United States
Environmental Protection
Agency
December 1991
5EF& Office of
Inspector General
Report to Congress
Fiscal 1991
.•*/
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ice of the Inspector General
The Inspector General Act of 1978 (P.L. 95-452), as
amended, created Offices of Inspector General (DIG) to
consolidate existing investigative and audit resources in
independent organizations headed by Inspectors General.
At EPA, the OIG's role is to review EPA's financial
transactions, programs, and administrative activities;
investigate allegations or evidence of possible criminal, civil,
and administrative violations; and promote economic, efficient,
and effective operations within the Agency.
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 and allows it to function as the
Agency's fiscal and operational watchdog.
Office of Inspector General
Office of Audit
Kenneth A. Konz
Assistant Inspector General
James 0 Rauch
deputy
Inspector General
John C. Martin
Deputy Inspector General
Anna Hopkins Virbick
Operations Staff
Elissa R Karpl
Director
Technical Assistance
Staff
Gordon Milbourn
Director
Planning and Resource*
Management Staff
Kenneth Hockman
Director
Office of Management
ohn C Jones
Assistant Inspector General
Office of Investigation
Daniel S Sweeney
Assistant Inspector General
Deputy
Vacant
Technical Assessment and
Fraud Prevention Division
Earline Broaden
Director
Administrative and Management
Services Division
Michael J Binder
Director
OIG Divisional Inspectors General are listed on the back panel.
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Profile of Activities and Results
Information reported in the semiannual report for the period
ending March 31, 1991, may have been adjusted subsequent
to the end of that period. Consequently, totals for the
semiannual periods ending March 31 and September 30,
1991, may not add to the fiscal year totals presented below.
Audit Operation* Fiscal 1991
(Dollars in Millions)
• Questioned Costs - Total* $451.6
- Federal Share $339.8
• Recommended Efficiencies
(Funds be Put to Better Use)
Total* $444.5
- Federal Share $428.4
• Costs Disallowed to
be Recovered
- Federal Share $ 73.6
(costs which EPA management
agrees are unallowable and
Is committed to recover or
offset against future payments)
• Costs Disallowed as
Cost Efficiency
- Federal Share $ 69.2
(funds made available by EPA
management's commitment to
Implement recommendations In DIG
performance or preaward audits)
• Recoveries from Audit $ 80.3
Resolutions of Current and Prior
Periods (cash collections or offsets
to future payments)**
• EPA Audits Performed/Issued by DIG 1,688
• Audit Reports Resolved (agreement by 517
Agency officials to take satisfactory
corrective action)
Investigative Operations
Fines and Recoveries (including civil) $8.2
Investigations Opened 257
Investigations Closed 284
Indictments of Persons or Firms 55
Convictions of Persons or Firms 27
Administrative Actions Taken against 49
EPA Employees
Fraud Detection and Prevention Operations
• Debarments, Suspensions, Voluntary 238
Exclusions, and Settlement Agreements
(actions to deny persons or firms from
participating In EPA programs or
activities because of misconduct or poor
performance)
• Hotline Cases Opened 64
• Legislative and Regulatory Items Reviewed 130
• Personnel Security Investigations 816
Adjudicated
•Questioned Costs: Ineligible, Unsupported and Unnecessary/Unreasonable;
and Recommended Efficiencies (Funds be Put to Better Use) are subject to
change pending further review In the audit resolution process.
"Information on recoveries from audit resolution is provided by the EPA
Financial Management Division and Is unaudited.
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Audit Activities
Questioned Costs And Recommended Efficiencies
By Type Of Audits—Fiscal 1991
500
•400]
•3001
-2001
100
j
Construction Grants
|H Federal Questioned
| | Fed. Share Rec.Eff.
Othors
Superfund
Non-Fed. Questioned |
Non-Fed. Rec. Eff. I I
Examples of Significant Audits
The following represents examples of some of our most
significant types of findings. They should not be considered
representative of the overall adequacy of EPA management.
