
0

7,941,825

0
0
0

1,341,948

0
0
0

1,844,039

0
0
0





UNUR = UNNECESSARY/UNREASONABLE COST
RCOM = RECOMMENDED EFFICIENCIES
SUST = RECOMMENDED EFFICIENCIES SUSTAINED


























































































30
                                                                                           OFFICE OF THE INSPECTOR GENERAL

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   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, 1992          214

New Investigations Opened
This Period              117

Investigations Closed This
Period                  126

Pending Investigations as of
September 30, 1992      205
Prosecutive and
Administrative
Actions

In this period, investigative
efforts resulted in 21
convictions and 13*
indictments. Fines and
recoveries, including those
associated with civil actions,
amounted to $3.6 million.
Sixteen administrative
actions** were taken as a
result of investigations:

Reprimands
Resignations/Removals
Suspensions
Other
 5
 3
 2
J
16
                                                           * 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-205)
                 General EPA Programs
                                                                               Superfund And LUST
                                       Construction
                                              29
                                      Procurement
                                      Fraud
                                      34
                                                               Employee
                                                               Integrity
                                                               U
                                                                            Other
                                                                            1
               Total Cases -135
                                                                                 Total Cases - 70
APRIL 1,1992 THROUGH SEPTEMBER 30,1992
                                                                                                                 31

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Description  Of
Selected
Prosecutive
Actions
Below is a brief description of
some of the prosecutive
actions which occurred during
the reporting period.  Some of
these actions resulted from
investigations initiated before
April 1, 1992.
Superfund Contract
Laboratory Program
Investigation

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

New York  Lab
President  Convicted
of Fraud

The president of Nanco
Environmental Services, Inc.,
of Dutchess County, New
York,  was convicted in
September 1992 of mail fraud
and submitting false
statements to  EPA, as well as
conspiring to submit false
statements.  The charges are
related to analyses of soil and
water samples for EPA.  Arun
Gaind, the president, and
Sohail Jahani, a supervisor,
engaged in a scheme of
setting back the dates on the
computer data systems to
which Gas Chromatograph/
Mass Spectrometer
instruments were attached in
order to make it appear that
laboratory analyses of samples
were performed within EPA-
approved holding times when,
in fact, they were not. Jahani
pled guilty in May 1992 to
conspiracy to  defraud EPA,
and James Daly, another
supervisor at Nanco, pleaded
guilty in October 1991 to
causing false submissions to
be made to EPA.
Lab Firm Vice
President Pleads
Guilty

In July 1992, Richard Posner,
a former vice president of
United States Testing
Company of Hoboken, New
Jersey, a subsidiary of SGS
North America, Inc. (a part of
the SGS Group, the world's
largest inspection and testing
company with over 21,000
employees in 140 companies),
pleaded guilty to a charge of
making a false statement to
EPA. Posner admitted that he
caused company employees to
falsify information contained in
his laboratory's report on the
chemical analysis of a
Performance Evaluation test
submitted by EPA as part of  its
laboratory evaluation
procedure.
    In April 1991, the
company was ordered to pay a
$100,000 criminal fine and to
repay the entire contract price
of $869,486.90 as  restitution  to
the United States.
    U.S. Testing admitted to
backdating tests of water and
soil samples at Superfund
sites.  By "peak shaving,"
(manual manipulation of
calibration), which violated the
required testing sequence,
U.S. Testing sought to
disguise its  failure to conduct
timely tests.


Two Lab Employees
Banned  from CLP

Two employees of Analytical
Services, Corp., Darren
Cothren and Randy Creighton,
have admitted to falsifying data
submitted to EPA.  The two
have agreed to a pre-trial
diversion agreement which
includes being banned from
CLP work for three years.
Cothren and Creighton claimed
that they were directed to
submit the false data by former
manager Lee Kidd. After
being interviewed and
admitting guilt, Kidd committed
suicide. As reported in the
previous semiannual report,
Analytical Services pleaded
guilty to making a false claim
and was fined $500,000.
EPA Computer
Supplier Made False
Claims

American Coastal Industries,
Inc. (ACI), a former supplier of
computer equipment and
software to EPA, pleaded
guilty in July 1992 to making
false claims to EPA. The
corporation was fined
$600,000 and ordered to pay
restitution in the amount of
$1.11 million, as part of a civil
settlement negotiated by the
Inspector General Division of
the EPA Office of General
Counsel and the Office of
Investigations, working with the
Department of Justice.  This
case arose from an OIG audit
and subsequent criminal
investigation which revealed
that ACI had intentionally
submitted false cost or pricing
certifications and had
overcharged EPA
approximately $600,000 under
a contract to provide personal
computers and related
products to EPA.
     In July 1990 ACI was
awarded an EPA contract
under provisions of a minority
set- aside program
administered by the Small
Business Administration.  The
contract had a firm fixed
price/indefinite
delivery/indefinite quantity
basis in which ACI was to
supply computer work stations,
computer software,
peripherals, and related
support services to  EPA. The
contract, with a potential value
of $67.5 million, was the
largest small business set-
aside contract ever awarded
by EPA and one of the largest
in the nation.
     The investigation also
resulted in the indictment of
Daniel Johnston, general
manager of ACI's
Communications Systems
Group, for major fraud, false
claims, and criminal
infringement of a copyright.
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The indictment alleges that
Johnston presented false cost
and pricing data to EPA
regarding the Durham facility,
presented false claims to EPA
for computer products, failed to
notify EPA of the change in
cost and pricing data of the
contract's standard computer
system when ACI replaced
that system, and infringed
upon the copyrights of IBM
and Diagsoft, Inc.
    Finally, ACI signed a
compliance agreement with
EPA, under which ACI agreed
to (1) cooperate fully in the
Government's ongoing criminal
investigation; (2) make
personnel changes at the
highest levels of ACI
management; (3) implement a
rigorous corporate ethics
program, including the
development of an anonymous
whistleblower program; and (4)
conduct management training
workshops for ACI personnel
on federal procurement.
    DIG audit personnel
assisted investigators in this
case.
Company President
Sentenced for False
Test  Results

Alan Stevens, president of
Stevens Analytical
Laboratories, Inc., Stoneham,
Massachusetts, was sentenced
to six months of home
confinement for mail fraud
relating to falsifying
environmental data. As a
result of a joint investigation
with EPA's Criminal
Investigations Division,
Stevens and  the lab were
charged in March 1992 with
providing false water quality
test results to several
customers, including 2 towns,
a hospital, EPA, and the
Massachusetts Water
Resources Authority. The
government alleged that the
defendants accepted from
customers a large number of
samples to be analyzed, failed
to analyze them in a timely
fashion, and provided false
and fictitious  results.
    The case resulted from a
joint investigation by the EPA
OIG and the Criminal
Investigations Division of
EPA's Office of Enforcement.
 Missouri Man Admits
 Knowledge of
 Impersonation
 Scheme

 Terry Catwalleder, an
 employee of a St. Louis,
 Missouri, executive search
 firm, has entered a plea
 agreement admitting he knew
 of schemes by other
 employees to falsely represent
 themselves as EPA
 employees.  They contacted
 various companies nationwide
 in search of engineers and
 contractors to meet requests of
 clients.  In a related case,
 detailed in our semiannual
 report for the period ending
 March 31, 1992, Timothy
 Austin pleaded guilty to
 impersonating an EPA
 employee to obtain  and
 subsequently sell a listing of
 employees who had both
 nuclear engineering and
 wastewater treatment
 expertise.
Man Pleads Guilty to
Faking EPA
Employment

Rex Robinson pled guilty in
May 1992 to falsely pretending
to be an EPA official.  In his
scheme, Robinson contacted
several employees of a
Lansing, Michigan, company
and told them that their
company had been targeted by
EPA as having  a copier toner
recycling problem. He met
with company employees in
October 1990 accompanied  by
a woman who produced a
business card indicating she
was a representative of a toner
company.  Robinson stated
that it was common for some
EPA employees to work with
toner companies.  In fact,
Robinson was a salesman for
an Eaton Rapids,  Michigan,
toner company.
Instructor Indicted
for Allegedly
Falsifying
Educational
Qualifications

In order to obtain the approval
of EPA for an asbestos
abatement course to be
provided by his company,
Safety Management Institute,
Christopher Tate allegedly
made false statements
regarding his qualifications as
a course instructor.  Tate has
been indicted for claiming he
had a B.S. degree in
environmental health and
physiology, with a major in
chemistry, and that he was a
Certified Industrial Hygienist,
when  he does not have these
qualifications.


City Clerk Gets 4
Months for
Embezzlement

Betty Nagy, a clerk in the city
Water Department in Chester,
West Virginia, was sentenced
in April 1992 for embezzling
$19,000 in cash bill payments
received from Water
Department customers.  She
was sentenced to 4  months of
home  detention, 3 years of
supervised release, and
ordered to pay restitution of
$14,000. Nagy transferred
money from a city account
containing EPA grant funds to
another account to conceal her
embezzling activities.
    The case was jointly
investigated by the Federal
Bureau of Investigation, the
West Virginia State Police, and
the EPA OIG.
Water Treatment
Plant Operator and
Assistant Charged
With Phony Reports
to State

As a result of a joint
investigation with the Criminal
Investigations Division of
EPA's Office of Enforcement,
Jimmie D.  Rogers, manager of
a Seqouyah County Utility
Service Authority (SCUSA)
water treatment plant, has
been indicted for making false
water quality reports to the
State of Oklahoma, which had
been delegated with
enforcement responsibility for
Safe Drinking Water Act
regulations.  These regulations
require daily monitoring of
water turbidity and submission
to the State of monthly reports
of the daily values  within 10
days of the end of  the month.
    Gerald Wright, an
assistant to Rogers, pled guilty
to 3 counts of making false
statements, was sentenced to
12 months probation  on each
count, and fined $250.
APRIL 1,1992 THROUGH SEPTEMBER 30,1992
                                                                                                                  33

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Description Of
Selected
Prosecutive And
Administrative
Actions
Concerning EPA
Employees
The OIG investigates and
reports information,
allegations, and indications of
possible wrongdoing or
misconduct by EPA employees
and persons or firms acting in
an official capacity directly with
EPA or through its grantees.
EPA Official Claimed
Degrees He Did Not
Earn

A former EPA official who
served as on-scene
coordinator at hazardous
waste cleanup sites has been
sentenced for making false
declarations during his
testimony as an expert witness
at a Federal criminal trial in
1988. The defendant was
sentenced to 3 months of
home detention (with electronic
surveillance at his own
expense), 3 years probation, a
fine of $2,000, and loss of his
EPA job.  He had falsely
claimed to hold a Bachelor of
Science degree and a Master
of Science degree, and to
have written a Master's thesis.
The investigation by the OIG
determined that the defendant
made false statements
concerning his academic
credentials in other sworn
statements,  including various
applications for Federal
employment (SF-171), a
Questionnaire for Sensitive
Positions  (SF-86), and
depositions and affidavits in
civil lawsuits.
                              EPA Employee
                              Charged With
                              Stealing Computer

                              An EPA Region 3 employee in
                              Philadelphia, Pennsylvania,
                              has been convicted of stealing
                              an EPA computer and other
                              supplies from the Agency's
                              office in downtown
                              Philadelphia. She  was fired
                              from her job. Her boyfriend
                              reported the theft to other EPA
                              employees and later provided
                              a  photograph of the computer
                              and a calculator to a security
                              guard at the EPA building.
                              The employee removed the
                              computer from the  building in a
                              large shopping  bag.
                                 The indictment resulted
                              from a joint investigation by
                              the EPA OIG and the United
                              States Secret Service.
Jury Duty  Length
Misstated

An EPA Headquarters
employee was indicted for
allegedly falsifying a jury duty
form so she could take up to 6
months off with pay when her
jury duty lasted only one week.
The employee collected nearly
$6,000 in pay during her
months off.
Civil And
Administrative
Actions To
Recover EPA
Funds
                             Investigations and audits
                             conducted by the Office of
                             Inspector General provide the
                             basis for civil and
                             administrative actions to
                             recover funds fraudulently
                             obtained from EPA.  Through
                             the Inspector General Division
                             (IGD) of the Office of General
                             Counsel, the OIG uses a
                             variety of tools  to obtain
                             restitution. These include
                             cooperative efforts with  the
                             Department of Justice in filing
                             civil suits under the False
                             Claims Act, the Program Fraud
                             Civil Remedies Act, and other
                             authorities; working with
                             grantees using  their own civil
                             litigation authorities; invoking
                             the restitution provisions of the
                             Victim and Witness Protection
                             Act during criminal sentencing;
                             using the Agency's authority to
                             administratively offset future
                             payments and to collect debts;
                             and negotiating voluntary
                             settlements providing for
                             restitution in  the context of
                             suspension and debarment
                             actions. Civil and
                             administrative actions to
                             recover funds usually extend
                             over several semiannual
                             reporting periods.
34
                                                                                      OFFICE OF THE INSPECTOR GENERAL

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 Analytical Services
 Corp.

 Analytical Services Corp.
 entered into a civil settlement
 agreement in which it agreed
 to pay the Government
 $490,000.  Analytical also
 pleaded guilty to filing a false
 claim and was fined $500,000.
 Finally, Analytical signed a
 compliance agreement with
 EPA, under which Analytical
 agreed to EPA audits of
 Analytical^ internal laboratory
 operation to ensure that
 Analytical uses good
 laboratory practices  and
 maintains measures designed
 to ensure the honesty and
 integrity of its employees. This
 case arose from  an OIG
 investigation which revealed
 that ETC Toxicon, a defunct
 laboratory formerly owned by
 Analytical and a participant in
 EPA's contract laboratory
 program, had falsified sample
 test data under two EPA
 contracts and had submitted
 false claims totalling
 approximately $216,000 for the
 falsified data.
 l-Chem Research,
 Inc.

 l-Chem Research, Inc., and its
 principal owners, Marvin and
 Anita Rudd, entered into a civil
 settlement agreement in which
 they agreed to pay the
 Government $435,000. The
 case arose from an OIG
 investigation of l-Chem's
 contracts with EPA to supply
 sample containers to
 laboratories.  The contracts
 had quality assurance testing
 requirements.  The OIG
 investigation revealed that I-
 Chem had defrauded EPA by
 intentionally failing to perform
 the required testing and by
 creating records to disguise
 that fact. In addition to the
 civil settlement, l-Chem and
 Ms. Rudd pleaded guilty to
 submitting false claims.
 Moreover, l-Chem and Ms.
 Rudd signed a compliance
 agreement with EPA, under
 which l-Chem and Ms. Rudd
 agreed to an 18 month
 voluntary exclusion from
 participation in Government
 contracts or grants.


 Geo-Con, Inc.

 Geo-Con, Inc., entered into a
 civil settlement, in which it
 agreed to pay the Government
 $312,000  and to withdraw its
 $353,723  contract claim. Geo-
 Con is a Superfund contractor
 that received a $4 million
 contract to treat contaminated
 water and stabilize hazardous
 sludge at the Bruin Lagoon
 Superfund site in Butler
 County, Pennsylvania. The
 contract was administered by
 the Army Corps of Engineers.
 An OIG investigation
 uncovered two major frauds
 committed by Geo-Con
 employees during the
 performance of that contract.
 First, Terry Lee Tebben, Geo-
 Con's health and safety officer,
 plugged the  air monitors that
 measured the amount of
 hazardous gases being
 released at the site, but falsely
 stated that the measurements
 reported in the air monitoring
 reports were accurate.
 Second, Charles Daniel
 Workman, Geo-Con's site
 superintendent, forced air
 through the water treatment
 system meter, causing a
 reading in  excess of the
 amount of contaminated water
 actually treated and thereby
 causing false claims to be
 submitted to EPA. Both Geo-
 Con employees pleaded guilty
 to these acts. Geo-Con also
 agreed to establish and
 implement a comprehensive
 compliance program to ensure
 integrity, environmental
 compliance,  and quality control
on all federally-funded
 projects. Based on the guilty
 pleas, both Mr. Tebben and
 Mr. Workman were
suspended, and subsequently
debarred, from receiving any
Government  contracts and
 assistance for three years (see
page 38).
 American
 Management
 Systems, Inc.

 American Management
 Systems, Inc. (AMS), a
 company that EPA had
 previously proposed for
 debarment, entered into a
 compliance agreement in
 which it agreed to pay EPA
 $140,962 to settle allegations
 that it had participated in an
 improper hiring scheme and
 had overcharged EPA under
 two contracts.  In addition,
 AMS paid $25,000 to cover a
 portion of the costs of the OIG
 investigation and the estimated
 future costs of EPA
 compliance audits.  Further,
 AMS agreed to take numerous
 steps to enhance its oversight
 of subcontractors, to increase
 internal accountability, and  to
 train and educate its
 employees about proper
 subcontracting practices. This
 case arose from an OIG
 investigation of the improper
 use of contractors by EPA's
 Office of  Policy, Planning and
 Evaluation.
 Cavour Yeh

 Cavour Yeh, a UCLA
 professor, entered into a civil
 settlement in which he agreed
 to pay the Government
 $1,600,000 for causing false
 claims to be submitted to EPA,
 the Department of Defense,
 and the National Science
 Foundation on various
 research  projects funded by
 those agencies. EPA's share
 of the civil settlement is
 $88,485.  In addition to the
 civil settlement, Mr. Yeh
 pleaded guilty to filing false
 claims and was sentenced to 2
 years in jail.
EPA Shares in Civil
Settlement Obtained
by New York City

Michael Gelb and Thomas
Gelb, electrical contractors,
were indicted in 1987 and
pleaded guilty in 1990 to fraud
committed on the EPA-funded
New York City Owls Head
Water Pollution Control Plant.
In 1990 they repaid the City
more than $96,000 plus
interest for the fraud
committed on this project.  In
November 1991, Region 2
referred the matter to the New
York State Department of
Environmental Conservation
(NYSDEC), which administers
the grant under an EPA
delegation of authority.  In May
1992, NYSDEC notified the
City that it was offsetting
$85,184 (the EPA share) from
future construction grant
payments to the City.
Program Fraud Civil
Remedies Act
Settlement

The Inspector General Division
of the Office of General
Counsel negotiated an
agreement with an EPA
employee who admitted to
submitting two fraudulent taxi
vouchers for reimbursement.
Under the  agreement the
employee paid $700, which
was more than ten times the
amount of the fraud, as a civil
penalty under the Program
Fraud Civil Remedies Act.
APRIL 1,1992 THROUGH SEPTEMBER 30,1992
                                                                                                                    35

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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. This  semiannual
reporting period, we reviewed
17 legislative and 67
regulatory items.  The most
significant items reviewed are
summarized below.
Proposed  Revisions
to OMB Circular
A-130

We reviewed and
recommended changes to the
proposed revisions to OMB
Circular A-130. In our opinion,
the Circular does not
adequately or clearly address
quality assurance of
application systems, which is
one of the most significant and
long-standing  Information
Resources Management (IRM)
problems in the Federal
government.  Quality
assurance over data integrity
of sensitive application
systems has been cited as a
significant problem in over 100
GAO and DIG audit reports
throughout most Federal
agencies over the last 15
years.  We recommended that
the Circular provide guidance
to Federal agencies regarding
the establishment of quality
assurance programs relative  to
application systems. We also
suggested that the Circular be
updated to make it consistent
with the Computer Security Act
by addressing development
and updating of security plans,
specific security training
requirements, and security
awareness programs.  Finally,
we recommended that the
Circular be revised to ensure
consistency with the
Department of Commerce's
Federal Information Processing
Publication regarding the
development of risk analyses
and contingency plans specific
to application  systems, since
the Circular only requires risk
analyses and  contingency
plans for installations.


Contractor Licensing
Reform Act of 1992
(S.2928)

The intent of this bill is to
establish the Office of
Contractor Licensing within the
Department of the Treasury.
The Office would establish and
maintain a licensing system for
the registration, issuance, and
review of a license for any
person seeking to enter into a
contract to provide services to
the U.S. Government. The bill
would also set forth that
certain functions are inherently
governmental in nature and
should not be performed by
contractors. We believe that
this bill should be revised.
The term "inherently
governmental functions," as
defined in S.2928, does not
explicitly cover  certain
functions described in OMB
Circular A-76 and the
proposed Office of Federal
Procurement Policy (OFPP)
Inherently Governmental
Functions Policy Letter.
S.2928 appears to be broader
than the current OMB Circular
A-76 definition and proposed
guidance in other areas, but it
does not make a clear
distinction between what
activities  allowed under the
proposed guidance would or
would not be allowed to be
contracted.  We recommended
that S.2928 be revised to
clarify whether  certain activities
are considered to be
governmental.
    Also, the bill does not
require license  applicants to
disclose suspensions or
debarments. The Federal
Acquisition Regulation (FAR)
requires that contracting
officers include a certification
clause regarding suspensions
or debarments  in solicitations
for contracts which exceed
$5,000. We suggested that
this information be collected as
part of the license application
and considered when issuing a
license. S.2928 indicates that
each applicant  must disclose
any conviction  of a
misdemeanor or felony but
does not specifically state that
contractors that have criminal
convictions will be disqualified
from obtaining  a license.  In
our opinion, an applicant
disclosing convictions of
criminal misconduct should be
disqualified from obtaining a
license.  S. 2928 requires that
the Office of Contractor
Licensing be notified within 60
days if the licensee is indicted,
registers as a foreign agent, or
changes any status the office
may designate as reportable.
We recommended that S.2928
be revised to shorten the
notification requirement to 15
36
                                                           OFFICE OF THE INSPECTOR GENERAL

-------
days to avoid allowing a
licensee to compete and
perhaps obtain government
contracts during the notification
period.
    Lastly, the bill would not
allow expenditure for the
maintenance or improvement
of morale. The FAR permits
the cost of employee morale
activities within limitations.
While the extent of the
limitations are currently under
review, certain expenses such
as house publications, health
clinics, and employee
counseling services that the
government provided free to
Federal employees are not
being considered  for
elimination. We recommended
that S.2928 be revised to
permit these expenses.
Proposed
Rulemaking to
Implement the Cash
Management
Improvement Act of
1990

We generally agreed with the
proposed rulemaking to
implement the Cash
Management Improvement Act
of 1990.  However, we
suggested that EPA's
Superfund and Leaking
Underground Storage Tank
Fund be included for treatment
in a similar manner as the
Federal Highway Trust Fund
since they operate in a similar
fashion.  We also
recommended that the section
on cost recovery be clarified
by indicating whether funds for
Federal reimbursement for the
State's cost of administering
the  interest calculation system
will  come from the Department
of the Treasury or Federal
agencies. In addition, we
suggested that the role of the
Inspectors General be clarified.
The section on oversight
indicates that States will be
audited through Single Audit
procedures, and that the
Secretary may request Federal
agencies to conduct audits of
States.  Since this will affect
the IGs' use of audit
resources, we recommended
that some mention of the
anticipated frequency of  such
requests should  be made.


Draft EPA
Comptroller
Announcement  on
Integrated Financial
Management System
(IFMS) Security
Policy and
Procedures

While we believe that the
policy announcement is
generally adequate, we had
several concerns. We
recommended that the
purpose section  of the policy
more clearly define how  it fits
into the  EPA Information
Security Program. We
suggested that the roles and
responsibilities section discuss
the relationship of IFMS
component systems and the
roles and responsibilities of the
managers of those systems to
overall IFMS security.  In
addition, we believe that an
IFMS coordinator should be
designated  for each
Headquarters program office.
    We further recommended
that the  policy section address
the responsible parties'
coordination roles and
responsibilities with the Office
of Information Resources
Management and assign
responsibility for maintaining
the required security
documentation.  Since this
document is designed to
address overall IFMS security
policies, we suggested that it
specify the position sensitivity
requirements for all
Government and contractor
employees who have access
to IFMS sensitive data or
provide support services for
IFMS component systems.
We also made several
suggestions to improve the
IFMS Security Request Form
and the  IFMS User
ID/Password Request  Form.
Environmental
Crimes Act of 1992

We reviewed and
recommended revisions to the
proposed Environmental
Crimes Act of 1992. We
strongly disagreed with
provisions of this bill which
would provide immunity to the
defendant, or any of its
subsidiaries, directors, officers,
agents, or employees from
criminal penalties for a
violation of environmental law
discovered during an
environmental compliance
audit. Such immunity could
encourage defendants to  not
contest their conviction if they
were concerned that the audit
would likely  disclose more
serious violations of
environmental law for which
they had not been prosecuted.
     We believe that the
subsection on audit reports
should be revised to include a
provision requiring the
independent expert conducting
the compliance  audit to notify
the EPA Office  of Inspector
General when any evidence of
possible criminal violations is
disclosed during the
performance of the compliance
audit. We also  suggested that
the subsection on review  of
audit reports be revised to
require the independent expert
to  provide a copy of any
compliance  audit reports
prepared in  accordance with
this subsection  to the
Environmental Protection
Agency's Office of
Enforcement and Office of
Inspector General. This would
allow the OIG to assess the
adequacy and feasibility of the
report's recommendations that
must be filed by recipients with
the court not later than 30
days after its receipt.
APRIL 1,1992 THROUGH SEPTEMBER 30,1992
                                                                                                                   37

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Suspension And
Debarment
Activities
EPA's policy is to do business
only with contractors and
grantees who are honest and
responsible.  EPA enforces
this policy by suspending or
debarring contractors or
grantees from further EPA
contracts or assistance if there
has been a conviction of, or
civil judgment for:

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

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

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

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

    A  contractor may also be
debarred for violating the
terms of a Government
contract or subcontract, such
as willful failure to perform in
accordance with the terms of
one or more contracts, or a
history of failure to perform, or
of unsatisfactory performance
on one or more contracts. A
contractor may also be
debarred for any other cause
of so serious or compelling a
nature  that it affects the
present responsibility of the
contractor.  Thus, a contractor
need not have committed fraud
or been convicted of an
offense to warrant being
debarred.  Debarments are to
be for a period commensurate
with the seriousness of the
cause,  but are generally not to
exceed 3 years.
     The effectiveness of the
suspension and debarment
(S&D) program has been
enhanced by regulations that
provide all Federal agencies a
uniform system for debarring
contractors from receiving
work funded by Federal grants,
loans, or cooperative
agreements. The system,
required by Executive Order
12549, provides that a
nonprocurement debarment or
suspension by one agency is
effective in all agencies and
requires the General Services
Administration (GSA) to
publish monthly a "List of
Parties Excluded from Federal
Procurement or
Nonprocurement Programs."
Formerly, a nonprocurement
debarment was effective only
in the programs administered
by the debarring agency, and
each agency maintained its
own list.  The EPA Grants
Administration Division
operates the S&D program at
EPA. The OIG assists the
EPA S&D program by
providing information from
audits,  investigations, and
engineering studies; and
obtaining documents and
evidence used in determining
whether there is a cause for
suspension or debarment.
     The OIG's Suspension
and Debarment Unit works
with the Grants Administration
Division to further educate and
inform State and local
governments and
environmental interest groups
about the effective use of
suspensions and debarments.
Summary of
Suspension and
Debarment  Activities

The following is  a summary of
S&D results achieved during
this reporting period:
              April 1, 1992 to
         September 30, 1992

Cases completed:

• Suspensions             15
• Debarmenls             35
• Settlements             _5
Total                     55

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

• On September 17, 1992,
while suspended, EPA sent a
notice of proposed debarment
to  Cavour Yeh, a former
professor at the  University of
California at Los Angeles
(UCLA), for participating in a
scheme to defraud EPA and
other Government agencies
(see page 35).  Also included
in the notice of proposed
debarment were EMtec
Engineering Inc., his affiliate,
and Richard Yeh, Victoria
Hsia, and Wei Li.

• Chemwest Analytical
Laboratories, Inc. has been
suspended by EPA.
Chemwest is a wholly owned
subsidiary of Compuchem
Corporation,  located in
Research Triangle Park, North
Carolina.  Chemwest has
performed analyses under
EPA's contract laboratory
program (CLP) since
November 12, 1987. Audits
covering a period from June 6,
1988 to May 1,1990 revealed
that numerous improper
practices occurred and that
CLP protocols contained in
Chemwest's contract with EPA
were not adhered to.

• Terry Lee Tebben and
Charles Daniel Workman were
debarred by EPA for 3 years
on the basis  of questionable
business integrity and making
false statements (see
page 35).
• Charles A. Donohoo Jr., a
demolition contractor who
operated a wrecking and
salvage business in Jefferson
County, Kentucky, was
debarred for 3 years by EPA
following his December 1989
conviction for improper
removal of asbestos, in
violation of the Clean Air Act.
The Court also convicted
Donohoo of failure to notify
EPA of a release of asbestos,
in violation of the
Comprehensive Environmental
Response, Compensation, and
Liability Act. The Court
imposed a three year
sentence, consisting of 6
months incarceration, followed
by probation.

• EPA suspended Alan
Stevens, President of Stevens
Analytical Laboratories Inc.,
and Stevens Environmental
Technology Inc.  Mr  Stevens
provided false and fictitious
analysis results of drinking
water and waste water
samples (see page 33).
38
                                                            OFFICE OF THE INSPECTOR GENEFIAL

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 Congressional
 Testimony By The
 Inspector  General
 During this semiannual
 reporting period, the Inspector
 General (IG) testified five times
 before congressional
 committees. This testimony
 covered EPA's contract
 management and oversight,
 various aspects of the
 Superfund program, pesticides,
 and how the OIG was working
 with the Defense Contract
 Audit Agency (DCAA) to
 strengthen the OIG's process
 for auditing EPA contracts.

 • On April 9, 1992, and July 8,
 1992, respectively, the IG
 testified before the House
 Subcommittee on
 Environment, Energy, and
 Natural Resources, Committee
 on Government Operations,
 and the House Subcommittee
 on Oversight and
 Investigations, Committee on
 Energy and  Commerce, on the
 widespread and recurring
 problems with  EPA's contract
 management and oversight.
 The problems.identified by OIG
 audits over the past several
 years, included:  (1) instances
 of overcharging by contractors,
 such as exorbitant markups  on
 materials and services, (2)
 award fees  being paid to
 contractors  for less than
 satisfactory performance, (3)
 EPA managers influencing
 prime contractors' selection of
 subcontractors and directing
 the performance of work
 outside the  contract scope of
 work, (4) lack of assurance
that contract laboratories
 participating in EPA's
 pesticides program adhered  to
 Good Laboratory Practices, (5)
the creation of a personal
 services relationship between
 contractors  and EPA, and (6)
 contractor employees
 performing inherently
governmental functions. The
July 8 testimony also
discussed a series of
questionable contracting
events that occurred at EPA's
 Duluth, Minnesota, laboratory
 (see page 12).

 •On May 6, 1992, the IG
 testified before the House
 Subcommittee on Legislation
 and National Security,
 Committee on Government
 Operations, about how the
 OIG was working with the
 Defense Contract Audit
 Agency (DCAA) to strengthen
 the process for auditing
 contracts at EPA. As of March
 1992,  EPA had 339
 outstanding requests with
 DCAA for incurred cost audits,
 of which 181 were outstanding
 for 2 or more years--
 considered "backlog." Further,
 at the  beginning of 1992, EPA
 had  150 requests with DCAA
 for contract closeout audits, of
 which  at least  58 were
 considered backlogged.

