.•to UNITED STATES ENVIRONMENTAL PROTECTION AGENCY WASHINGTON, D.C. 20460 Dtt L 0 1991 THE ADMINISTRATOR The President The White House Washington, D.C. 20500 Dear Mr. President: This letter is my annual report to you on the management integrity programs of the U. S. Environmental Protection Agency (EPA), required by the Federal Managers' Financial Integrity Act. I am pleased to report that EPA's management control and financial systems, taken as a whole, reasonably assure that the objectives of- the Act have been achieved. EPA's Inspector General has reviewed the Agency's processes for carrying out the requirements of the Act. He has concluded that the Agency implements the Act in a reasonable and prudent manner. MANAGEMENT INTEGRITY IS A HIGH PERSONAL PRIORITY EPA is faced increasingly with a long list of statutory deadlines and requirements, and we seek constantly to improve in reaching out to a broad spectrum of the public to protect health and safety, while recognizing economic realities. This is a difficult and complex task, but an essential one if the American people are to receive the environmental protection services they require. Ensuring the highest standards of personal, organizational and systems integrity in EPA is one of my personal priorities. Through our Senior Council on Management Controls, my top managers and I ensure that this priority is shared with all management and staff levels of the Agency. We want to encourage a culture in which potential problems are forthrightly identified and corrected early; we want our people empowered to be leaders in prevention. I sincerely believe that we cannot build a sound long-term quality approach to environmental protection unless we give priority attention to management vulnerabilities. EPA is committed to identifying, preventing and following up on management vulnerabilities in contracts, facilities and data management, and we are making a major investment in total quality management to make this happen. ^ . : ^ i , -I- r ' — Printed on Recycled Paper O on ------- MAJOR MANAGEMENT CONTROL AND FINANCIAL SYSTEMS ACCOMPLISHMENTS i Some of EPA's notable accomplishments for FY 1991 include: EPA's Senior Council on Management Controls; EPA's Senior Council continues to operate very effectively in heightening management attention to emerging issues and the correction of material weaknesses. Its activities — • Keep EPA's senior managers alert to potential problems identified by the Office of the Inspector General (OIG) and the General Accounting Office (GAO), as well as concerns of the Office of Management and Budget (OMB); • Provide to the Agency strategies and guidance for the internal control and audit management programs; and • Increase awareness and discussions of management controls at senior managers' conferences. Improved Program Effectiveness: EPA continues to promote the processes of the Federal Managers' Financial Integrity Act (FMFIA) as a management tool. Program effectiveness has been improved through increased training, and a number of offices have established work groups to improve their management control programs. Linking Management Controls with Other Agency Processes; Achieving the President's vision of effective environmental protection requires new approaches to how we develop our budget. We are now examining the Agency's statutory mandates across all of our offices in an effort to integrate programmatic activities to achieve the greatest environmental payoffs. EPA's budget proposal now focuses on several key priority themes, which cross traditional program and environmental media boundaries. We will initiate selected cross-program vulnerability assessments in our 1992 management control processes. Using Total Quality Management (TQM) Concepts in Implementing FMFIA: EPA believes that the philosophies of TQM are directly applicable to our FMFIA processes. For example, one manager used a "Quality Action Team" to prepare and update the FMFIA description of activiti€»s. This manager now uses the descriptions as the branch's standard operating procedures, because of their completeness and accuracy. Validating Effectiveness of Corrective Actions; Managers are now required to verify the effectiveness of their corrective actions to remedy weaknesses. EPA has a management information system that tracks the progress of corrective actions, including the final step of verifying the effectiveness of the actions that have been taken to cure the weakness. ------- Rotational Assignments in the Management Integrity Program; EPA's rotational assignment program has resulted in improved understanding of the management control and audit management programs by participating offices. Office-Specific Accomplishments: Several offices improved their own management integrity efforts. • Our Office of Solid Waste and Emergency Response established several TQM/FMFIA work groups to improve and simplify various office processes. ' • The Office of Research and Development established its own Council on Management Controls, modeled after the Agency's Senior Council on Management Controls. • EPA's Region III Office developed an Automated Management Control Plan and distributed it to the other Regions and Headquarters Offices. Response has been highly favorable, and many have elected to use this more efficient approach. These and other accomplishments reflect the seriousness and consideration with which EPA managers regard our management control program. AREAS RECEIVING PARTICULAR MANAGEMENT ATTENTION BY EPA Procurement-Related Issues: Superfund Operations Reorganization - A plan for the reorganization of EPA's Superfund/RCRA Procurement Operations has been prepared. This reorganization is intended to serve the changing needs of the Superfund program and will facilitate EPA's efforts to ensure high quality contract management in the Regional offices. Contract Management Improvements - The ARCS review findings and reports by EPA's Inspector General point to persistent, widespread problems in EPA's oversight of the large, task order contracts that are vital to most EPA functions and sites. A senior management team will review contract management personnel and practices in all EPA headquarters and field offices during FY 1992. Our goal is to emphasize preventative measures to head off a series of embarrassing audits and costly corrective actions. Building continuous improvement into our contracting operations is a top management priority. Conflict of Interest - EPA issued Procedures for Documenting Organizational Conflict of Interest Decisions Prior to Contract Award on July 23, 1991. A recent Comptroller General's decision involving an EPA Contracting Officer's ------- proper decision to exclude a contractor due to a potential Organizational Conflict of Interest (OCI), provided clarification of a Contracting Officer's responsibility in evaluating OCIs. The new procedures, based in part on the Comptroller General's decision, provide guidance for Contracting Officers to use in resolving and documenting potential OCIs prior to contract award. The procedures and the award upon which the Comptroller General's decision was based are examples of the more rigorous interpretation and application of the conflict of interest requirements of the Federal Acquisition Regulation in EPA, particularly in the Superfund program. EPA has published a proposed Conflict of Interest Rule in the Federal Register which, when finalized, will provide the Agency with comprehensive and consistent guidelines and stronger contract clauses to protect the Superfund program from conflict of interest. A data base for tracking and researching conflict of interest actions is being developed. It will serve as a valuable tool for Contracting Officers throughout the country to use in making conflict of interest determinations. Contract Property - The Office of the Inspector General reviewed EPA's oversight of contractor property control systems in January 1991, and found inadequacies. EPA has revised its Contract Property Administration Program to comply with the Inspector General's recommendations. Centralized Contract Management and Administration Efforts in the Office of Solid Waste and Emergency Response (OSWER) - OSWER's Technology Innovation Office has centralized its contract administration efforts to improve efficiency, and has instituted new control techniques. Elsewhere in OSWER, similar initiatives are underway to ensure that contract management and administration responsibilities are carried out in a prudent manner. Scientific Misconduct: EPA is cognizant of the national concern