Effects of Many Inert Ingredients
In Pesticides Are Unknown
EPA had not promptly reviewed about 1,300 inert ingredients
in pesticides of unknown toxicity to determine whether they
pose potential adverse effects to human health and the
environment. Inert ingredients in pesticides serve as a
solvent, thickener, or propellant to make them more effective
or usable. EPA issued an Inerts Strategy in 1987 classifying
inerts into four categories: (1) those of unknown toxicity
(1,300), (2) those known to be toxic (56), (3) those potentially
toxic (68), and (4) those generally recognized as having no
toxic effect (300). The Strategy did not detail how EPA would
address those inerts of unknown toxicity even though they
were the largest category. As a result of EPA's actions, the
toxic inert ingredients identified in the Inerts Strategy had
been removed from most of the 1,228 products previously
containing these inert ingredients. However, EPA had not
completed several other actions intended to reduce the risk
from pesticides containing toxic inert ingredients, including
completing the review of 68 inerts identified as potentially
toxic for reclassification as toxic or generally safe.
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Improvements Needed To Protect Wetlands
Protection of the nation's wetlands from the discharge of
dredged or fill material was undermined by EPA's inconsistent
program implementation. Significant management
improvements are needed in EPA's wetlands protection
program if legislative and Agency goals are to be achieved.
EPA had not established measurable goals and commitments
for regional wetlands activities. Regional implementation of
the basic wetlands program elements-enforcement,
permitting, and strategic initiatives-varied in emphasis and
results. Consequently, wetlands regulation was inconsistent
and unpredictable and subject to public distrust and criticism.
Specifically, the Regions did not (1) coordinate with the Army
Corps of Engineers to consistently identify illegal discharges
of dredged or fill material into regulated waters and take
enforcement against those violators, (2) identify and prioritize
wetlands as to value and vulnerability to target limited
program resources and inform the public of most threatened
wetlands.and (3) maintain sufficient data to take regulatory
decisions.
EPA'S $20 Million Financial Management
System May Not Meet Agency Needs
Despite its projected $20 million cost (more than double its
initial estimate of $7.7 million), EPA had not devoted sufficient
attention or resources to effectively implement its new
Integrated Financial Management System (IFMS) that would
combine accounting and budgeting systems with other
financial and administrative systems. EPA had delegated the
task of implementing IFMS to committees, composed largely
of part-time employees. Completion of the initial 3-year
project had been extended 3 years. Many key requirements
for developing a major information system were not met. For
example, the Agency had not updated its needs statement,
feasibility study, and cost-benefit analysis since 1986. Also,
the Agency had not complied with other key Agency and
Federal requirements for a system, including (1) adequate
system testing, (2) risk analysis of the entire IFMS, and (3)
adequate training and provision of guidance to users.
Significant data integrity and security problems led to user
dissatisfaction and the development of duplicate systems.
Agency management agreed with our findings and has taken
actions to significantly improve the Financial Management
System.
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EPA Did Not Aggressively Pursue Regulation
Of Potentially Harmful Chemical Substances
EPA's Office of Toxic Substances (OTS) had regulated few
existing chemicals thought to pose a significant risk to
humans. There are over 60,000 existing chemicals in the
Toxic Substances Control Act (TSCA) inventory, of which
about 10,000 potentially pose a health risk. OTS had not
followed established guidelines for designating chemicals for
priority review if data indicates a chemical may pose a
substantial risk from cancer, genetic mutations, or birth
defects. Also, OTS had not developed adequate procedures
to expedite ongoing priority reviews. As a result, it took years
for OTS to review and determine if a chemical posed an
unreasonable risk to health or the environment. Since
January 1, 1977, the effective date of TSCA, only four existing
chemicals had been regulated (PCBs, CFCs, dioxin, and
asbestos). The Agency agreed with our findings and began
implementing our recommendations.
EPA Region 8 Created A Personal Services
Relationship With Support Contractor
Region 8's administration of support contracts with Computer
Sciences Corporation (CSC) created a personal services
relationship between EPA and CSC contract employees,
thereby violating federal civil service laws and the Federal
Acquisition Regulation. Delivery order project officers
prepared broad statements of work which were not adequate
to ensure that CSC would perform needed tasks and services.