     The IG stated that in
 1990 the OIG  began  assuming
 audit responsibility from DCAA
 for some of EPA's largest
 contractors. At the time of the
 hearing, the OIG had assumed
 audit responsibility for 16
 major EPA contractors and
 planned to assume
 responsibility for others.  The
 IG also stated  that DCAA had
 set a goal to eliminate its audit
 backlog at EPA over the next
 5 years. Further, as a part of
 this testimony, the IG
 expressed support for a
 system whereby each Federal
 audit agency would be funded
 so that it could conduct all
 audits for which it is
 responsible, those of  its own
 agency as well as audits on
 behalf of other Federal
 agencies.  He  pointed out that
 this approach would eliminate
 interagency transfers  of funds
 and duplicate billing and
 payment records that are
 inherent in the present set-up;
 improve accountability; and
 provide more of an incentive to
 carefully plan and estimate the
 cost  of audits.

 •On June 11,  1992, the IG
 testified before the House
 Subcommittee  on Oversight,
 Committee on Ways and
 Means, on OIG audits of the
 Superfund program.  His
testimony addressed the issue
 of delays in cleaning up
 Superfund  sites and some of
 the reasons that caused these
 delays, contract management,
 enforcement, and the
 Superfund  management
 information system.

     The IG testified that
 responsible parties conduct 60
 percent of  new work
 conducted  at Superfund sites.
 In 3 of 4 reviewed EPA
 regions, the OIG found
 Superfund  cleanups were
 unnecessarily delayed after
 EPA reached agreements with
 responsible parties due to (1)
 EPA lacking definitive
 guidelines on how long its
 reviews of  responsible parties
 plans for cleanups should take,
 (2) EPA managers granting
 informal extensions to
 responsible parties for
 completion of cleanups, (3)
 multiple requests by EPA for
 revisions to responsible
 parties' plans and reports, (4)
 high EPA project manager
 turnover, and (5) the lack of a
 common milestone tracking
 system.  In addition, the IG
 testified that EPA has also
 grappled with delays in its own
 cleanups performed by
 contractors. The Alternative
 Remedial Contract Strategy
 (ARCS) concept, under which
 each Superfund site becomes
 the responsibility of a single
 contractor,  has delayed rather
 than accelerated cleanups.
     The 1986 Superfund
 amendments required EPA to
 start 175 substantial and
 continuous, physical on-site
 remedial actions of sites on
 the National Priorities List (a
 list of the 1,200 most
 hazardous Superfund sites in
 the country) within 3 years.
 Although EPA claimed to have
 started 178 remedial actions
 within the period, the OIG
 found that more than half of its
judgmental  sample of 42
 actions did  not meet the
 criteria for starts.
     The IG also summarized
 how  EPA's  past laissez-faire
 attitude toward contract
 management had resulted in
 many of the same problems
existing with Superfund
contractors  as the OIG had
found generally at EPA (see
 above).  Further, the IG
 discussed deficiencies which
 OIG audits had found in EPA's
 efforts to locate and negotiate
 cleanups with potentially
 responsible parties,
 assessment of penalties
 against responsible parties
 when they fail to meet the
 terms of settlement
 agreements, and recording
 and tracking monies owed by
 responsible parties for
 cleanups. Finally,  the IG
 testified that although EPA has
 been working to improve its
 Comprehensive  Environmental
 Response, Compensation  and
 Liability Information System,
 commonly called CERCLIS,
 significant problems remained,
 and EPA cannot effectively
 manage  the Superfund
 program until the system is
 more reliable.

 • Again testifying on July 23,
 1992, before the House
 Subcommittee on
 Environment, Energy,  and
 Natural Resources, Committee
 on Government Operations,
 the IG discussed the OIG's
 planned  approach for issuing a
 theme report on  pesticides.
 He stated that within the last 2
 years the OIG had  issued
 audit reports on weaknesses in
 EPA's  Emergency Suspended
 and Canceled Pesticide
 Program, the Good Laboratory
 Practices Program, and most
 recently on EPA's strategy for
 managing inert ingredients in
 pesticides. The  IG added that
 reviews were underway of the
 labeling of pesticides and the
 special review process for
 pesticides and that a review
 was planned of the pesticide
 registration process. The IG
 pointed out that the General
 Accounting Office was
 reviewing the remaining major
 program  area, reregistration.
 Once the ongoing and planned
 reviews are completed, the
 OIG will issue its pesticides
theme report, addressing the
question:  "Have EPA's
pesticide programs  efficiently
 and effectively protected the
public health and environment
from pesticide hazards?"
APRIL 1,1992 THROUGH SEPTEMBER 30,1992
                                                                                                                      39

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OIG  Management
Initiatives
This section discusses OIG
initiatives to promote
management and financial
improvements and integrity in
EPA's operations.  During this
semiannual period, we are
highlighting OIG efforts to
conduct financial audits of EPA
contracts.
Expansion of Audit Program
of Contractors

During this semiannual period,
the OIG continued to
implement its long-term
program for conducting
financial audits of EPA
contracts.  While continuing to
work with DCAA to schedule
high priority audits, the OIG
conducted significant financial
audits at the 16 contractors
over which it has audit
cognizance and participated  in
the Office of Management and
Budget's (OMB) SWAT Team
on civilian agency contracting.
As a result of focusing
attention on becoming more
current with audits of
contractors, both the Office of
Audit and DCAA are now
auditing contractors' 1989
submissions compared to
auditing 1986 and 1987
submissions last year.
Significant reports were issued
on financial audits of contracts
during this period, including
the following:

• CH2M Hill claimed significant
costs, which the OIG
considered unallowable, in its
indirect cost pools for 1987,
1988, and 1989. These costs
included employee  bonus
costs which represented
unallowable distribution of
profits to company owners; bid
and proposal costs incurred
without the required negotiated
advance agreements;
excessive rent and  lease
costs; travel costs in excess of
Federal limits; inadequately
supported travel, lobbying and
public relations costs; aircraft
usage costs exceeding
standard commercial fares;
and expenses exceeding
Federal relocation and
residence selling limits.

• A contractor already holding
EPA contracts and  submitting
a $20 million bid on another
contract was found to have
weak internal controls which
permitted contractor
employees to take
compensatory time before it
was earned; did not exclude all
expressly unallowable costs
from its indirect cost rate
proposals; and resulted in
billing for subcontract costs
before they were paid.
Further, the contractor was not
complying with various cost
accounting standards, had no
written accounting procedures,
and did  not have an internal
audit function.  We
recommended that the
Financial Administrative
Contracting Officer require the
contractor to correct the
internal control weaknesses.

    In addition to conducting
audits such as those described
above, OIG and Procurement
and Contracts Management
Division staff participated in
the OMB SWAT Team on
civilian agency contracting.
EPA was one of twelve
participating agencies in the
project which was to identify
agency-specific and
Government-wide problems
and corrective actions
concerning the allowability of
contractor costs,  particularly
indirect costs.
    The EPA Team's report
contained 31
recommendations for
improvements to  EPA
operations and 45
recommendations for
Government-wide
improvements. The
Government-wide
recommended improvements
include changes to the Federal
cost principles governing
employee morale and
entertainment costs, employee
compensation costs, and
contingent fees.  The
recommended changes are
designed to clarify the
allowability of costs and the
records the contractor must
maintain to support claimed
costs.
    The Government-wide
SWAT Team will issue a
report.  EPA will then develop
an action plan to correct those
matters within its control. The
corrective actions identified will
significantly improve Federal
cost principles and EPA cost
review procedures.
Personnel
Security  Program
The personnel security
program is one of the
Agency's first-line defenses
against fraud.  The program
uses background
investigations and National
Agency Checks and Inquiries
to review the integrity of EPA
employees and contractors.
During this semiannual
reporting period, the Personnel
Security Staff reviewed  489
investigations.  The following
conditions were identified  and
administrative actions taken:

• 1 employee resigned pending
disciplinary action for failure to
list previous drug usage,
failure to make payments  on
several delinquent accounts,
and failure to meet basic
security criteria for the
clearance needed in
connection with official duties.

• 3 employees were issued
written reprimands for failing to
list on the SF-171, Application
for Federal Employment,
previous terminations, a
conviction for writing bad
checks, and convictions for
driving while intoxicated.

• 3 employees received oral
admonishments for failing to
list misdemeanor convictions
on the SF-171  and financial
delinquencies on the SF-85P,
Questionnaire for  Public Trust
Positions.

• 2 employees were counseled
regarding the need to be
financially responsible.

• The access of 4 contractor
employees to Confidential
Business Information was
terminated for failing to list, on
the SF-86, Questionnaire  for
Sensitive Positions, previous
drug usage, continuous usage
of controlled substances, and
conviction for assault.
                                                                                           OFFICE OF THE INSPECTOR GENERAL

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 President's
 Council  On
 Integrity And
 Efficiency
 The Office of Inspector
 General participates in the
 activities of the President's
 Council on  Integrity and
 Efficiency (PCIE), which was
 established by Executive Order
 12301 in March 1981 to attack
 fraud and waste, and to
 improve management in the
 Federal Government. The
 PCIE was re-established by
 Executive Order 12805 on May
 11, 1992. The PCIE
 coordinates interagency
 activities involving common
 issues, and develops
 approaches and techniques to
 strengthen the effectiveness of
 the entire Inspector General
 community. The PCIE is
 headed by the Deputy Director
 for Management, Office of
 Management and Budget
 (OMB), and includes all civilian
 Presidentially appointed
 Inspectors General  and other
 key Federal officials.
     During this reporting
 period, Inspector General
 Martin was a member of the
 PCIE Chief  Financial Officers
 (CFO) Act Task Force. The
 Task  Force comprised seven
 teams which focused  on major
 issues and obstacles  to
 successful implementation of
 the CFO Act.
     Staff members of the OIG
 participated in three of the
 projects undertaken by the
 Task  Force. The three
 projects and their objectives
were: (1) auditor assistance to
management - to determine
the amount  and type of
assistance to provide
management in the
preparation  of financial
statements and other  related
 reports while still maintaining
 independence; (2) use of OIG
staff versus independent public
accountants to perform the
financial statement audits
required by  the CFO Act; (3)
performance measures - to
develop standards for selecting
performance measures to be
included in annual reports.
     During August we
provided comments on the
consolidated draft task force
report. The final report to be
issued in October 1992 will
include a policies and
procedures handbook for
performing Federal financial
statement audits and guidance
on assisting management in
carrying out its responsibilities
under the CFO Act.
Committee On
Integrity And
Management
Improvement
The Committee on integrity
and Management Improvement
(CIMI) was established in 1984
by EPA Order 1130.1.  The
purpose of CIMI is to
coordinate the Agency's effort
to minimize the opportunities
for fraud, waste, and
mismanagement in EPA
programs and to advise the
Administrator on policies to
improve the efficiency and
effectiveness of EPA programs
and activities.  The Committee
is composed of senior EPA
program and regional officials
and is chaired by the Inspector
General.
                              Awareness Bulletins

                              Hotel/Motel Tax Exemptions

                              Every EPA employee who
                              travels on  official business is
                              responsible for avoiding
                              unnecessary expense to the
                              Government.  Use of
                              hotel/motel tax exemption
                              certificates is one method of
                              saving Agency funds. Since
                              many destinations  to which
                              EPA employees regularly
                              travel on official business offer
                              exemptions from State and
                              local hotel  and motel taxes,
                              the savings can play a major
                              role in helping the  Agency
                              stretch its travel budget. To
                              assist the Agency  in  reducing
                              travel costs, CIMI developed
                              an awareness bulletin which
                              identifies the States and
                              localities offering hotel and
                              motel tax exemptions to  the
                              Federal traveler on official
                              business, describes how to
                              obtain the exemptions, and
                              provides general guidance on
                              the proper  use of tax
                              exemption  certificates. The
                              bulletin also cautions
                              employees that the use of
                              forms other than the official
State and local government tax
exemption certificates will not
legally exempt them from
taxes.

Political Activity

Certain amendments to the
Hatch Act were proposed
which would substantially
liberalize permissible political
behavior by Federal
employees, to include running
for elective office. Since these
proposed changes were  not
signed into law, and because
this is an election year, CIMI
believed that employees
should be cognizant of the
present political activity
provisions of the Hatch Act.
As a result, CIMI developed an
awareness bulletin which
focused on acceptable and
prohibited political practices by
Federal employees as well as
criminal provisions concerning
political activity which are
prescribed in United States
Code.

Leave Policies

Most  Federal supervisors and
employees are familiar with
basic  information about leave.
However, there are areas of
leave  administration which can
create confusion  because they
may not be common
knowledge. EPA has
developed specific policies and
procedures for taking and
recording leave, and CIMI
believed that it would be
beneficial to supervisors ar,d
employees if a document could
be developed concerning
unfamiliar leave categories.
Consequently,  CIMI developed
an awareness bulletin in a
question and answer format
designed to answer questions
pertaining  to lesser known
leave  categories.
APRIL 1,1992 THROUGH SEPTEMBER 30,1992
                                                                                      41

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 Public Service Recognition
 Week

 To communicate support and
 appreciation to EPA
 employees at all levels, CIMI
 sought an opportunity for the
 Agency to show its
 commitment to human
 resources.  To demonstrate
 Agency appreciation to
 employees, CIMI developed
 and coordinated a series of
 special events during Public
 Service Recognition Week.
 The program, hosted by EPA's
 Administrator, William  Reilly,
 was highlighted by a speech
 from Esther Peterson, former
 top-level advisor to three
 Presidents and consumer
 affairs advisor to Giant Food.
 Anna Hopkins Virbick, Deputy
 Inspector General, emceed the
 event, which also included a
 special tribute to Rachel
 Carson, in honor of the 30
 year anniversary of the
 publication of "Silent Spring," a
 book to which  many people
 attribute the start of the
 environmental  movement. As
 part of this tribute, the
 Administrator presented a
 plaque to Shirley Briggs,
 Executive Director Emeritus of
 the Rachel Carson Council.
 Hotline Activities
 The DIG Hotline Center
 opened 50 new cases and
 completed and closed 46
 cases during the reporting
 period.  Of the cases closed, 8
 resulted in environmental,
 prosecutive, or administrative
 corrective action, while 38 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 2,938 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 to the DIG Hotline
 Center.

• A complainant alleged that
 an EPA employee was
 conducting personal business
 on government time and was
 using a government computer
 to facilitate the operation of a
furniture business which the
employee owned. A review of
the complaint disclosed that
the employee had used
government time, equipment
(computer, printer, paper,
toner), and employees to
operate a personal business.
As a result, the employee was
given a written reprimand and
strongly cautioned that any
future misconduct could result
in severe disciplinary
measures.

• A complainant alleged that
an EPA employee was
improperly obtaining office
supplies by asking company
employees to substitute items
such as pen sets and
calculators in place of the
items actually specified on the
procurement request. A
review of the complaint
disclosed that the employee
was obtaining office  supplies
other than what was ordered,
and that EPA was billed for the
items on the procurement
request rather than the
substitutions.  As a result, the
employee  received a written
reprimand and is no longer
authorized to purchase any
material.
 Professional And
 Organizational
 Development
For the semiannual period
ending September 30, 1992,
we approved 1,312 training
enrollments for a total of 987
days of training and
participation in professional
development seminars and
conferences. Contract and in-
house courses conducted by
the DIG are summarized
below.

OIG-Developed Courses

• Detection and Prevention of
Fraud.  Although this course
was  developed to prepare
independent public
accountants doing work for the
EPA OIG to detect and refer
possible instances of fraud to
the OIG for criminal
investigation, it also increases
the awareness of  EPA
managers and supervisors.
During this reporting period,
the course was substantially
revised and was presented
twice, to the majority of new
OIG  auditors.
      OIG Employee Honored

  Lou Ella Harris, Second from left,
      of the OIG's Southern Audit
   Division in Atlanta, received the
   CY 1991 Gary Chin Award from
 Inspector General John C. Martin,
       left, in a May ceremony in
 Washington. Harris was honored
    for her work on audits of EPA
contractors.  The Gary Chin Award
      is given annually to the OIG
   employee who best exemplifies
  the perseverance and dedication
      of the late Mr. Chin, an OIG
    employee who died in 1990 of
    cancer at age 33.  On hand to
witness the ceremony,  were, left to
  right, Wee Chin and Elaine Chin,
   brother and sister of Gary Chin,
  and Dr. Allen Chin, Gary's uncle.
        (photo by Tom Maloney)
42
                                                                                          OFFICE OF THE INSPECTOR GENERAL

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• Superfund and the Role of
the OIG. This course was
developed to provide OIG
staffers with an understanding
of the Superfund program and
the role of the OIG in the
program. The development of
this course, coordinated by the
OIG employee development
specialist, was a combined
effort of all three primary
components of the OIG. The
course consists of six units:
(1) history of  Superfund, (2)
major concepts of the
Superfund program, (3)
Superfund program
organizations and resources,
(4) auditing cooperative
agreements, (5) auditing
Superfund contracts, and (6)
internal (management) audits.
• Effective Briefing Techniques.
This course was designed to
prepare auditors, investigators,
and managers to give effective
and persuasive presentations,
deal with confrontational
situations, and improve OIG
relations with affected
organizations or individuals.
The course includes sections
on effective oral
communication, visual
imagery, confrontational
management, and a video
workshop.  It stresses the
importance of teamwork
between OIG employees  and
Agency management. The
course was presented once
during this reporting period.

OIG  Contracted Courses

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

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

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

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

• Evaluating and Reporting on
Management Control Systems.
This course was designed for
management personnel
responsible for implementing
agency management control
evaluations.

• Introduction to EDP Auditing.
This course introduces
auditors to the terms and
concepts necessary to audit
electronic data processing
(EDP) systems.

• EDP Auditing, Controls and
Applications.  This course
introduces the necessary
controls for application
systems.  It pinpoints specific
controls to evaluate when
auditing currently installed
systems.

OIG Training Activities

• OIG Orientation Seminar.
The OIG orientation workshop
for new employees included
opening remarks by John C.
Martin, Inspector General, and
Anna Hopkins Virbick, Deputy
Inspector General.  Each
Assistant Inspector General
and  his managers and the
Associate General Counsel,
Inspector General Division,
OGC, presented an overview
of the office's organization and
functions.

     To help OIG supervisors
identify and select appropriate
development opportunities for
members of their staffs, we
have updated the OIG training
catalog. This catalog
describes national CPA
training sources, lists video
tapes available, and provides
schedules of over 97 courses
that are included in the OIG
career profiles for auditors,
investigators,  and support
staff.

Total Quality Management

The Office of  Inspector
General has adopted the
management  philosophy
known as Total Quality
Management  (TQM). A
Quality Council consisting of
the Deputy Inspector General,
the three Assistant  Inspectors
General, and  the Quality
Coordinator has been formed
to direct the TQM process
within the OIG. Also, the
Deputy Inspector General
participates as a member of
EPA's Deputy Leadership
Team. OIG employees are
members of Headquarters and
Regional Quality Action Teams
seeking to improve  processes
such as performance
management, employees
recognition and awards, and
implementation of the Chief
Financial Officers Act.
     During Fiscal 1992 the
OIG's cadre of 18 TQM
facilitators  provided at least
one day of TQM awareness
training to 326 OIG
employees. Also, Quality
Action Teams on the
recruitment and training
processes made significant
progress in their subject areas.
Three additional Quality Action
Teams were chartered -- on
improving the OIG's
consolidated index system, on
OIG data standards, and on
improving the processing of
Superfund interagency
agreements.
APRIL 1,1992 THROUGH SEPTEMBER 30,1992
                                                                                                                        43

-------
     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.
   Assignment
   Control Number
                        Title
                                                            Questioned Costs             _        .  .
                                                	   Recommended
                                 Final Report     Ineligible   Unsupported   Unnecessary/      Efficiencies
                                 Issued             Costs         Costs   Unreasonable    (Funds Be Put
                                                                                Costs   To Better Use)
1. INTERNAL  & MANAGEMENT ASSIGNMENTS

Administrator

E1NMF1-15-0032-2100641  LONGSTANDING  INFORMATION RESOURCES
                       MANAGEMENT PROBLEMS               9/28/92

Assistant Administrator for Administration and Resources Mansaamnt

E1JBF1-05-0175-2100443  CONTRACTING ACTIVITIES AT ORO'S
                       DULUTM LAB                        7/ 7/92

E1NMF1-15-0055-2100591  EPA NEEDS TO  STRENGTHEN GENERAL
                       CONTROL OVER  SYSTEM SOFTWARE       9/22/92

E6FKG2-02-0072-2400048  HAZARDOUS WASTE RESEARCH LAB       6/24/92

P1SFF1-11-0026-2100660  SUPERFUND FISCAL 1991 TRUST FUND
                       AUDIT                            9/30/92

E6AMG2-13-2043-2400068  PRINTING AND  PHOTOCOPYING         9/ 2/92
Assistant  Administrator for Pesticides and Toxic Substances
E1EPG2-11-6000-2400065

E1EPF1-05-0429-2100613

E1EPF2-11-0041-2100661
PCB FOLLOWUP REVIEW

LABELING OF PESTICIDES

COORDINATION PROBLEMS LIMIT
EFFECTIVE USE OF GOOD LAB
PRACTICES PROGRAM
Assistant  Administrator for Research and Development
E1SKFO-09-0137-2100624

E1J8B2-04-0283-2300093


E1JBB2-11-0038-2300100


E1JBB2-11-0039-2300101
CONTRACT  LAB QA/AC PROGRAM

CONTRACTING ACTIVITIES AT
GULF BREEZE LAB

CONTRACTING ACTIVITIES AT ORD'S
AREAL LAB

CONTRACTING ACTIVITIES AT ORD'S
HERL LAB
8/21/92

9/30/92



9/30/92



9/21/92


9/29/92


9/30/92
                                                        9/30/92

Assistant  Administrator for Solid Wa«tt and Emergency Response
E1SKF1-03-0065-2100666

E1GMG1-09-6001-2400085



Region 1

E1HWG2-01-6000-2400062

Region 2

E1SJC1-02-0113-2100501

E1SHG2-02-0020-2400074
SAMPLE MANAGEMENT OFFICE
9/30/92
FOUOWUP REVIEW OF ADMINISTRATIVE
PENALTIES UNDER RCRA ENFORCEMENT
PROGRAM                          9/30/92
NPDES FOLLOUUP REVIEW             8/11/92
COST RECOVERY NEGOTIATIONS         7/27/92

MANAGEMENT OF MINI-
ERCS CONTRACTORS                   9/10/92
15,300,000
 44
                                                                         OFFICE OF THE INSPECTOR GENERAL

-------
                                                                                        Questioned Costs
    Assignment
    Control Number
                         Title
                                                 Final Report
                                                 Issued
Ineligible
   Costs
Unsupported
      Costs
Unnecessary/
Unreasonable
       Costs
Recommended
   Efficiencies
 (Funds Be Put
To Better Use)
          -6007-2400060  IMPREST FUND FOLLOUUP REVIEW       7/29/92
          •0263-2400056  HAZARDOUS WASTE INCINERATOR AT
                         EAST LIVERPOOL, OH                 7/15/92
 Region  6

 E1SGG2-14-
0017-2400079  SUPERFUND RI/FS REVIEW AT
              KOPPERS, TX                        9/29/92
          •0200-2100665   IMPLEMENTATION OF THE LUST
                         PROGRAM IN CALIFORNIA              9/30/92
 E1SG*7-09-0219-2300063   MANAGEMENT OF STRINGFELLOW
                         SUPERFUND SITE                     7/30/92

               TOTAL  INTERNAL  1 MANAGEMENT REPORTS          -   23
                                                                                                                         15,300,000
2. CONSTRUCTION GRANT  ASSIGNMENTS
E2CUL2-01 -0095-2100628 LAKE WINNIPESAUKEE 2
E2CWL2-01 -0033-2100658 LAKE WINNIPESAUKEE
P2BWL2-01 -0212-2100335 CONCORD
P2CWL9-01 -01 11 -2100336 CONCORD
S2CWL9-01 -0066-2100401 MILFORD
S2CWLO-01 -0104-2100632 FITCHBURG
S2CUL 1-01 -0054 -21 00633 BOSTON WATER I SEWER
TOTAL OF REGION 01 * 7
E2CWMO-02-0183-2200016 BUFFALO SA
E2CWMO-02-0175-2200017 GLENS FALLS
E2CWMO-02-0042-2200018 WARREN COUNTY S01
E2CWMO-02-023&-2200025 CASTLETON-ON- HUDSON
E2CWMO-02-0268-2200027 NORTH CASTLE
E2CUM1 -02-01 18-220003* MIDDLESEX COUNTY
P2CWLO-02-0030-2100319 ITHACA
P2CWL9-02-0019-2100328 WESTCHESTER CO
P2CWL9-02-0229-2100356 WEBSTER
P2CWL9- 02- 0231 -21 00399 TONAWANDA
P2CWL9-02-0247-2100400 ERIE COUNTY - SOUTHTOWNS
P2CWL9-02-0341 -2100402 SARATOGA COUNTY SEWER
P2CULO-02-0149-2100448 NIAGARA COUNTY S01
P2BU*8-02-0017-2100449 NYC - NORTH RIVER
P2BW*8-02-0268-2100450 NYC-OAKWOOO BEACH
TOTAL OF REGION 02 » 15
E2AWT 2 -03 -0603 -2400084 EW PHILADELPHIA
P2CWM9-03-0341 -2200022 CRAIGSVILLE PSD
P2CWMO-03-0270-2200023 LEESBURG
P2CWMO-03-0031 -2200028 KINGWOOD CITY OF
P2CWMO-03-0029-2200033 LAKE HERITAGE MUNI AUTH
P2CWMO-03-0114-2200041 BERKELEY COUNTY PSD
P2CU-8- 03 -0048 -2300051 RED JACKET PUBLIC SERVICE
P2CWN1 -03-0123-2300062 PHILADELPHIA CITY OF
P2CWNO-03-OU4-2300070 BALTIMORE MAYOR & CTY COUN
P2CWN1 -03-0022-2300072 ST. MARY'S CTY METRO COMM
TOTAL OF REGION 03 * 10
E2CWM1 -04-0510-2200019 CARYVILLE
E2CWM2-04-0360-2200024 RADCLIFF
E2CWM2- 04 -0406- 2200026 FLEMING-NEON
E2CWM2-04-0416-2200032 HUNTSVILLE
E2BUN1 -04-0050-2300081 FT LAUDERDALE
NH
NH
NH
NH
MA
MA
MA

NY
NY
NY
NY
NY
NJ
NY
NY
NY
NY
NY
NY
NY
NY
NY

PA
WV
VA
WV
PA
WV
WV
PA
MD
MD

TN
KY
KY
AL
FL
9/22/92
9/29/92
4/23/92
4/24/92
6/ 9/92
9/22/92
9/22/92

4/15/92
4/16/92
5/ 6/92
7/30/92
9/ 2/92
9/22/92
4/14/92
4/16/92
5/ 5/92
6/ 9/92
6/ 9/92
6/ 9/92
7/ 5/92
7/ 5/92
7/ 5/92

9/30/92
7/15/92
7/23/92
9/ 2/92
9/18/92
9/30/92
5/11/92
7/23/92
8/27/92
9/ 3/92

5/ 7/92
7/29/92
8/25/92
9/17/92
9/24/92
3,421
299,148
21,605
4,262
156,786
147,818
164,180
797.220
533,913
253,681
416,260
217,984
469,490
264,500
288,151
1,766,797
267,200
307,04*
128,752
266,624
56,662
1,463,727
304,715
7,005.500
343,698
236,112
299,289
329,667
388,467
232,382
15,396,996
156,785
92,621
17,476,017
321,556
201,748
235,685
218,944
1,475,976
13,158
47,603
1.105.250
0
114,666
0
0
1,280,677
0
0
0
1,403
0
1,188,912
0
0
10,396
424,880
67,643
29,906
703,678
4.652,173
917,165
7,996.156
465,237
0
0
54,040
18,319
263,583
13,596,473
7,747
0
14,405,399
0
0
67,357
0
55,610
                                                                                                                  0
                                                                                                                  0
                                                                                                                  0
                                                                                                                  0
                                                                                                                  0
                                                                                                                 0
                                                                                                                 0
                                                                                                                 0
                                                                                                                 0
                                                                                                                          3.311,261
                                                                                                                         3.311,261
              TOTAL OF REGION 04 *
                                                               2,453,909
                                                                                           122,967
APRIL 1,1992 THROUGH SEPTEMBER 30,1992
                                                                                                                               45

-------
Assignment
Control Number
E2AUT2-05-0097- 2400042
P2CUNO-05-0032-2300074
P2BWP1 -05-0357-2400064
P2CWP8- 05- 0264 - 2400077
TOTAL OF
E2CWM1 -06-01 19-2200020
E2CUH2-06-0170-2200021
TOTAL OF
P2CUMO- 07- 0299- 2300058
TOTAL OF
E2CWM8-08-0032-2200037
P2CV*7-08-0023-2100333
P2CW*8-08-0052-2100634
P2CUL9-08-0065-2100668
TOTAL OF
E2CUMO-09-0052-2200030
E2CWM7-09-0131 -2200031
E2CUM9- 09- 0261 - 2200035
E2CWN 1 - 09- 0092- 2300082
E2CWNO-09-0071 -2300085
E2AUP2 - 09- 0243 - 2400076
P2CUMO - 09- 0294 - 2200036
P2CWN1 -09-0044- 2300086
S2CUM7-09-0193-2200039
S2CWM1 -09-0157- 2200040
S2CWNO-09-0124-2300076
S2CWN9-09-0163-2300078
S2CUNO-09-0262-2300089
S2BUN1 -09-0095-2300090
TOTAL OF
P2CUL8 - 1 0 - 0007- 2 1 00664
P2CUL9- 10-0002-2100669
P2CW8- 10-0021 -2200029
P2CWN1- 10-0042-2300088
P2CWN9- 10-0107-2300091
TOTAL OF
Title
FRANKLIN EUS
UASHTENAW CO DPW
MILWAUKEE MSD
GARY SO
REGION 05 * 4
PRYOR CREEK
SULPHUR
REGION 06 - 2
OMAHA
REGION 07 * 1
NILBANK, CITY OF
BILLINGS, CITY OF
HAYDEN, TOWN OF
GRAND FORKS, CITY OF
REGION 08 * 4
HAWAII, COUNTY OF
KAUAI, COUNTY OF
MALI I, COUNTY OF
RUSSIAN RIVER CSO
HONOLULU, CITY 1 CO
SAN DIEGO, CITY OF
EL MIRAGE, CITY OF
MACO SAN OIST.
SO SAN FRANCISCO, CITY OF
SUTTER CREEK, CITY OF
SELMA - K I NGSBURG - FOWLER
SEWERAGE AGCY-SO. MAR1N
SAN FRANCISCO, CITY 4 CO
SAN FRANCISCO, CAC SEUWTP
REGION 09 ' 14
LOON LAKE SEWER DIST NO 4
PIERCE COUNTY UTILITIES OEP
UNALASKA, CITY OF
NEWBERG, CITY OF
FED WAY WATER AND SEW
REGION 10 = 5

MI
MI
WI
IN

OK
LA

ME

SO
MT
CO
ND

HI
HI
HI
CA
HI
CA
AZ
AZ
CA
CA
CA
CA
CA
CA

WA
WA
AK
OR
WA

TOTAL CONSTRUCTION GRANT ASSIGNMENTS
Final Report
Issued
5/ 4/92
9/ 4/92
8/18/92
9/28/92

6/ 8/92
7/10/92

7/13/92

9/25/92
4/20/92
9/22/92
9/30/92

9/15/92
9/15/92
9/25/92
9/25/92
9/29/92
9/24/92
9/29/92
9/29/92
9/30/92
9/30/92
9/ 8/92
9/14/92
9/30/92
9/30/92