about incidents of scientific misconduct that may affect the validity of research findings. This issue has potential management control implications for EPA. We are addressing the issue through a work group, which will develop policies and guidelines to ensure the integrity of the scientific information that affects our programs. Contract Laboratory Program: EPA has conducted a major review of management controls to ensure the integrity of data coming from laboratories that do work for EPA under contracts. The review concluded that there are material weaknesses in the management ------- controls of the program. It is important that data from the contract laboratories be accurate because of its potential impact on regulatory policy and enforcement decisions. The issue is addressed in the material weakness section below. HIGH RISK AREAS We have made great strides in strengthening the high risk areas identified by OMB. Based on our corrective actions to develop an integrated data base for enforcement activities, EPA is requesting that the enforcement issue be removed from OMB's high risk list. The corrective actions have been validated and proven effective. In addition, OMB has lowered our financial systems issue from a high to a low priority. Although EPA has made progress with the Superfund enforcement issue, OMB has added two new Superfund issues to the list: Alternative Remedial Contracting System (ARCS) Contract Management and Accelerated Remedial Clean-up. We have made it an Agency priority to resolve these high risk issues expeditiously. These areas are discussed in Enclosure C. MATERIAL WEAKNESSES AND NONCONFORMANCES EPA is reporting 16 material weaknesses, seven for the first time. In order of priority, they are: 1. ARCS Contract Management; Charges made by ARCS contractors appear excessive; program management costs were high relative to the charges for site clean-up work; EPA is not conducting effective administration and oversight; and, EPA has to improve oversight without overloading ARCS contractors with administrative paperwork. 2. Accelerating Remedial Cleanup: EPA's clean-up of Superfund sites has been criticized as too slow. The issues are: 1) what are EPA's options for accelerating the rate of clean-up at Superfund sites, and 2) whether the Superfund program uses realistic assumptions when evaluating and managing risks at Superfund sites. 3. Federal Facilities; EPA has not had sufficient resources to perform an adequate level of oversight of other Federal agencies' environmental compliance and restoration plans and activities. We recognize that this is a government-wide challenge that needs improved interagency attention. EPA's experience with two military bases that are on Superfund's National Priorities List indicates that EPA's oversight and assistance role for newly planned DOD base closings will be more resource intensive than the facilities clean-up work anticipated earlier. ------- 4. Contract Laboratory Program: The Contract Laboratory Program is vulnerable to waste and fraud, and does not have a national tracking system to provide an early identification of problems and involve top management in their resolution. 5. Superfund: EPA's 1989 major review of the Superfund program (entitled "A Management Review of the Superfund Program," also known as the "90-Day Study") identified the Superfund program as a material weakness. » 6. Data Integrity for Pesticides and Toxic Substances: The effectiveness of the program is weakened by EPA's inspectors' lack of training in fraud detection in a laboratory setting; by the advance notice given when laboratories are to be inspected; and, by the lack of reporting mechanisms to identify laboratories and the studies they are conducting on various chemicals. 7. Growing Backlog of Requests for Audits of EPA Contractors; Almost 90% of EPA's contracting dollars are spent on cost reimbursable contracts. It is critical that incurred cost audits of contracts be conducted in a timely manner. There is a substantial and growing backlog of requests for audits of EPA contractors, including at least 390 unmet requests for incurred cost audits. 8. Implementation of Storm Water Permitting Requirements Under the Clean Water Act; EPA has worked to meet the requirements and deadlines for storm water permits under the Clean Water Act amendments of 1987 and has met most of the NPDES program requirements. However, the Agency has missed deadlines in the law and is substantially behind in dealing with unregulated discharges of storm water. 9. Management of Research and Development Extramural Resources; With increased R&D funding and limited workyears, there is growing inability to adequately manage our extramural resources. 10. Research and Development Facilities: The majority of EPA's R&D laboratories are more than 20 years old and in serious disrepair. High quality, timely, scientific and technical information required to meet EPA's goals cannot be generated in these facilities. 11. Audit Follow-up: The Agency's audit follow-up practices are not adequate to ensure that corrective actions resulting from audit recommendations are accurately tracked and reported. ------- 12. Inadequate Resources for Research and Development Laboratory Operating Expenses: The shortage of resources for R&D laboratory operating expenses has adversely affected activities essential to operating the labs. 13. Lack of Effectiveness and Productivity in Chemical Testing: There has been a lack of effectiveness and productivity in chemical testing. Without sufficient test data on chemicals, EPA is impeded in taking appropriate regulatory action. 14. Research and Development Equipment: EPA has no process for equipment planning, proper forecasting of needs, ensuring compliance with property management procedures, or planning for sufficient budgetary support for adequate scientific equipment. As a result, EPA's scientific and "technical equipment is becoming obsolete faster than it is being replaced. 15. Weaknesses in Pesticides/ Antimicrobial Program: Inadequate data integrity, systems support, and enforcement follow-up may exist in the antimicrobial program. 16. Pesticides Disposal Program: State and local actions can disrupt implementation of the program and management of its resources. The Enforcement Data Integration weakness reported last year as a material weakness has been corrected. EPA now has the ability to develop enforcement actions and set enforcement priorities by associating data on compliance and enforcement activities from the'various program offices' data bases. EPA is reporting five material nonconformances in its accounting system, the Integrated Financial Management System (IFMS). These nonconformances, ranked in order of priority, are: 1. Lack of centralized capability to record, bill, and write- off accounts receivable: IFMS accounts receivable capabilities are not yet fully implemented. 2. Reconciliation to external Treasury Department reports: The procedure used to reconcile external Treasury Department reports is inadequate. 3. Reconciliation between the Personal Property Accountability System and IFMS: Property management and accounting records are not subject to adequate controls to assure accurate data. ------- 8 4. General ledger accounts from the prior accounting system have not yet been converted to the IFMS: The ledger accounts from the prior accounting system have not yet been entered into the IFMS. 5. More automation of the exchange of information between IFMS and other administrative systems: Opportunities exist for more automation of the accounting system with other administrative systems. The Lack of Complete Financial Reporting reported last year as a material nonconformance has been corrected. An ad hoc reporting system was developed to meet user needs. CONCLUSION EPA's management controls are in place, reviewed and evaluated to reveal strengths and weaknesses. We are pleased with progress made in securing senior managers' attention to identifying and disclosing problems early and in building systems to institutionalize follow-up, correction and prevention of recurrences. The Agency's administrative, financial and management control programs are critical to the success of our environmental protection work. We are committed to improving and strengthening these programs on a continuing basis. Sincerely, LC&L^ • William Enclosures (5) A - Statistical Summary of Performance B - Review Process C - Progress Report on High Risk Areas D - Material Weaknesses/Corrective Actions E - Material Nonconformances/Corrective Actions ------- U. S. ENVIRONMENTAL PROTECTION AGENCY STATISTICAL SUMMARY OF PERFORMANCE FISCAL YEAR 1991 ENCLOSURE A PAGE 1 OF 4 SECTION 2. INTERNAL CONTROL SYSTEMS Overall Compliance: Yes X year achieved 1983. Number of Material Weaknesses: In year indicated, number reported for the first time, Prior Years: 16 1989 Report: 6 1990 Report: 5 1991 Report: 7 TOTAL: 34 For that year, number that have been corrected. 