Region 8 personnel extensively supervised CSC employees to
ensure they performed tasks and services as intended. CSC
employees were commingled with Region 8 employees, were
furnished principal tools and equipment, and performed
ongoing services which lasted more than 1 year and were
expected to continue indefinitely. Region 8 regarded CSC
employees as an integral part of the Region's organization in
carrying out EPA's mission, and paid CSC for more hours
than its employees worked. The Agency agreed with our
findings and has committed to take corrective action.
EPA Unnecessarily Delays Responsible
Parties From Cleaning Up Hazardous Sites
Completions of Superfund cleanups in 3 of 4 EPA regions
were unnecessarily delayed by untimely review of responsible
parties' (RP) work products, failure to enforce stipulated
penalties against RPs for noncompliance with voluntary
agreements, and inadequate monitoring of contractors,
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possibly further degrading the environment. At 24 of 39 sites
reviewed, EPA's review and approval of RP documents and
plans took up to 36 months due to lack of guidelines for
completing reviews; unauthorized extensions; multiple
revisions of documents; lack of a milestone tracking system;
and personnel turnover.
EPA regions were not assessing stipulated penalties for
RPs' noncompliance with post-settlement milestone dates.
For 15 sites in noncompliance, for example, the regions
assessed penalties against RPs in only three cases totaling
$45,000, failing to assess potential penalties of $4,855,500
against RPs in seven other cases. EPA also gave up
potentially $8 million in sanctions against RPs by not referring
them for enforcement action. The regions generally limited
their enforcement actions to verbal negotiations or warning
letters. The Agency agreed with our findings and had initiated
corrective action.
EPA Overstated Remedial Action
Starts In Its Report To The Congress
Inadequate documentation and insufficient controls resulted in
EPA incorrectly reporting to Congress that it had met the
National Priorities List (NPL) remedial action starts
requirement of the Superfund Amendments and
Reauthorization Act of 1986 (SARA). In an October 17, 1989,
report to Congress entitled "Commencement of Post-SARA
Remedial Actions," EPA stated that it had started 178
remedial actions at NPL sites. We found that many of the
reported 178 remedial actions did not represent the start of
initial, substantial, and continuous physical on-site cleanup
actions at the most contaminated NPL sites. From our sample
of 42 remedial actions included in the report, we concluded
that 28 actions did not meet the criteria established by SARA
and its legislative history.
Los Angeles Claimed $90.3 Million In Questioned
Costs
EPA awarded nine grants totaling $101,520,254 to the City of
Los Angeles for various projects, including the design and
construction of a wet weather water reclamation plant; the
planning, design and construction of a sludge processing and
disposal system; portions of the Hyperion Energy Recovery
System; and various tank modernization projects. We
questioned $10,871,601 of the grantee's final claim as
ineligible, and $79,434,029 of project costs as unreasonable,
including $57,928,957 claimed for the underutilized Tillman
Reclamation Plant. Although the plant was designed and
constructed as a reclamation plant, at an increased level of
expenditure and funding, it was not being used to reclaim any
wastewater.
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Grantee's $36.8 Million Project Claim Questioned
After 12 years of Violating Discharge Limitations
EPA awarded two grants to Gary, Indiana, Sanitary District
(GSD) for modification of an existing wastewater treatment
plant and the training of facility operators. Because of its
inability to properly operate and maintain the modified plant,
GSD has consistently violated its National Pollutant Discharge
Elimination System permit since 1978. In 1983, EPA obtained
a final Consent Decree requiring GSD to comply with the
effluent limitations specified in its permit and, in 1984, the
United States filed a Motion to Enforce the Consent Decree.
EPA filed an additional complaint in 1986 against the grantee
for violations of the Toxic Substances Control Act (TSCA). To
settle the Motion to Enforce and the TSCA complaint, EPA
entered into a modified Consent Decree in 1987 requiring
several actions by GSD.