9/30/92
9/30/92
9/10/92
9/30/92
9/30/92

= 67
Ineligible
Costs

707,156
2,385.191
65,276
3,157,623
0
66,776
66,776
339.254
339,254

13.408
0
227,048
240.456
67,118
45,698
89,132
6,258,050
1,292,855

62,094
6,408
8,898
10,422
758,053
125,405
240,830
5,425,295
14,390,258
173,476
2,179,647
153,450
6,749
978,544
3,491,866
49,418,879
Unsupported
Costs

2,807,133
2,128,006
167,486
5,102,625
0
22,500
22,500
0
0

0
12,251
0
12,251
0
0
0
0
0

63,585
32,673
0
0
0
0
501,591
0
597,849
0
2,316,534
39,676
115,831
1,681,536
4,153,577
33,694,001
Unnecessary/
Unreasonable
Costs

0
0
14,627,757
14,627,757
16,768
0
16,768
0
0

0
1,036,830
2.348,278
3,385,108
5,386,048
0
0
13,685,550
4,516,290

3,620,730
1.054,893
2,310,428
333,367
3,040,477
0
0
0
33,947,783
120,652
0
246,508
11,944,536
0
12,311,696
64,289,112
nct/wiiiuidiucu
Efficiencies
(Funds Be Put
To Better Use]




















5,500,00








5,500,00






8,811,26
3. OTHER GRANT ASSIGNMENTS
C3HVK2-01 -0336-2501091
E3BUL1-01-0178-2100522
G3HVK2-01 -0154-2500731
G3HVK2-01 -0287-2500970
G3HVK2-01 -0301 -2501022
G3HVK2-01 -0335-2501070
G3HVK2-01 -0359-2501 108
G3HVK2-01-0361-2501109
G3HVK2-01 -0365-2501 110
G3HVK2-01 -0362-25011 11
N3HVK2-01 -0159-2500719
N3HVK2-01 -0166-2500720
N3HVK2-01-0178- 2500825
N3HVK2-01 -01 12-2500826
N3HVK2-01 -021 1-2500827
N3HVK2-01 -0160-2500833
N3HVK2-01 -0141-2500834
N3HVK2-01 -0070-2500879
N3HVK2- 01 - 0288- 2500969
U3HVK2-01 -0289-2500980
CH1COPEE
RI ESTUARY PROGRAM GRANTS
YARMOUTH, TOWN OF
BURLINGTON
HARTFORD
KENNEBUNKPORT
MASS WATER RESOURCES AUTH.
NORTHUMBERLAND
MARSHFIELD.
MATTABASSETT DISTRICT
NANTUCKET, TOWN AND COUNTY
NANTUCKET
VERMONT
NASHUA
SOUTHERN NH PLANNING CCMM.
BRISTOL, CITY OF
NEW HAMPSHIRE, STATE OF
METRO. AREA PLANNING
MA
RI
MA
VT
VT
ME
MA
NH
MA
CT
MA
MA
VT
NH
NH
CT
NH
MA
N. MIDDLESEX COUNCIL OF GOVTMA
GR. PORTLAND COUNCIL OF GOVTME
9/22/92
8/11/92
4/16/92
7/27/92
8/21/92
9/15/92
9/25/92
9/25/92
9/25/92
9/25/92
4/10/92
4/10/92
5/28/92
5/28/92
5/28/92
6/ 1/92
6/ 1/92
6/ 9/92
7/27/92
7/28/92
0
1,635
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
154,522
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
41,954
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0




















46
                                                                                            OFFICE OF THE INSPECTOR GENERAL

-------
    Assignment
    Control Number
                         Title
                                    Final Report
                                    Issued
                        Ineligible
                           Costs
                                                                                         Questioned Costs
                            Unsupported
                                   Costs
                        Unnecessary/
                        Unreasonable
                               Costs
                         Recommended
                            Efficiencies
                          (Funds Be Put
                         To Better Use)
N3HVK2-01-0286-2501033
N3HVK2-01-0209-2501090
PIONEER VALLEY PLAN. COMM.
MAINE AUDUBON SOCIETY
MA
ME
8/27/92
9/21/92
              TOTAL OF REGION 01
            22
    0
    0

1,635
      0
      0

154.522
C3HVK2- 02 -0075 -2500704
G3HVK2-02-0107-2500744
G3HVK2-02-011 1-2500760
G3HVK2-02-01 14-2500813
G3HVK2-02-01 12-2500835
G3HVK2-02-0125-2500904
G3HVK2-02-0127-2500915
G3HVJ2-02-0132-2500933
33HVK2-02-0139-2501011
53HVK2-02-0147-2501038
33HVK2-02^T148-2501059
*3HVK2-02-0077-2500701
43HVK2-02-0060-2500702
J3HVK2-02-0044-2500703
<3HUK2- 02- 0099- 2500745
(3HVK1 -02-013*- 2500746
I3HVK2-02-01 19-2500896
I3HVK2-02-0058-2500902
13HVK2-02-0124-2500916
(3HVK2-02-0129-2500967
I3HVK2-02-0128-2500968
3HVK2-02-0123-2500971
3HVK2-02-0134-2500972
3HVK2-02-0135-2500973
3HVK2-02-0117-2501010
3HVK2-02-0039-2501027
3HVK2-02-0143-2501032
3HVK2-02-0140-2501034
3HVK2-02-0145-2501035
3HVK2-02-0019-2501058
3HVK2-02-0150-2501062
3HVK2-02-0144-2501063
TOTAL OF
:3HVK2-03-0352-2500754
:3HVK2-03-0340-2500829
.'3HVIC2-03-0359-2500830
3HVK2- 03 -0454 -2500898
:3HVK2-03-04 78-2501085
I3BST2-03-0452-2400059
13HVK2-03-0292-2500677
13HVK2 - 03 - 0366-2500775
;3HVK2- 03 -0374 -2500788
;3HVK2-03-0375-2500789
J3HVK2-03-0377- 2500790
I3HVK2 - 03 - 0378- 2500791
J3HVK1 -03-0238-2500926
S3HVK2-03-0372-2500927
i3HVK2 - 03-0386-2500928
J3HVK2-03-0383-2500929
53HVK1 -03-0282-2500930
53HVK2-03-0381 -2500942
33H Vtt - 03 - 0502- 2500983
53HVK2-03-0503-25 00984
33HVK2-03-0504-2500985
33HVK2-03-0519-2501023
3HVK2-03-0529-2501024
33HVK2-03-0530-2501025
G3HVK2-03-0534-2501026
G3HVK2 - 03 - 0537- 2501029
G3HVK2-03-0538-2501030
33HVK2-03-0575-2501083
33HVK2-03-0527-2501115
N3HVK1 -03-0393-2500678
N3HVK2-03-0166- 2500679
M3HVM1 -03-0182-2500728
N3HVH1 -03-0388-2500769
M3HVKO-03-0129-2500776
EOB
OXFORD
CAPE MAY COUNTY MUA
LAND IS SA
BERGEN COUNTY UA
GLOVERSV I LLE- JOHNSTOWN JT
GREAT NECK UPCO
INTERSTATE SANITATION COMM
ALEXANDRIA
BOLIVAR
ORISKANY FALLS
NEWBURGH
ERIE COUNTY
UAUARSING
RESEARCH FOUNDATION OF SONY
MAMARONECK
TRENTON
NASSAU COUNTY
CHEMUNG COUNTY
TRENTON
JERSEY CITY
ELIZABETH
ELIZABETH
ELIZABETH
NEW YORK CITY
PR OEM OF HEALTH
RENSSCLAER COUNTY
SENECA NATION OF INDIANS
DUNDEE
NEW JERSEY
GOUVERNEUR
GOUVERNEUR
REGION 02 * 32
CHESTERFIELD COUNTY 90
PRINCE WILLIAM COUNTY
CARROLL COUNTY
HARFORO COUNTY
FAIRFAX COUNTY
CERMA EARLY WARNING
BOONSBORO, TOWN OF
CAMBRIDGE CITY OF
HAMPTON ROADS SANITATION
DELAWARE RIVER BASIN
BUCKINGHAM TOWNSHIP
LANSBORO BOROUGH
STROUDSBURG
DUBOISTOWN BOROUGH
STROUDSBURG BOROUGH
INDIAN HEAD TOWN OF
INDIAN HEAD TOWN OF
WESTMINSTER
TALBOT COUNTY
TALBOT COUNTY
GARRETT COUNTY
TALBOT COUNTY
SAINT MARY'S COUNTY
SAINT THOMAS TOWNSHIP
DUBLIN BOROUUGH
PR
NY
NJ
NJ
NJ
NY
NY
NY
NY
NY
NY
NY
NY
NY
NY
NY
NJ
NY
NY
NJ
NJ
NJ
NJ
NJ
NY
PR
NY
NY
NY
NJ
NY
NY

VA
VA
MD
MD
VA

MD
MO
VA
PA
PA
PA
PA
PA
PA
MD
MD
MD
MD
MD
MD
MO
MO
PA
PA
FA I RCHANCE -GEORGES JOINT MSAPA
UPPER GWYNEDO-TOWAMENCIN
UPPER MONTGOMERY JOINT AUTH
ELKTON, TOWN OF
CECIL COUNTY
METRO WASHINGTON COUNCIL
BALTIMORE CITY OF
PHILADELPHIA CITY 6/90
ARLINGTON COUNTY 6/89
PA
PA
MD
MO
DC
MD
PA
VA
4/ 6/92
4/27/92
5/ 5/92
5/20/92
6/ 2/92
6/19/92
6/26/92
7/ 8/92
8/12/92
9/ 2/92
9/ 8/92
4/ 6/92
4/ 6/92
4/ 6/92
4/27/92
4/27/92
6/15/92
6/18/92
7/ 2/92
7/27/92
7/27/92
7/28/92
7/28/92
7/28/92
8/12/92
8/24/92
8/27/92
9/ 1/92
9/ 1/92
9/ 8/92
9/ 9/92
9/ 9/92

4/30/92
5/28/92
5/28/92
6/16/92
9/21/92
7/ 9/92
4/ 1/92
5/ 7/92
5/14/92
5/13/92
5/14/92
5/14/92
6/26/92
6/26/92
6/26/92
6/30/92
6/30/92
7/13/92
7/27/92
7/27/92
7/27/92
8/20/92
8/20/92
8/20/92
8/21/92
8/25/92
8/24/92
9/21/92
9/29/92
4/ 1/92
4/ 1/92
4/15/92
5/ 7/92
5/ 7/92
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
1,402,999
0
0
0
0
0
0
0
                                                                                  0
                                                                                  0
                                                                                  0
                                                                                  0
                                                                                  0

                                                                                  0
                                                                                  0
                                                                          2,153,646
                                                                                  0
                                                                                  0
                                                                                  0
                                                                                  0
                                                                                  0
                                                                                  0
                                                                                  0
                                                                                  0
                                                                                  0
                                                                                  0
                                                                                  0
                                                                                  0
                                                                                  0
                                                                                  0
                                                                                  0
                                                                                  0
                                                                                  0
                                                                             34,889
                                                                                  0
                                                                                  0
                                                                                  0
                                                                                  0
                                                                            310,686
                                                                                  0
                                                                                  0
                                                                 1,402,999

                                                                         0
                                                                         0
                                                                         0
                                                                         0
                                                                         0

                                                                         0
                                                                         0
                                                                         0
                                                                         0
                                                                         0
                                                                         0
                                                                         0
                                                                         0
                                                                         0
                                                                         0
                                                                         0
                                                                         0
                                                                         0
                                                                         0
                                                                         0
                                                                         0
                                                                         0
                                                                         0
                                                                         0
                                                                         0
                                                                         0
                                                                         0
                                                                         0
                                                                         0
                                                                         0
                                                                 2.947,758
                                                                 7,959,906
                                                                         0
     0
     0

41,954

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

                                                             0
                                                             0
                                                             0
                                                             0
                                                             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 1,1992 THROUGH SEPTEMBER 30,1992
                                                                                                       47

-------
Assignment
Control Number
N3HUK1 -03-0150-2500786
N3HUK2-03-0371 -2500787
N3HVK2-03-0370-2500832
N3HVK2-03-0385-2500917
N3HVK9-03-0356-2500934
N3HVK 1 - 03 - 0074 - 2500940
N3HVKO - 03 - 0087- 2500941
N3HVK9-0>-«357- 2500943
N3HVKO-03-0271 -2500944
N3HVK2-03-0164-2500961
N3HUKO- 03 -0343 -2500963
N3HVKO- 03 - 021 0- 2500964
N3HVK2-03- 016fc 2500965
N3HVKO-03-0127-2S00966
N3HVK2-03-0505-2500986
N3HVK2-03-0506-2500987
N3HVK1 -03-0394-2501017
N3HUK2-03-0525-2501018
N3HVK 1-03 -0275 -250 1020
N3HVK2-03-0526-2501031
N3HVK2-03-0053-2501039
N3HVK1 -03-0141 -2501040
N3HVK2-03-0171 -2501041
N3HVK1 -03-0181 -2501042
N3HVK2-03-0168-2501043
N3HUK2-03-0165-2501084
N3HVK2-03-0373-2501086
N3HVK2-03-OS23-2501116
Title
JOHNS HOPKINS UNIVERSITY
JOHNS HOPKINS UNIVERSITY
CECIL COUNTY
MIL FORD
TALBOT COUNTY -FYE 6/88
LEES8URG TOUN OF
LEESBURG TOUN OF
CAPE CHARLES TOUN OF
BROUNSVILLE AREA SCHOOL 01 S
FREDERICK, CITY OF
WASHINGTON SCHOOL DISTRICT
BUCHANAN COUNTY OF
WEST VIRGINIA STATE
FAUQUIER COUNTY OF 6/89
WILMINGTON
CHESTER UPLAND SCHOOL
ELKTON TOUN OF
PITTSBURGH UNIVERSITY
DELAWARE STATE OF
FREDERICK COUNTY
VA INSTITUTE MARINE SCIENCE
ERIE COUNTY
ERIE COUNTY
HENRI CO COUNTY
HENRI CO COUNTY
NATIONAL COUNCIL OF SENIOR
MARYLAND STATE OF
DELAWARE STATE

MD
MD
MD
DE
MD
VA
VA
VA
PA
MD
PA
VA
WV
VA
DE
PA
MD
PA
DE
MD
VA
PA
PA
VA
VA
DC
MD
DE
Final Report
Issued
5/13/92
5/13/92
5/29/92
6/29/92
7/ 8/92
7/13/92
7/13/92
7/13/92
7/13/92
7/23/92
7/23/92
7/22/92
7/22/92
7/22/92
7/27/92
7/27/92
8/15/92
8/12/92
8/12/92
8/25/92
9/ 2/92
9/ 1/92
9/ 1/92
9/ 1/92
9/ 1/92
9/18/92
9/21/92
9/30/92
Ineligible
Costs
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
	 I1G*«WI*IIIIGII\«GU
Unsupported Unnecessary/ Efficiencies
Costs Unreasonable (Funds Be Put
Costs To Better Use)
0
0
0
0
0
0
0
0
0
1,076,996
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
              TOTAL OF REGION 03 *  62

C3HVK2-04-0246-2500682  TAMPA
C3HVK2-04-0304-2500735  JACKSONVILLE
C3HVK2-04-0247-2500736  PENSACOLA
C3HVJ2-04-0292-2500796  JEFFERSON COUNTY
C3HVK2-04-0356-2500806  COBB COUNTY
C3HVK2-04-0306-2500906  JEFFERSON CO. FISCAL COURT
C3HVK2-04-0248-2500919  COLUMBIA
E3CLN2-04-0097-2300056  LUST/LUST FINANCIAL
G3HVK2-04-0210-2500680  REIDSVILLE
G3HVK2-04-0162-2500681  WACHULA
G3HVK2-04-0260-2500690  PINE HILL
G3HVK2-04-0256-2500691  LEIGHTON
G3HVK2-04-0258-2500692  LUVERME
G3HVK2-04-0250-2500693  LOXLEY
G3HVK2-04-0243-2500711  KOSCIUSKO
G3HVK2-04-0192-2500725  ELKTON
G3HVK2-04-0305-2500726  WAVELAND WU MAN DISTRICT
G3HVK2-04-0294-2500729  PUNTA GORDA
G3HVK2-04-0295-2500730  SALTILLO
G3HVK2-04-0296-2500732  DOTHAN
G3HVK2-04-0307-2500733  RED BAY
G3HVK2-04-0308-2500734  RED BAY
G3HVK2-04-0310-2500738  ARCADIA
G3HVK2-04-0324-2500755  PAMLICO COUNTY
G3HVK2-04-0274-2500799  HEFLIN WATER WORKS I SEWER
G3HVK2-04-0273-2500800  HEFLIN WATER WORKS I SEWER
G3HVK2-04-0328-2500810  MONROE
G3HVK2-04-0326-2500812  SANFORD
G3HVK2-04-0336-2500817  MACON-BIBB COUNTY WSA
G3HVK2-04-0337-2500818  MACON-BIBB COUNTY WSA
G3HVK2-04-0374-2500839  JACKSONVILLE WUSO
G3HVK2-04-0387-2500918  ROANOKE UTILITIES BOARD
G3HVK2-04-0398-2500936  INEZ
G3HVK2-04-0357-2500938  SHELBY COUNTY SANITARY DIST KY
G3HVK2-04-0408-2501001  CHICKAMAUGA
G3HVK2-04-0431-2501073  CHAPEL HILL
G3HVK2-04-0437-2501074  BULLS GAP
03HVK2-04-0438-2501075  FAYETTEVILLE
G3HVK2-04-0430-2501076  CHAPEL HILL
G3HVK2-04-0429-2501077  CAMDEN
G3HVK2-04-0428-2501078  VENICE
G3HVK2-04-0441-2501087  PULASKI
G3HVK2-04-0435-2501088  TROY
FL
FL
FL
AL
GA
KY
SC
TN
GA
FL
AL
AL
AL
AL
MS
KY
MS
FL
MS
AL
AL
AL
FL
NC
AL
AL
GA
FL
GA
GA
AL
AL
KY
KY
GA
TN
TN
TN
TN
TN
FL
TN
TN
4/ 1/92
4/17/92
4/17/92
5/18/92
5/18/92
6/22/92
7/ 6/92
7/ 8/92
4/ 1/92
4/ 1/92
4/ 3/92
4/ 3/92
4/ 3/92
4/ 3/92
4/ 7/92
4/15/92
4/15/92
4/16/92
4/16/92
4/17/92
4/17/92
4/17/92
4/21/92
5/ 1/92
5/18/92
5/18/92
5/19/92
5/19/92
5/22/92
5/22/92
6/ 4/92
7/ 6/92
7/ 9/92
7/ 9/92
8/ 6/92
9/17/92
9/17/92
9/17/92
9/17/92
9/17/92
9/17/92
9/21/92
9/21/92
2,499,221

        0
        0
        0
        0
        Q
    7,346
        0
   10,588
        0
        0
        0
        0
        0
        0
        0
        0
        0
        0
        0
        0
        0
        0
        0
        0
        0
        0
        0
        0
        0
        0
        0
    3,384
        0
        0
        0
        0
        0
        0
        0
        0
        0
        0
        0
11,984,660

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

-------
Assignment
Control Number
G3HVK2-04-0433-2501089
G3HVK2-04-0436-2501092
G3HVK2-04-0461-2501093
G3HVK2-04-0440-2501094
G3HVK2-04-0439- 2501095
G3HVK2-04-0434-2501096
G3HVK2-04-0442-2501097
G3HVK2-04-0446- 2501098
G3H VK2 - 04 - 0445 - 250 1 099
G3HVK2-04-0448- 2501 100
G3HVK2-04-0465-2501101
G3HVK2-04-0479-2501112
N3HVK2 - 04 - 0259- 2500683
N3HUK2-04-0142-2500694
N3HVK2-04-0255-2500695
N3HVK2-04-0287-2500710
N3HVK2-04-0065-2500712
N3HVK2 -04-0257- 250071 3
N3HVK2-04-0104-2500747
N3HVK2-04-0325-2500756
N3HVK2-04-0106-2500757
M3HVK2-04-0151 -2500758
N3HUK2 - 04 - 0349-2500803
N3HVK2-04-0351 -2500804
N3HVK2 - 04 - 0348- 2500805
N3HVK2-04-0168-2500807
N3HVK2 • 04 - 0245 - 2500808
N3HVK2- 04 - 0077- 2500809
N3HVK2-04-0364-2500831
M3HUJ2-04-0329- 2500897
N3HVJ2-04-0067-2500905
M3HUJ2-04-0390-2500935
N3H VK2 - 04 - 0396- 2500937
N3HVK2 - 04 - 0285 - 2500982
M3HVK2-04-041 1-2501037
N3HVK2-04-0069-2501047
N3HVK2-04-0391 -2501048
N3HVK2-04-0315-2501049
Title
EAST RIOGE
BULLS GAP
ALAMO
MCMINNVILLE
PARIS
TROY
CORNERSVILLE
WA8TRACE
UAJJTRACE
LEBANON
NEWKRN
LINDEN
LUVERNE
LOUISVILLE, UNIVERSITY OF
DALEVILLE
MANCHESTER
CHATTAMOOGA
LEIGHTON
RALEIGH
ATMORE
DURHAM
BELLE GLADE
MORE HE AD STATE UNIVERSITY
HUNTSVILLE
SARAMTA
BUNCOMBE COUNTY
ORLANDO
WINSTON- SALEM
CAMP HILL
MISSISSIPPI MEDICAL CENTER
SOUTH CAROLINA STATE OF
MISSISSIPPI ST. UNIVERSITY
FREEPORT
INDIAN RIVER COUNTY
BELLE GLADE
WASHINGTON

TN
TN
TN
TN
TN
TN
TN
TN
TN
TN
TN
TN
AL
KY
AL
ICY
TN
AL
NC
AL
NC
FL
KY
AL
FL
NC
FL
NC
AL
MS
SC
MS
FL
FL
FL
NC
EASTERN BAND OF CHEROKEE INONC
MEMPHIS
TN
Final Report
Issued
9/21/92
9/22/92
9/22/92
9/22/92
9/22/92
9/22/92
9/24/92
9/24/92
9/24/92
9/24/92
9/24/92
9/25/92
4/ 1/92
4/ 3/92
4/ 3/92
4/ 7/92
4/ 7/92
4/ 7/92
4/27/92
5/ 1/92
5/ 1/92
5/ 4/92
5/18/92
5/18/92
5/18/92
5/19/92
5/19/92
5/19/92
5/29/92
6/17/92
6/22/92
7/ 9/92
7/ 9/92
7/29/92
9/ 1/92
9/ 4/92
9/ 4/92
9/ 4/92
	 • — i IG«*VI* **• •*•! IUGU
Ineligible Unsupported Unnecessary/ Efficiencies
Costs Costs Unreasonable (Funds Be Put
Costs To Better Use)
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
2,461
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
              TOTAL OF REGION 04 *  81

C3HVK2-05-0206-2500715  AKRON FY 90
C3HVK2-05-0261-2500846  KENT CO FY 90
C3HVK2-05-0372-2501053  LANSING FY 91
C3HVK2-05-0371-2501055  JOL1ET FY 90
G3HVJ2-05-0205-2500685  ST PAUL MWCC FY 90
G3HVJ2-05-0209-2500687  VERSAILLES FY 89/90
G3HVJ2-05-0192-2500727  ORLEANS FY 89/90
G3HVK2-05-0215-2500737  MILWAUKEE MSO FY 90
G3HVJ2-05-0213-2500761  CHURUBUSCO FY 89/90
G3HVK2-05-0217-2500762  RENVILLE FY 91
G3HVJ2-05-0218-2500763  LAKE STATION FY 90
G3HVJ2-05-0214-2500764  ZIONSVILLE FY 89/90
G3HVJ2-05-0242-2500795  LITTLE RACCOON RWD FY 89/90
G3HVJ2-05-0240-2500797  MEDORA FY 89/90
G3HVK2-05-0243-2500798  OTTAWA CO PUS FY 90
G3HVJ2-05-0241-2500802  MEDORA FY 91
G3HVK2-05-0247-2500815  GREENWOOD FY 90/91
G3HVJ2-05-0257-2500845  WILMINGTON FY 90
G3HVK2-05-0270-2500873  PLUMMER FY 91
G3HVK2-05-0267-2500880  FOLEY FY 90
G3HVK2-05-0271 -2500881  MONROE CO DC FY 91
G3HVK2-05-0268-2S00882  FOLEY FY 91
G3HVJ2-05-0288-2500889  COLDWATER VSO FY 90
G3HVJ2-05-0286-2500890  CRESTVIEW LSD FY 90
G3HVJ2-05-0289-2500891  MANSFIELD CSO FY 90
G3HVK2-05-0302-2500922  ADAMS FY 91
G3HVK2-05-0308-2500923  COLD SPRING FY 91
G3HVK2-05-03<*-2500924  LA CRESCENT FY 91
G3HVJ2-05-0304-2500925  SMITH-GREEN CSC FY 90/91
G3HVJ2-05-0315-2500946  FRANKTON FY 89/90
G3HVK2-05-0322-2500948  LONSOALE FY 90/91
G3HVK2-05-0364-2500949  CLEVELAND NEORSO FY 91
G3HVK2-05-0347-2500955  RANTOUL FY 88
OH
MI
MI
IL
MN
IN
IN
WI
IN
MN
IN
IN
IN
IN
MI
IN
IN
OH
MN
MN
MI
MN
OH
OH
OH
MN
MN
MN
IN
IN
MN
OH
IL
4/ 7/92
6/ 5/92
9/ 4/92
9/ 4/92
4/ 2/92
4/ 2/92
4/15/92
4/21/92
5/ 5/92
5/ 5/92
5/ 5/92
5/ 5/92
5/18/92
5/18/92
5/18/92
5/18/92
5/20/92
6/ 5/92
6/ 9/92
6/10/92
6/10/92
6/10/92
6/12/92
6/12/92
6/12/92
7/ 6/92
7/ 6/92
7/ 6/92
7/ 6/92
7/15/92
7/15/92
7/15/92
7/20/92
21,318

     0
     0
     0
     0
     0
     0
     0
OOf VOO
     o
     o
     o
     o
     o
     o
     o
     o
     o
     o
     o
     o
     o
     o
     o
     o
     o
     0
     0
     0
     0
     0
     0
     0
     0
2,461

    0
    0
    0
    0
    0
    0
    0
    0
    0
    0
    0
    0
    0
    0
    0
    0
    0
    0
    0
    0
    0
    0
    0
    0
    0
    0
    0
    0
    0
    0
    0
    0
    0
      0
      0
      0
      0
      0
      0
      0
      0
      0
      0
      0
      0
      0
      0
      0
      0
      0
      0
      0
      0
      0
      0
      0
      0
      0
      0
      0
      0
259,386
      0
      0
      0
      0
APRIL 1,1992 THROUGH SEPTEMBER 30,1992
                                                  49

-------
Assignment
Control Number
G3HVJ2-05-0348-2500956
G3HVJ2-05-0340-2500958
G3HVK2-05-0338-2500988
G3HVK2-05-0349-2500991
G3HVJ2-05-0343-2500992
G3HVK2 - 05 - 0367- 2500994
G3HVK2 • 05 • 0368- 2500995
G3HVK2-05-0363-2500996
G3H VK2 - 05 - 0375 - 2500997
G3HVK2 - 05 - 0377- 2500998
G3HVK2-05-0388-2500999
G3HVK2-05-0407-2501012
G3HVK2-05-0401 -2501013
G3HVK2-05-0410-2501014
G3HVK2-05-0417-2501050
G3HVK2-05-0408-2501052
G3HVK2-05-0402-2501104
G3HVJ2-05-0418-2501105
G3HVK2-05-0457- 2501 106
M3HVK 1-05 -0394 -2500684
N3HVJ 1-05 -0260 -2500686
N3HVK2-05-0132-2500717
N3HVK2-05-0226-2500794
N3HVJ2-05-0239-2500801
N3HVK2-05-0133-2S00816
N3HVK1 -05-0395-2500866
N3HVJ2- 05 -0250- 2500874
M3HVJ2-05-0254-2500876
N3HVJ2-05-0136- 2500907
N3HVJ2-05-0252-2500908
N3HVJ2-05-0251 -2500909
N3HVJ2- 05- 0275 -2500921
N3HVJ2-05-0282-2500945
N3HVJ2-05-0253-2500947
N3HVK2-05-0143-2500957
N3HVJ2-05-0353-2500989
N3HVK2-05-0212-2500990
N3HUJ2-05-0345-2500993
N3HVK2-05-0041 -2501000
N3HVJ2-05-022S-25010S1
N3H VK2 - 05 - 0406- 250 1 054
N3HUK2-05-0404-2S01 103
TOTAL OF
C3HVK2-06-0157-2500781
C3HVJ2-06-0175-2500895
C3HVK2-06-0179-2500903
C3HVK2-06-0204-2501060
C3HVK2-06-0199-2501067
E3CLN1 -06-0157- 2300052
G3HVK2-06-0133-2500688
G3HVK2-06-0134-2500689
G3HVK2-06-0148-2500748
G3HVK2-06-0149-2500749
G3HVK2-06-0164-2S00821
G3HVJ2-06-0176-2500899
G3HVK2 • 06- 01 77-2500900
G3HVK2- 06- 01 7»- 250090 1
G3HVK2-06-0183-2S00931
G3HVK2-06-0208-2501072
G3HVK2-06-0212-2501080
N3HWKO-06-0155-2500706
N3HWKO-06-0141 -2500707
N3HUKO-06-0144-2500708
N3HWKO-06-0145-2500709
N3HVK2-06-0138-2500714
N3HVK2-06-0137-2500716
N3HVK2-06-0150-2500750
N3HVK2-06-0151 -2500751
N3HVK2-06-0152-2500752
N3HVK2-06-0165-2500823
N3HVK2-06-0169-2500838
N3HVK2-06-0171-25 00887
Title
ILL I HOI 8 DNS FY 90/91
HAPPANEE FY 91
HUMARD SO FY 91
LYL8 FY 91
CANTOH FY 89
LAKE SHORE FY 90
HEWITT FY 91
STAPLES FY 91
HUTCHINSON FY 91
ALLOUEZ TUP FY 91
OGILVIE
BARNESVILLE FY 91
CALUMET TUP FY 91
E JORDAN FY 92
DUNDEE FY 92
N HOUGHTON CWS FY 91
PILLAGER FY 91
INDIANA D&M FY 91
MN SRF FY 92
DANVILLE FY 90
OHIO ST U FY 89
TOLEDO FY 90
N CHICAGO CSO FY 91
PLYMOUTH FY 90
MACOM8 CO FY 90
DANVILLE FY 89
YOUNGSTOUN FY 89
SELLERS8URG FY 89/90
EVANSVILLE FY 90
BLOGMINGTON FY 90
LICKING CO FY 90
MUSKINGUM CO FY 90
FAIRFIELD CO FY 90
MICHIGAN SP FY 88/89
OAKLAND CO FY 90
ILLINOIS DOA FY 90/91
ONE I DA TRIBE FY 91
INDIANA ST U FY 91
MACKINAW FY 90
MICHIGAN DNR FY 88/89
WHITE EARTH RESERV FY 90
OHIO ST U FY 90
REGION 05 » 75
SAN ANTONIO
ARKANSAS DEPT. OF POLLUTION
SHREVEPORT
NORTH LITTLE ROCK
WITCH I TA FALLS
LUST COOPERATIVE AGREEMENTS
DENHAM SPRINGS
MILFORO
DENVER CITY
BRYAN
TROY
STATE PLAN BOARD
MIDWEST CITY
MIDWEST CITY
BROWNWOOD