15 2 0 r 18 For that year, number still pending. 1 4 •5 6 16 The total number of weaknesses corrected in 1991: Pending Material Weaknesses*: Category: Program Management Number; 13 Year Identified Target for Correction 1. 2, 3. 4. 5. 6. 8, 9, 10, 11, 12, 13, ARCS Contract Management 1991 TBD Accelerating Remedial Cleanups 1991 FY 1993 Federal Facilities 1991 TBD Contract Laboratory Program 1991 TBD Superfund 1989 FY 1992 Data Integrity for Pesticides and Toxic Substances 1991 FY 1992 Implementation of Storm Water Requirements Under the Clean Water Act..1991 FY Audit Follow-up 1989 R&D Laboratory Operating Expenses 1990 Chemical Testing 1990 Pesticides' Antimicrobial Program 1990 Pesticides Disposal Program 1990 Requests for Audits of Contractors 1991, FY .FY FY FY FY 1992 1992 1995 1992 1992 1992 .Ongoing * Due to the OMB format for Enclosure A, these material weaknesses are presented in priority order within the appropriate category. Please see the narrative ------- U. S. ENVIRONMENTAL PROTECTION AGENCY STATISTICAL SUMMARY OF PERFORMANCE FISCAL YEAR 1991 ENCLOSURE A PAGE 2 OF 4 portion of the letter for the ranking of material weaknesses. —Program Execution ** —Systems Development & Implementation —Asset Disposition —Environmental Impact —Safety/Health-Related —Other (Specify) 11 (#1,4,5,6,7,8 9,10,11,12,13) 0 0 0 2 (#2,3) 0 Category: Functional Management Number: Year Identified Target for Correction 14. R&D Extramural Resources, 15. R&D Facilities 16. R&D Scientific Equipment, —Procurement —Grant Management —Personnel & Organizational Management —ADP Security —Payment Systems & Cash Management —Loan Management & Debt Collection —Property & Inventory Management —Other 1990 FY 1994 1989 FY 1993 1988 FY 1994 1 (#14) 0 0 0 0 2 (#15,16) 0 TOTAL 16 SECTION 4. FINANCIAL MANAGEMENT SYSTEMS Compliance Assurance: Overall Compliance: o Compliance with financial information standards o Compliance with systems functional standards Yes No Year Achieved X 1983 (with exceptions as noted in Enclosure E) X 1983 (with exceptions as noted in Enclosure E) ------- U. S. ENVIRONMENTAL PROTECTION AGENCY STATISTICAL SUMMARY OF PERFORMANCE FISCAL YEAR 1991 ENCLOSURE A PAGE 3 OF 4 Number of Nonconformances: In year indicated, number reported time. Prior years: 15 1989 report: 3 1990 report: 0 1991 report: 0 TOTAL: 18 For that year, number that have been corrected. 12 1 0 0 13 For that year, number still pending. 3 2 0 0 The total number of nonconformances corrected in 1991: Pending Nonconformances; Name of System IFMS IFMS IFMS/PPAS IFMS IFMS Type of Nonconformance Financial Information (Data Quality) Financial Information (Data Quality) Financial Information (Data Quality) Financial Information (Data Quality) System Function (Effective Interfaces) Title of Nonconformance Regional accounts receivable recording, documentation, and collection problems have impacted the accuracy of the general ledger accounts receivable balances. Comprehensive reconciliation between Treasury reports and IFMS needs to be performed. Reconciliation with property and accounting records for FY 1989 and 1990 needs to be performed. General ledger account adjustments as a result of the implementation of IFMS need to be accomplished. Opportunities exist for greater interface between the accounting system and other administrative systems. ------- U. S. ENVIRONMENTAL PROTECTION AGENCY ENCLOSURE A STATISTICAL SUMMARY OF PERFORMANCE PAGE 4 OF 4 FISCAL YEAR 1991 Number of Section 4 Systems in Operation; Type of System: 1990 1991 Core Financial System 1 1 Subsidiary systems: Budget planning/formulation 1 1 Payroll/personnel 1 1 Purchasing/grants 1 1 Property/inventory 1 I Other (Contract Information/ 3 3 Contract Payment/Document Control) • 0. 0. Total 8 8 ------- U. S. ENVIRONMENTAL PROTECTION AGENCY ENCLOSURE B REVIEW PROCESS PAGE 1 OF 7 FISCAL YEAR 1991 SECTION 2: Description of Organization and Structure of Review Process: EPA's FMFIA review process is organized around eleven primary tasks: 1. Issuing annual policy with a list of areas to emphasize and a planning calendar. 2. Organizing and segmenting the Agency. This entails updating records, responding to reorganizations and ensuring full coverage. 3. Updating event-cycle documentation. 4. Assessing each segment's risk. This includes identifying programs with more susceptibility to waste, fraud or mismanagement. EPA has a three-year risk assessment cycle. EPA's most recent Agency-wide vulnerability assessment was performed in FY 1989. A few offices completed assessments due to reorganizations in FY 1991. In early FY 1992, EPA will embark on a new approach in conducting risk assessments. We will continue to conduct assessments along organizational lines. Additionally, we will conduct assessments across organizations and media lines. 5. Developing the Management Control Plan (MCP) to schedule internal control evaluations [Internal Control Reviews (ICRs) and Alternative Internal Control Reviews (AICRs)]. 6. Evaluating the effectiveness of controls through AICRs and ICRs. The reviews may include Office of Inspector General (OIG) and General Accounting Office (GAO) audits, management reviews, and other internal and external studies. 7. Developing corrective action plans for weaknesses identified in ICRs and AICRs. These action plans include milestone dates for correcting particular weaknesses and validation procedures that ensure the corrective actions are effective. 8. Implementing corrective actions according to the action plans. 9. Submitting CATS quarterly updates to track and monitor weaknesses and assure quality. 10. Reviewing and evaluating effectiveness and cost efficiency of the FMFIA program and reporting the results in the annual report on controls to the President and Congress. ------- U. S. ENVIRONMENTAL PROTECTION AGENCY ENCLOSURE B REVIEW PROCESS PAGE 2 OF 7 FISCAL YEAR 1991 11. Linking FMFIA and budget preparation to identify resources to correct material weaknesses and high risk areas. The Assistant Administrator for Administration and Resources Management, as the Agency's Senior Internal Control Official, is responsible for oversight of the FMFIA review process. Primary Organization Heads (POHs) are EPA's senior managers who oversee EPA's major organizational components. They included in FY 1991, the Deputy Administrator, nine Assistant Administrators, ten Regional Administrators, the Inspector General and the General Counsel. Directives and guidance are in place for POHs and their Internal Control Coordinators (ICCs) to carry out their responsibilities under FMFIA. To facilitate complete FMFIA coverage, EPA's assessable unit segmentation structure parallels the Agency's budget and program operating structure. Managers of a particular operation are responsible and accountable for its management controls. In FY 1991, EPA managers reported that they conducted 48 formal ICRs and 807 AICRs. EPA's MCP shows that 33 ICRs, 808 AICRs, and numerous other reviews are planned for FY 1992. In FY 1991, we issued improved guidance outlining the criteria for developing event cycle documentation. This was accentuated through management controls workshops held in Headquarters and the Regions. EPA continues to gain assistance from GAO and OIG in evaluating the effectiveness of internal controls. Issues raised in audits are discussed with senior and program managers, and often are addressed in the POH assurance letters. Several such issues are reported in this letter as material weaknesses. Each year, we ask the Inspector General to suggest potential material weaknesses. In 1991, the IG presented several issues at the September 12 meeting of the Senior Council on Management Controls. Representatives from OMB and GAO attended this meeting and identified their recommended material weaknesses for EPA managers to consider. These suggestions are factored into our FMFIA reporting. Management initiatives undertaken by EPA in FY 1991 have improved internal control processes in an already successful FMFIA program. • Automated Management Control Plan (AMCP): Our Region III office automated their Management Control Plan. This data ------- U. S. ENVIRONMENTAL PROTECTION AGENCY ENCLOSURE B REVIEW PROCESS PAGE 3 OF 7 FISCAL YEAR 1991 system tracks the internal control evaluations that are planned and conducted. The data system has been distributed Agency-wide for testing. Future plans include implementing the AMCP on an Agency-wide level. 