We found that GSD still had not complied with the
modified Consent Decree, and we questioned as ineligible the
grantee's total claimed costs of $36,853,715. Should the
grantee eventually comply with the Consent Decree, almost
$4 million will still remain questioned as ineligible or
unsupported.
Inefficient Contracting Practices May Cost EPA An
Extra $10.7 Million for Automatic Data Processing
(ADP) Equipment And Services
EPA was delayed in competitively awarding a contract to
procure workstations and other ADP equipment having an
estimated value of $206 million. (Even if awarded in
December 1991, as planned at the completion of our review in
July 1991, the competitive award would be 19 months
overdue.) As a result, assuming full contract performance,
EPA could incur excess costs of as much as $8.4 million over
the life of an interim contract awarded to a small and
disadvantaged firm for such equipment. EPA did not use all
available means to modify the contract to take advantage of
decreasing market prices after the interim contract's award.
Also, EPA did not perform a sufficiently thorough analysis of
cost data provided by the contractor during negotiations and
could pay $2.3 million more than the contractor actually incurs
for certain expenses, such as freight, rent, and insurance.
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Audit Resolution
During fiscal 1991, the Office of Inspector General issued
1,688 audit reports and closed 517. Of the 309 audit reports
in the follow-up system at year end, 68 reports remained for
which no management decision was made within 6 months of
issuance.
For the audits closed, $73.6 million of questioned costs were
disallowed for recovery, and $69.2 million were agreed to by
EPA management as funds that could be put to better use.
The Agency reported cost recoveries from current and prior
periods of $11.5 million in cash collections and $68.8 million
in offsets against billings.
Significant Problems Render EPA's Audit Followup
System Unreliable
Our September 1991 report, the fourth in a series assessing
the Agency's audit followup program, found that data in EPA's
Management Audit Tracking System (MATS) was still
incomplete and incorrect. We found that EPA Management's
Semiannual Reports to the Congress on Audits for fiscal 1990
produced from the system were seriously flawed. The
reported number of audits on which final corrective actions
had been taken was inaccurate and reported recoveries as a
result of audit findings were grossly understated. Our review
of three EPA regions found unreported recoveries ($7.4
million) were almost as much as the Agency reported ($8.3
million) for all 10 regions. Also, an additional $7.4 million of
disallowed costs that were reduced through the appeals
process in those three EPA regions were not reported as
writeoffs in either of the 1990 semiannual reports to Congress.
Region 9's Air Grants Program Deficiencies Not
Corrected
In March 1987 we reported that Region 9's air grants program
was hindered by inadequate controls. Air grants totaling $2.6
million for fiscal 1983 through fiscal 1985 were identified as
ineligible. Our followup report found that Region 9 had not
developed effective procedures to (1) ensure that grant
recipients meet the statutory maintenance of effort (MOE)
requirements and (2) monitor grant performance. Four of the
grantees discussed in our prior audit still had not met their
required MOE requirements for all grants awarded. Of the
$2.6 million of ineligible grants made from fiscal 1983 to fiscal
1985, $1.5 million had not been recovered and grantees
received about $1.9 million of additional ineligible grants.
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Investigative Activities
During this fiscal year, our investigative efforts resulted in 55
indictments, 27 convictions and over $8.2 million of fines and
recoveries from persons or firms who defrauded the Agency.
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.
Two actions resulting from the contract lab investigations are
described below.
Major Testing Firm Fined $1 Million
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), pled guilty in
April to making false statements to EPA. 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. U.S. Testing, by "peak
shaving" (manual manipulation of calibration), which violated
the required testing sequence, sought to disguise its failure to
conduct timely tests.
Connecticut Company Backdated Results, Used
Unapproved Lab
A Connecticut company, YWC Inc., pled guilty in December
1990 to two charges of making false statements to EPA and
was fined $500,000. EPA's contract with YWC required them
to analyze water samples within seven days of receipt and
soil samples within 10 days. YWC's York Laboratories
Division facility in Monroe, Connecticut, was an approved CLP
site. YWC was charged with backdating over 60 analyses
and using a then-unapproved laboratory at Whippany, New
Jersey, to do the analyses.