IL
IN
MN
MN
OH
MN
MN
MN
MN
MI
MN
MN
MI
MI
MI
MI
MN
IN
MN
IL
OH
OH
IL
IN
MI
IL
OH
IN
IN
IN
OH
OH
OH
MI
MI
IL
UI
IN
MI
MI
MN
OH

TX
AR
LA
AR
TX
OK
LA
TX
TX
TX
TX
AR
OK
OK
TX
EL PASO PUBLIC SERVICE BOARDTX
EDCOUCH
NORMAN
ASSOCIATION OF CENTRAL OKLA
WESLACO
SAN MARCOS
ST. CHARLES PARISH COUNCIL
BRYAN
AUSTIN
ARKANSAS DEPT. OF HEALTH
SAND I A, PUEBLO OF
PECOS
MARSHALL
CLEBURNE
TX
OK
OK
TX
TX
LA
TX
TX
AR
NM
NM
TX
TX
Final Report
Issued
7/20/92
7/20/92
8/ 3/92
8/ 3/92
8/ 3/92
8/ 3/92
8/ 4/92
8/ 4/92
8/ 4/92
8/ 4/92
8/ 4/92
8/12/92
8/12/92
8/12/92
9/ 4/92
9/ 4/92
9/24/92
9/24/92
9/24/92
4/ 2/92
4/ 2/92
4/ 7/92
5/15/92
5/18/92
5/20/92
6/ 8/92
6/ 9/92
6/ 9/92
6/22/92
6/22/92
6/22/92
7/ 6/92
7/15/92
7/15/92
7/20/92
8/ 3/92
8/ 3/92
8/ 3/92
8/ 4/92
9/ 4/92
9/ 4/92
9/24/92

5/ 8/92
6/12/92
6/18/92
9/ 8/92
9/ 9/92
5/20/92
4/ 3/92
4/ 3/92
4/28/92
4/28/92
5/22/92
6/17/92
6/17/92
6/17/92
7/ 7/92
9/16/92
9/21/92
4/ 6/92
4/ 6/92
4/ 6/92
4/ 6/92
4/ 7/92
4/ 7/92
4/29/92
4/29/92
4/29/92
5/22/92
6/ 2/92
6/11/92
Ineligible Unsupported Unnecessary/ Efficiencies
Costs Costs Unreasonable (Funds Be Put
Costs To Better Use)
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
618,173
0
0
685,161
0
0
0
0
0
501,190
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
2,329
0
0
2,329
0
0
0
0
0
7,891
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
259,386
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
50
OFFICE OF THE INSPECTOR GENERAL

-------
Assignment
Control Number
N3HVK2-06-0173-2500888
N3HVJ2-06-0174-2500894
N3HVK2-06-0182-2500932
N3HVJ2-06-0200-2501036
N3HVJ2-06-0203-2501056
N3HVK2- 06- 0205 -2501 068
N3HVK2- 06- 0206- 2501 069
N3HVK2-06-0207-2501071
N3HVK2-06-0210-2501079
N3HVK2-06-0213-2501081
N3HVK2-06-021 1-2501082
N3HVK2-06-0218-2501113
Title
DALLAS, CITY OF
LOUISIANA STATE OF
BROWNSVILLE
ARKANSAS DEPT OF HEALTH
TEXAS, STATE OF
BATON ROUGE
GALVESTON COUNTY HEALTH
TEXARKANA
FORT WORTH
THIBOOAUX

TX
LA
TX
AR
TX
LA
OISTTX
TX
TX
LA
NEW MEXICO HEALTH ft ENVIRON NX
JEFFERSON PARISH
LA
Final Report
Issued
6/12/92
6/12/92
7/ 7/92
9/ 1/92
9/ 6/92
9/10/92
9/10/92
9/16/92
9/18/92
9/21/92
9/21/92
9/29/92
Ineligible Unsupported Unnecessary/ Efficiencies
Costs Costs Unreasonable (Funds Be Put
Costs To Better Use)
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
12,190
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
              TOTAL OF REGION 06 >  41
C3HVJ2-07-0185-25008H
C3HVK2-07-0120-2500836
G3HVK2-07-0188-2500723
G3HVK2-07-0200-2500857
G3HVK2-07-0201 -2500859
G3HVK2-07-0202-25008M
G3HVK2-07-0197-2500871
G3HVK2-07-0209-2501002
G3HVK2-07-0210-2S01061
G3HVK2-07-0198-2501064
G3HVK2-07-0219-2501065
G3HVK2-07-0218- 2501066
N3HVK2-07-0186- 2500721
N3HVK2-07-017S-2500837
N3H VK2 - 07- 0203 • 2500863
TOTAL OF
G3HVK2-08-00 73-2500828
G3HVJ2-08-0074-2500855
G3HVK2-08-008S-2S01003
N3HVK2 -08-0067- 2500724
N3HVK2 - 08- 0079-2500849
N3HVJ2-08-0078-2500852
N3HUK2-08-0077-2500856
N3HVK2 - 08-0076- 2500861
N3HVK2- 08- 0075 -2500862
N3HVJ2-08-0083-2500865
N3HVK2-08-0082-2500867
N3HVK2-08-0081 -2500868
N3HVK2-08-0080-2500869
TOTAL OF
G3HVK2-09-0171 -25 00739
G3HVK2-09-0232-J500843
G3HVK2-09-0241 -2500885
G3HVK2-09-0314-2501007
N3HVK2-09-0165-2500696
N3HVK2-09-0166-2500697
N3HVK2-09-0167-2500698
N3HVK2-09-0168-2500705
N3HVK2-09-0172-2500740
N3HVK2-09-01 73-2500741
N3HVK2-09-0182-2500765
N3HVK2-09-0183-2500766
N3HVK2-09-0184-2500767
N3HVK2-09-0185-2500768
N3HVH2-09-0188-2500771
N3HVK2-09-0189- 2500772
N3HVK2-09-0190-2500773
N3HVK2-09-0191-2500774
N3HVK2-09-0193-2500777
N3HVK2-09-0194-2500778
N3HVK2-09-0195-2500779
N3HUK2-09-0196-2500780
N3HVK2-09-0199-2500782
N3HVK2-09-0200-2500784
N3HVK2-09-0201 -2500785
DEPT OF ENVIRON CONTROL
KANSAS CITY
MARSHALLTOUN
GRANT CITY
GRANT CITY
LIBERAL
COLUMBIA
EMPORIA
NORTHEAST PVB SEWER OIST
ROCK CREEK SEWER DIST
CHILLICOTHE
MANSFIELD
POLK COUNTY
CEDAR RAPIDS
DES MOINES
REGION 07 * 15
E DAKOTA WATER DIST
DEVILS LAKE
LOVELL
SOUTHERN UTE INDIAN TRIBE
OGLALA SIOUX TRIBE
DEPT OF ENVIRON QUALITY
U OF WY/WESTERN RESEARCH
S ADAMS COUNTY WATER DIST
SALISH AND KOOTENAI TRIBES
PENNINGTON COUNTY
WELD COUNTY
ANACONDA/DEER LODGE COUNTY
NORTHERN CHEYENNE TRIBE
REGION 08 « 13
SEDONA, CITY OF
PINETOP-LAKESIDE SAN DIS
LITTLE COLORADO SAN. DIST
CARSON CITY
NAPA, COUNTY OF
COMMONWEALTH OF NO MARIAN
LOS ANGELES COUNTY SAN DIST
COMMONWLTH OF N. MARIANA IS
PALAU, REPUBLIC OF
FERNMLE, CITY OF
GUAM, PORT AUTHORITY OF
MONTEREY BAY UNIF. AIR POL
SO TAHOE PUBLIC UTIL 01
SOUTH COAST AIR QUAL MGMT
RUSSIAN RIVER CNTY WATER DI
SACRAMENTO, COUNTY OF
PACIFICA, CITY OF
PETALUMA, CITY OF
LAKE, COUNTY OF
SANTA ANA WTR.SHED PROJ AUT
MARICOPA ASSN OF GOVTS
HORNET FOUNDATION, INC
ALAMEDA, COUNTY OF
MARSHALL ISLANDS, REPUBLIC
MARSHALL ISLDS. REPUBLIC OF
NE
KS
IA
MO
MO
MO
MO
KS
MO
MO
MO
MO
IA
IA
IA


NO
WY
CO
SO
WY
WY
CO
MT
SD
CO
MT
MT

AZ
AZ
AZ
NV
CA
FM
CA
FM
PW
CA
GM
CA
CA
CA
CA
CA
CA
CA
CA
CA
AZ
CA
CA
MH
MH
5/20/92
6/ 2/92
4/15/92
6/ 5/92
6/ 5/92
6/ 8/92
6/ 8/92
8/ 7/92
9/ 8/92
9/ 9/92
9/ 9/92
9/ 9/92
4/15/92
6/ 2/92
6/ 8/92

5/29/92
6/ 5/92
8/ 7/92
4/15/92
6/ 5/92
6/ 5/92
6/ 5/92
6/ 5/92
6/ 5/92
6/ 8/92
6/ 8/92
6/ 8/92
6/ 8/92

4/22/92
6/ 4/92
6/10/92
8/10/92
4/ 3/92
4/ 3/92
4/ 3/92
4/ 6/92
4/22/92
4/22/92
5/ 5/92
5/ 5/92
5/ 5/92
5/ 5/92
5/ 7/92
5/ 7/92
5/ 7/92
5/ 7/92
5/ 8/92
5/ 8/92
5/ 8/92
5/ 8/92
5/13/92
5/13/92
5/13/92
501,190

      0
      0
      0
      0
      0
      0
      0
      0
      0
      0
      0
      0
      0
      0
      0
20,081

     0
     0
     0
     0
     0
     0
     0
     0
     0
     0
     0
     0
     0
     0
     0
                                                                                                0
                                                                                                0
                                                                                          115,612
                                                                                                0
                                                                                                0
                                                                                                0
                                                                                                0
                                                                                                0
                                                                                                0
                                                                                                0
                                                                                                0
                                                                                                0
                                                                                                0
                                                                                                0
                                                                                                0
                                                                                                0
                                                                                                0
                                                                                                0
                                                                                                0
                                                                                                0
                                                                                                0
                                                                                                0
                                                                                                0
                                                                                                0
                                                                                                0
APRIL 1,1992 THROUGH SEPTEMBER 30,1992
                                                                                                                            51

-------
Assignment
Control Number
N3HVK2-09-0206-2500793
N3HVK2-09-0210-2500811
N3HVK2-09-0214-2500819
N3HVK2-09-0215-2500820
N3HVK2-09-0216-2500822
N3HVK2 - 09- 0229- 2500840
N3HVK2-09-0230-2500842
N3HVK2-09-0231 -2500844
N3HVK2 - 09- 0235 - 2500848
N3HVK2-09-0234-2500850
N3HVJ2-09-0233-2500851
N3HVK2-09-0238-2500872
N3HVK2- 09- 0236- 2500875
N3HVK2-09-0237-2500877
N3HVK2 -09-0239- 2500883
N3HVK2-09-0240-2500884
N3HVK2-09-0242-2500886
N3HVK2- 09- 0249- 2500892
N3HVK2-09-0248-2500893
N3H VK2 - 09- 0256- 250091 0
N3HVK2-09-0258-2500911
N3HVK2-09- 0257- 250091 2
N3HVK2-09-0255-2500914
N3HVK2-09-0298-2500952
N3HVK2 -09-0297- 2500953
N3HVK2-09-0296-2500954
N3HVK2 - 09- 0300 - 2500959
N3HVK2-09- 0302-2500974
N3HVK2-09-0304-2500975
N3HVK2 - 09- 0303 - 2500976
N3HVK2 - 09- 0305 - 2500977
M3HVK2-09-0306-2500979
N3HVK2-09-0307- 2500981
N3HVK2-09-0311-2501004
N3HVK2-09-0312-2501005
M3HUK2-09-0313-2501006
N3HVK2-09-0320-2501015
N3HVK2-09-0321 -2501016
N3HVK2-09-0322-2501019
N3HVK2-09-0281 -2501021
N3HVK2-09-033J-2501028
N3HVK2-09-0336-2501044
N3HVK2-09-0335-2501046
N3HVK2 - 09- 0338- 2501 057
N3HVJ2-09-0352-2501 102
N3HVK2-09-0357-2501114
TOTAL OF
G3HVJ2- 10-0064-2500759
G3HVJ2- 10-0065-2500770
G3HVK2- 10-0061 -2500783
G3HVJ2- 10-0069-2500792
G3HVK2- 10-0071 -2500824
G3HVK2- 10-0088-2500939
G3HVJ2-10-0112-2500978
G3HVK2- 10-0122-2501008
G3HVK2- 10-0108- 2501009
N3HUK2- 10-0051 -2500699
N3HVJ2- 10-0052-2500700
N3HVJ2- 10-0054-2500718
N3HVK2- 10-0059- 2500742
M3HVJ2- 10-0058-2500743
M3HVJ2- 10-0075-2500841
N3HVJ2- 10-0076-2500847
N3HVJ2- 10-0077- 2500878
N3HVK2- 10-0084-2500913
N3HVJ2- 10-0109- 2500950
N3HVJ2- 10-01 11 -2500960
N3HVJ2- 10-0101 -2501045
Title
SANTA -CLARA VALLEY WTR DIST CA
NEVADA, COUNTY OF CA
CHUUK STATE OF FH
PHOENIX, CITY OF AZ
SAC. AREA COUN. OF HOU CA
SANTA CRUZ, CITY OF CA
YAP STATE FM
YAP STATE GOVERNMENT FN
LIVE OAK, CITY OF CA
SAN JOAOUIN VLYWIDE AIR POL CA
CALIFORNIA, STATE OF CA
RURAL CONN. ASSIST. CORP. CA
FEDERATED STATES MICRONESIA FM
KOSRAE, STATE OF FM
ASSN MONTEREY BAY AREA GOVT CA
SAN JOAOUIN, COUNTY OF CA
MAUI, COUNTY OF HI
YUCAIPA VALLEY WTR. OIST. CA
CENTRAL MAR IN SANT AGCY CA
FRESNO, COUNTY OF CA
PIEDMONT, CITY OF CA
CORNING, CITY OF CA
POHNPEI, STATE OF FM
NAVAJO NATION AZ
VALLEJO SANIT 1 FLOOD CTRL CA
NAVAJO NATION AZ
CALAVERAS COUNTY WATER DIST.CA
KERN COUNTY OF CA
MERCED, COUNTY OF CA
QUECHAN INDIAN TRIBE AZ
SANTA MONICA, CITY OF CA
INOIO, CITY OF CA
QUECHAN INDIAN TRIBE AZ
ORANGE, COUNTY OF CA
EASTERN MUNICIPAL WATER DIS CA
CALIF., UNIV. OF SAN DIEGO CA
FLAGSTAFF, CITY OF AZ
FLAGSTAFF, CITY OF AZ
SAN DIEGO ASSN. OF GOVTS. CA
COMMONWEALTH NO MARIANA IS MP
WEOTT COMMUNITY SRVCS. DI CA
PLACER, COUNTY OF CA
GERBER - LAS FLORES COMM.SERCA
MARINA COUNTY WATER DI CA
ARIZONA, STATE OF AZ
FIELDBROOK COMM SERVICES CA
REGION 09 * 71
SAMMAMISH PLAT. WtS DIS WA
BLACK DIAMOND, CITY OF WA
ATHENA, CITY OF OR
MOSES LAKE IRRIG i REHAB 01 WA
NEWBERG, CITY OF OR
VERNONIA, CITY OF OR
ELBE WATER -SEWER DISTRICT WA
SPRINGFIELD, CITY OF OR
HOMER, CITY OF AK
HOONAH PUBLIC SCHOOLS AK
OLYMPIA, CITY OF WA
IDAHO DPT OF HLT I WELFARE ID
CORVALLIS, CITY OF OR
SEATTLE, CITY OF WA
THURSTON COUNTY WA
SPOKANE COUNTY WA
OREGON, STATE OF OR
TULALIP TRIBES OF WASH WA
SPOKANE, CITY OF WA
TACOMA, CITY OF WA
KING COUNTY WA
Final Report
Issued
5/14/92
5/19/92
5/22/92
5/22/92
5/22/92
6/ 4/92
6/ 4/92
6/ 4/92
6/ 5/92
6/ 5/92
6/ 5/92
6/ 9/92
6/ 9/92
6/ 9/92
6/10/92
6/10/92
6/10/92
6/12/92
6/12/92
6/25/92
6/25/92
6/25/92
6/25/92
7/16/92
7/16/92
7/16/92
7/21/92
7/28/92
7/28/92
7/28/92
7/28/92
7/28/92
7/29/92
8/10/92
8/10/92
8/10/92
8/13/92
8/13/92
8/19/92
8/19/92
8/24/92
9/ 3/92
9/ 3/92
9/ 4/92
9/24/92
9/30/92

5/ 4/92
5/ 7/92
5/13/92
5/14/92
5/22/92
7/ 9/92
7/28/92
8/10/92
8/10/92
4/ 3/92
4/ 3/92
4/ 9/92
4/22/92
4/22/92
6/ 4/92
6/ 5/92
6/ 9/92
6/25/92
7/16/92
7/21/92
9/ 3/92
	 ' 	 m*\*v*i i n i «ci lut
Ineligible Unsupported Unnecessary/ Efficiency
Costs Costs Unreasonable (Funds Be Pi
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
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
24
0
0
0
154
0
178
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
115,612
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
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 *   21



               TOTAL  OTHER GRANT REPORTS
52
433         3,708,703     13,682,664         301,340




                                      OFFICE OF THE INSPECTOR GENEFI/

-------
    Assignment
    Control Number
                        Title
                        Final Report
                        Issued
            Questioned Costs
	  Recommended
Ineligible   Unsupported   Unnecessary/      Efficiencies
   Costs
     Costs
Unreasonable   (Funds Be Put
       Costs  To Better Use)
5. SUPERFUNO GRANT ASSIGNMENTS

P5EGN1 -02-0138-2300054  EOB-FOUOWUP REVIEW SUPERFUNPft

              TOTAL OF REGION 02 »   1

55BGL2-06-0156-2100583  WOODWARD CLYDE CONSULTANTS  TX

              TOTAL OF REGION 06 *   1

:5FGQ1-07-0064-2100671  SUPERFUNO COOP AGRMT SURVEY KS

              TOTAL OF REGION 07 *   1

I5FM1-08-0064-2100670  SUPERFUNO COOP AGRMT SURVEY

              TOTAL OF REGION 08 *   1

'5BFL1-09-0149-2100657  ARIZONA DEPT OF ENV QUALITY AZ
5BGH1-09-0133-2300087  SWRCB SAN GABRIEL VAL. MUD  CA

              TOTAL OF REGION 09 *   2

5BGL1-10-0046-2100612  IDAHO DHW S/F COOP AGREEM.  ID

              TOTAL OF REGION 10 «   1

5BFL1-11-0036-2100341  SF-IAG DOI FY 89 RECLAM.
5BFL2-11-0024-2100342  SF IAG FY90 DO! OBS.
5BFL2-11-0024-2100343  SF IAG FY90 DOI OBS.
5BFL2-11-004f-2100344  SF IAG DOJ FY 90
5BFL2-11-0043-2100502  SF IAG ARMY FY 90 REIMBURSE.
5BFL2-11-0024-2100513  SF IAG FY90 001 OBS.

              TOTAL OF REGION 11 (EPA HEADQUARTERS)

              TOTAL SUPERFUNO GRANT REPORTS

 . OTHER  CONTRACT ASSIGNMENTS

8BML2-01-0162-2100352  COMBUSTION ENGINEERING CORP.CT
8DML2-01-0248-2100367  STONE t WEBSTER
8AML2-01-0214-2100382  ASCENSION TECH.
8AML2-01-0163-2100383  EASTERN RESEARCH GROUP
8AML2-01-0184-2100384  CAMBRIDGE SYSTEMATICS INC.
8AML2-01-0168-2100385  ARTHUR D. LITTLE
8CPL2-01-0165-2100386  MITRE CORPORATION
8AML2-01-0215-2100392  ENERGY PHOTOVOLTAICS INC.
8AML2-01-0184-2100394  CAMBRIDGE SYSTEMATICS INC.
8AML2-01-0230-2100406  XENERGY INC.
8AML2-01-0089-2100408  ENVIRONMENTAL HEALTH ENG.
8AML2-01-0184-2100409  CAMBRIDGE SYSTEMATICS INC.
8AML2-01-0249-2100436  EASTERN RESEARCH GROUP INC.
8AAL2-01-0231-2100455  CAMBRIDGE SYSTEMATICS
8AML2-01-0263-2100456  CADMUS GROUP
SAMLi 01-0277-2100461  MAOUIRE GROUP
8AML2-01-0278-2100462  NORMANDEAU ASSOC., INC.
8DML2-01-0062-2100463  ALLIANCE TECHNOLOGIES CORP.
8DML2-01-0063-2100464  ALLIANCE TECHNOLOGIES CORP.
>8AML2-01-0277-2100471  HAQUIRE GROUP
I8AML2-01-0293-2100500  H L TURNER GROUP INC.
i8CML2-01-0065-2100509  SPRINGBORN LAB.
8AML2-01-0292-2100511  CAMROOEN ASSOC.
8AML2-01-0279-2100530  METCALF i EDDY
8AML2-01-0338-2100579  HORSLEY WITTEN HEGEMANN
I8AML2-01-0339-2100625  ARTHUR D. LITTLE, INC.
I8AXN2-01-0182-2300049  SYRACUSE RESEARCH CORP.
'8AML2-01-0175-2100387  ALLIANCE TECHNOLOGIES CORP.
•8AML2-01-0270-2100446  ALLIANCE TECHNOLOGIES CORP.
•8AXL2-01-0302-2100526  HIE,  INC
                       6/2S/92
                       9/ 8/92
                       4/27/92
                       4/27/92
                       9/29/92
                       9/30/92
                       9/15/92
DC
DC
DC

.
DC
3
S
.CT
MA
MA
MA
MA
MA
MA
NJ
MA
MA
MA
MA
MA
MA
MA
CT
NH
MA
MA
CT
NH
CT
NY
MA
MA
MA
NY
MA
MA
MA
4/29/92
4/29/92
4/29/92
4/29/92
7/30/92
8/ 6/92
6
13
5/ 1/92
5/18/92
5/26/92
5/26/92
5/26/92
5/26/92
5/26/92
6/ 3/92
6/ 3/92
6/10/92
6/10/92
6/10/92
6/23/92
7/ 6/92
7/ 6/92
7/ 9/92
11 9/92
7/10/92
7/10/92
7/15/92
7/24/92
8/ 4/92
8/ 4/92
8/21/92
9/ 4/92
9/21/92
4/28/92
5/26/92
7/ 2/92
8/17/92
 66,137


 66,137

      0

      0
1,554,010


1,554,010

3,013,629

3,013,629
                                         66,137
             4,567,639
                                 •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.
              TOTAL OF REGION 01
30
\PR\i 1,1992 THROUGH SEPTEMBER 30,1992
                                                                                            53

-------
                                                                                       Questioned Costs
Assignment
Control Number
Title
Final Report
Issued
Ineligible
Costs
Unsupported
Costs
Unnecessary/
Unreasonable
Costs
Efficiencies
(Funds Be Put
To Better Use)
D80M*7-
D80ML2-
08DML2-
D8AML2-
D8DML2-
08AKL2-
P8AXL2-
P8AML2-
P8AXL2-
P8AXL2-
02-0269-2100403
02-0121-2100404
02-0122-2100405
02-0281-2100499
02-U256-2100508
02-0295-2100529
02-0213-2100415
02-0227-2100444
02-0232-2100445
02-0301-2100492
MALCOLM PIRN IE
MALCOLM PIRNIE INC
MALCOLM PIRNIE INC
SYRACUSE RESEARCH CORP.
HYDROQUAL INC.
SYRACUSE RESEARCH
ECOLOGY I ENVIR
ECOLOGY t ENVIR
ECOLOGY & ENVIRONMENT
ECOLOGY AND ENV.
NY
NY
NY
NY
Nj
NY
NY
NY
NY
NY
              TOTAL OF REGION 02
                             10
6/10/92
6/10/92
6/10/92
7/24/92
8/ 4/92
8/21/92
6/12/92
7/ 2/92
7/ 2/92
7/23/92
D8CAL2-03-0224-2100308
08EML2-03-0302-2100315
D8EML2-03-0303-2100316
D8AAL2-03-0213-2100321
D8AAL2-03-0290-2100353
08AML2-03-0288-2100354
D8BAL2-03-0369-2100365
08BML2-03-0132-2100370
08ASL2-03-0328-2100378
D8AML2-03-0320-2100481
D8AML2-03-0363-2100482
08AML2-03-0356-2100483
D8AAL2-03-0360-2100485
D8AAI2-03-0347-2100487
D8APL2-03-0358-2100491
D8ASL2-03-0332-2100493
D8AML 2 - 03 • 0492 - 2 1 00494
D8APL2-03-0330-2100495
D8AAL2-03-0354-2100497
D8ASL2-03-0333-2100498
OSAML2-03-0406-2100534
D8AML2-03-0540-2100535
080ML2-03-0549-2100536
08AML2-03-0421 -2100537
D8AML2-03-0446-2100538
D8EML2-03-0548-2100539
08AML2-03-0425-2100541
D8AML2- 03 -0355 -21 00542
D8AML2-03-0440-2100543
D8AML2-03-0428-2100544
08AML2-03-0420-2100545
D8AML2-03-0368-2100552
D8ABL2-03-0435-2100553
08AML2-03-0449-2100555
D8APL2-03-0418-2100556
08AML2-03-0539-2100559
D8AML2-03-0209-2100560
D8APL2-03-0380-2100561
D8AML2-03-0404-2100562
08AML2-03-0521 -21005*3
D8A8L2-03-0379-2100S64
D8AML2-03-0424-2100565
08APL2-03-0376-2100566
D8AML2-03-0405-2100568
08ABL2-03-0554-2100569
D8AML2-03-0422-2100570
D8AML2-03-0551 -21005 71
D8AML2-03-0407-2100574
D8CML2-03-0545-2100575
D8AML2-03-0154-2100577
08AML2-03-0186-2100578
D8EML2-03-0550-2100588
D8CPL2-03-0128-21 00589
D8AML2-03-0450-2100590
D8EML2-03-0559-2100592
08AML2-03-0447-2100593
080ML2-03-0560-2100594
080ML2-03-0558-2100595
D8DML2-03-0557-2100596
08EML2-03-0556-2100597
D8EML2-03-0555-2100598
JACA CORPORATION PA
GILBERT ASSOCIATES INC PA
ASCI VA
PATHWAY DIAGNOSTICS VA
E.H. PECHAN t ASSOCIATES VA
PACIFIC ENVIRONMENTAL VA
ICF / SYSTEMS APPLICATIONS CA
ENGINEERING COMPUTER OPTEC MO
S. COHEN 1 ASSOCIATES, INC. VA
ENVIRO-MANAGEMENT & RESEARCHVA
CONS IS CORP MD
MERIDIAN MD
ROY F UESTON PA
JACK FAUCETT MO
WESTAT MO
TRAINING RESOURCES INC VA
ETS INCORPORATED VA
SURVEY RESEARCH ASSOCIATES MD
PACIFIC ENVIRONMENTAL SERVI VA
JACK FAUCETT VA
8IONETICS VA
BIONET-ICS VA
VI CYAN INC VA
ELECTRONIC DATA SYSTEMS
S. COHEN & ASSOC. VA
COMPUTER SCIENCE CORP VA
E.H. PECHAN VA
BRUCE COMPANY DC
VERSAR VA
E.H. PECHAN VA
BOOZ ALLEN HAMILTON
HAMPSHIRE RESEARCH VA
O'BRIEN ENVIRONMENTAL ENERGYPA
R F SIMON DC
SOCIOMETRICS MD
SOC 10- TECHNICAL RESEARCH VA
SOC 10- TECHNICAL RESEARCH VA
DYNAMAC CORP MD
PATHOLOGY ASSOCIATES MD
PRC VA
J T t A INC DC
JACA CORPORATION PA
VERSAR VA
UESTAT, INC MD
JT t A INC. DC
PLANNING ANALYSIS CORP VA
UESTAT, INC. MD
E.H. PECHAN I ASSOC VA
EXXON RESEARCH I ENGINEERINGNJ
BRUCE COMPANY DC
EDS CORPORATION VA
PERRIN QUARLES ASSOCIATION VA
DYNAMAC MD
INFORMATION VENTURES PA
ROY F UESTON PA
VERSAR INC VA
COMPUTER SCIENCE CORP VA
WESTAT INC MD
BOOZ ALLEN HAMILTON MD
HAZTRAIH INC MD
BIONETICS CORPORATION VA
4/ 6/92
4/ 7/92
4/ 7/92
4/14/92
5/ 4/92
5/ 4/92
5/12/92
5/19/92
5/21/92
7/23/92
7/23/92
7/23/92
7/23/92
7/23/92
7/23/92
7/23/92
7/23/92
7/23/92
7/23/92
7/23/92
8/28/92
8/28/92
8/31/92
8/31/92
8/31/92
8/31/92
8/31/92
8/31/92
8/31/92
8/31/92
8/31/92
9/ 3/92
9/ 3/92
9/ 3/92
9/ 3/92
9/ 4/92
9/ 4/92
9/ 4/92
9/ 4/92
9/ 4/92
9/ 4/92
9/ 4/92
9/ 4/92
9/ 4/92
9/ 4/92
9/ 4/92
9/ 4/92
9/ 4/92
9/ 4/92
9/ 4/92
9/ 4/92
9/ 9/92
9/ 9/92
9/ 9/92
9/10/92
9/10/92
9/10/92
9/10/92
9/10/92
9/10/92
9/10/92
 54
                                                                                           OFFICE OF THE INSPECTOR GENERAL