1991 Statistical Data For Review Process: o Number of assessable units: 239. o Number of vulnerability assessments: Planned 239. Conducted 234. o Number of 1991 Internal Control Reviews: Planned 44. Conducted 48. o Number of 1991 Alternative Internal Control Reviews: Planned 686. Conducted 807. o Percentage of assessable units reviewed in 1991: 76% Comments on Discrepancy between Reviews Planned Versus Conducted: EPA revised its plans for conducting reviews based on changing priorities and funding availability. SECTION 4: Description of Organization and Structure of Review Process; The FY 1991 accounting system evaluation included five OMB Circular A- 127 detailed evaluations and eight quality assurance reviews. Other reviews and testing provided reasonable assurance that the Agency's accounting system generally conforms to the principles and standards developed by the Comptroller General and implemented through OMB Circular A-127. EPA's formal quality assurance program provides a balanced basis for annually reviewing the Agency's accounting system. The quality assurance program consists of eight assessment tools: 1. Annual review plans prepared by each branch in the Financial Management Division (FMD) and all Financial Management Officers (FMOs). 2. In-house transaction testing of each financial management function on a three-year cycle. 3. Quality Assurance Reviews (QARs) performed at each servicing finance office on a three-year cycle by FMD. ------- U. S. ENVIRONMENTAL PROTECTION AGENCY ENCLOSURE B REVIEW PROCESS PAGE 4 OF 7 FISCAL YEAR 1991 4. Financial Assistance Reviews (FARs) of specific issues and Management Assistance Reviews (MARs) performed on an ad hoc basis by FMD. 5. Independent audits by the General Accounting Office and the Office of Inspector General. 6. Internal Control Reviews performed by independent parties on a contractual basis when funding is available. 7. Self-assessments and certifications by all FMOs and accounting system managers. 8. Quarterly tracking of status toward completing corrective action on internal control weaknesses/nonconformances. The accounting system review process will continue during FY 1992 as part of our formal Quality Assurance Program. Provide an Inventory of Agency's Financial Management Systems and indicate the Total Number of Systems: EPA has one primary accounting system which is the Integrated Financial Management System (IFMS). Three subsidiary systems provide substantial accounting information to IFMS. They are Payroll/Personnel System (EPAYS), Contract Payment System (CPS), and Automated Document Control Register (ADCR). In addition, four administrative systems contain accounting data. These systems are Contract Information System (CIS), Grants Information and Control System (GIGS), Personal Property Accountability System (PPAS), and Resources Management Information System (RMIS). These eight systems constitute the financial management system for the Agency. 1991 Statistical Data for Reviews Process; o Number of annual reviews: 0 o Number of detailed cyclical reviews: 13 o Principal review findingsr The reviews did not identify any new material nonconformances for this year. However, they did identify improvements needed in the regional quality assurance programs, regional compliance with established accounting procedures, and minor accounting system nonconformances. ------- U. S. ENVIRONMENTAL PROTECTION AGENCY ENCLOSURE B REVIEW PROCESS PAGE 5 OF 7 FISCAL YEAR 1991 OVERALL Description of the Agency System for Tracking Reviews. Weaknesses. and Corrective Actions; Agency-wide, EPA managers use the Management Control Plan to schedule reviews and the Corrective Action Tracking System (CATS) to track weaknesses identified in internal control evaluations. This system tracks and monitors the status of weaknesses reported in the annual assurance letters as well as other, less significant weaknesses. Internal Control Coordinators (ICCs) from each primary organization provide quarterly status reports for the system on the corrective actions taken. Weaknesses identified in audit reports are tracked in the Agency's Management Audit Tracking System (MATS). Some of EPA's primary organizations have separate tracking systems to help monitor their progress. For example, the EPA office responsible for correcting the Superfund material weakness uses its Superfund Management Review Progress Report, specifically related to progress in correcting that material weakness. Relevant reviews, along with recommendations and associated responses, are summarized in the Superfund Reports Information System. Other offices have tracking systems for management of controlled items within those offices. Additionally, senior management uses the Agency's Strategic Targeted Activities for Results System (STARS) to provide early warning on .potentially troubling national/regional trends and vulnerability. STARS is also used to determine where targets are met or exceeded in hopes of isolating successful strategies for duplication elsewhere in the Agency. Description of the Process for Validating Corrective Actions: EPA's validation ensures that corrective actions were successful in eliminating weaknesses. The Agency now requires the final milestone in corrective action plans to be a validation action. Various validation activities used by EPA managers include: review processes, audits, surveys, and follow-up interviews. EPA's directive on Internal Control requires POHs to carefully review their operations to ensure that corrective actions taken for each internal control weakness were sufficient to solve the problems identified and to preclude future occurrences of these or similar problems. If the actions appear insufficient, POHs are asked to modify their corrective actions. We highlight the importance of validation through the accountability of the ICC, the responsibility of the POH, and the oversight, monitoring and guidance of the Agency senior management official. ------- U. S. ENVIRONMENTAL PROTECTION AGENCY ENCLOSURE B REVIEW PROCESS PAGE 6 OF 7 FISCAL YEAR 1991 The ICCs and POHs complete Quality Control Evaluation Reports (QCER) as part of their annual assurance letters. This is an integral part of the Agency's quality control and assurance program each year. Each QCER examines various aspects of internal controls. Results of the QCER are used to evaluate EPA's overall program and identify areas for improvement. * The ICCs review all QCERs completed by their managers, validate existing risk assessment ratings, review MCPs, consolidate sub-assurance letters, and consolidate and sign QCERs. ICCs perform this work to ensure the accuracy, reasonableness, and reliability of the data. Description of the Agency's Training in Management Controls: In FY 1991, we offered more training than in previous years and developed a management controls workshop for managers. EPA Internal Control Coordinators arranged training for their managers on EPA's FMFIA process and their management control responsibilities. There were 542 managers in 16 offices throughout EPA trained in management controls for FY 1991. Most offices reported that they plan to arrange additional training in 1992. Some offices arranged for the Headquarters Resource Management Division (RMD) — which oversees EPA's implementation of FMFIA — to conduct specialized management controls workshops. To "personalize" the workshops and enhance their effectiveness, RMD worked closely with those offices' Internal Control Coordinators to determine what their managers needed. The workshops usually included: • An overall explanation of EPA's FMFIA process and objectives; • An explanation of each document required in the FMFIA process, such as the risk assessment, event cycle documentation, and Management Control Plan; • Managers self-assessment of internal control documents and on- the-spot development of documents for future use. In addition to receiving training from within EPA, some managers received outside training. There were three outside training courses attended by EPA managers. One well-received course was Internal Controls given by the Federal Bureau of Investigations. Another course attended by EPA managers was given by the Association of Certified Fraud Examiners entitled Introduction to Fraud Examination. The third course entitled Evaluating and Reporting on Internal Control Systems was given