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Electrical Contractors Sentenced for Racketeering
Michael Gelb, president, and Thomas Gelb, vice president,
Federal Chandros Inc., were sentenced in December 1990 for
their involvement from 1980 to 1986 in a scheme to defraud
the City of New York by submitting false or fraudulently
altered payment claims for electrical work to various City
agencies. One of the projects involved was the Owls Head
Water Pollution Control plant, which was funded by an EPA
construction grant. The Gelbs photocopied original invoices
paid by Federal Chandros and subsequently altered dollar
amounts and delivery information. They then submitted them
to the City for payment. The fraudulent billings for the Owls
Head plant totalled $79,180. Michael Gelb was sentenced to
11 months in jail and fined $20,000. His brother received a
seven month sentence and was also fined $20,000.
Fraud Alleged at Superfund Cleanup Site
Terry Lee Tebben and Daniel Workman, employees of Geo-
Con, Inc., a Pennsylvania company, have been charged with
fraud in connection with the cleanup of a Superfund site at
Bruin Lagoon, Butler County, Pennsylvania. EPA funded a $4
million contract with Geo-Con to clean up the lagoon, which
was used by the Bruin Oil Company since the 1930's and
contaminated with, among other things, sulfuric and
hydrochloric acid.
Tebben allegedly used the finger of a rubber glove and
grease to cover up the air monitors required by the contract,
causing them to give false readings on the amount of
hazardous gases being released.
Workman of Geo-Con also allegedly pumped air through
the water metering system, leading to $62,000 in false claims
for reimbursement for water treated.
Unregistered Pesticides Shipped Abroad
Kamal Salieb Gabra of New Jersey pled guilty to charges that
his three businesses—Liberty International Agricultural
Products, Nevacide Ltd, and Hercules Chemicals USA—sold
mislabeled, unregistered pesticides to overseas companies in
violation of the Federal Insecticide, Fungicide, and
Rodenticide Act (FIFRA), which is administered by EPA.
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Fraud Prevention Activities
Suspension and Debarment Activities
EPA's policy is to do business only with contractors, grantees,
and persons who are responsible, honest, and who comply
with applicable rules and regulations. EPA enforces this
policy by suspending or debarring any organization or person
for acting improperly, having a history of substandard work, or
willfully failing to perform on EPA or other Federally funded
activities. Suspensions and debarments deny participation in
Agency programs and activities to those who represent a
business risk to the Government.
Both procurement and nonprocurement debarments or
suspensions by one agency are effective in all agencies.
Suspension/Debarment Activities
r250
200
1-150
.100
•50
FY 89 FY 90
Includes suspensions, debarment, and voluntary settlements
FY91
In fiscal 1991, 238 debarment or suspension actions were
taken. Examples include:
• Based on an DIG proactive investigation, John G. Mason, a
contract wastewater treatment operator, was found guilty of
submitting fraudulent effluent reports, required under the
National Pollutant Discharge Elimination System, to the State
of North Carolina. He was sentenced to jail and fined. Mason
was also debarred from all Federal procurement and non-
procurement programs for 3 years.
• Chem-TLE Environmental Services, Inc. (Chem-TLE), the
EPA Emergency Response Cleanup Services Zone Contractor
responsible for cleaning up a dioxin site in Lexington,
Kentucky, was charged with submitting false claims to the
EPA. EPA suspended and subsequently debarred Chem-TLE
from all future assistance, loan and benefit programs and
direct Federal procurement for three years. EPA also
debarred B.F. Rippy Jr., Chem-TLE's operations manager,
and Thomas L. Ewing, the President of Chem-TLE.
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• Dominic Nicassio, Inc. (DNI), Dominic Nicassio, Western
Pennsylvania Minority Enterprises Inc. (WPME), and Eugene
Minard all allegedly participated in a scheme to fraudulently
obtain EPA-funded sewer construction contracts totaling
millions of dollars by misrepresenting that WPME was a
legitimate minority business enterprise. EPA has suspended
WPME, Minard, DNI and Dominic Nicassio.