-------
Assignment Title
Control Number
JAML2-03-0468-2100599 ETS INTERNATIONAL INC VA
JEML2-03-0270i2100601 COASTAL ENVIRONMENTAL
JAML2-03-0448-2100602 GECMET TECHNOLOGIES NO
5AML2-03-0399-2100603 EXPERIMENTAL PATHOLOGY LABS
CAL2-03-0433-2100604 ENERGY AND ENVIRONMENTAL VA
5EML2-03-0561 -2100605 COMPUTER SCIENCE CORP VA
JEML2-03-0562-2100606 AMERICAN MANAGEMENT SYSTEMS VA
JML2-03-0565-21006U ARTHUR YOUNG DC
AAL2-03-0453-2100615 JUPITER CORPORATION MO
JML2-03-0564-2100616 PEER CONSULTANTS MD
>ML2-03-0566-2100617 8IONETICJ CORPORATION VA
•ML2-03-0563-2100619 ROY F ICSTON PA
CPL2-03-0432-2100620 MIRANDA ASSOCIATES INC DC
AML2-03-0496-2100621 I -NET INC MO
AML2-03-0517-2100644 UNISYS VA
AML2-03-0522-2100645 GTE GOVERNMENT SYSTEMS CORP VA
BHL2-03-0283-2100M6 BIONETICS VA
AUL2-03-0490-2100647 GANNETT FLEMING VA
APL2-03-0470-2100648 TECHNICAL RESOURCES IHC MO
AML2-03-0465-2100649 OAVID C COX ASSOCIATES DC
CPL2-03-0349-2100650 MIRANDA ASSOCIATES, INC. DC
BML2- 03- 0590-2100655 VA INSTITUTE Qf MARINE SCIENVA
BML2- 03 -0258- 21 00656 VA INSTITUTE OF MARINE SCIENVA
AML2-03-0423-2100659 BRUCE COMPANY DC
AML2-03-0429-2100663 RCG HAQLER BALLY INC VA
EMN2-03-0436-2300073 MARASCO NEWTON GROUP, LTD. VA
AMN2- 03 -0458- 23000 79 CENTER FOR INTERNATIONAL ENVDC
APN2-03-0493-2300084 VERSAR VA
EHP2-03-0309-2400071 COMPUTER SCIENCE CORP VA
BML2-03-01 79-2100667 E. H. PECHAN VA
AXL2-03-0262-2100332 ICF TECHNOLOGY INC VA
ASL2-03-0329-2100390 ICF CORP VA
AML2-03-0357-2100419 ICF CORP VA
AXL2-03-0361 -2100434 ICF CORP- ICF RESOURCES INC VA
AXL2-03-0514-2100640 ICF CORP VA
AAN2-03-0289-2300050 ICF SYSTEMS APPLICATIONS VA
8XN2-03-025C-2300053 1CF-LEWIN AND ASSOCIATES VA
BXN2-03-0443-2300055 ICF CORP/LEWIN-ICF INC VA
AAN2- 03 -0445 -2300059 ICF CORP VA
BXN2-03-0455-2300060 ICF CORP VA
AXN2-03-0198-2300065 ICF CORP/LEUIH VA
AXN2-03-0481 -2300067 ICF CORP/ICF RESOURCES VA
AXN2- 03 -0482 -2300068 ICF CORP/ICF RESOURCES VA
AXN2-03-0484-2300069 ICF CORP VA
AXN2- 03 -0491 -2300071 ICF CORP/CHARTUAY TECH VA
AXN2-03-0512-2300077 ICF CORP INFOTEK VA
AXN2-03-0513-2300080 ICF CORP/ICF RESOURCES VA
TOTAL OF REGION 03 » 108
>ML2-04-0299-2100312 SOUTHERN RESEARCH INSTITUTE AL
AML2-04-0236-2100314 DEECO INC. NC
AML2- 04- 0235-2100323 INDUSTRIAL & ENVIRON. ANAL. NC
AML2-04-0233-2100324 ANALYTICAL TESTING CONSULT. NC
EML 2 -04 -0309- 2 100326 ADVANCED SYSTEMS TECHNOLOGY GA
AML2-04-0234-2100327 EASTERN TECHNICAL ASSOCIATESNC
AML2-04-0232-2100331 ALPHA-GAMMA TECHNOLOGIES INCNC
AML2-04-0286-2100337 ENTROPY ENVIRONMENTALISTS NC
AML2-M-0265-2100338 SOUTHERN RESEARCH INSTITUTE AL
SAML2-OA 0290-2100355 RESEARCH INFO ORGANIZERS INCNC
5AML2-0-^T278-2100360 SOUTHERN RESEARCH INSTITUTE AL
5AML2- 04 -0330- 21 00391 SOUTHERN RESEARCH INSTITUTE AL
JAML2-04-0141 -2100411 GEORGIA TECH RESEARCH CORP. GA
50ML2-04-0182-2100420 CLAUDE TERRY I ASSOCIATES GA
5AML2-04-0343-2100421 INDUSTRIAL & ENVIRONMENTAL NC
30ML2-04-0136-2100422 CLAUDE TERRY 1 ASSOCIATES GA
5DML2-04-0181 -2100423 CLAUDE TERRY t ASSOCIATES GA
JOML2-04-0183-2100424 CLAUDE TERRY t ASSOCIATES GA
5AML2-04-0331 -2100425 OEECO, INC. NC
3AML2-04-0333-2100426 ENTROPY ENVIRONMENTLIST NC
8AML2-04-0363-2100429 INTEGRATED LABORATORY SYSTEMNC
8AML2-04-0334-2100431 TRIANGLE LAB NC
8AML2- 04- 0340- 21 00432 INTEGRATED LABORATORY SYSTEMNC
8AML2-04-0342-2100433 TRIANGLE LABORATORIES OF RTPNC
8AML2-04-0335-2100440 ALPHA-GAMMA TECHNOLOGIES INCNC
Final Report
Issued
9/10/92
9/10/92
9/10/92
9/10/92
9/10/92
9/11/92
9/11/92
9/16/92
9/16/92
9/16/92
9/16/92
9/16/92
9/16/92
9/16/92
9/29/92
9/29/92
9/29/92
9/29/92
9/29/92
9/29/92
9/29/92
9/29/92
9/29/92
9/29/92
9/30/92
9/ 4/92
9/16/92
9/29/92
9/ 9/92
9/30/92
4/17/92
5/27/92
6/16/92
6/18/92
9/25/92
4/30/92
6/15/92
7/ 2/92
7/16/92
7/16/92
8/ 4/92
8/19/92
8/20/92
8/26/92
9/ 1/92
9/11/92
9/18/92

4/ 7/92
4/ 7/92
4/15/92
4/15/92
4/16/92
4/16/92
4/17/92
4/27/92
4/27/92
5/ 5/92
5/ 7/92
5/29/92
6/11/92
6/17/92
6/17/92
6/17/92
6/17/92
6/17/92
6/17/92
6/17/92
6/18/92
6/18/92
6/18/92
6/18/92
6/25/92
	 IIGWIIM IIGI»M**W
Ineligible Unsupported Unnecessary/ Efficiencies
Costs Costs Unreasonable (Funds Be Put
Costs To Better Use)









































































PRIL 1,1992 THROUGH SEPTEMBER 30,1992
55

-------
Assignment
Control Number
D8AAL2-04-0367-2100465
D8AML2-04-0372-2100466
D8AML2-04-0242-2100467
D8DML2-04-0403-2100468
D8DML2-04-0402-2100469
D8AML2- 04 -0371 -21 00473
D8AML2-04-0362-2100474
08AML2-04-0385-2100506
D8BML2-04-01 14-2100507
086ML2-04-0410-2100514
D8BML2-04-0409-2100515
D8EML2-04-0413-2100519
D8AW.2-04-0366-2100520
08BML2-04-0414-2100521
D8AML2-04-0404-2100S48
D8AHL2-04-0405-2100S81
08DML2 - 04 - 0 1 33 - 2 1 00639
D8EM02-04-01 10-2300094
08EM02 • 04 - 0266- 2300096
08EMQ2-04-0112-2300097
D8EH02-04-0109- 2300098
08EM02-04-01 13-2300099
TOTAL OF
D8CML2-05-0096-2100325
D8BML2-05-0153-2100346
D8AML2-05-01 70-2100357
D8AML2-05-0272-2100396
D8AML2-05-0276-2100410
08CML2- 05-0095-21 004 78
D8AML2 • 05 - 0046- 2 1 005 1 7
D8AML2-05-0044-2100518
08AML2 - 05 - 0387- 2 1 00546
08AML2-05-0392-2100610
08AML2-05-0394-2100611
08AHL2-05-0393-2100635
08ESN1 -05-0190-2300047
E8AXP2 - 05 - 0266- 2400044
E8AXP2-05-0285-2400045
E8AXP2-05-0264-2400047
E8ASP2-05-0314-24000S1
P80MLO-05-0421 -2100376
P80ML1 -05-0189-2100528
P8AMP2 - 05 - 0229- 240004 1
P8CSP1 -05-0408-2400043
P8BMPO - 05 - 0422 - 2400046
P8AXP2-05-0280- 2400049
P8AHP2 - 05 - 030 1 - 2400052
P8CXP2 - 05 - 0262- 2400054
P8CXP1 -05^0349-2400057
P8AXP2-05 - 0297- 2400069
P88MP 1 - 05 - 0335 - 2400073
TOTAL OF
D8BML2-06-0106-2100313
08BML2-06-0135-2100317
D8AML2-06-0129-2100373
D8AML2-06-0172-2100414
D8AML2-06-0166-2100427
08AML2-06-0153-2100428
D8BML2-06-0186-2100470
D88ML2-06-0185-2100475
08BML2-06-0089-2100476
08AML2-06-0162-2100479
D80ML2-06-0198-2100531
D80ML2-06-0201 -2100582
08AML2-06-0196-2100626
08CMN2-06-0202-2300075
D8EM02- 06- 01 24 -2300095
D8BMP2-06-0132-2400037
D8EMP2-06-0141 -2400038
Title
EOUAM) AUL I ASSOCIATES NC
ENTROPY ENVIRONMENTALIST NC
EC/R INC. NC
HANTECH ENVIRONMENTAL TECH NC
NANTECH ENVIRONMENTAL TECH NC
KILKELLY ENVIRONMENTAL ASSOCMC
ANALYTICAL TESTING CONSULT NC
ENVIR RESEARCH t TECH FL
LEE UAN I ASSOCIATES GA
INTEGRATED LABORATORY SYS NC
INTEGRATED LABORATORY SYS NC
AIR QUALITY SCIENCES, INC. GA
AIR QUALITY SCIENCES INC. GA
TECHNOS INC. FL
BRUCE KARDON I ASSOC NC
BARRY VITTOR ASSOCIATES AL
GEORGIA INSTITUTE OF TECH GA
RESEARCH I EVALUATION ASSOC NC
ZEDEK CORPORATION NC
ENTROPY ENVIRONMENTALISTS NC
MANTECH ENVIRONMENTAL TECH NC
HANTECH ENVIRONMENTAL TECH NC
REGION 04 > 47
LIFE SYSTEMS INC OH
LIFE SYSTEMS INC OH
DORGAN ASSOC WI
BATTELLE OH
BATTELLE OH
BATTELLE OH
ESE (PEORIA) IL
ILLINOIS DENR ILUS IL
BATTELLE OH
CLEVELAND TELECOM OH
CHARLES COLEMAN CORP OH
DAWK INS OH
AT KEARNEY IL
PRC EMI (NAVY CLEAN3) IL
PRC EMI (DO I DENVER) IL
PRC EMI (DOE SAVANNAH R2) IL
PRC EMI (RCRA SUPPORT) IL
PEI ASSOC FY 90 OH
PEI ASSOC FY 85 OH
EQM (AIR) OH
PEI ASSOC (68-01-6515) OH
PEI ASSOC FY 90 OH
OONOHUE UI
EQM (AIR) OH
PEI ASSOC DLA ASSIST OH
OHM REM (KELLY AFB) OH
OHM REM (FUS) OH
PEI ASSOC (FY 85) OH
REGION 05 > 28
TILLMAN t ASSOCIATES INC. OK
LOCKHEED TX
RADIAN CORP TX
RADIAN CORP. TX
RADIAN CORP. TX
SOUTHWEST RESEARCH INSTITUTETX
SOUTHWESTERN PUBLIC SERVICE TX
SOUTHWESTERN PUBLIC SERVICE TX
SOUTHWESTERN PUBLIC SERVICE TX
RADIAN CORP TX
LOCKHEED TX
LOCKHEED TX
EGlfi TX
RADIAN CORPORATION TX
H t GCL INCORPORATED NM
FTN ASSOCIATES LTD. AR
LOCKHEED TX
Final Report
Issued
7/10/92
7/10/92
7/10/92
7/14/92
7/14/92
7/15/92
7/15/92
7/31/92
8/ 3/92
8/ 6/92
8/ 6/92
S/ 11/92
8/11/92
8/11/92
9/ 2/92
9/ 4/92
9/28/92
4/ 1/92
4/ 1/92
6/ 4/92
9/ 4/92
9/ 9/92

4/15/92
4/29/92
5/ 5/92
6/ 5/92
6/10/92
7/20/92
8/ 7/92
8/10/92
8/31/92
9/14/92
9/14/92
9/24/92
4/15/92
5/26/92
5/28/92
6/ 4/92
6/29/92
5/20/92
8/20/92
4/29/92
5/ 5/92
6/ 2/92
6/24/92
7/ 2/92
7/ 8/92
7/20/92
9/ 4/92
9/ 9/92

4/ 7/92
4/ 7/92
5/19/92
6/12/92
6/18/92
6/18/92
7/14/92
7/15/92
7/15/92
7/21/92
8/25/92
9/ 4/92
9/21/92
9/ 8/92
4/ 1/92
4/ 7/92
4/15/92
Ineligible Unsupported Unnecessary/ Efficiencies
Costs Costs Unreasonable (Funds Be Put
Costs To Better Use)





































































              TOTAL OF REGION 06 *  17
56
                                                                                               OFFICE OF THE INSPECTOR GENERAL

-------
                                                                                        Questioned Costs
   Assignment
   Control Number
                         Title
                                    Final Report
                                    Issued
                                  Ineligible
                                     Costs
                                   Unsupported
                                         Costs
                                           Unnecessary/
                                           Unreasonable
                                                  Costs
Recommended
   Efficiencies
 (Funds Be Put
To Better Use)
08AAL2-07-0182-2100363
D8AAL2-07-0191-2100397
D8AAL2-07-0192-2100438
LANTERN CORP
MIDWEST RESEARCH
AMEGA INC
INC
              TOTAL OF REGION 07 »    3

D8ABL2-08-0057-2100318  NO AMERICAN WEATHER  CONS
MO
MO
MO
                            UT
              TOTAL OF REGION 08
             1
              TOTAL OF  REGION  10  *   12

              TOTAL OTHER CONTRACT  REPORTS      *  298
5/11/92
6/ 8/92
6/25/92
                                   4/14/92
08BML2-09-0102-2100306 JONES I STOKES OHtOC 1989 CA
08BML2-09-0100-2100307 JONES 1 STOKES OHtOC 1987 CA
D8BML2-09-0101 -2100320 JONES t STOKES OHtOC 1988 CA
08AAL2-09-0156-2100322 ACUREX P. A. CA
08AAL2-09-0141 -2100329 ECOSERVE, INC P. A. CA
D8BML2-09-0169-2100334 TETRA TECH 85 1 86 OH t DC CA
D8AML2-09-0176-2100345 IT CORP REVISED P. A. RATES CA
D80ML2-09-01 15-2100348 ACUREX CORPORATION 89 OH CA
D8DML2-09-01 14-2100349 ACUREX CORPORATION 88 -OH CA
D8AAL2-09-0155-2100358 EERC P. A. CA
D8AAL2-09-0160-2100359 SAIC P. A. CA
D8BML2-09-0197-2100364 KVB RESEARCH INC DCiOH 86 CA
D8DML2-09-0211-2100369 ENRGY.i ENVL RES CORP FY 86 CA
D8CML2-09-0139-2100380 ACUREX FINAL CA
D8AAL2-09-0180-2100381 ACUREX CORP. P. A. CA
D8AAL2-09-0181 -2100395 S-CUBED P. A. CA
J8AAL2-09-0186-2100413 CAR NOT P. A. CA
J8AAL2- 09-0178-2100417 ENERGY t ENVL RESEARCH P. A. CA
58AML2-09-0207-2100435 MAXWELL LABS-S CUBED CA
)8AML2-09-0179-2100437 SAIC P. A. CA
)80ML2-09-0264-2100451 S-CUBED OH I, DC FY'86 CA
58DML2-09-0265-2100452 ACURX OH t DC FY'86 CA
38AML2-09-0175-2100457 MAXWELL LABORATORIES INC PA CA
D3DML2-09-0267-2100458 ACUREX WING G SEG OH t DC 34CA
D8DML2-09-0268-2100459 ACUREX OH & DC '85 CA
38AML2-09-0250-2100510 JONES t STOKES P. A. CA
58AAL2- 09-0187-2100523 COAST TO COAST ANALYTCL. SV CA
58CML2-09-0319-2100524 GEO RESOURCE CONSULTANTS FN CA
38AWL2-09-0270-2100525 GEO/RES RFP CA
380ML2- 09-0334-2100549 SAIC CO 1 OH t DC FY'86 CA
D8AML2-09-0317-2100554 GENERAL ATOMICS CORP P. A. CA
J8BML2-09-0337-2100580 OGDEN ENVTL. t ENRGY SVCS CA
)8AML2-09-0316-2100627 ALL STAR MAINTENACE CA
380ML2-09-0349-2100630 SAIC OH t DC FY'83 CA
D80HL2-09-0350-2100631 SAIC OHtOC FY '84 CA
D8ARN2-09-0251-2300061 SAIC P. A. CA
D8AMN2-09-0198-2300066 APPL INC P. A. CA
D8AAP2-09-0174-2400039 ECOSERVE, INC CA
D8AHP2-09-0226-2400053 SAIC P. A. CA
D8AMP2- 09 -0222 -2400055 SAIC P. A. CA
08FHP2-09-0327-2400067 ROCKWELL INTL ROCKETDYNE CA
D8AMP2-09-0228-2400081 SAIC PA CA
TOTAL OF REGION 09 » 42
D8AWL2- 10-01 10-2100533 BATTELLE-NORTHWEST P. A. WA
D8AMN2- 10-0043-2300048 OMNI ENVIRONMENTAL SVCS P. A. OR
D8AAN2- 10-0083-2300064 OMNI ENVIRONMENTAL P. A. OR
P8EML1- 10-0080-2100330 CH2M CAS OIS COMPLIANCE OR
P8AXL2- 10-0055-2100447 CH2M P. A. OR
P8AXL2- 10-0070-2100477 CH2M HILL OR
P8AXL2- 10-0060-2100480 CH2M P. A. OR
P8AXL2- 10-0056-2100512 CH2M P. A. OR
P8AXL2- 10-0078-2100516 CH2M RFP OR
P8AXL2- 10-0121 -2100547 CH2M PA RFP DACA05-92-R-00660R
P8AXL2- 10-0087-2100584 CH2M P. A. OR
P8AXL2- 10-01 13-2100585 CH2M P. A. OR
4/ 6/92
4/ 6/92
4/14/92
4/14/92
4/16/92
4/21/92
4/29/92
4/30/92
4/30/92
5/ 5/92
5/ 6/92
5/12/92
5/19/92
5/21/92
5/21/92
6/ 4/92
6/11/92
6/15/92
6/18/92
6/24/92
7/ 6/92
7/ 6/92
7/ 7/92
7/ 9/92
7/ 9/92
6/ 4/92
8/11/92
8/12/92
8/14/92
9/ 3/92
9/ 3/92
9/ 4/92
9/21/92
9/22/92
9/22/92
7/22/92
8/ 6/92
4/24/92
7/ 8/92
7/ 9/92
9/ 1/92
9/29/92

8/28/92
4/16/92
8/ 4/92
4/16/92
7/ 2/92
7/17/92
7/22/92
8/ 4/92
8/ 6/92
9/ 1/92
V/ 8/92
9/ 8/92
                                                                             1,297,886
                                                                     421,388
                                                                                42,144,706
APRIL 1,1992 THROUGH SEPTEMBER 30,1992
                                                                                                         57

-------
                                                                                        Questioned Costs
    Assignment
    Control Number
                        Title
                                                  Final Report
                                                  Issued
                                                                     Ineligible
                                                                        Costs
Unsupported
      Costs
Unnecessary/
Unreasonable
       Costs
Recommended
   Efficiencies
 (Funds Be Put
To Better Use)
9. SUPERFUND CONTRACT ASSIGNMENTS
D9AKL2-01-0228-2100407
D9CGL2-01-0143-2100416
09CGL2-01-0290-2100418
D9CFL2-01-0296-2100460
               INDUSTRIAL ECONOMICS INC.
               ALLIANCE TECHNOLOGIES CORP
               ALLIANCE TECHNOLOGIES CORP.  MA
               ARTHUR 0 LITTLE,  IMC.
              TOTAL OF REGION 01
D90FL2-02-0091-2100350
09DFL2-02-0090-2100351
D90FL2-02-0110-2100393
090FL2-02-0091-2100412
D9AFL2-02-0251-2100454
E9BHL1-02-0114-2100586
               EBASCO
               EBASCO
               EBASCO
               EBASCO
               FU ENVIRESPONSE
               ERCS - SCO ENVIRONMENTAL
09EFL2
D9EFL2
D9AFL2
D9EFL2
09AFL2
09AFL2
09AGL2
09AFL2
D9AGL2
D9AFL2
09AFL2
D9AFL2
D9AFL2
D9EFL2
D90FL2
09AFL2
D9AFL2
D9AFL2
09BFL2
D9BFL2
D9BFL2
D9EFL2
D90FL2
D9EFL2
D98FL2
09CFL2
D9EFL2
09AKN2
D9EFP2
P9BXF2
P90GL2
P9DGN2'
P9AKN2
                                      INC.
        TOTAL OF  REGION 02 «   6

•03-0299-2100309   COMPUTER SCIENCE  CORP
•03-0300-2100310   COMPUTER SCIENCE  CORP
•03-0307-2100371   S.  COHEN t ASSOCIATES,
•03-0387-2100372   ROY F UESTON
•03-0345-2100484   VIAR
•03-0346-2100486   APEX ENVIRONMENTAL
•03-0304-2100488   NUS CORP - HALLIBURTON
•03-0341-2100489   BOOZ ALIEN HAMILTON
•03-0305-2100490   NUS CORP - HALLIBURTON
•03-0343-2100496   ENVIROMENTAL QUALITY SPECIALVA
•03-0394-2100550   WESTINGHOUSE ELECTRIC CORP
•03-0390-2100551   NUS CORP - HALLIBURTON
•03-0240-2100557   UNISYS
•03-0552-2100558   ROY F UESTON  •
03-0553-2100567   VERSAR
03-0393-2100572   EXECUTIVE RESOURCE  ASSOCIATEVA
03-0344-2100573   HORSLEY  WITTEN HEGEMAN
03-0392-2100576   ROY F WESTON
03-0459-2100600   LAURENCE JOHNSON  I  ASSOCIATE*)
•03-0400-2100618   COMPUTER SCIENCE  CORP
03-0367-2100622   COMPUTER SCIENCE  CORP
•03-0101-2100623   ROY F UESTON
•03-0592-2100643   BOOZ ALLEN HAMILTON
03-0595-2100651   OYNAMAC
03-0594-2100652   COMPUTER SCIENCE  CORP
03-0593-2100653   VERSAR
03-0591-2100654   COMPUTER SCIENCE  CORP
03-0488-2300083   BRUCE COMPANY
03-0308-2400072   COMPUTER SCIENCE  CORP
03-0264-2100388   ICF INC
03-0193-2100527   ICF INC/KAISER
03-0241-2300057   ICF
03-0547-2300092   ICF CORP

        TOTAL OF  REGION 03 *  33
090KL2-04-0377-2100430
D9BGL2-04-0368-2100587
09BKL2-04-0270-2100636
09BKL2-04-0269-2100637
D9BKL2-04-0268-2100638
               CONTINENTAL SHELF ASSOCIATESFL
               VESTA TECHNOLOGY LTD
               WILLIAM RUSSELL I JOHNSON
               WILLIAMS RUSSELL & JOHNSON
               WILLIAMS RUSSELL I JOHNSON
              TOTAL OF REGION 04 *
09AKL2-05
D9BGL2-05
E9AKP2-05
E9AXP2-05
P90GL1-05
P9DGL1-05
P9BGP1-05
P9AHP2-05
P9AHP2-05
P9BHP1-05
•0296-2100453
•0342-2100609
•0303-2400050
•0354-2400061
•0157-2100340
•0277-2100532
•0158-2400040
•0306-2400058
•0350-2400063
•0283-2400075
                  PSARA TECHNOLOGIES
                  WARZYN ENG
                  PRC EMI  (TRAINING)
                  PRC EMI  (DOE  PRE-018.10)
                  WU ENG FY 90
                  OOHOHUE  ARCS  RS FY 90
                  WW ENG FY 90
                  OHM REM  ERCS3 R2
                  MAECORP  ERCS3 RS
                  OHM REM  ERCS2 Z1 FY 90
MA
MA
MA
MA
NY
NY
NY
NY
NJ
'NJ
VA
VA
VA
PA
VA
MD
PA
MD
PA
LVA
PA

VA
PA
VA
EVA
NO
PA
END
VA
VA
PA
MD
MD
VA
VA
VA
DC
VA
VA
VA
VA
VA
SFL
FL
GA
GA
GA
OH
WI
IL
IL
MI
UI
MI
OH
IL
OH
6/10/92
6/12/92
6/15/92
11 9/92
5/ 1/92
5/ 1/92
6/ 3/92
6/11/92
7/ 6/92
9/ 9/92
4/ 6/92
4/ 6/92
5/19/92
5/19/92
7/23/92
7/23/92
7/23/92
7/23/92
7/23/92
7/23/92
9/ 3/92
9/ 3/92
9/ 4/92
9/ 4/92
9/ 4/92
9/ 4/92
9/ 4/92
9/ 4/92
9/10/92
9/16/92
9/17/92
9/17/92
9/29/92
9/29/92
9/29/92
9/29/92
9/29/92
9/29/92
9/ 9/92
5/27/92
8/19/92
7/10/92
9/30/92
6/18/92
9/ 9/92
9/25/92
9/25/92
9/25/92
71 6/92
9/14/92
6/26/92
8/ 6/92
4/28/92
8/27/92
4/28/92
7/23/92
8/11/92
9/16/92
58
                                                                                                   OFFICE OF THE INSPECTOR GENEFIAL

-------
                                                                                        Questioned Costs
   Assignment
   Control Number
Title
Final Report
Issued
Ineligible
   Costs
Unsupported
      Costs
              TOTAL OF REGION 05 *  13

09BGL2-06-0121-2100374  FLOUR DANIELS INC.

              TOTAL OF REGION 06 *   1
                            TX
              TOTAL OF REGION 10 >   6

[9HHF2-11-0031-2100662  RESPONSE CLAIMS

              TOTAL OF REGION 11 (EPA HEADQUARTERS)  -

              TOTAL SUPERFUND CONTRACT REPORTS  =   84

              TOTAL ASSIGNMENTS *   918

'01  -  REPORTS ISSUED BY ASSIGNMENT TYPE AND EPA REGION
            SEMI-ANNUAL PERIOD ENDING  9/30/92
5/19/92
D9BGL2-07-0133-2100398
D9AKL2-07-0189-2100439
TOTAL OF
)9BGL2-09-0152-2100339
59BFL2-09-0170-2100347
)9BGL2-09-0153-2100361
59BFL2-09-0192-2100362
)9BFL2-09-0208-2100366
)9DGL2-09-0209-2100368
390GL2-09-0212-2100375
590GL2-09-0213-2100377
590GL2-09-0220-21003S9
>9DGL2-09-0259-2100441
J9DGL2-09-0260-2100442
I9DGL2-09-0075-2100472
I9DGL2-09-0348-2100629
TOTAL OF
>90H*8- 10-0080-2100503
•9DHL9-10-0174-2100504
'90HLO- 10-0085-2100505
>9AGL2- 10-0079-2100607
>9DHL9-10-0148-2100642
•9FHP1- 10-0076-2400078
SVERDRUP MO
MIDWEST RESEARCH INSTITUTE MO
REGION 07 « 2
BECHTEL- VOUCHER AUDIT CA
WOODS IDE SUMMIT OHtOC 85-87 CA
URS CONSULTANTS-VOUCHER AUD CA
WOOOSIDE SUMMIT OHiDC 88-89 CA
S- CUBED FY'87 CA
INTERN'L. TECH (IT) 88 OH CA
ENERGY ENVL RES. FY 87 CA
ENERGY ENVL RESEARCH FY 88 CA
AQUA TERRA OH 1 DC FY' 86-88 CA
ENERGY ENVL RESEARCH FY89 CA
AEROCOMP OH 1 DC FY 86-89 CA
JAMES MONTGOMERY 88-90 OH CA
SAIC OH i DC FY'87 CA
REGION 09 > 13
CH2M 87 OH OR
CH2M 88 OH OR
CH2M 89 OH OR
RES PRE- AWARD OR
RES 88 OH OR
RES-ADVANCE AGREEMENT OR
6/ 8/92
6/25/92

4/28/92
4/30/92
5/ 7/92
5/ 7/92
5/18/92
5/18/92
5/19/92
5/20/92
5/27/92
6/26/92
6/26/92
7/15/92
9/22/92

7/30/92
7/30/92
7/30/92
9/11/92
9/28/92
9/28/92
                                   9/30/92
Unnecessary/
Unreasonable
       Costs
Recommended
   Efficiencies
 (Funds Be Put
To Better Use)
P9BHP1 -05-0284-2400080
P9DGP2-OS-0465-2400082
P9BGP2-OS-0127-2400083
OHM REM ERCS2 ZN 2
UU ENG ARCS1 FY 91
WW ENG FY 91
FY 90


OH
MI
MI
9/29/92
9/30/92
9/30/92
                                                    845,495

                                                 55,337,100
                              1,113,325

                             53,478,967
                             64,590,452
                                   1,100,000

                                 55,396,462

                                 121,652,429
 APRIL 1,1992 THROUGH SEPTEMBER 30,1992
                                                                                                         59

-------
     Appendix  2-Reports Without Management  Decision
  THE INSPECTOR GENERAL ACT REQUIRES A SUMMARY OF EACH REPORT ISSUED BEFORE THE COMMENCEMENT OF THE REPORTING
  PERIOD FOR WHICH NO MANAGEMENT DECISION HAS BEEN MADE BY THE END OF THE REPORTING PERIOD (INCLUDING THE DATE AND
  TITLE OF EACH SUCH REPORT), AN EXPLANATION OF THE REASON SUCH MANAGEMENT DECISION HAS NOT BEEN MADE, AND A 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 9/30/92:

           1. No Response
           2. Incomplete Response Received
           3 Proposed Response Received Awaiting Final Determination
           4. Proposed Response Received in Review Process
           5. Final Response Received in Review Process
           6. Resolution Under Negotiation in Headquarters
Assignment Control
Number
Title
                                Final Report
                                    Issued
Assignment Control
Number
                                                                  Title
Final Report
     Issued
 ASSISTANT ADMINISTRATOR FOR PREVENTION.  PESTICIDES AMD TOKIC
SUBSTANCES

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

 - EXPLANATION OF THE REASONS MANAGEMENT  DECISION HAS MOT BEEN
MADE:  THE OFFICE OF PREVENTION. PESTICIDES AND TOXIC SUBSTANCES
(OPPTS) RESPONDED TO OIG'S RECOMMENDATIONS ON MARCH 26, 1992.
DIG REQUESTED FURTHER INFORMATION, WHICH  OPPTS PROVIDED IN JULY
1992.  OIG AGAIN ASKED FOR ADDITIONAL DOCUMENTATION.

 = DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION:  THIS
AUDIT IS EXPECTED TO BE RESOLVED BY NOVEMBER 30, 1992.

 IG FOLLCUJP STATUS AS OF  9/30/92:  [23

 ASSISTANT ADMINISTRATOR FOB SOUP WASTE  AND EMERGENCY RESPONSE

 E6ESP1-08-0037-2400029  RCRIS CONFERENCE                3/30/92
  Suaaary:  THE OFFICE OF SOLID WASTE IMPROPERLY REIMBURSED
UESTON FOR FOOD AND BEVERAGES, INCLUDING  ALCOHOLIC BEVERAGES,
SERVED AT THE RGBIS PILOT CONFERENCE.  EPA PAID AN ESTIMATED
$2,390 FOR UNALLOWABLE CHARGES TO THE UESTON CONTRACT.