by the Department of Agriculture. ------- U. S. ENVIRONMENTAL PROTECTION AGENCY ENCLOSURE B REVIEW PROCESS PAGE 7 OF 7 FISCAL YEAR 1991 Another form of training is our rotational assignment program for Internal Control and Audit Follow-up Coordinators. These coordinators — from EPA's various program and regional offices - - work with EPA staff overseeing the Agency's FMFIA and audit management programs. In FY 1991, several Internal Control Coordinators participated in this program. Region Ill's coordinator assisted in preparing for the November meeting of the Senior Council on Management Controls and also helped in writing the Agency assurance letter. The Region IX coordinator reviewed the Agency's new cross-media approach to conducting vulnerability assessments. Region X's coordinator reviewed the annual guidance and segmentation and annual work plan calls. Description of the Agency's Actions to Ensure Accountability for Results in Identifying and Correcting Material Weaknesses and Non- conformances: All members of EPA's Senior Executive Service are required to have an element for management controls and their FMFIA responsibilities in their performance standards. The same is true for all Performance Management and Recognition System managers. Additionally, the Agency requires all General Schedule employees with specific FMFIA responsibilities — such as Internal Control Coordinators — to have an element for controls in their performance standards. As discussed earlier, EPA's Senior Council on Management Controls plays a big role in the oversight of correcting weaknesses and nonconformances. At several Council meetings this year, senior managers were asked to provide a status report on their corrective actions and steps to validate the effectiveness of the actions. Because of the Senior Council presence, managers have become more aware of their responsibilities in EPA's management control program. ------- ------- U. S. ENVIRONMENTAL PROTECTION AGENCY ENCLOSURE C PROGRESS REPORT ON HIGH RISK AREAS PAGE 1 OF 18 FISCAL YEAR 1991 i HIGH RISK AREA: Alternative Remedial Contracting System (ARCS) Contract Management This high risk area is also reported as a material weakness in Enclosure D. Over the past several months, the EPA has been subjected to serious criticism for its management of the Superfund program. EPA has been accused of allowing certain Superfund contractors to spend an inordinate amount of public funds on activities other than the direct cleanup of contaminated sites. In response to these allegations, the EPA Administrator established a Task Force comprised of senior EPA managers and analysts from EPA Headquarters and Regional offices. The Task Force is addressing whether or not these allegations of waste are fair and accurate; if EPA is taking the necessary steps to assure that any problems are corrected; if oversight of ARCS contractors is adequate and if improvements are necessary in this area; and if ARCS is still an appropriate approach to Superfund contracting. Principal Staff Contact: Name: Paul Nadeau Title: Acting Director, Hazardous Site Control Division Agency/Office: EPA/OSWER/OERR/HSCD Telephone Number: (202) 308-8313 Appropriation; Superfund 68/20X8145/TFAY9A Pace of Corrective Action: • Year Identified: 1991 How Identified: Superfund Management Task Force Targeted Correction Date in Last Year's Report: Not Applicable. Current Target Date; 09/30/92 Strategy: The strategy for corrective action will follow the Task Force Implementation Plan which was not issued as of September 30, 1991. Details of the corrective action measures will be included in the .Corrective Action Tracking System (CATS). Critical Milestones: A. Completed Actions/Events: Since the ARCS Report has just been issued and an implementation plan has not been prepared, there are no specific milestones at this time. Results Indicators; OERR identified a series of issues and recommendations that are grouped into six categories: (1)- Program ------- U. S. ENVIRONMENTAL PROTECTION AGENCY ENCLOSURE C PROGRESS REPORT ON HIGH RISK AREAS PAGE 2 OF 18 FISCAL YEAR 1991 Management, (2) ARCS Capacity and Utilization, (3) ARCS Contract Controls, (4) ARCS Financial Audits, (5) Award Fee Process, and (6) EPA Management Process. An implementation plan will be developed during the first quarter of FY 1992 to further identify areas of vulnerability and to establish mechanisms to evaluate progress in addressing the areas of vulnerability. ------- U. S. ENVIRONMENTAL PROTECTION AGENCY ENCLOSURE C PROGRESS REPORT ON,HIGH RISK AREAS PAGE 3 OF 18 FISCAL YEAR 1991 HIGH RISK AREA: Accelerating Remedial Cleanups (Programmatic) The programmatic weakness for this high risk area is also reported as a material weakness in Enclosure D. In June 1991, a 30-Day Task Force was convened by the Assistant Administrator of OSWER, in response to key questions posed by the Administrator. The primary question is "What are EPA's options for accelerating the rate of cleanups at Superfund sites?" The approach of this task force was to apply TQM principles in looking at all- phases of Superfund site management to determine how the pace of cleanup could be accelerated. The corrective actions describe the plans OSWER will implement to accelerate the pace of remedial cleanups. Principal Staff Contact; Name: Paul Nadeau Title: Acting Director, Hazardous Site Control Division Agency/Office: EPA/OSWER/OERR/HSCD Telephone Number: (202) 308-8313 Appropriation: Superfund 68/20X8145/TFAY9A Pace of Corrective Action; Year Identified; 1991 How Identified: Superfund 30 Day Study Task Force Report Targeted Correction Date in Last Year's Report: new issue Current Target Date; 09/30/92 Strategy: The corrective action plans outlined in this report are based on the Implementation Plan issued by the Task Force. Implementation of corrective actions will be facilitated via a senior management task force chaired by the Deputy Assistant Administrator, OSWER with Deputy Regional Administrators from each Region. The DAA of OSWER will meet with the Regions, individually and in groups, shortly. Issues specific to the Regions will receive a high level of attention. Regions have already been asked for an assessment of where Superfund resources might be added to have the most impact on the speed of site cleanups. Critical Milestones COMPLETION DATE ORIGINAL CURRENT ACTUAL PLAN PLAN A. Completed Actions/Events: There are several corrective action plans to correct this weakness. See Enclosure D for details of these plans. ------- U. S. ENVIRONMENTAL PROTECTION AGENCY PROGRESS REPORT ON HIGH RISK AREAS FISCAL YEAR 1991 ENCLOSURE C PAGE 4 OF 18 Critical Milestones ORIGINAL PLAN •COMPLETION DATE- CURRENT PLAN ACTUAL B. Planned Actions/Events (short-term - next 12 months) Enclosure D for detailed corrective action plans. Segregate Federal Facilities 12/31/91 Communications Strategy 11/30/91 Publish NPL #12 with new language 12/31/91 Set Aggressive Cleanup targets 09/30/93 Meet with Regions 12/31/91 Dev. plan and reallocation strategy ' 01/31/92 Standardize the Planning Process 06/30/92 Analysis of options 02/28/92 Prioritize approaches 06/30/92 Expand Measures of Success 06/30/92 Draft Strategy 03/31/92 See C. Planned Actions/Events (longer-term): detailed corrective action plans. See Enclosure D for Expand Flexibility of Contracts 09/30/93 Develop options 03/31/92 Evaluate effects of pilots 09/01/93 Elevate Issues Causing Delays 09/30/93 Prepare strategy • 12/31/91 Monitor progress 12/31/91 Results Indicators: OERR has developed Corrective Action Plans to address the following weaknesses identified in the 30-Day internal study of the Superfund program. Set aggressive cleanup targets Standardize remedial planning and remedy selection Expand flexibility of design/construction contracts Elevate issues causing site-specific delays Expand Superfund's measures of success Assessment of Progress; See Enclosure D. ------- U. S. ENVIRONMENTAL PROTECTION AGENCY ENCLOSURE C PROGRESS REPORT ON HIGH RISK AREAS PAGE 5 OF 18 FISCAL YEAR 1991 HIGH RISK AREA; Accelerated Remedial Cleanups (Enforcement) The enforcement weakness for this high risk area is also reported as a material weakness in Enclosure D. In June 1991, a 30-Day Task Force was convened by the Assistant Administrator of OSWER. Its mission was to respond to key questions posed by the Administrator. The primary question is "What are EPA's Options for accelerating the rate of cleanups at Superfund sites?" The approach of this task force was to apply TQM principles in looking at all phases of Superfund site management to determine how