• Jerome Brown, president of U.S. Brick Corp. (USBC),
Brooklyn, N.Y., and an officer of Atlantic Demolition, Inc. (ADI)
was convicted of bribing an asbestos inspector. All
respondents were suspended by EPA, and USBC was
debarred for 3 years.
Personnel Security Program
The Personnel Security Program is one of the Agency's first
line defenses against fraud, using background investigations
to review the integrity of EPA employees and contractors.
During fiscal 1991, 816 investigations were reviewed, resulting
in the following actions:
• 2 employees resigned prior to administrative removal for
falsifying their SF-171S, Applications for Federal Employment,
by not listing previous convictions for drug trafficking and
writing worthless checks.
• 6 employees received oral reprimands/verbal counseling
regarding failure to report delinquent taxes, delinquent debts,
and previous convictions for driving while intoxicated.
• 3 employees received written reprimands for falsifying their
SF-171s by not listing previous terminations and convictions.
• 3 employees received 14-day suspensions for not listing
prior convictions on the SF-171.
• 11 employees had to submit corrected SF-171S for failure to
list minor offenses.
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Hotline Activities
The OIG Hotline Center opened 64 new cases and completed
and closed 47 cases during fiscal 1991. Of the 47 cases
closed, 14 resulted in environmental, administrative, or
prosecutive action. We also received 4,157 calls in which
callers were referred to the appropriate program office, State
agency, or other Federal agency for assistance.
The following are examples of corrective action resulting from
calls to the OIG Hotline Center:
• A complainant alleged that a manufacturing company had
dumped chemical wastes in or near water supplies. A review
of the complaint disclosed illegal activity which resulted in a
joint investigation by EPA's Chicago Criminal Investigations
Division, the Federal Bureau of Investigation, and the U.S.
Army Criminal Investigation Division. As a result, a federal
grand jury in Michigan indicted six individuals for conspiracy;
unlawful treatment, storage and disposal under RCRA; and
failure to report a release under CERCLA.
• A complainant alleged that an EPA project manager
accepted gifts in return for influencing contract awards. A
review of the complaint disclosed that the project manager
had a close personal relationship with a contractor's family
and that the employee should have recused himself from
managing and evaluating the contractor. The project
manager's failure to take this step created a reasonable
appearance of giving preferential treatment. As a result of
this complaint, the employee has been counseled, reassigned,
and received a written reprimand.
If you are aware of any fraud, waste, or mismanagement,
please contact the EPA Inspector General Hotline or the
appropriate Divisional Inspector General listed on the
back panel.
• Information is confidential.
• Calls can be made toll free on (800) 424-4000. Callers
in area code 202 should use 260-4977. FTS network
callers may also use 260-4977.
Remember—Act Like It's Your Money—It Is!
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Divisional Inspectors General
Region Subject Name
Headquarters Audit (Internal Edward Gekosky
Audit Div)
Investigations Francis C. Kitey
(Wash. Fid Office)
1 &2
4&6
7&8
9&10
Audit
Audit
Audit
Audit
Audit
Audit
Paul McKechnie
Investigations Robert M. Byrnes
Paul R. Qandolfo
Investigations Martin Squitieri
Mary Boyer
Investigations James F. Johnson
Anthony Carrollo
5,7 & 8 Investigations Alex Falcon
Nikki Tinsley
Truman R. Beeler
Investigations H. Brooks Griffin
Telephone
FTS 678-8222
(703) 308-8222
FTS 678-8282
(703) 308-8282
FTS 835-3160
(617)565-3160
FTS 264-0399
(202) 264-0399
FTS 597-0497
(215)597-0497
FTS 597-9421
(215)597-9421
FTS 257-3623
(404) 347-3623
FTS 257-2398
(404) 347-2398
FTS 353-2486
(312) 353-2486
FTS 353-2507
(312) 353-2507
FTS 276-7824
(913) 551-7824
FTS 484-2445
(415) 744-2445
FTS 484-2465
(415) 744-2465
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