 - EXPLANATION OF THE REASONS MANAGEMENT  DECISION HAS NOT BEEN
MADE:  PER OFFICE OF SOLID WASTE AND EMERGENCY RESPONSES AFC
CONVERSATION WITH THE OIG, THIS AUDIT SHOULD BE CLOSED.  OIG
AGREED WITH AFC THAT FINAL DETERMINATION  LETTER (FDD WAS ISSUED
ON JULY 2, 1992.

 » DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION:  A
FINAL DETERMINATION LETTER WAS ISSUED'ON  JULY 2, 1992.

 16 FOLLOUUP STATUS AS OF  9/30/92:  IS]  (FDL was received after
September 30.  Report is to be closed out in October 1992.)

 ASSISTANT ADMINISTRATOR FOR WATER

E1HUEO-04-0291-1100434   WETLANDS CONSOL. AUDIT           9/30/91
  Suaaary:  WETLANDS MAY BE UNNECESSARILY LOST TO DREDGE AND FILL
DISCHARGES BECAUSE OF EPA'S INCONSISTENT  PROGRAM IMPLEMENTATION
IN THE AREAS OF ENFORCEMENT, PERMITTING,  AND STRATEGIC
INITIATIVES.

 - EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN
MADE: OIG AND OW MET ON OCTOBER U, 1992 TO DISCUSS OUTSTANDING
ISSfFS.  RESOLUTION HAS BEEN REACHED ON ALL BUT ONE ISSUE WHICH
IS BEING EXAMINED BY ATTORNEYS.

 - DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION: UNLESS
OUTSTANDING ISSUE CANNOT BE RESOLVED, RESOLUTION IS EXPECTED BY
NOVEMBER 30, 1992.

 16 FOLLOUUP STATUS AS OF  9/30/92:  [6]
                                               ASSISTANT ADMINISTRATOR  FOR ADMINISTRATION AND RESOURCES
                                               MANAGEMENT

                                                E1NME1-04-0169-2100295  EPA MGT OF CSC CONTRACT          3/27/92
                                                 Suaaary:  A GENERAL  LAISSEZ-FAIRE CULTURE THAT AFFECTED EPA'S
                                               MANAGEMENT  OF ITS SUPPORT SERVICES CONTRACT WITH COMPUTER
                                               SCIENCES CORPORATION LESSENED EPA CONTROL  OVER CRITICAL PROGRAM
                                               ACTIVITIES AND PERMITTED NUMEROUS PROHIBITED AND IMPROPER ACTIONS
                                               BY BOTH AGENCY AND CONTRACTOR STAFFS.

                                                - EXPLANATION OF THE  REASONS MANAGEMENT DECISION HAS NOT BEEN
                                               MADE:  THE OIG DID NOT ACCEPT DARN'S RESPONSE OF JUNE 30, 1992.
                                               A MEETING BETWEEN OARM AND THE OIG ON SEPTEMBER 18, 1992,
                                               RESOLVED ALL OUTSTANDING ISSUES.  THE OIG  WILL REVIEW ADDITIONAL
                                               DOCUMENTATION PROVIDED BY OARM AND ISSUE ITS RESPONSE.
                                               CORRECTIVE ACTIONS BY  OARM ARE UNDERWAY.

                                                » DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION:
                                               RESOLUTION IS ANTICIPATED BY OCTOBER 30, 1992.

                                                16 FOLLOWUP STATUS AS OF  9/30/92:  O3

                                                E6EMPO-15-0039-1400060  MGT OF  INT PC UKSTATION CONT.    9/30/91
                                                 SUBBary:  EPA COULD  PAY UP TO S8.4 MILLION OVER DECREASING
                                               MARKET PRICES FOR MICROCOMPUTER WORKSTATIONS AND OTHER ADP
                                               EQUIPMENT BY NOT MODIFYING ANINTERIM CONTRACT AND DELAYING A
                                               COMPETITIVE AWARD. EPA COULD ALSO PAY THE CONTRACTOR $2.3 MILLION
                                               MORE THAN ACTUALLY INCURRED FOR OPERATING EXPENSES.

                                                - EXPLANATION OF THE  REASONS MANAGEMENT DECISION HAS NOT BEEN
                                               MADE:  OARM'S INITIAL  RESPONSE DATED JUNE  15, 1992, TO THE 016
                                               WAS NOT ACCEPTED.  A REVISED RESPONSE WAS  HELD BY OARM PENDING A
                                               COURT DECISION ON THE  SUSPENSION OF THE CONTRACT.  THE REVISED
                                               RESPONSE IS EXPECTED TO  BE SIGNED BY OCTOBER 30, 1992.

                                                - DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION:
                                               RESOLUTION ANTICIPATED BY NOVEMBER 30, 1992.

                                                IG FOLLOWUP STATUS AS OF 9/30/92:   [4]
                                                FINANCIAL MAMAG
                                                                    DIVISION
                                                N5BFL1-11-0035-2100290  SF  IA6 FT 87-89 DOI/MINES
                                                  -  EXPLANATION OF THE REASONS MANAGEMENT DECISION  HAS NOT BEEN
                                                MADE:
                                                  = DESIRED TIMETABLE FOR AOHIMM A
                                                                                               DECISION:
                                                 16 FOLLOUUP STATUS AS OF  9/3t/«Kl  111 (An explanation was not
                                                provided by EPA relating to the raaaona a aanagaaant decision had
                                                not been aada at 9/30/92. Discussions art bains held with
                                                Financial Management Division to resolve this report by 3/31/93.)
 60
                                                                               OFFICE OF THE INSPECTOR GENERAL

-------
 Assignment Control
 Number
Title
                                 Final Report
                                      Issued
 SMUTS ADMINISTRATION DIVISION

 E5M3M-04-0290-23000*5  NORTH CMflLIMA STATE UNIV.  HC    3/26/92
  -[•mill   NORTH CAROLINA STATE UNIVERSITY CLAIMED S 1.17
MILLION OF INELIGIBLE COSTS AND $898,206 OF UNSUPPORTED COSTS
UNDER A SUPERFUND GRANT THAT IMS NOT USED FOR THE INTENDED
PURPOSES.
 - EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT
HADE: SEVERAL COMPLEX ISSUES REQUIRED ADDITIONAL COMMUNICATION
BETWEEN THE OIG AND GAD.  GAD IS WORKING CLOSELY WITH THE OIG AND
PROGRAM OFFICES TO RESOLVE OUTSTANDING ISSUES.

 » DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION:
RESOLUTION EXPECTED NOVEMBER 30, 1992.
 16 FOLLOUUP STATUS AS OF  9/30/92:   [1]
N3HVJ1-04-0432-2500251
 •SuMM-y:
   TENNESSEE STATE TN
                                                          12/18/91
 - EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN
MADE:  MANAGEMENT ACTION WAS DELAYED BECAUSE THE FINAL AUDIT
REPORT WAS TRANSMITTED TO REGION 4 INSTEAD OF THE GRANTS
ADMINISTRATION DIVISION.  AS A RESULT, GAD WAS NOT ABLE TO BEGIN
WORK ON THIS AUDIT UNTIL AUGUST 1992.

 • DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION:
RESOLUTION EXPECTED DECEMBER 31, 1992.

 IG FOLLOUUP STATUS AS OF  9/30/92:  [11
                                                                      Assignment Control
                                                                      Number
                                                                     Title
                                                      Final Report
                                                           Issued
 P2CUP8-05-0026-1400038  GARY SD                     IN   9/9/91
  SlMMry:   ALMOST S25 MILLION WASTED WHEN THE GRANTEE FAILED TO
OPERATE AND MAINTAIN A WASTEWATER TREATMENT PLANT.

 - EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN
MADE:  THE EHTIRE GRANT OF S33 MILLION WAS QUESTIONED DUE TO
ALLEGED IMPROPER PLANT OPERATION AND VIOLATION OF NPDES.
VOLUMINOUS DOCUMENTATION SENT TWO WEEKS BEFORE THE FINAL
DETERMINATION LETTER DUE  DATE.  A CONSENT DECREE GIVES GARY UNTIL
1994 TO COMPLY.

 - DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION: A
CONSENT DECREE GIVES GARY UNTIL 1994 TO COMPLY.

 16 FOLLOUUP STATUS AS OF  9/30/92:  131

P2CUP6-OS-0298-2400004 U LAKE SUPERIOR (DULUTH)MN        12/12/91
  '[•111   THE WESTERN LAKE SUPERIOR SANITARY DISTRICT CLAIMED
$8,595,588 OF INELIGIBLE CONSTRUCTION, ENGINEERING AND
ADMINISTRATIVE COSTS AND $166,834 OF UNSUPPORTED COSTS.

 - EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN
HADE:  THE REPORT QUESTIONED OVER S8 MILLION RELATED TO THE SOLID
WASTE PROCESSING PORTION OF THE PLANT.  CONSTRUCTION COSTS OF
$7,563,075 PLUS RELATED A/E EXPENSES ARE AT ISSUE.  THE
HEADQUARTERS OIG HAS INITIATED DISCUSSIONS WITH THE OFFICE OF
WATER TO CLARIFY THE ISSUES.

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

 16 FOLLOUUP STATUS AS OF  9/30/92:  [6]
 Cincinnati Cost Advisory Branch

 D8CML1-04-0442-1100311  MANTECN ENVIRONMENTAL.!*:          7/10/91
 - EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS HOT BEEN
MADE:  CONTRACTOR'S EXPLANATION FOR OVERRUN CLAIM IS DUE OCTOBER
20, 1992.  FINAL CONTRACTING OFFICER DETERMINATION ON
ALLOWABILITY OF CLAIM TO BE ISSUED NOVEMBER 20, 1992.

  - DESIRED TIMETABLE FOR AOUCVMBi A MANAGEMENT DECISION: FINAL
DETERMINATION IS EXPECTED BY NOVEMBER 30, 1992.

 IG FOLLOUUP STATUS AS OF  9/30/92:  [11

 REGION 5. REGIONAL ADMINISTRATOR

 P2CWN9-05-0336-0300076  UELLSVILLE                  ON   8/6/90
  SUBMry:  WE QUESTIONED AS INELIGIBLE OVER SI.9 MILLION BECAUSE
OF THE GRANTEE'S FAILURE TO REHABILITATE ITS SEWERS.

 - EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN
MADE: GRANTEE UNDER CONSENT ORDER BY U.S. DISTRICT COURT FOR THE
NORTHERN DISTRICT OF OHIO, DATED AUGUST 27, 1988 TO RESOLVE
COMPLIANCE FINDINGS BY JANUARY 1, 1993.  WE ANTICIPATE THAT THE
GRANTEE WILL MEET THIS ORDER.

 - DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION:
RESOLUTION EXPECTED BY JANUARY 1, 1993.

 IG FOLLOUUP STATUS AS OF  9/30/92:  [1]

 P2CWP9-Q5-0075-1400037  GARY SD                     IN   9/9/91
  TIBBII,:  ALMOST S2.8 MILLION WASTED WHEN THE GRANTEE FAILED TO
OPERATE AND MAINTAIN A WASTEWATER TREATMENT PLANT.

 - EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN
MADE:  THE ENTIRE GRANT WAS QUESTIONED DUE TO ALLEGED IMPROPER
PLANT OPERATION AND VIOLATION OF  NPDES.  VOLUMINOUS DOCUMENTATION
SENT TWO WEEKS BEFORE THE  FINAL DETERMINATION LETTER DUE DATE.  A
CONSENT DECREE GIVES GARY UNTIL 1994 TO COMPLY.

 « DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION:
RESOLUTION EXPECTED IN 1994.

 IG FOLLOUUP STATUS AS OF  9/30/92:  (31
                                                 P2CWP9-05-0072-2400023  UASHTENAU CO DPU  MI              3/12/92
                                                  SuBBf-y:  UASHTENAU CO, MI DPW CLAIMED $599,523 OF  INELIGIBLE
                                                COSTS.

                                                 - EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN
                                                MADE: THE OIG DISAGREED WITH PROPOSED FINAL DETERMINATION
                                                SUBMITTED ON AUGUST 3, 1992.  AFTER ALLOWING TECHNICAL EXPERTS
                                                THE OPPORTUNITY TO EVALUATE AND RESPOND TO QIC'S COMMENTS, A
                                                REVISED DETERMINATION LETTER INCORPORATING OIG COMMENTS UAS
                                                ISSUED TO THE GRANTEE ON SEPTEMBER 30, 1992.

                                                 * DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION:  THE
                                                AUDIT IS EXPECTED TO BE CLOSED DURING THE FIRST QUARTER OF FISCAL
                                                1993.
                                                                        IG FOLLOUUP STATUS AS OF  9/30/92:    [3]

                                                                        P2CUN4-05-0183-5100159  EUCLID ON
                                                                                                          7/1Z/S
                                                                         SUBBry:   WE  QUESTIONED THE ENTIRE GRANT AWARD OF ALMOST S14.3
                                                                       MILLION.  THE GRANTEE FAILED TO MEET GRANT CONDITION NO. 3 AND
                                                                       OPERATE  THE  PLANT SUFFICIENTLY TO MEET ITS NPOES PERMIT.

                                                                        - EXPLANATION  OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN
                                                                       MADE:  RESOLUTION OF  QUESTIONED COSTS DEPENDS UPON GRANTEE'S
                                                                       SATISFACTORY COMPLETION OF ACTIONS IMPOSED BY CONSENT DECREE.
                                                                       CONSENT DECREE  ALLOWS GRANTEE UNTIL 1996 TO COMPLETE CORRECTIVE
                                                                       ACTIONS.

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

                                                                        IG FOLLOUUP STATUS AS OF  9/30/92:  Ol
APRIL 1,1992 THROUGH SEPTEMBER 30,1992
                                                                                                                61

-------
 Assignment Control
 Number
Title
                                 Final Report
                                      Issued
Assignment Control
Number
Title
Final Report
     Issued
  P3DUL1-05-0360-5100559  PRC ENG CT FT 80/81 IL           9/25/85
  •SuMery:  UE RECOMMENDED OVERHEAD RATES OF 145.36 PERCENT AND
 131.73 PERCENT FOR FISCAL YEARS 1981 AND 1980,  RESPECTIVELY.
 THESE RATES NEED TO BE FINALIZED BY THE COST POLICY AND RATE
 NEGOTIATION BRANCH.

  - EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN
 MADE: THE REGION UAS AWAITING LEGAL ADVICE FROM REGIONAL COUNSEL
 AND ADDITIONAL INFORMATION FROM CONTRACTOR.  THE FINAL
 DETERMINATION LETTER IS CURRENTLY UNDER REVIEW BY REGIONAL
 COUNSEL.

  « DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION:
 TARGETED FINAL DETERMINATION DATE IS OCTOBER 30, 1992.

  16 FOLLOUUP STATUS AS OF  9/30/92:  D]

  P2CUM4-05-0357-6100389  DETROIT USD  MI                  8/25/86
   SUBwy:  THE CITY OF DETROIT, MI. CLAIMED OVER $169,000 OF
 UNREASONABLE ENGINEERING COSTS.

  - EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN
 MADE: REGION S'S RESPONSES HAVE NOT BEEN ACCEPTED BY THE DIGA.
 AUDIT RESOLUTION BOARD (ARB) INTERVENTION NAY THEREFORE BE
 NEEDED.   THE HEADQUARTERS OIG UAS ASKED TO WORK WITH THE OFFICE
 OF WATER TO REVIEW THE ISSUES AND, IF NECESSARY, REFER THE AUDIT
 TO THE ARB FOR RESOLUTION.

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

  IG FOLLOUUP STATUS AS OF 9/30/92:  CQ

  P2GUN4-05-0264-6100390  DETROIT USD    HI                8/25/86
   SUMary:  WE QUESTIONED INELIGIBLE FORCE ACCOUNT COSTS OF
 $20,872 INCURRED PRIOR TO THE GRANT AWARD. IN ADDITION,
 UNSUPPORTED FORCE ACCOUNT COSTS OF $36,370 INCURRED AFTER THE
 APPROVED CONSTRUCTION COMPLETION DATE WERE QUESTIONED.

  - EXPLANATION OF THE REASONS NMMGEMENT DECISION IAS NOT BEEN
 MADE: REGION  S'S RESPONSES HAVf NOT BEEN ACCEPTED BY THE DIGA.
 AUDIT RESOLUTION BOARD (ARB) INTERVENTION NAY THEREFORE BE
 NEEDED.  THE HEADQUARTERS OIG UAS ASKED TO WORK WITH THE OFFICE
 OF WATER TO REVIEW THE ISSUES AND,  IF NECESSARY. REFER THE AUDIT
 TO THE ARB FOR RESOLUTION.

  = DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION:  NO
 ACCURATE RESOLUTION DATE CAN BE ESTIMATED AT THIS TIME.
  IG FOLLOUUP STATUS AS OF  9/30/92:   [2]

  P2CUN4-05-0263-6100391  DETROIT USD    MI
   Sugary:
                                      8/25/86
 THE GRANTEE CLAIMED UNREASONABLE  FORCE ACCOUNT  COSTS OF $286,000.
 THE GRANTEE ALSO CLAIMED  INELIGIBLE COSTS OF $15,000.

   - EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS  NOT BEEN
 MADE:   REGION S'S RESPONSES HAVE  NOT  BEEN ACCEPTED BY  THE DIGA.
 AUDIT  RESOLUTION  BOARD (ARB) INTERVENTION HAY  THEREFORE BE
 NEEDED.  THE  HEADQUARTERS OIG WAS ASKED  TO WORK WITH THE  OFFICE
 OF WATER TO REVIEW THE ISSUES AND, IF NECESSARY, REFER THE AUDIT
 TO THE ARB FOR RESOLUTION.
  P2CUN4-05-0280-6100574  DETROIT USD   MI                 9/XM6
   TlMMfr  WE QUESTIONED INELIGIBLE COST OF $293,000 MOSTLY FOR
 CHANGE ORDERS.  UE ALSO QUESTIONED UNNECESSARY COST OF $399,000
 FOR FORCE ACCOUNT AND GRANTEE DELAYS.  CHANGE ORDER COSTS OF
 $148,00 WERE UNSUPPORTED.

  - EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN
 HADE: REGION S'S RESPONSES HAVE NOT BEEN ACCEPTED BY THE DIGA.
 AUDIT RESOLUTION BOARD (ARB) INTERVENTION MAY THEREFORE BE
 NEEDED.  THE HEADQUARTERS OIG UAS ASKED TO WORK WITH THE OFFICE
 OF WATER TO REVIEW THE ISSUES AND, IF NECESSARY, REFER THE AUDIT
 TO THE ARB FOR RESOLUTION.

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

  16 FOLLOUUP STATUS AS OF  9/30/92:   [21

  P2CUN4-05-0265-6100575  DETROIT USD      MI              9/3V8S
   SuBwy:  THE GRANTEE CLAIMED INELIGIBLE AND UNSUPPORTED
 CONSTRUCTION COSTS OF $559,000.  THE GRANTEE ALSO CLAIMED
 UNREASONABLE ENGINEERING COSTS OF $374,000.

  - EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN
 HADE:  REGION S'S RESPONSES HAVE NOT BEEN ACCEPTED BY THE DIGA.
 AUDIT RESOLUTION BOARD (ARB) INTERVENTION MAY THEREFORE BE
 NEEDED.  THE HEADQUARTERS OIG UAS ASKED TO WORK WITH THE OFFICE
 OF WATER TO REVIEW THE ISSUES AND, IF NECESSARY, REFER THE AUDIT
 TO THE ARB FOR RESOLUTION.

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

  IG FOLLOUUP STATUS AS OF  9/30/92:   123

  P2CUN5-05-0242-70Q0034  DETROIT USD         MI            YW8&
   TIMMO"  UE QUESTIONED INELIGIBLE  CONSTRUCTION AND ENGINEERING
 COSTS OF $20,006.  IN ADDITION, UE QUESTIONED UNSUPPORTED
 ENGINEERING COSTS OF $40,495 INCURRED AFTER THE APPROVED
 CONSTRUCTION COMPLETION DATE.

  - EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS HOT BEEN
 MADE:  REGION S'S RESPONSES HAVE NOT  BEEN ACCEPTED BY THE DIGA.
 AUDIT RESOLUTION BOARD (ARB) INTERVENTION MAY THEREFORE BE
 NEEDED.  THE HEADQUARTERS OIG WAS ASKED TO WORK WITH THE OFFICE
 OF WATER TO REVIEW THE ISSUES AND, IF NECESSARY, REFER THE AUDIT
 TO THE ARB FOR RESOLUTION.

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

  IG FOLLOUUP STATUS AS OF  9/30/92:   121

 P2CUNS-05-0246-7000044   DETROIT USD   HI                 10/7/86
   SUMry:  THE GRANTEE CLAIMED UNREASONABLE FORCE ACCOUNT COSTS
 OF $336,000.

  - EXPLANATION OF THE REASONS MANAGEMENT DECISION  HAS  HOT  BEEN
 MADE:   REGION S'S RESPONSES HAVE NOT BEEN  ACCEPTED  BY  THE DIGA.
 AUDIT  RESOLUTION BOARD  (ARB)  INTERVENTION NAY  THEREFORE  BE
 NEEDED.  THE HEADQUARTERS OIG UAS ASKED TO WORK WITH THE OFFICE
 OF WATER TO REVIEU THE  ISSUES AND,  IF NECESSARY,  REFER THE AUDIT
  TO THE ARB FOR RESOLUTION.
   • DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION:
  ACCURATE RESOLUTION DATE CAN BE ESTIMATED AT THIS TIME.

   IG FOLLOUUP STATUS AS OF  9/30/92:  CD
                                                             HO
                                                   * DESIRED TIMETABLE  FOR ACNIEVIM A MAHAGEMEHT DECISION:
                                                  ACCURATE  RESOLUTION DATE CAN Bf ESTIMATED AT THIS TIME.

                                                   IG FOLLOUUP STATUS AS OF   9/30/92:   121
                                                                                                                                   NO
62
                                                                                                         OFFICE OF THE INSPECTOR GENERAL

-------
Assignment Control
Number
Title
                                 Final Report
                                      Issued
                                                                    Assignment Control
                                                                    Number
Title
Final Report
     Issued
  PZOMS-OS-OZTS-TDOOMS  DETtOIT USD        HI            10/7/86
   Suanry:  UE QUESTIONED $80,000 OF INELIGIBLE ENGINEERING AND
 CONSTRUCTION COSTS.   ENGINEERING COSTS OF (112,000 INCURRED AFTER
 THE APPROVED CONSTRUCTION COMPLETION DATE UERE NOT SUPPORTED.

  - EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT KEN
 HADE:   REGION 5'S RESPONSES HAVE NOT BEEN ACCEPTED BY THE DIGA.
 AUDIT  RESOLUTION BOARD (ARB) INTERVENTION MAY THEREFORE BE
 NEEDED.  THE HEADQUARTERS OIG WAS ASKED TO UORK WITH THE OFFICE
 OF WATER TO REVIEW THE ISSUES AND, IF NECESSARY, REFER THE AUDIT
 TO THE ARB FOR RESOLUTION.

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

  1C FOLLOUUP STATUS  AS OF  9/30/92:  CQ

  P2CUN5-05-0247-7000049  DETROIT USD   Ml                 10/8/86
   SuMBsry:  UE QUESTIONED UNREASONABLE TECHNICAL SERVICES AND
 CONSTRUCTION COSTS OF $559,000.

  - EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN
 MADE:   REGION 5'S RESPONSES HAVE NOT BEEN ACCEPTED BY THE DIGA.
 AUDIT  RESOLUTION BOARD (ARB) INTERVENTION MAY THEREFORE BE
 NEEDED.  THE HEADQUARTERS OIG WAS ASKED TO WORK UITH THE OFFICE
 OF WATER TO REVIEW THE ISSUES AND, IF NECESSARY, REFER THE AUDIT
 TO THE ARB FOR RESOLUTION.

  = DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION:  HO
 ACCURATE RESOLUTION  DATE CAN BE ESTIMATED AT THIS TIME.

  1C FOLLOUUP STATUS  AS OF  9/30/92:  CQ

  P20M5-05-0276-7000050  DETROIT USD     MI               10/8/86
   SUBWy:  WE QUESTIONED $59,000 OF INELIGIBLE ENGINEERING
 COSTS. ENGINEERING COSTS OF $433,600 INCURRED AFTER THE APPROVED
 CONSTRUCTION COMPLETION DATE WERE NOT SUPPORTED.

  - EXPLANATION Of THE REASONS MANAGEMENT DECISION HAS NOT BEEN
 MADE:   REGION 5'S RESPONSES HAVE NOT BEEN ACCEPTED BY THE DIGA.
 AUDIT  RESOLUTION BOARD (ARB) INTERVENTION NAY THEREFORE BE
 NEEDED.  THE HEADQUARTERS OIG WAS ASKED TO WORK WITH THE OFFICE
 OF WATER TO REVIEW THE ISSUES AND, IF NECESSARY. REFER THE AUDIT
 TO THE ARB FOR RESOLUTION.

  * DESIRED TIMETABLE FOR AOUffVIM A MANAGEMENT DECISION:  HO
 ACCURATE RESOLUTION  DATE CAN • ESTIMATED AT THIS TIME.
IG FOLLOUUP STATUS AS OF  9/3BVtt  (21

E2BUL5-05-0136-7000980  SAUGET      IL
                                                           3/31/87
 SAUGET,  IL  WAS AWARDED  FEDERAL FUNDS IN  EXCESS OF $7 MILLION FOR
 INELIGIBLE  AND UNNECESSARY PROJECT  COSTS.

  -  EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN
 MADE:  BECAUSE OF COMPLEXITY  OF ISSUES,  THE  REGION IS SEEKING
 GUIDANCE  FROM REGIONAL  COUNSEL AND  THE WATER DIVISION.  DEVIATION
 REQUEST  IS  PENDING IN HEADQUARTERS.

  -  DESIRED  TIMETABLE FOR ACHIEVING  A MANAGEMENT DECISION:  FINAL
 DETERMINATION EXPECTED  NOVEMBER 30,  1992.

 1C FOLLOUUP STATUS AS OF  9/30/92:   £23

 P2GUNS-05-0132-8000464  DETROIT USD      MI               1/20/83
  SuMaary:  DETROIT CLAIMED INELIGIBLE COSTS OF ALMOST 12.6
MILLION RESULTING FROM ITS FAILURE TO HONOR A CONTRACT.  WE ALSO
QUESTIONED UNSUPPORTED COSTS OF ALMOST S2.1 MILLION.

 - EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN
MADE: REGION  5'S RESPONSES HAVE NOT BEEN ACCEPTED BY THE DIGA.
AUDIT RESOLUTION BOARD (ARB) INTERVENTION MAY THEREFORE BE
NEEDED.  THE HEADQUARTERS OIG WAS ASKED  TO WORK WITH THE OFFICE
OF WATER TO REVIEW THE ISSUES AND, IF NECESSARY, REFER THE AUDIT
TO THE ARB FOR RESOLUTION.

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

 16 FOLLOUUP STATUS AS OF  9/30/92:   GS

 APRIL 1,1992 THROUGH SEPTEMBER 30,1992
                                                  P2CUN7-05-0237-8100724  DETROIT USD        MI            8/29108
                                                   SuBMry:  DETROIT, MI CLAIMED OVER S274.000 OF INELIGIBLE
                                                 CONSTRUCTION COSTS.  UE ALSO QUESTIONED UNSUPPORTED ENGINEERING
                                                 AND FORCE ACCOUNT COSTS OF S662.000.

                                                  - EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN
                                                 HADE:  REGION 5'S RESPONSES HAVE NOT BEEN ACCEPTED BY THE DIGA.
                                                 AUDIT RESOLUTION BOARD (ARB) INTERVENTION MAY THEREFORE BE
                                                 NEEDED.  THE HEADQUARTERS OIG WAS ASKED TO WORK WITH THE OFFICE
                                                 OF WATER TO REVIEW THE ISSUES AND, IF NECESSARY, REFER THE AUDIT
                                                 TO THE ARB FOR RESOLUTION.

                                                  - DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION:  HO
                                                 ACCURATE RESOLUTION DATE CAN BE ESTIMATED AT THIS TIME.

                                                  IG FOLLOUUP STATUS AS OF  9/30/92:  [21
                                                 P2GUNS-05-0169-8100774   DETROIT USD          HI          9/1/88
                                                   Tiaaai):  WE QUESTIONED  INELIGIBLE CONSTRUCTION AND ENGINEERING
                                                 COSTS OF $96.520. IN ADDITION, WE QUESTIONED THAT ENGINEERING
                                                 COSTS OF $992,430 INCURRED AFTER THE APPROVED CONSTRUCTION
                                                 COMPLETION DATE WERE NOT SUPPORTED.

                                                  - EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN
                                                 MADE:  REGION 5'S RESPONSES HAVE NOT BEEN ACCEPTED BY THE DIGA.
                                                 AUDIT RESOLUTION BOARD (ARB) INTERVENTION MAY THEREFORE BE
                                                 NEEDED.  THE HEADQUARTERS OIG WAS ASKED TO WORK WITH THE OFFICE
                                                 OF WATER TO REVIEW THE ISSUES AND, IF NECESSARY, REFER THE AUDIT
                                                 TO THE ARB FOR RESOLUTION.

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

                                                  IG FOLLOUUP STATUS AS OF  9/30/92:  G3

                                                  PROCUREMENT CONTRACTS MANAGEMENT DIVISION

                                                  Cost Policy and Rate Negotiation Section

                                                  P2DW-8-03-0174-1300105  PHILADELPHIA CITY OF    PA       W2/9I
                                                   Suanry:  PUD CLAIMED THAT OPERATING COSTS WERE ALLOCABLE TO
                                                 EPA GRANTS, BUT ALSO CHARGED THESE SAME COSTS TO CUSTOMERS
                                                 THROUGH THEIR WATER AND SEWER RATES.

                                                  - EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN
                                                 MADE: THE GENERAL COUNSEL IS TO PROVIDE AN OPINION ON THE
                                                 CONTRACT CPA'S INTERPRETATION OF OMB COST PRINCIPLES.  EXPECT
                                                 RESPONSE FROM GENERAL COUNSEL BY DECEMBER 31, 1992.

                                                   = DESIRED TIMETABLE FOR  ACHIEVING A MANAGEMENT DECISION:  FINAL
                                                 RESOLUTION IS EXPECTED BY FEBRUARY 28,  1993.
                                                 IG FOLLOUUP STATUS AS OF  9/30/92:   [1]

                                                 D8AML2-09-0022-2100073  TETRA TECH P.A.     CA
                                                             fPVFJUMBD MBIT !••«• •ECOTIATIONl
                                                                                                                             11/19/91
                                                 - EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS HOT BEEN
                                                MADE:  THIS CONTRACT WAS THE UNSUCCESSFUL OFFEROR AS DETERMINED
                                                ON SEPTEMBER 30, 1992.

                                                 - DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION:  THIS
                                                AUDIT SHOULD BE CLOSED IN OCTOBER 1992.

                                                 IG FOLLOUUP STATUS AS OF  9/30/92:  Ml  (OIG had not received •
                                                copy of the contract award.  This audit Mill be closed upon
                                                receipt of the award docuaent.)
                                                 P90HL9-10-0110-1100108  RES FY86 INDIRECT COSTS OR
                                                                                                                               1/24/91
                                                 - EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS HOT BEEN
                                                MADE:   SEVERAL COMPLEX ISSUES ARE UNDER EXTENDED REVIEW.  NO
                                                FOLLOW-UP ACTION CAN BE TAKEN AT THIS TINE.