the pace of cleanup could be accelerated. The corrective actions outlined in this Annual Assurance Letter describe the plans Superfund will implement to accelerate the pace of remedial cleanups. Principal Staff Contact: Name: Sally Mansbach Title: Director, CERCLA Enforcement Division Agency/Office: EPA/OSWER/OWPE Telephone Number: FTS 308-8404 Appropriation: Superfund Trust Fund Pace of Corrective Action: Year Identified: 1991 How Identified: Superfund 30 Day Task Force Report Targeted Correction Date in Last Year's Report: new issue Current Target Date: 9/30/92 Strategy; OWPE is following the implementation plan developed by the Superfund 30-day Study Task Force. The plan includes a detailed listing of the milestones to implement the recommendations outlined in the study. Critical Milestones A. Completed Actions/Events: None B. Planned Actions/Events (FY 1992): Elevate Site-Specific Issues (EPA/DOJ issues): see Enclosure D. Accelerate Private Party Cleanups (Begin Remedial Design before entry of Consent Decree): see Enclosure D. ------- U. S. ENVIRONMENTAL PROTECTION AGENCY ENCLOSURE C PROGRESS REPORT ON HIGH RISK AREAS PAGE 6 OF 18 FISCAL YEAR 1991 Results Indicators: - Increased numbers of early settlements with de minimis PRPs in order to minimize delays in settlements with other contributors for overall site remedy,. - An increase in PRP remedial design starts at or prior to consent decree lodging. This is currently optional language in the model RD/RA consent decree. Making this mandatory language is now under consideration. - Innovative agreements which show effective negotiations with other collateral PRPs, thereby minimizing delays in the overall settlement process. - Remedial Pipeline trends as evaluated through the STARS system to ensure continuous management improvement. - Effective compliance monitoring and enforcement follow-up. Assessment of Progress; Because of the recent release of the 30- Day Study, limited progress has been achieved to date with the real measures of success expected during FY 92. Those items which have occurred to date are as follows: - EPA conducted both the municipal and de minjlmis.conferences to devise effective ways to get these types of collateral PRPs through the enforcement process as quickly as possible and to minimize delays in the overall site settlement process. - EPA established STARS measures to evaluate trends in Remedial Pipeline duration and to encourage continuous improvement with respect to pipeline mamigement. ------- U. S. ENVIRONMENTAL PROTECTION AGENCY ENCLOSURE C PROGRESS REPORT ON HIGH RISK AREAS PAGE 7 OF 18 FISCAL YEAR 1991 HIGH RISK AREA: The 90-Day Study (Programmatic) In FY 1989, EPA identified all of Superfund as a high risk area based on the "Superfund Management Review" (also known as the 90 Day Study). The recommendations outlined in this report led to the corrective action plans associated with one material weakness—the Superfund Program—which EPA reported in the FY 1989 FMFIA report. A FY 1989 review of this $8.5 billion program indicated that EPA had to set fair and realistic goals and put controls in place to assure the program's integrity. Fifty recommendations for improvement Were made. The agency believes full implementation of the recommendations will help to restore public confidence in the program. Principal Staff Contact: Name: Clem L. Rastatter Title: Director, Office of Program Management Agency/Office: EPA/OSWER/OERR/OPM Telephone Number: (202) 260-2441 Appropriation: Superfund; 68/20X8145/TFAY9A. Pace of Corrective Action; Year Identified; 1989 How Identified:Internal Report "A Management Review of the Superfund Program". Targeted Correction Date in Last Year's Report: September 30, 1991 Current Target Date: December 31, 1991 Reason for Change in Date: Although much progress has been made, certain workplans required adjustments through the year. Enclosure D Workplans detail specific explanation for any workplan that has slipped. Strategy: In FY 1989, at the Administrator's reguest, a major review of the Superfund program (entitled "A Management Review of the Superfund Program" and known as the "90-Day Study") was completed. The study led us to declare one material weakness, the Superfund program. This weakness met OMB's criteria for "materiality". The Administrator required corrective action workplans for all offices that had a role in implementing the study's recommendations. EPA's corrective actions for this high risk issue are included in Enclosure D. OERR maintains an automated Milestone Tracking System (MTS) that can provide detailed planned corrective actions for each of these weaknesses and the relevant action officials. During FY ------- U. S. ENVIRONMENTAL PROTECTION AGENCY ENCLOSURE C PROGRESS REPORT ON HIGH RISK AREAS PAGE 8 OF 18 FISCAL YEAR 1991 1991, OERR worked on 15 90-Day Study corrective action workplans as part of the FY 1991 material weakness corrective action process. Since last year, OERR completed 13 of these workplans, with each workplan consisting of multiple corrective actions. Of the remaining workplans, both will be completed in FY 1992. Critical Milestones COMPLETION DATE ORIGINAL CURRENT ACTUAL PLAN PLAN See Enclosure D for detailed corrective action plans. A. Completed Actions/Events: 13 Corrective Action Workplans were completed in FY 1991. For a listing and specific details, see Enclosure D. B. Planned Actions/Events (short-term - next 12 months): Two workplans from the 90-Day Study will be completed by 12/31/91: NPL Listing Consistency 12/31/91 TAG Application Process 10/31/91 See Enclosure for details of these corrective action plans. Results Indicators; OERR has established several mechanisms to evaluate progress in addressing areas of vulnerability. These include: (1) annual review of Records of Decision and subsequent meetings with Regional staff/management to discuss results and needed areas of improvement, (2) annual regional reviews have been revised to ensure that senior OSWER managers focus attention on areas of vulnerability, (3) assessments of contract management and operations are designed to evaluate and provide corrective measures to areas of vulnerability, and (4) strategic program issues are identified by OERR and independent analysis is undertaken to determine if program implementation is accomplishing the intended results. Options for improvements are presented to management as needed. Assessment of Progress: Summary Information Highlights - Fifteen 90-Day Study Workplans were active in FY 1991. 13 plans were completed in FY 1989 and FY 1990. - Eight workplans involved the development of major program guidance/training sessions/technical manuals/technology transfer/documents and catalogues. - Seven workplans involved the development of short sheets and fact sheets, many of which focused on community relations issues. ------- U. S. ENVIRONMENTAL PROTECTION AGENCY ENCLOSURE C PROGRESS REPORT ON HIGH RISK AREAS PAGE 9 OF 18 FISCAL YEAR 1991 - Five workplans resulted in the development of other products such as support on OSW soil and debris regulations, Environmental Indicators report, a new jargon matrix, and conducting removal assessments at each NPL site and removal actions to eliminate immediate threats. See Enclosure D for more detailed information on each corrective action workplan. ------- U. S. ENVIRONMENTAL PROTECTION AGENCY ENCLOSURE C PROGRESS REPORT ON HIGH RISK AREAS PAGE 10 OF 18 FISCAL YEAR 1991 HIGH RISK AREA: The 90-Day Study (Enforcement) In FY 1989, EPA identified all of Superfund as a high risk area based on the "Superfund Management Review" (also known as the 90 Day Study). The recommendations outlined in this report led to the corrective action plans associated with one material weakness—the Superfund Program—which EPA reported in the FY 1989 FMFIA report. A FY 1989 review of the $8.5 billion Superfund program indicated that EPA had to set fair and realistic goals and put controls in place to assure the program's integrity. Fifty recommendations for improvement were made. The Agency believes full implementation of the recommendations will help to restore public confidence in the program. Principal Staff Contact:: Name: Sally Mansbach Title: Director, CERCLA Enforcement Division Agency/Office: EPA/OSWER/OWPE Telephone Number: FTS 398-8404 Appropriation: Superfund Trust Fund Pace of Corrective Action: Year Identified; 1989 How Identified: Internal Report "A Management Review of the Superfund Program". Targeted Correction Date in Last Year's Report: September 30, 1991 Current Target Date; December 31, 1991 Reason for Change in Date: Milestones vary in complexity Strategy: The Superfund Implementation Program was based on the 90-day Superfund Management Review (SMR) and set forth a comprehensive long-term strategy for the Superfund Program. The basic elements of the strategy are to: (1) control acute threats immediately, (2) deal with the worst sites and worst problems first, (3) carefully monitor/maintain sites over the long'term., (4) emphasize enforcement to induce private-party cleanup, (5) seek new technologies for more effective cleanup, (6) improve the efficiency of program operations, and (7) encourage full participation of communities. Critical Milestones; OWPE had the lead on approximately 23 major SMR projects, involving 50 major milestones. - 13 major projects (57%) completed - 38 milestones (76%) completed ------- U. S. ENVIRONMENTAL PROTECTION AGENCY ENCLOSURE C PROGRESS REPORT ON HIGH RISK AREAS PAGE 11 OF 18 FISCAL YEAR 1991 The most critical concerns for Superfund Enforcement were: more aggressive use of enforcement tools; - review of remedy selection to ensure that remedies at sites where responsible parties (RPs) perform the RI/FS or express a willingness to perform the remedy are as protective and permanent as those developed exclusively by the Agency; and strengthening of the Cost Recovery Program. A. Completed Actions/Events: see Enclosure D, Work Plans #90002, 90008 and 90019. B. Planned Actions/Events (FY 1992); see Enclosure D, Work Plans #90010, 90011 and 90013. ' Results Indicators: -Increased use of Unilateral Administrative Orders for RD/RA. - Requirement established for Headquarters consultation with the Region when not issuing a UAO prior to Fund-financing Remedial Design. - Finalization of the Site Management Planning Guidance. - A National Workgroup on CERCLA Enforcement Compliance Monitoring established including the drafting of a directive outlining minimum compliance tracking requirements. - Continued use of treble damage authorities under CERCLA. - Increased number of settlements of all types, particularly those for RD/RA. - Increased use of de minimis provisions of SARA. - Response/Enforcement Integrated Timeline established. - Strategic performance evaluation measures established to . evaluate trends in pipeline duration and resulted in improvements and/or weaknesses. - The Cost Recovery Rule developed and planned for submission to OMB. - Increased funding flexibility for remedial pipeline events, particularly in the area of Regional Case Budget management. ------- U. S. ENVIRONMENTAL PROTECTION AGENCY ENCLOSURE C PROGRESS REPORT ON HIGH RISK AREAS PAGE 12 OF 18 FISCAL YEAR 1991 - Increased number of cost recovery referrals. Assessment of Progress: Unilateral Administrative Orders have increased as follows: FY 1988 FY 1989 FY 1990 FY 1991 RD/RA 13 28 44 46 - The total number of treble damage cases filed since the passage of SARA in 1986 has been 15. -The statistics for settlements/compliant UAOs for RD/RA are ,as follows: FY 1983 FY 1989 FY 1990 FY 1991 Settlements: 30 49 60 71 UAOs in Compliance: 6 23 37 27 Total: 36 72 97 98 - To date, there have been 35 de minimis settlements and there are an additional 17 pending. - To date, there have been only 10 mixed funding/preauthorization settlements. However, due to the success of the Enforcement- First initiative, including use of UAOs, there has been little need to pursue greater use of mixed funding settlements. - Since SARA, referrals have increased through FY 1989, and then stabilized, primarily due to the increase in the rate of settlements to conduct work in all phases of the remedial pipeline. Performance is as follows: FY 1987 FY 1988 FY 1989 FY 1990 FY 1991 37 56 83 79 72 ------- U. S. ENVIRONMENTAL PROTECTION AGENCY ENCLOSURE C PROGRESS REPORT ON HIGH RISK AREAS PAGE 13 OF 18 FISCAL YEAR 1991 HIGH RISK AREA: Financial Systems GAO, OIG and in-house management reviews have reported nonconformances and deficiencies in EPA financial systems. Installation of the new Integrated Financial Management System (IFMS) has led to delays in rectifying the systems' problems. Specific problems include a lack of flexibility in the accounts receivable module for interest calculations and insufficient general ledger controls. Principal Staff Contact: Name: Sallyanne Harper Title: Director, Financial Management Division Agency/Office: US EPA, Office of the Comptroller •Telephone Number: (202) 260-5097 Appropriation: All Appropriations Pace of Corrective Action: Year Identified: 1989 Original Targeted Correction Date; September 1990 Targeted Correction Date in Last Year's Report: June 1993 Current Target Date: June 1993 Strategy; A corrective action plan has been developed that addresses the issue. Milestones are used to ensure progress is monitored. Revisions are made to the corrective action plan when additional information or problems are identified. Critical Milestones COMPLETION DATE ORIGINAL CURRENT ACTUAL PLAN PLAN A. Completed Actions/Events: Accounts Receivable: Issued 2/90 2/90 policies and procedures to track enforcement actions. General Ledger: Automatically 4/90 4/90 performed month-end and year-end closing and roll over of account balances. ------- U. S. ENVIRONMENTAL PROTECTION AGENCY ENCLOSURE C PROGRESS REPORT ON HIGH RISK AREAS PAGE 14 OF 18 FISCAL YEAR 1991 Critical Milestones COMPLETION DATE ORIGINAL CURRENT ACTUAL PLAN PLAN A. Completed Actions/Events (Continued); Accounts Receivable: Implemented IFMS feature to 5/90 5/90 automatically calculate interest, penalties and handling charges. Implemented IFMS feature to 5/90 5/90 automatically generate demand and billing letters. All EPA Regions started 5/90 5/90 implementing improved procedures for establishing accounts receivable. Issue final policies and 1/91 11/90 procedures on billings and receivables. First quarterly reports on 9/90 1/91 implementation due. Start first round of on-site 10/90 2/91 verification reviews. Implement IFMS features to 10/90 3/91 perform -on-line write-off of uncollectible accounts. Complete implementation of 12/90 6/91 improved procedures in all regions. Complete first round of on-site 6/91 7/91 verification reviews. Financial Reporting: Modified existing report formats 7/90 7/90 based on user comments, issued seven new reports on budget and construction grants, and published clear instructions to assist report users. 4 ------- U. S. ENVIRONMENTAL PROTECTION AGENCY ENCLOSURE C PROGRESS REPORT ON HIGH RISK AREAS PAGE 15 OF 18 FISCAL YEAR 1991 Critical Milestones COMPLETION DATE ORIGINAL CURRENT ACTUAL PLAN PLAN A. Completed Actions/Events (Continued): Complete IFMS Management and 12/90 3/91 prototype testing of the IFMS Management and Accounting Reporting System. Train users in Management and 5/91 7/91 Accounting Reporting System. Implement Management and 5/91 7/91 Accounting Reporting System Agency-wide. General Ledger: Install edit verify data entries. 6/91 6/91 B. Planned Actions/Events (short term - next 12 months). Accounts Receivable: Complete 6/92 6/92 second round of on-site verification reviews. C. Planned Actions/Events (longer term) • General Ledger: Reconcile general ledger data. 2/92 10/92 Update policies and procedures 3/92 10/92 for recording transactions in IFMS. Accounts Receivable: Complete 6/93 6/93 third round of on-site verification reviews. Corrective actions consist of improvements to automated financial system reporting, general ledger and accounts receivable capabilities. Specifically, the following actions were completed in FY 1991: (1) implemented the Management and Accounting Reporting System (MARS); (2) installed general ledger data edit checks to verify data entries; (3) implemented enhanced system features to perform on-line write-off of uncollectible accounts; and (4) issued new accounts receivable directives, ------- U. S. ENVIRONMENTAL PROTECTION AGENCY ENCLOSURE C PROGRESS REPORT ON HIGH RISK AREAS PAGE 16 OF 18 FISCAL YEAR 1991 implemented strengthened procedures throughout EPA, and began on- site reviews of EPA Regions to verify that past problems were corrected. During FY 1992, general ledger data will be fully reconciled and financial system procedures will be updated. During FY 1993, we will complete on-site reviews and follow- up reviews to verify that accounts receivable are promptly recorded in the Agency's financial system. EPA anticipates this action may enable OMB to remove EPA's financial system from OMB's high risk list. Results Indicators: 1. Accounts Receivable: Matching program and accounting records of accounts receivable. Increased recording and collection of accounts receivable. 