                                                 » DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION:  NO
                                                TIMETABLE CAN BE ESTABLISHED UNTIL COMPLETION OF THE REVIEW.

                                                 IG FOLLOUUP STATUS AS OF  9/30/92:  [11 (OIG is in concurrence
                                                with above statue and do not expect a response until the review
                                                has been completed.)
                                                                                                                 63

-------
Assignment Control
Number
                     Title
Final Report
     Issued
 P9DHLO-10-0096-2100304  RES 87 OH   01
    3/31/92
 - EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS HOT BEEN
MADE:  SEVERAL COMPLEX ISSUES ARE UNDER EXTENDED REVIEW.  NO
FOLLOU-UP ACTION CAN BE TAKEN AT THIS TINE.

 - DESIRED TIMETABLE FOR ACNIEVIH6 A MANAGEMENT DECISION:  NO
TIMETABLE CAN BE ESTABLISHED UNTIL COMPLETION OF THIS REVIEW.

 1C FOLLOW STATUS AS OF  9/30/92:   [11 (016 U in concurrence
with above status and do not expect a response until the review
has been completed.)

 PROCUREMENT CONTRACTS MANAGEMENT DIVISION

 Financial Analysis Section

 D88ML2-03-0143-2100117  NUS CORP HD                    12/12/91
DCAA WAS UNABLE TO VERIFY THE ACCURACY OF 16,205 BILLED FOR
EQUIPMENT USAGE.

 - EXPLANATION OF THE REASONS NANAtDCHT DECISION HAS HOT BEEN
MADE:  PROBLEMS IN NEGOTIATING  ISSUES CAUSED A DELAY IN
DEVELOPING OVERALL PROPOSAL.  PER THE CONTRACTING OFFICER,
RESOLUTION WILL BE REACHED BY OCTOBER 31, 1992.

 = DESIRED TIMETABLE FOR ACHIEVING A NANMEHENT DECISION:
RESOLUTION WILL BE REACHED BY OCTOBER 31, 1992.
  IG FOLLOUUP STATUS AS OF  9/30/92:   [1]

  P8BNN1-03-0146-23000U  OCR MANAGEMENT CORPORATION  ND
    11/5/91
O&R MANAGEMENT CLAIMED $557,442 OF OTHER DIRECT COSTS.  ONE
HUNDRED PERCENT OF THE CONTRACT WAS QUESTIONED BECAUSE O&R DID
NOT MAINTAIN RECORDS.

 - EXPLANATION OF THE REASONS MANAGEMENT DECISION  HAS NOT BEEN
            >
MADE:  THE CONTRACTOR IS BANKRUPT AND EPA HAS NOT BEEN ABLE TO
CONTACT CONTRACTOR.  AS A RESULT, THE UNSUPPORTED COSTS HAVE NOT
BEEN RESOLVED. IF FURTHER CONTACT IS UNSUCCESSFUL, THIS AUDIT
WILL BE TURNED OVER TO THE ATTORNEY GENERAL.

 « DESIRES TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION:  AN
ACCURATE RESOLUTION DATE CAN NOT BE DETERMINED AT THIS TIME.

 IG FOLLOUUP STATUS AS OF  9/30/92:  [1] (01G is auare of the
above circumstances.)
 P9ANN9-05-0347-0300036  OH MATERIALS (PR EQ RATESXM
  SUBBBTy:  CPREAUARD AUDIT UNDER NEGOTIATION)
    3/27/93
   EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN
   E:  NEGOTIATIONS ARE STILL PENDING.  EPA REQUESTED FURTHER
AUDITS ON THE CONTRACTOR'S EQUIPMENT UTILIZATION RATES FOR 1987,
1988, 1989, AND 1990 IN ORDER TO RESOLVE THESE COSTS.

 * DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION:
RESOLUTION IS EXPECTED TO OCCUR BY NOVEMBER 30, 1992.
 IG FOLLOUUP STATUS AS OF  9/30/92:   [11

 P9ANNO-OS-0260-0300047  OH MATERIALS (PR EQ RATESXM
            fPBFAUABO AUDIT UDFB. NEGOTIATION)
    4727/90
 - EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS HOT BEEN
HADE:  THE PROVISIONAL RATE NEGOTIATIONS HAVE NOT BEEN COMPLETED.
THIS AUDIT IS EXPECTED TO BE RESOLVED IN APRIL 1999.

 • DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION:  THIS
AUDIT IS EXPECTED TO BE RESOLVED BY APRIL 1993.

 IG FOLLOUUP STATUS AS OF  9/30/92:  [1]
Assignment Control
Number
                                                                                          Title
Final Report
     Issued
                 P9AHN1 -05-0144-2300023  OHM REN ERCS2 72 FY 89 OH
                            (PBEAUARD AUDIT UNDER HECTTIATIOHI
                                                                                                                              12/26/91
                 - EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS HOT BEEN
                MADE:  AS A RESULT OF NEGOTIATIONS WITH CONTRACTOR,  PROCUREMENT
                AND CONTRACTS MANAGEMENT DIVISION AND REGION 4, A DECISION WAS
                MADE TO REQUEST A SECOND AUDIT OF COST DATA FOR OPTION YEARS.  AS
                OF RESULT OF THIS DECISION, THERE WILL NOT BE A JOINT
                NEGOTIATION.  REGION 4 WILL NEGOTIATE AND FIX ZONE II ERCS
                PROVISIONAL RATES.

                 • DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION:  THIS
                AUDIT IS EXPECTED TO BE RESOLVED BY APRIL 1993.
                 IG FOLLOUUP STATUS AS OF  9/30/92:  11]

                 P9AHH1-OS-0143-2300024  OHM REN ERCS2 21 FY 89 OH
                            fpiriiunn UDIT UHDEB MEBOMATKID
                                                         12/27/91
                 - EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN
                MADE:  THE CONTRACTING OFFICER (CO) IS REVIEWING AND NEGOTIATING
                THE AUDIT ISSUES.  THE CO EXPECTS THIS AUDIT TO BE RESOLVED BY
                NOVEMBER 30, 1992.

                 - DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION:  THIS
                AUDIT IS EXPECTED TO BE RESOLVED BY NOVEMBER 30, 1992.

                 IG FOLLOUUP STATUS AS OF  9/30/92:  [1]
  Washington Cost Advisory Branch

  P9AHL1-02-0110-1100370  SID ENGINEERING SERVICES NJ      9/6/91
          r-  (PREAWARD AUDIT UNDER NEGOTIATION)
                 - EXPLANATION OF THE REASONS MANAGEMENT DECISION IMS HOT BEEN
                MADE:  THIS CONTRACT WAS NOT AWARDED AND THE PROPOSAL WAS
                WITHDRAWN BY THE CONTRACTING OFFICER.  A WITHDRAWAL LETTER WILL
                BE SENT TO THE 01G IN OCTOBER 1998.

                 » DESIRED TIMETABLE FOR ACNIEVIM A MANAGEMENT DECISION:  THIS
                AUDIT SHOULD BE CLOSED BY OCTOBER 31, 1992.

                 IG FOLLOUUP STATUS AS OF  9/30/92:  [1]

                 D9EHL2-02-0031-2100080  ENVIRONMENTAL PRODUCTS INC  NY   12/2/91
                 - EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS HOT
                MADE:  NO CONTRACT AWARD HAS BEEN MADE.
                  * DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION:  THIS
                AUDIT SHOULD BE CLOSED BY NOVEMBER 30, 1992.
                 IG FOLLOUUP STATUS AS OF  9/30/92:  [1]

                 D9AKL2-03-0016-2100056  DYMANAC   ND
                        r-  (PREAUARD AUDIT UNDER NEGOTIATION)
                                                            11/8/91
                 - EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS HOT BEEN
                MADE:  THIS CONTRACTOR WAS AN UNSUCCESSFUL OFFEROR AS DETERMINED
                ON SEPTEMBER 30, 1992.

                 - DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION:  THIS
                AUDIT SHOULD BE CLOSED DURING OCTOBER 1992.
   IG  FOLLOUUP STATUS AS OF  9/30/92:   [1]

   P8AAL2-03-0072-2100087  ICF CORP VA
    SUBBM-y:  (PREAWARD AUDIT UNDER NEGOTIATION)
                                                                                                                                 12/4/91
                 - EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN
                MADE:  THIS CONTRACT WAS AWARDED ON AUGUST 31, 1992.

                 - DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION:  THIS
                AUDIT SHOULD BE CLOSED.

                 IG FOLLOUUP STATUS AS OF  9/30/92:  [1]  (OIG had not received a
                copy of the contract award.  This audit will be closed upon
                receipt of the award document.)
64
                                                  OFFICE OF THE INSPECTOR GENERAL

-------
 Assignment Control
 Number              Title
Final Report
     Issued
Assignment Control
Number
Title
Final Report
     Issued
 D9AKL2-03-0015-2100130  GANNETT  FLEMING INC    PA       12/17/91
   SiaBBU-y:      »
                         CPREAUARD ffftT  VfflMiR NEGOTIATION)

 - EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN
 MADE:   THIS CONTRACTOR UAS AN UNSUCCESSFUL OFFEROR AS DETERMINED
 ON SEPTEMBER 30,  1992.

 * DESIRED TIMETABLE FOR ACHUVIM A MANAGEMENT  DECISION:  THIS
 AUDIT  SHOULD BE CLOSED IN OCTOBtt 1992.

 IG  FOLLOW STATUS AS OF  9/3O/92i   [11 (016 had not  received a
 copy of the contract award.   This audit  will be  closed  upon
 receipt of the award document.)
                                         VA
   12/20/91
 P8AML2-03-0152-2100144  ICF CORP
  SuBBary:
                         (PREAUARD AUDIT UNDER NEGOTIATION)
  -  EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN
MADE:   THIS CONTRACT HAS NOT  BEEN AWARDED.   EPA  EXPECTS  TO AWARD
THIS CONTRACT BY NOVEMBER 30, 1992.

  =  DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT  DECISION: EPA
EXPECTS TO AWARD THIS CONTRACT  BY NOVEMBER 30. 1992.
  IG  FOLLOUUP STATUS AS OF  9/30/92:   [11

  D9AKL2-03-0115-2100169  DYNAMIC         MD
                      A1DIT UNDEI NEGOTIATION)
    1/6V92
  - EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN
MADE:   THIS CONTRACT HAS NOT BEEN AWARDED.  EPA EXPECTS TO AWARD
THIS CONTRACT BY NOVEMBER 30, 1992.

  - DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION:  EPA
EXPECTS TO AWARD THIS CONTRACT BY NOVEMBER 30, 1992.
  IG FOUOUUP STATUS AS OF  9/30/92:   [11

  D9AKL2-03-0120-2100181  APEX ENVIRONMENTAL  MB
             CPRFflUftTO AUDIT UNDER NEGOTIATION)
    1/6/92
  - EXPLANATION OF THE REASONS MANAGEMENT DECISION  HAS HOT BEEN
MADE:   THIS  CONTRACT HAS HOT  BEEN AWARDED.  EPA EXPECTS TO AWARD
THIS CONTRACT BY NOVEMBER 30, 1992.

  • DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION:  EPA
EXPECTS TO AWARD THIS CONTRACT BY NOVEMBER 30, 1992.
  IG FOLLOW* STATUS AS OF  9/30/92:   [1]

  DSAML2-03-0124-21001B  ECU WASHINGTON ANALYTICAL  MD
             CPBEAIaUD  MA IT UDO NEGOTIATION)
    1/6/92
  -  EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN
 MADE:  THIS CONTRACT  HAS NOT  BEEN AWARDED.  EPA EXPECTS TO AWARD
 THIS CONTRACT BY NOVEMBER  30, 1992.

  *  DESIRED TIMETABLE  FOR ACHIEVING A MANAGEMENT DECISION:  EPA
 EXPECTS TO AWARD THIS CONTRACT  BY NOVEMBER 30, 1992.
  IG FOLLOW STATUS AS OF  9/30/92:   [1]

  P9AMN1-05-0191-13000B  OHM REN ERCS3 R1  ON
             (PREAWARD AUDIT  UNDER NEGOTIATION)
    7/9/91
  - EXPLANATION OF THE REASONS MANAGEMENT DECISION  HAS NOT BEEN
 MADE:  NO CONTRACT HAS BEEN  AWARDED, AND NEGOTIATIONS ARE
 CONTINUING.

  - DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION:  AN
 ACCURATE RESOLUTION DATE CANNOT BE DETERMINED AT THIS TINE.

  IG FOLLOW* STATUS AS OF  9/30/92:    [11
                 P9ANP1-05-02S1-U00034  OHM REN ERCS3 R5  ON
                            CPREAVARD AUDIT UNDER NEGOTIATION)
                                                           9/6/91
                 - EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS HOT BEEN
                MADE:  THIS CONTRACTOR WAS AN UNSUCCESSFUL OFFEROR AS DETERMINED
                ON SEPTEMBER 30. 1992.

                 * DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION:

                                                     (51  (THIS AUDIT UAS CLOSED
   IG FOLLOWUP STATUS AS OF  9/30/92:
 ON OCTOBER 6, 1992.)
                 P9AHP1-05-0313-H00035  OHM REN ERCS3 R2  OH
                            CPBEAWftHP A"MT UNDER NEGOTIATION)
                                                           9/6/91
                 - EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN
                MADE:  NEGOTIATIONS ARE ON HOLD WAITING FOR THE COMPLETION OF THE
                CONTRACTOR'S COST ACCOUNTING STANDARDS DISCLOSURE REPORT.

                  * DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION: AN
                ACCURATE RESOLUTION  DATE CANNOT BE DETERMINED AT THIS TIME.
                 IG FOLLOUUP STATUS AS OF  9/30/92:    [1]

                 P9AHP1-05-0313-U00036  OHM REN ERCS3 R2   ON
                  SuBBBry:   (PREAUARD A*"IT UHPER NEGOTIATION)
                                                           9/6/91
  - EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS HOT BEEN
 MADE:  NEGOTIATIONS ARE ON HOLD WAITING FOR THE COMPLETION OF THE
 CONTRACTOR'S COST ACCOUNTING STANDARDS DISCLOSURE REPORT.

  x DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION:  AN
 ACCURATE RESOLUTION DATE CANNOT BE DETERMINED AT THIS TIME.
                 IG FOLLOUUP STATUS AS OF  9/30/92:    [1]

                 P9AHP1-05-0297-14000U  MAECORP ERCS3 tS   II
                 Suawy:   (PREAUARD AUDIT UNDER NEGOTIATION)
                                                           9/20/91
  - EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN
 MADE:  THIS CONTRACTOR WAS AN UNSUCCESSFUL OFFEROR AS DETERMINED
 ON SEPTEMBER 30,  1992.

  - DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION:

                                       C51 (THIS AUDIT WAS CLOSED
                 IG FOLLOUUP STATUS AS OF  9/30/92:
               ON OCTOBER 6, 1992.)
                E9AHP2-05-0036-2400001  EON ERCS3 R5  ON
                 SuBBary:   CPREAWARD AUDIT UNDER HEGOTIATION)
                                                          11/27/91
  - EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN
 MADE:   THIS CONTRACT  WILL  BE AWARDED BY OCTOBER 31,  1992.

  - DESIRED TIMETABLE  FOR ACHIEVING A MANAGEMENT DECISION:  THIS
 CONTRACT  IS EXPECTED  TO BE AWARDED BY OCTOBER 31, 1992.
                IG FOLLOUUP STATUS AS OF  9/30/92:    [1]

                P9AHP2-05-0054-2400007  MARS E/S ERCS3 RS    IL
                 SUBBBry:  CPREAIIARD AUDIT UNDER NEEPTIATIONI
                                                          12/18/91
  -  EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN
 MADE:   THIS  CONTRACT  IS  EXPECTED  TO BE  AWARDED  BY OCTOBER 31.
 1992.

  *  DESIRED TIMETABLE  FOR ACHIEVING A MANAGEMENT DECISION: THIS
 CONTRACT  IS  EXPECTED  TO  BE AWARDED BY OCTOBER 31,  1992.

  IG FOLLOUUP STAJUS AS OF  9/30/92:   [1]
APRIL 1,1992 THROUGH SEPTEMBER 30,1992'
                                                                               65

-------
Assignment Control
Number
Title
                                 Final Report
                                      Issued
Assignment Control
Number
                                                                     Title
Final Report
     Issued
 P9AHP2-05-0052-2400010  SANSEL SERVICES ERCS3 R5 ON      12/26/91
  SuBBary:
                        fPREAUARD JM"IT UMDER NEGOTIATION)

 - EXPLANATION OF THE REASONS NAHAGEMENT DECISION HAS HOT BEEN
HADE:  THIS CONTRACT IS EXPECTED TO BE AWARDED BY OCTOBER 31,
1992.

 » DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION:  THIS
CONTRACT IS EXPECTED TO BE AWARDED BY OCTOBER 31, 1992.
 IG FOLLOW STATUS AS OF  9/30/92:

 REGION 3. REGIONAL ADMINISTRATOR
                 [11
 E2CUN9-03-0090-22000U  LEOLA SEUER AUTHORITY  PA
  SuMary:
                                     3/31/92
OVER $200,00 OF INELIGIBLE COSTS WERE QUESTIONED PRIMARILY
BECAUSE THE GRANTEE CLAIMED ENGINEERING COSTS ASSOCIATED WITH
FIVE INELIGIBLE TIME EXTENSIONS.

 - EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS HOT BEEN
HADE: DUE TO COMPLEX ISSUES INVOLVED IN THIS AUDIT,  THE REVIEW OF
THE ISSUES REQUIRED MORE TIME THAN ANTICIPATED.

 * DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION: AUDIT
IS EXPECTED TO BE RESOLVED DURING OCTOBER 1992.
 IG FOLLOUUP STATUS AS OF  9/30/92:   Bl

 REGION 10. REGIONAL ADMINISTRATOR

 P5CKN9-10-0151-0300095  OREGON DEQ
                                             OR
                                     9/27/90
 - EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS HOT BEEN
MADE: THE SUPERFUND BRANCH IS WORKING WITH THE DIG ON LEAVE
ISSUE.  SUPERFUND WILL BE SEEKING A DEVIATION FROM CIRCULAR A-87
TO RESOLVE THE LEAVE ISSUE.  BECAUSE OMB APPROVAL MUST BE
OBTAINED FOR THE DEVIATION. REGION PROPOSES TO COMPLETE FINAL
DETERMINATION LETTER PENDING OMB'S DECISION.

 * DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION:
ANTICIPATED FINAL RESOLUTION IS FEBRUARY 28, 1993.

 IG FOLLOUUP STATUS AS OF  9/30/92:   [11

 P5CG*8-10-0076-1100146  WASHINGTON DEPT OF ECOLOGY  UA   3/2WI
  SuBBry:  COSTS QUESTIONED FOR IMPROPER PROCUREMENT, PERSONNEL
SERVICES AND INDIRECT COSTS.

 - EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS HOT BEEN
MADE:  THE SUPERFUND BRANCH IS WORKING WITH THE OIG ON THE
PROCUREMENT ISSUE.  THE FINAL DETERMINATION LETTER  IS EXPECTED TO
BE COMPLETED BY DECEMBER 31, 1992.

 * DESIRED TIMETABLE FOR ACHIEVING A NAHAGEMENT DECISION:
ANTICIPATED FINAL RESOLUTION IS DECEMBER 31, 1992.

 IG FOLLOUUP STATUS AS OF  9/30/92:   [11

 P5CC*8-10-0084-1100156  ALASKA DEPT OF EHV COHSER AT     3/29/91
  SUBBM-y:  COSTS QUESTIONED AS INELIGIBLE FOR SUBCONTRACTOR
SERVICES NOT PERFORMED, EXCESS PROFIT AND ENGINEERING SERVICES
PERFORMED ON SITES OUTSIDE THE SCOPE OF THE COOPERATIVE
AGREEMENT.

 - EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS HOT BEEN
MADE:  THE SUPERFUND BRANCH IS NEGOTIATING WITH THE OIG ON THE
PROCUREMENT AND LEAVE ISSUE.  SUPERFUND WILL BE SEEKING A
DEVIATION FROM CIRCULAR A-87 TO RESOLVE THE LEAVE ISSUE.  BECAUSE
THE REGION MUST RECEIVE OMB APPROVAL FIRST, THE REGION PROPOSES
TO COMPLETE FINAL DETERMINATION LETTER BY FEBRUARY 28, 1993.

 • DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION:
ANTICIPATED FINAL RESOLUTION IS FEBRUARY 28, 1993.

 16 FOLLOUUP STATUS AS OF  9/30/92:   [11
  P2CU*8-10-0057-1100419  RAYMOND. CITY OF  UA             9/25/91
   SUBUry:  INELIGIBLE COSTS QUESTIONED FOR ADMINISTRATIVE AND
 ENGINEERING COSTS ALLOCABLE TO THE INELIGIBLE CONSTRUCTION,
 UNSUPPORTED COSTS QUESTIONED FOR ADMINISTRATIVE AND FORCE ACCOUNT
 SERVICES.  UNNECESSARY/UNREASONABLE COSTS FOR COSTS TO CORRECT
 PROJECT DEFICIENCIES.

  - EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN
 MADE:  THE REGION HAD DIFFICULTIES RECEIVING DOCUMENTATION FROM
 THE CONTRACTOR WHO CONDUCTED THE AUDIT.  THIS DELAYED RESOLUTION
 EFFORTS.  THE FINAL DETERMINATION LETTER WAS ISSUED ON SEPTEMBER
 30, 1992.

  = DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION:

 IG FOLLOUUP STATUS AS OF  9/30/92:  Bl  (THE FINAL
DETERMINATION LETTER WAS ACCEPTED BY THE OIG ON OCTOBER 5, 1992.)

 P2CW7-10-0046-1200039  BRISTOL BAT BOROUGH   AK         9/30/91
  SUBBBry:  BRISTOL BAY BOROUGH, NAKNEK, ALASKA (THE GRANTEE)
CLAIMED INELIGIBLE COSTS OF S1,145,973 AND UNSUPPORTED COSTS OF
$6,699.  ALSO, COSTS OF $148,300 WERE QUESTIONED AS
UNNECESSARY/UNREASONABLE.

 - EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS HOT BEEN
MADE:  REGION HAS RECEIVED OIG'S WORKPAPERS AND IS PREPARING THE
FINAL DETERMINATION LETTER.  REGION WILL SEND DRAFT TO OIG FOR
CONCURRENCE BY DECEMBER 15. 1992.

 * DESIRED TIMETABLE FOR ACHIEVIHG A MANAGEMENT DECISION:
ANTICIPATED FINAL ACTION IS FEBRUARY 28, 1993.
 IG FOLLOUUP STATUS AS OF  9/30/92:  [13

 P5CHN9-10-0155-1300047  WASHINGTON DEPT OF ECOLOGY  UA
                                                                                                                                3/26/91
                                                 - EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS HOT BEEN
                                                MADE:  THE SUPERFUND BRANCH IS NEGOTIATING UITH THE OIG ON THE
                                                PROCUREMENT AND LEAVE ISSUE.   SUPERFUND UILL BE SEEKING A
                                                DEVIATION FROM CIRCULAR A-87 TO RESOLVE THE LEAVE ISSUE.  BECAUSE
                                                THE REGION MUST RECEIVE OMB APPROVAL, IT PROPOSES TO COMPLETE
                                                FINAL DETERMINATION LETTER BY FEBRUARY 28, 1993.

                                                 * DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION:
                                                ANTICIPATED FINAL RESOLUTION IS FEBRUARY 28, 1993.

                                                 IG FOLLOUUP STATUS AS OF  9/30/92:  [1]
                                                 P5CGNO-10-0011-1300066
                                                SuBBary:
                         UASHIHGTOH DEPT OF ECOLOGY  UA   5/7/91
                                                THE WASHINGTON DEPARTMENT OF ECOLOGY (UDOE) DID NOT PROCURE ITS
                                                CONTRACTS IN A MANNER THAT ASSURED A REASONABLE PRICE OR THAT THE
                                                BEST OFFERORS ARE AWARDED CONTRACTS.  UDOE NEEDS TO STRENGTHEN
                                                MANAGEMENT CONTROLS.  UDOE CLAIMED COSTS THAT WERE NOT ALLOCABLE
                                                TO THE COOPERATIVE AGREEMENT.
                                                 - EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT
                                                MADE:  THE SUPERFUKD BRANCH IS NEGOTIATING WITH THE OIG ON THE
                                                PROCUREMENT AND LEAVE ISSUE.  SUPERFUND WILL BE SEEKING A
                                                DEVIATION FROM CIRCULAR A-87 TO RESOLVE THE LEAVE ISSUE.  BECAUSE
                                                THE REGION MUST RECEIVE OMB APPROVAL, IT PROPOSES TO COMPLETE
                                                FINAL DETERMINATION LETTER BY FEBRUARY 28, 1993.

                                                 - DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION:
                                                ANTICIPATED FINAL RESOLUTION IS FEBRUARY 28, 1993.

                                                 IG FOLLOUUP STATUS AS OF  9/30/72:   [1]
 66
                                                                                   OFFICE OF THE INSPECTOR GENERAL

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Assignment Control
Number
                     Title
Final Report
     Issued
                                                                     Assignment Control
                                                                     Number
Title
Final Report
     Issued
 P5CGLO-10-0066-2100299
                         IMS! DOE MULTI-SITE   IM
                                                           3/30/92
GRANTEE DID NOT PROCURE SERVICES  IN A MANNER  THAT  ASSURED
REASONABLE PRICE OR THAT BEST OFFERORS WERE AWARDED CONTRACTS.
ALSO, MANAGEMENT CONTROLS NEED STRENGTHENING TO PROPERLY RECORD AND
CLAIM TO GRANTS.  FINALLY, CONTRACTOR PERFORMANCE  MONITORING
NEEDS IMPROVEMENT.

 - EXPLANATION OF THE REASONS MANAGEMENT DECISION  HAS NOT  BEEN
MADE:  THE SUPERFUND BRANCH  IS NEGOTIATING WITH  THE OIG ON THE
PROCUREMENT AND LEAVE ISSUE.  SUPERFUND WILL  BE  SEEKING A
DEVIATION FROM CIRCULAR A-87 TO RESOLVE THE LEAVE  ISSUE.   BECAUSE
THE REGION MUST RECEIVE OMB  APPROVAL FIRST, REGION PROPOSES TO
COMPLETE FINAL DETERMINATION LETTER BY FEBRUARY  28,  1993.
 * DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION:
ANTICIPATED FINAL RESOLUTION  IS FEBRUARY 28, 1993.

 IG FOLLOUUP STATUS AS OF  9/30/92:   [4]

 P2OI*7-10-0104-2100303  OLYHPIA. CITY OF            WA    3/JV*
  limmuin   COSTS QUESTIONED  FOR UNSUPPORTED ENGINEERING COSTS,
ARCHITECT/ENGINEERING COSTS IN EXCESS OF APPROVED AMOUNTS,
CONSTRUCTION COSTS IN EXCESS  OF ELIGIBLE AMOUNTS, FORCE ACCOUNT
COSTS WITHOUT PROPER AUTHORIZATION OR SUPPORT AND UNSUPPORTED
CONSTRUCTION COSTS.

 - EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT  BEEN
MADE:  A DRAFT FINAL DETERMINATION LETTER WAS SENT TO THE  OIG ON
JULY 31, 1992.  REGION IS AWAITING OIG'S RESPONSE.

 * DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION:
ANTICIPATED FINAL RESOLUTION  IS JANUARY 29, 1993.

 IG FOLLOUUP STATUS AS OF  9/30/92:   [11
 P2CU*7-10-0086-2300018  POCATELLO. CITY OF   ID
  SUBnry:  COSTS QUESTIONED  INCLUDED $52,397 FOR
ARCHITECT/ENGINEERING COSTS RELATED TO TESTING FAILED HEAT
TREATMENT SYSTEM AND $283.758 OF  FORCE ACCOUNT AND EQUIPMENT
RELATED TO CORRECTION OF FAILED HEAT TREATMENT SYSTEM.
 - EXPLANATION OF THE REASONS MANAGEMENT DECISION  HAS NOT BEEN
HADE:  OIG'S RESPONSE WAS RECEIVED ON SEPTEMBER U, 1992.  REGION
IS AWAITING CITY'S RESPONSE TO OIG'S  RECOMMENDATIONS.

 * DESIRED TIMETABLE FOR ACHIEVING A  MANAGEMENT DECISION:
ANTICIPATED FINAL RESOLUTION IS JANUARY 15,  1993.
  IG  FOLLOUUP STATUS AS OF  9/30/92:    [4]
                                                           3/12/92
 E2AUP2-10-0002-2400024  KPDES PERMIT       AK
  SUBMry:  REGION 10 MADE AN IMPROPER AND INADEQUATELY
DOCUMENTED DECISION TO ISSUE A NPDES PERMIT FOR SEAFOOD WASTE
DISCHARGE INTO A RELATIVELY PRISTINE ALASKAN BAY.  REGION 10
DELAYED IN ENFORCING OVER 170 VIOLATIONS OF THE PERMIT
CONDITIONS, INCLUDING ILLEGAL DISCHARGE.

 - EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN
HADE: THE REGION IS IN DISAGREEMENT WITH OIG ON ONLY ONE
RECOMMENDATION -- INITIATING ENFORCEMENT ACTIONS AGAINST THE
COMPANY FOR PERMIT RESOLUTIONS.  REGION IS GETTING GENERAL
COUNSEL OPINION ON THIS MATTER AND ANTICIPATES ISSUING ANOTHER
FINAL DETERMINATION LETTER TO OIG BY NOVEMBER 15, 1992.

 * DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION:  THIS
AUDIT IS EXPECTED TO BE RESOLVED BY NOVEMBER 15, 1992.

 IG FOLLOUUP STATUS AS OF  9/30/92:  [21
                 E3BG*6-10-0066-8100761  NOSES LAKE IRt I REHAB DIST WA   8/31/83
                  SUMM-y:   INTERIM AUDIT OF DEMONSTRATION GRANT TO RESTORE MOSES
                LAKE AND TO CONTROL NON-POINT POLLUTION SOURCES FOUND TOTAL COSTS
                QUESTIONED OF  $2,439,103 (F.S.  $1,205,039).   GRANTEE USED
                STANDARD METHODOLOGY  INSTEAD  OF DEVELOPING NEW INNOVATIVE
                TECHNIQUES.

                 - EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT  BEEN
                MADE:  ERA'S AUDIT REVIEW GROUP IS REVIEWING THIS AUDIT.
                CURRENTLY THE  OFFICE  OF WATER AND  OIG ARE PROVIDING ADDITIONAL
                INFORMATION  TO THE ARC.

                 « DESIRED TIMETABLE  FOR ACHIEVING A MANAGEMENT DECISION:  THIS
                AUDIT IS EXPECTED TO  BE RESOLVED BY MARCH 31,  1993.

                 IG FOLLOUUP STATUS AS OF  9/30/92:  [61

                 REGION 2. REGIONAL ADMINISTRATOR

                 P5BGLO-02-0196-11004Z3  NTS  LOVE  CANAL REMEDIAL PROJNY   9/27/91
                  SuHMry:   THE RECIPIENT CLAIMED  $953,392 OF UNALLOWABLE  COSTS
                ($1,390 OF INELIGIBLE COSTS AND $952,002 OF UNSUPPORTED COSTS)
                FOR THE LOVE CANAL REMEDIAL PROJECT.

                 - EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT  BEEN
                MADE: NEW YORK STATE  HAS EXTRACTED AND CONSOLIDATED SEVEN  YEARS
                OF EXPENDITURE INFORMATION TOTALING $27.4 MILLION.  BASED  ON
                DIG/REGION 2 DISCUSSIONS,  OIG REQUESTS A REGION 2 REVIEW OF
                ORIGINAL SOURCE DOCUMENTATION FOR  THE $705,525 OF UNSUPPORTED
                COSTS.

                 = DESIRED TIMETABLE  FOR ACHIEVING A MANAGEMENT DECISION:
                ESTIMATED FINAL DETERMINATION EXPECTED BY NOVEMBER 30, 1992.

                 IG FOLLOUUP STATUS AS OF  9/30/92:  [1]

                 E1SHF1-02-0132-2100063  UNANNOUNCED SITE VISIT-SOBEUU  11/18/91
                  SUBBry:   THERE WAS A NEED  TO IMPROVE THE MONITORING OF
                CONTRACTOR ACTIVITIES AND COSTS. CONTROL DOCUMENTS NEEDED  TO BE
                BETTER  MAINTAINED AND REVIEWED. IN ADDITION, TOO MUCH RELIANCE
                WAS PLACED ON  THE ERCS CONTRACTORS REPORTING OF COSTS CLAIMED
                WITHOUT ADEQUATE OSC  VERIFICATION.

                 - EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS HOT  BEEN
                MADE: OIG REQUESTED ADDITIONAL INFORMATION AND CLARIFICATION OF
                REGION  2 FINAL RESOLUTION DATED SEPTEMBER 1, 1992.

                 x DESIRED TIMETABLE  FOR ACHIEVING A MANAGEMENT DECISION:
                ESTIMATED FINAL DETERMINATION EXPECTED NOVEMBER 30, 1992.
                                                                       IG FOLLOUUP STATUS AS OF  9/30/92:  (21

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

                                                                       - EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN
                                                                      MADE: AUDIT QUESTIONED ALL COSTS AS UNSUPPORTED DUE TO RECORDS
                                                                      REPORTEDLY LOST IN HURRICANE.  EQB SUBSEQUENTLY FOUND SOME
                                                                      DOCUMENTATION.  REGION 2 SUBMITTED DRAFT RESOLUTION TO OIG
                                                                      SEPTEMBER 25, 1992.

                                                                       * DESIRED TINETHBLE FOR ACHIEVING A MANAGEMENT DECISION:
                                                                      ESTIMATED FINAL DETERMINATION EXPECTED DECEMBER 31, 1992.

                                                                       IG FOLLOUUP STATUS AS OF  9/30/92:  O3
APRIL 1,1992 THROUGH SEPTEMBER 30,1992
                                                                                                                                    67

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Assignment Control
Number
                    Title
Final Report
     Issued
Assignment Control
Number
                                                                                          Title
Final Report
     Issued
  P5BGLO-02-0252-2100218  MJOEP GENS          HJ           2/5/92
  •SuMry:  THE GRANTEE CUIMED $28,271 Of UNSUPPORTED COSTS.

  - EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN
 MADE: DUE TO COMPLEXITY OF ISSUES, STATE OF NEW JERSEY HAD TO
 DEVELOP ADDITIONAL FACTUAL DOCUMENTATION TO CLARIFY AND SUPPORT
 AUDIT FINDINGS.  DRAFT RESPONSE SUBMITTED TO OIG SEPTEMBER 18,
 1992.  OIG WILL RESPOND BY OCTOBER 23, 1992.

  = DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION:
 ESTIMATED FINAL DECISION EXPECTED NOVEMBER 15. 1992.

  IG FOLLOUUP STATUS AS OF  9/30/92:   O3

  P2CUL9-02-0031-2100241  NDODNA BASIN   NY                2/20/92
   SUMary:  THE GRANTEE CLAIMED $514,959 OF UNALLOWABLE COSTS OF
 WHICH $105,657 WERE INELIGIBLE AND $409,302 WERE UNSUPPORTED.

  - EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS HOT BEEN
 MADE: THE NEW YORK STATE DEPARTMENT OF ENVIRONMENTAL CONSERVATION
 (NYSDEC) IS THE DELEGATED AUTHORITY RESPONSIBLE FOR THE AUDIT
 RESOLUTION.  DUE TO A LARGE NUMBER OF AUDITS REQUIRING RESOLUTION
 AND A LACK OF STAFF AT NYSDEC, THE AUDIT COULD NOT BE RESOLVED BY
 SEPTEMBER 30, 1992.

  » DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION:
 EXPECTED RESOLUTION, FIRST QUARTER FY 1993.

  IG FOLLOUUP STATUS AS OF  9/30/92:   [11

  P2CULO-02-0174-2100291  GLENS FALLS NY                   3/&K
   Suwy:  THE GRANTEE CLAIMED $2,498,118 OF INELIGIBLE COSTS
 AND $18,634 OF UNSUPPORTED COSTS.

  - EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS HOT BEEN
 MADE: THE NEW YORK STATE DEPARTMENT OF ENVIRONMENTAL CONSERVATION
 (NYSDEC) IS THE DELEGATED   AUTHORITY RESPONSIBLE FOR THE AUDIT
 RESOLUTION.  DUE TO A LARGE NUMBER OF AUDITS REQUIRING RESOLUTION
 AND A LACK OF STAFF AT NYSDEC, THE AUDIT COULD NOT BE RESOLVED BY
 SEPTEMBER 30, 1992.

  - DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION:
 EXPECTED RESOLUTION, FIRST QUARTER FY 1993.

  IG FOLLOUUP STATUS AS OF  9/30/92:   [1]

  P2CUL9-02-0332-2100294  BATAVIA    NT                    3/27/9B
   SuBBM-y:  THE GRANTEE CLAIMED $6,733,580 OF WHICH $491,931 WAS
 DETERMINED TO BE  INELIGIBLE AND $1,285 UNSUPPORTED.

  - EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN
 MADE: THE NEW YORK STATE DEPARTMENT OF ENVIRONMENTAL CONSERVATION
 (NYSDEC) IS THE DELEGATED AUTHORITY RESPONSIBLE FOR THE AUDIT
 RESOLUTION.  DUE TO A LARGE NUMBER OF  AUDITS REQUIRING RESOLUTION
 AND A LACK OF STAFF AT NYSDEC.  THE AUDIT COULD NOT BE RESOLVED BY
 SEPTEMBER 30,  1992.

  * DESIRED TIMETABLE  FOR ACHIEVING A MANAGEMENT DECISION:
 EXPECTED RESOLUTION,  FIRST QUARTER FY 1993.

  IG  FOLLOUUP STATUS AS OF  9/30/92:   [11
  REGION 3. REGIONAL ADMINISTRATOR
                                                            3/51/92
 P6DUNO-03-0261-2300046  DC GOVERNMENT     DC
  SUBBN-y:  REVIEW OF THE "WASHINGTON TIMES" ALLEGATIONS
CONCERNING THE BLUE PLAINS TREATMENT PLANT DISCLOSED CONTRACT
OVERRUNS OF $21 MILLION.  IN ADDITION, EXCESSIVE DELAYS OCCURRED
BECAUSE OF PROCUREMENT POLICIES AND PRACTICES.

 - EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS HOT BEEN
MADE: THE WATER MANAGEMENT PROGRAM NEEDED ADDITIONAL TIME TO
REVIEW THE AUDIT ISSUES.  THE FINAL DETERMINATION LETTER WILL BE
SENT TO THE OIG BY OCTOBER 30, 1992.

 - DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION:
RESOLUTION EXPECTED BY NOVEMBER 30, 1992.

 IG FOLLOUUP STATUS AS OF  9/30/92:   [1]
                                                                      REGION 4. REGIONAL ADMINISTRATOR

                                                                      E2CUN7-04-0302-0300054  SYLACAUGA UTILITIES BD      AL   5/10/93
                                                                       SUMary:  THE GRANTEE TERMINATED THE ORIGINAL CONTRACTOR FOR
                                                                     CONVENIENCE AND DID NOT HOLD THE CONTRACTOR AND/OR THE BONDING
                                                                     COMPANY FOR CHANGED SITE CONDITION AND INCREASED COSTS OF $1.6
                                                                     MILLION.

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

                                                                       * DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION: NO
                                                                     ACCURATE  RESOLUTION DATE CAN  BE  ESTIMATED  AT  THIS TIME.
                                                                       IG FOLLOUUP STATUS AS OF  9/30/92:   (61
                                                                                               NILLS
                                                                                                            CTY
                                                                                                                    FL
                                                                           7/17/91
   E2CUN1-04-0052-1300086
    SuBBBry:  THE GRANTEE RECEIVED  EPA FUNDS TO EXPAND ITS
  WASTEWATER  TREATMENT  PLANT.   WE FOUND HO JUSTIFICATION FOR THE
  EXPANSION AND  THEREFORE,  WE  QUESTIONED OVER $5 MILLION OF THE
  EXPANSION COST AS  BEING UNNECESSARY.

   - EXPLANATION OF  THE REASONS MANAGEMENT DECISION HAS HOT BEEN
  MADE:  JUSTIFICATION  TO EXPAND THE  TREATMENT PLANT DEPENDS ON THE
  COMPLETION  OF  THE  CORRECTIVE ACTION PLAN FOR THE RUSKIN/WIMAUMA
  PROJECT.  REGION 4 AND OIG CONCUR THAT A FINAL DETERMINATION IS
  PREMATURE.

   - DESIRED  TIMETABLE  FOR ACHIEVING  A MANAGEMENT DECISION:
  RESOLUTION  EXPECTED JUNE 1994.

   IG FOLLOUUP STATUS AS OF 9/30/92:  [2]

   REGION 5.  REGIONAL ADMINISTRATOR

   E2AWTO-05-0223-0400020  SELLERS8URG EUS     IN           6/14/90
    SuBBBry:  REGION 5  AWARDED A $5.5 MILLION STEP 2+3 GRANT TO
  SELLERSBURG, IN FOR A PROJECT WHICH DID NOT MEET THE ELIGIBILITY
  REQUIREMENTS FOR SUCH A GRANT.
                  - EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS HOT
                MADE:  REGION AND DIVISIONAL  OIG CANNOT  REACH AGREEMENT  ON A
                MANAGEMENT DECISION.  THE  HEADQUARTERS OIG HAS  INITIATED
                DISCUSSIONS WITH THE OFFICE OF WATER  TO  CLARIFY THE  ISSUES.

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

                  IG  FOLLOUUP STATUS AS OF  9/30/92:   [6]

                  E2AUTO-05-0224-0400045  W TERRE HAUTE EUS      IH        9/28/90
                  SuBBBry:  REGION 5 AWARDED  A STEP 2+3  GRANT OF $5,275,325 TO
                WEST TERRE HAUTE, IN FOR A PROJECT WHICH DID NOT MEET THE
                ELIGIBILITY REQUIREMENTS FOR  SUCH  A GRANT.

                  - EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN
                MADE:  REGION AND DIVISIONAL  OIG CANNOT  REACH AGREEMENT  ON A
                MANAGEMENT DECISION.  THE  HEADQUARTERS OIG HAS  INITIATED
                DISCUSSIONS WITHfrTHE OFFICE OF WATER  TO  CLARIFY THE  ISSUES,

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

                  IG  FOLLOUUP STATUS AS OF  9/30/92:   [61

                  E2AWT1-05-0134-1400007  S HENRY RSB  EWS    IN              2/25/91
                  Suwy:  REGION 5 AWARDED  A STEP 2+3  GRANT OF $4,461,050 TO
                SOUTH  HENRY REGIONAL WASTE DISTRICT,  IN  FOR A PROJECT WHICH DID
                NOT  MEET THE ELIGIBILITY REQUIREMENTS FOR SUCH  A GRANT.

                  - EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN
                MADE:  REGION AND DIVISIONAL OIG CANNOT REACH AGREEMENT ON A
                MANAGEMENT DECISION.  THE  HEADQUARTERS OIG HAS  INITIATED
                DISCUSSIONS WITH THE OFFICE OF WATER  TO  CLARIFY THE  ISSUES.

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

                  IG  FOLLOUUP STATUS AS OF  9/30/92:   [61
 68
                                                                                                      OFFICE OF THE INSPECTOR GENERAL

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Assignment Control
Number
Title
                                 Final Report
                                      Issued
Assignment Control
Number
                                                                     Title
Final Report
     Issued
   E2AUT1-05-0116-1400048  ENGLISH EUS III
                                                           9/25/91
             THE GRANTEE HAS BEGUN A SIGNIFICANT REDEVELOPMENT
  PROJECT WHICH RAISES QUESTIONS ABOUT THE CONCLUSIONS OF THE
  FACILITIES PLANNING PROCESS. AS A RESULT, THE GRANT AWARD OF
  $2,676,600 WAS PREMATURE AND THE PRELIMINARY PLANNING NEEDS TO BE
  REEVALUATED.

   - EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN
  MADE:  REGION AND DIVISIONAL OIG CANNOT REACH AGREEMENT ON A
  MANAGEMENT DECISION.  THE  HEADQUARTERS OIG HAS INITIATED
  DISCUSSIONS WITH THE OFFICE OF UATER TO CLARIFY THE ISSUES.

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

   IG FOLLOUUP STATUS AS OF   9/30/92:  [6]

   REGION 9. REGIONAL ADMINISTRATOR

   8586*8-09-0202-0300037 CA DEPT OF HEALTH CA             3/XV9J
    '!•!! 1   COSTS OF $2,419,415 QUESTIONED AS INELIGIBLE AND
  $1,639,629 AS UNREASONABLE INELIGIBLES RELATED TO FORCE ACCOUNT
  AND CONTRACT COSTS UNREASONABLE RELATED TO CONTRACT COSTS.
  GRANTEE'S FINANCIAL MANAGEMENT SYSTEM DETERMINED INADEQUATE.
  MOST INELIGIBLE COST RESULT OF THIS.

   - EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN
  MADE:  THE OIG IS WAITING  FOR THE COMPLETION  OF SEVERAL
  CORRECTIVE ACTIONS BEFORE  CONCURRING WITH THE DRAFT FINAL
  DETERMINATIONS FOR THIS AUDIT.

   « DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION:  THIS
  AUDIT IS EXPECTED TO BE RESOLVED BY MARCH 31,  1993.

   16 FOLLOUUP STATUS AS OF   9/30/92 :  CO

   55809-09-0267-0300096 SOUTH BAT MULTI-SITE        CA   9/2B/90
    SIMM?:   COSTS OF $2,903,899 WERE QUESTIONED AS UNSUPPORTED
  BY ADEQUATE SOURCE DOCUMENTATION.

   - EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN
  MADE:  THE OIG IS WAITING  FOR THE COMPLETION  OF SEVERAL
  CORRECTIVE ACTIONS BEFORE  CONCURRING WITH THE DRAFT FINAL
  DETERMINATIONS FOR THIS AUDIT.

   » DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION:  THIS
  AUDIT IS EXPECTED TO BE RESOLVED BY MARCH 31,  1993.

   IG FOLLOUUP STATUS AS OF   9/30/92:   12]

   P2BULO-09-0175-1100436 CLARK COUNTY SO      NV          9/JV91
    SUM-?:  THE CLARK COUNTY SANITATION DISTRICT,  NEVADA CLAIMED
  INELIGIBLE COSTS OF $6,851.921.  UNSUPPORTED COSTS OF $688,395
  AND, MORE SIGNIFICANTLY, CLAIMS FOR $25,390,310 WERE QUESTIONED
  AS UNNECESSARY/UNREASONABLE.

   - EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN
  MADE:  THE STATE IS REVIEWING THE FINAL PAYMENT REQUEST.   MORE
  INFORMATION IS NEEDED FROM THE GRANTEE.  WE CONTINUE TO WORK WITH
  THE GRANTEE ON A NUMBER Of  TECHNICAL ISSUES.   THE  AUDIT AND THE
  GRANTEE ARE $62 MILLION APART.  THIS WILL REQUIRE  EXTENSIVE
  RESEARCH,  DISCUSSION. AND REVIEW.

   » DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION:  THIS
  AUDIT IS EXPECTED TO BE RESOLVED  BY SEPTEMBER  30,  1993.

   IG FOLLOUUP STATUS AS OF   9/30/92:  [1]
                                                  E2CW7-09-0192-1300053  SUN VALLEY UATER I SAN DIST NV  3/28/91
                                                   Siamry:  THE SUN VALLEY UATER AND  SANITATION DISTRICT, NEVADA,
                                                 CLAIMED S6.2 MILLION OF  INELIGIBLE ENGINEERING, EQUIPMENT,
                                                 CONSTRUCTION, AND  ADMINISTRATIVE COSTS.  ALSO, $2.3 MILLION OF
                                                 UNNECESSARY COSTS WERE QUESTIONED.

                                                  - EXPLANATION OF THE REASONS NMMEMENT DECISION  HAS  NOT BEEN
                                                 MADE:  TO ADDRESS THE 2/3 RULE ILIGIBILITY REQUIREMENT, THE
                                                 REGION SUBMITTED ADDITIONAL DOCUMENTATION TO THE OIG FOR REVIEW.
                                                 THE OIG HAS NOT COMPLETED ITS REVIEW. ONCE THE OIG COMMENTS. THE
                                                 REGION UILL ISSUE ITS FDL.

                                                  » DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION:  THIS
                                                 AUDIT IS EXPECTED TO BE  RESOLVED BY  JANUARY 1993.

                                                  IG FOLLOUUP STATUS AS OF  9/30/92:  [4]

                                                  S2CW8-09-0157-1300112  LOS ANGELES. CITY OF        CA  9/25/91
                                                   Sumry:  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 FORCE ACCOUNT AND $1,099,261 ARCHITECT/ENGINEERING
                                                 COSTS INCURRED UNDER PROHIBITED CONTRACT METHOD.

                                                  - EXPLANATION OF THE REASONS MANAGEMENT DECISION  HAS  HOT BEEN
                                                 MADE:  THE STATE IS STILL REVIEWING  THE FORCE  ACCOUNT  AND OTHER
                                                 TECHNICAL ISSUES.  THIS  AUDIT IS RELATED TO TWO OTHERS ON THIS
                                                 GRANTEE.

                                                  » DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION:  THIS
                                                 AUDIT IS EXPECTED TO BE  RESOLVED BY  SEPTEMBER  30,  1993.

                                                  IG FOLLOUUP STATUS AS OF  9/30/92:  [11

                                                  S2CUN9-09-0039-1300117  LOS ANGELES, CITY OF        CA  9/30/91
                                                   SuBnry:  INELIGIBLE COSTS INCLUDED $4,004,695 FOR COST
                                                 INCURRED PRIOR TO APPROVAL $3,659,407 IN EXCESS OF  APPROVAL
                                                 ADDITIONAL AE QUESTIONED $3,999,353  RELATED TO REPLACEMENT OF BAS
                                                 ENGINES WITH ELECTRIC MOTORS I $5,275,186 FOR  INADEQUATELY
                                                 DOCUMENTED FORCE ACCOUNT COSTS.

                                                  - EXPLANATION OF THE REASONS MANAGEMENT DECISION  HAS  NOT BEEN
                                                 MADE:  THE STATE IS STILL REVIEWING  THE FORCE  ACCOUNT  AND OTHER
                                                 TECHNICAL ISSUES.  THIS  AUDIT IS RELATED TO TWO OTHERS ON THIS
                                                 GRANTEE.

                                                  = DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION:  THIS
                                                 AUDIT IS EXPECTED TO BE  RESOLVED BY  SEPTEMBER  30,  1993.

                                                  IG FOLLOUUP STATUS AS OF  9/30/92:  [11
                                                                 *
                                                  S2CUN9-09-0032-1300118  MONTEREY REG UATER POLL CON CA   9/30/91
                                                   Sugary:  STATE CLAIMED $7.491,007 OF INELIGIBLE  CONSTRUCTION,
                                                 ENGINEERING, ADMINISTRATIVE AND OTHER COSTS.   AN ADDITIONAL
                                                 $51,118,958 OF UNREASONABLE PROJECT  COSTS WERE QUESTIONED PENDING
                                                 AN ELIGIBILITY DETERMINATION.

                                                 - EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN
                                                 MADE:  THIS AUDIT INCLUDES 36 ISSUES, MANY OF  WHICH ARE RESEARCH
                                                 INTENSIVE OR TECHNICAL TO RESOLVE.   THEREFORE,  THE DRAFT FDL HAS
                                                 NOT BEEN COMPLETED.  THE SWRCB IS STILL WORKING ON  THE MANY
                                                 TECHNICAL ISSUES.

                                                  - DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION:  THIS
                                                 AUDIT IS EXPECTED TO BE  RESOLVED BY  SEPTEMBER  30,  1993.

                                                  IG FOLLOUUP STATUS AS OF  9/30/92:  [1]
APRIL 1,1992 THROUGH SEPTEMBER 30,1992

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 Assignment Control
 Number
                        Title
Final Report
     Issued
Assignment Control
Number
                                                                                              Title
Final Report
     Issued
  S2CU*8-09-0156-1300119  LOS ANGELES.  CITY OF        CA   9/30/91
   Suanery:   INELIGIBLE  COSTS OF  $2,463,877 INCLUDED $2,039,554 OF
 CONSTRUCTION AND  FORCE  ACCOUNT COST  OUTSIDE SCOPE OF APPROVED
 PROJECT; $444,318 OF FORCE  ACCOUNT ALLOCABLE TO INELIGIBLE
 CONSTRUCTION; UNREASONABLE  COSTS OF  $68,150,598 RELATED TO
 EXCESSIVE LANDSCAPING,  FORCE ACCOUNT AND  UNUSED FACILITIES WERE
 ALSO QUESTIONED.

    - EXPLANATION OF  THE  REASONS MANAGEMENT DECISION HAS NOT BEEN
  MADE:   THE  STATE IS STILL  REVIEWING THE  FORCE ACCOUNT AND OTHER
  TECHHICAL  ISSUES.  THIS AUDIT IS RELATED TO TWO OTHERS ON THIS
  GRANTEE.

   - DESIRED  TIMETABLE FOR ACHIEVING  A  MANAGEMENT DECISION: THIS
  AUDIT  IS EXPECTED  TO BE RESOLVED BY SEPTEMBER 30,  1993.

   16 FOLLOUUP STATUS AS OF   9/30/92:  [1]

   S2CWN9-09-0171-1300120 TRACY.  CITY  OF      CA            9/3D/91
     SuMry:  INELIGIBLE COSTS INCLUDED: $11,438 FOR
  ARCHITECT/ENGINEERING  COSTS; 1655,329 OF  INTEREST  EARNED;
  S2.916.2U FOR LITIGATION  SETTLEMENT; UNREASONABLE COST OF
  SS,516,623 WERE  RELATED TO FIX UP OF  FAILED FACILITIES.

   - EXPLANATION OF THE  REASONS MANAGEMENT DECISION  HAS NOT BEEN
  MADE:  THE CLAIMS POLICY HAS BEEN ISSUED.   THE  STATE  SUBMITTED
  THE DRAFT FDL TO THE DIG FOR THEIR  REVIEW.

   « DESIRED TIMETABLE FOR ACHIEVING  A MANAGEMENT DECISION:  THIS
  AUDIT  IS EXPECTED TO BE RESOLVED BY APRIL  30,  1993.
                                       [1]   (QIC  has not received •
  16 FOLLOUUP STATUS AS OF  9/30/92:
 copy of the draft FDL.)

  E2AUP9-09-0189-1400006 EARLY WARNING - MONTEREY    CA   2/1V9I
   SlBMry:  REGION 9  AWARDED S8.1  MILLION GRANT AMENDMENT  WHICH
 DID HOT MEET THE REQUIREMENTS OF THE CLEAN WATER ACT OR EPA
 REGULATIONS IN ADDITION  THE  U.S. ARMY OVERPAID S6.2 MILLION FOR
 ITS SHARE  OF THE CONSTRUCTION PROJECT.

  - EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT  BEEN
 MADE:   THE WMD HAS MET WITH MONTEREY. THE ARMY COE, AND FORT ORD.
 WORK OH THE  SETTLEMEHT IS ON HOLD WHILE THE OIG CONDUCTS AN AUDIT
 OF MONTEREY'S BOOKS TO DETERMIHE THE ACTUAL COST OF THE PLAHT
 EXPANSION.   AFTER THIS COST HAD BEEH DETERMINED AND ACCEPTED, THE
 ARMY WILL  BE ABLE  TO  MAKE  SETTLEMEHT OFFER TO MONTEREY FOR FORT
 ORO'S SHARE  OF THE EXPANSION COSTS.   WE  ESTIMATE THE ARMY  IS DUE
 A  REFUND OF  U MILLION.

 « DESIRED TIMETABLE  FOR ACHIEVING A MANAGEMENT DECISION:  THIS
 AUDIT IS EXPECTED  TO  BE  RESOLVED BY  SEPTEMBER 30.  1993.

 16 FOLLOUUP STATUS AS OF  9/30/92:   [1]

 E1KA61-09-6094-1400049  FOLLOW UP REVIEW REG.IX  CA      9/5/91
   SuBBary:   REGION 9  TOOK  INADEQUATE ACTION  TO MONITOR  AIR GRANT
 ELIGIBILITY.  AS A RESULT, S2.1  MILLION  IN AIR  GRANTS  FROM 1983
 TO  1985  REMAINED QUESTIONABLE. AN  ADDITIONAL SI.9 MILLION  IH
 QUESTIONABLE  GRANTS WAS AWARDED  FROM FISCALS 1986  TO 1990.

 - EXPLANATION OF THE REASONS MANAGEMENT DECISION  HAS HOT BEEN
 MADE:  THE REGION FORWARDED A  (DRAFT} FINAL  DETERMINATION LETTER
 TO THE OIG FOR REVIEW ON SEPTEMBER 17, 1992.  THIS LETTER
 REFLECTS MANY OF THE LOCAL  OIG'S COMMENTS ON AH APRIL 1992 DRAFT.
 THE LETTER IS CURRENTLY UNDER REVIEW AND SHOULD BE  ISSUED BY THE
END OF THE FIRST QUARTER OF FY 1993.

 - DESIRES TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION:  THIS
AUDIT IS EXPECTED TO IE RESOLVED BY DECEMBER 31, 1992.

 16 FOLLOUUP STATUS AS OF  9/30/92:   [4]
                 P2CV*8-09-0021-2100298  PRESCOTT. CITY OF  AZ             3/30/92
                  Suoaary:  THE GRANTEE CLAIMED ARCHITECTURAL, ENGINEERING, AND
                CONSTRUCTION COSTS TOTALING $109,222 (FEDERAL SHARE) WHICH WERE
                INELIGIBLE BECAUSE THEY DID NOT CONFORM TO GRANT TERMS OR BECAUSE
                THE COSTS WERE IMPROPERLY ALLOCATED TO THE GRANTS.

                 - EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN
                MADE:  THE DRAFT FINAL DETERMINATION LETTER HAS BEEN WRITTEN AND
                WILL BE SENT TO THE OIG FOR REVIEW BY OCTOBER 30,  1992.

                 = DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION:   THIS
                AUDIT  IS EXPECTED TO BE RESOLVED BY JANUARY 31, 1993.

                 IG FOLLOUUP STATUS AS OF  9/30/92:   [11

                 P2CUNO-09-0031-Z300017  PINETOP LAKESIDE SO  AZ           12/4/91
                  Suanry:  UNNECESSARY COSTS OF $4,105,313 QUESTIONED RELATED TO
                UNUSED AND UNDERUTILIZED FACILITIES CONSTRUCTED UNDER THE
                PROJECT.

                 - EXPLANATION OF THE REASONS MANAGEMENT  DECISION HAS NOT  BEEN
                MADE:  THE WMD SUBMITTED ITS DRAFT FINAL  DETERMINATION LETTER TO
                THE OIG FOR REVIEW.  WMD IS AWAITING COMMENTS FORM THE OIG.

                 - DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION:  THIS
                AUDIT  IS EXPECTED TO BE RESOLVED BY MARCH 31, 1993.

                 IG FOLLOUUP STATUS AS OF  9/30/92:   [21

                 S2CUN9-09-0064-2300030  NOVATO SAN DIST    CA             1/28/92
                  SUMary:  COSTS QUESTIONED OF $578,002  INCLUDED $548,578 FOR
                UNALLOWABLE ENGINEERING COSTS AND S29.424 FOR COSTS INCURRED FOR
                THE PURCHASE OF LAND THAT WAS NOT USED AS PART OF THE TREATMENT
                WORKS.

                 - EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS HOT  BEEN
                MADE:  THE STATE HAS JUST COMPLETED WRITING THE FINAL
                DETERMINATION LETTER.  REGION 9 EXPECTS TO RECEIVE THE FDL BY
                OCTOBER 30, 1992.  AFTER REGIONAL REVIEW  IT WILL BE SUBMITTED TO
                THE OIG FOR THEIR REVIEW.

                 = DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION:  THIS
                AUDIT IS EXPECTED TO BE RESOLVED BY MARCH 31, 1993.

                 IG FOLLOUUP STATUS AS OF  9/30/92:  [1]

                 S5BGHO-09-0303-2300043  L.A. DEFT WATER & POWER     CA    3/13/92
                  SuBBry:  INELIGIBLE COSTS OF $2,321,195 INCURRED; $4,810 OF
                UNALLOWABLE TRAINING AND STORAGE COST; $287,450 FOR RETENTIONS
                NOT PAID AND $1,991,131 FOR UNALLOWABLE FORCE ACCOUNT;
                UNREASONABLE OF $4,354,690 FOR ARCHITECT/ENGINEERING
                SUBAGREEMENTS NOT CONTAINING EPA PRIVITY CLAUSE.

                 - EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN
                MADE:   REGION 9 IS CURRENTLY REVIEWING AND DOCUMENTING ISSUES.  A
                MEETING WITH THE»LOCAL OIG TO DISCUSS AND RESOLVE OUTSTANDING
                ISSUES WILL BE SCHEDULED IN NOVEMBER.

                 * DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION:  THIS
                AUDIT  IS EXPECTED TO BE RESOLVED BY MARCH 31, 1993.

                 IG FOLLOUUP STATUS AS OF  9/30/92:  [2]

                 S2CUN1-09-0228-2300044  LOS ANGELES.  CITY OF    CA        3/13/92
                  SuBMry:   INELIGIBLE COSTS INCLUDED  S1.400.564 FOR UNUSED
                EQUIPMENT ITEMS;  $202,058 FOR UNALLOWABLE ARCHITECT/ENGINEERING
                FEES AND $572,354 FOR UNALLOWABLE FORCE ACCOUNT UNREASONABLE
                COSTS  OF $1,010,586 FOR EXCESSIVE ARCHITECT/ENGINEERING AND FORCE
                ACCOUNT.  ADDITIONAL $11,188,321 PLAHT HOT OPERATING IH
                ACCORDANCE  WITH GRANT CONCEPTS.

                 -  EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN
                MADE:   THE  STATE IS STILL REVIEWING THE FORCE ACCOUNT AND OTHER
                TECHNICAL ISSUES.
                                                                        = DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION:   THIS
                                                                       AUDIT IS EXPECTED TO BE RESOLVED BY SEPTEMBER 30,  1993.

                                                                        IG FOLLOUUP STATUS AS OF  9/30/92:   [1]
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                                                                                                       OFFICE OF THE INSPECTOR GENERAL

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