2. Financial Reporting: Ready availability of financial information in formats that meet user requirements. Discontinued reliance on ad hoc reporting capabilities of former system. 3. General Ledger: Ability to rely on cumulative trial balances. Assessment of Progress; EPA's progress toward enhancing the Integrated Financial Management System was been delayed. Our progress has been delayed because we want to ensure that the software meets our requirements prior to implementation. However, we have successfully implemented the ad hoc reporting system (Management and Accounting Reporting System) needed by EPA users and met several other milestones. For example, the Accounts Receivable Task Force (ARTF) has completed their first round of visits to regional finance offices. The purpose of the ARTF is to ensure compliance with accounts receivable policies and procedures. Corrective actions have been developed by the finance offices in response to problems identified by the ARTF, These action plans are being monitored by the Financial Management Division. We fully expect that the remaining milestones will be accomplished. ------- U. S. ENVIRONMENTAL PROTECTION AGENCY ENCLOSURE C PROGRESS REPORT ON HIGH RISK AREAS PAGE 17 OF 18 FISCAL YEAR 1991 HIGH RISK AREA: Data Integration OE was hampered in its ability to develop enforcement actions, set enforcement priorities and target enforcement, respond to crises and conduct program oversight because of the inability to associate data on compliance and enforcement activities from various program offices data bases. Principal Staff Contact: Name: Gerald A. Bryan Title: Director, Office of Compliance Analysis and Program Operations Agency/Office: U.S. EPA, Office of Enforcement Telephone Number: 260-4140 Appropriation: 6800200 Pace of Corrective Action: Year Identified: FY 1989 How Identified: IG Audit Targeted Correction Date in Last Year's Report: 12/90 Current Target Date; Completed February 21, 1991 Reason for Change in Date: Delays occurred in the initial development of IDEA because of the inability to quickly .resolve with the National Computer Center (NCC) how direct access to the data systems running in ADABAS would be provided. As a result, several of the milestone dates were achieved two months later than originally planned. ------- U. S. ENVIRONMENTAL PROTECTION AGENCY ENCLOSURE C PROGRESS REPORT ON HIGH RISK AREAS PAGE 18 OF 18 FISCAL YEAR 1991 Critical Milestones -—COMPLETION DATE- ORIGINAL CURRENT ACTUAL PLAN PLAN 1. Form Workgroup to develop linking mechanism, resource requirements and schedule for implementation 11-01-89 2. Define linking approach and systems to be linked 11-21-89 3. Develop resource requirements and construct a strategy for implementa- tion, including a project plan (review projected milestones and revise as appropriate) 01-26-90 4. Modify systems where necessary to accommodate link ID number 09-30-90 5. Complete update of systems with link ID number for current records 12-31-90 • 6. Develop automated ID number assignment proce- dures and programs 12-31-90 7. Final implementation of linkage capability including ongoing operations and maintenance 12-31-90 11-89 11-89 3-2-90 9-30-90 1-91 2-21-91 2-21-91 Validation: Validation of the effectiveness of the corrective action tied to the use of the capability. All headquarters and regional offices have been trained on the use of IDEA and currently several offices are incorporating analysis using IDEA in enforcement screening, enforcement targeting, and strategic planning. Procedures have been developed requiring that before individuals can use IDEA and gain access to enforcement sensitive data, authorization must be granted at the DRA level. Additional procedures are being developed to provide access to nonsensitive data. ------- U.S. ENVIRONMENTAL PROTECTION AGENCY MATERIAL WEAKNESS/CORRECTIVE ACTIONS FISCAL YEAR 1991 ENCLOSURE D PAGE 1 OF 97 PART ONE: SUMMARY/TABLE Title ARCS Contract Management Accelerating Remedial Cleanup Federal Facilities Contract Laboratory Program Superfund Data Integrity for Pesticides and Toxic Substances Requests for Audits Storm Water Managing R&D Extramural Resources R&D Laboratory Facilities Audit Follow-Up R&D Laboratory Operating Expenses Chemical Testing R&D Scientific Equipment Antimicrobial Program Pesticides Disposal Enforcement Data Integration First Reported 1991 1991 1991 1991 1989 1991 1991 1991 1990 1989 1989 1990 1990 198.8 1990 1990 r XSL-AJj-I J1AK 1990 FMFIA Report Target for Correction n/a n/a n/a n/a 1991 n/a n/a n/a 1992 1991 1991 1993 1992 1994 1992 1992 Current Target for Correction To Be Determined 1993 1993 To Be Determined 1991 1992 Ongoing 1992 1994 1993 1991 1995 1992 1994 1992 1992 Page 2 4 21 24 26 66 68 70 72 76 80 83 87 90 92 94 1989 1991 Complete 96 ------- U. S. ENVIRONMENTAL PROTECTION AGENCY ENCLOSURE D MATERIAL WEAKNESS/CORRECTIVE ACTIONS PAGE 2 OF 97 FISCAL YEAR 1991 PART TWO; DESCRIPTION OF UNCORRECTED MATERIAL WEAKNESSES CATS Tracking Number: Assessable Unit/AU *; OERR/HSCD/1902 Title of Material Weakness: ARCS Contract Management Description' of Material Weakness and Its Impact on Agency Operations: Weaknesses identified through the Administrator's Task Force on ARCS Contract Management. EPA has been subjected to serious criticism for its management of the Superfund program. EPA has been accused of allowing certain Superfund contractors to spend public funds on activities other than the direct site cleanup of Superfund sites. Workplan #: 01222 Functional Category in Statistical Summary; Environmental Impact Appropriation/Program Element: Superfund; 68/20X8145/TFAY9A Administrative Activity/Program Activity: Program Activity Year Identified: 1991 Source of Discovery; Superfund Management Task Force Original Target Correction Date: 09/30/92 Current Target Date; 09/30/92 Critical Milestones in Planned Corrective Action: A. Completed Actions/Events: M/S # MILESTONE TITLE ORIG PLAN ACTUAL M 001 Participate in Task 09/20/91 09/20/91 09/20/91 Force B. Planned Actions/Events (Short-Term - Next 12 Months): M/S # MILESTONE TITLE ORIG PLAN ACTUAL M 002 Task Force Issues 10/02/91 10/02/91 10/02/91 Report ------- U. S. ENVIRONMENTAL PROTECTION AGENCY ENCLOSURE D MATERIAL WEAKNESS/CORRECTIVE ACTIONS PAGE 3 OF 97 FISCAL YEAR 1991 M/S # MILESTONE TITLE ORIG PLAN ACTUAL M 003 Draft HSCD 11/15/91 11/15/91' / / Implementation Plan M 001 Verification of 09/30/92 09/30/92 / / Completion Validation Process to be Used: HSCD staff will conduct on-site review of Regional ARCS project management process. Corrective Action Plan Status Updates: o September 30. 1991. Status Update: The Superfund Task Force (Dunne Workgroup) has reviewed the ARCS program and issued a report. This report included a discussion of ARCS areas of vulnerability. Because of the recent issuance of this report, a more specific workplan of corrective action is not available at this time. The first quarter CATS report will contain more detailed information. ------- U. S. ENVIRONMENTAL PROTECTION AGENCY ENCLOSURE D MATERIAL WEAKNESS/CORRECTIVE ACTIONS PAGE 4 OF 97 FISCAL YEAR 1991 CATS Tracking Number: Assessable Unit/AU #: OERR/HSED/1902 Title of Material Weakness: Accelerating Remedial Cleanups: Segregate Federal Facilities from the NPL 'Description of Material Weakness and Its Impact on Agency Operations: More effectively segregate Federal facilities on the NPL. EPA is required to place Federal facilities on the NPL, although cleanup at those sites is not EPA's responsibility. Because the NPL is the most commonly used measure of EPA progress, it would be appropriate to more clearly distinguish between Federal facilities and sites for which EPA has responsibility. Workplan #: To Be Determined Functional Category in Statistical Summary; Environmental Impact Appropriation/Program Element: Superfund; 68/20X8145/TFAY9A Administrative Activity/Program Activity; Program Activity Year Identified; 1991 Source of Discovery: The Superfund 30 Day Study Task Force Original Target Correction Date: 1993 Current Target Date: 1993 Critical Milestones in Planned Corrective Action; A. Completed Actions/Events: M/S # MILESTONE TITLE ORIG PLAN ACTUAL M 001 Review of Options by 09/30/91 09/30/91 09/30/91 AA B. Planned Actions/Events (Short Term; next 12 months) M/S # MILESTONE TITLE ORIG PLAN ACTUAL ------- U. S. ENVIRONMENTAL PROTECTION AGENCY ENCLOSURE D MATERIAL WEAKNESS/CORRECTIVE ACTIONS PAGE 5 OF 97 FISCAL YEAR 1991 M 002 Draft Preamble 10/31/91 10/31/91 / / Language for Fed. Register ff M 003 Dev. Communications 11/30/91 11/30/91 / / Strategy M 004 Publish Proposed NPL 12/31/91 12/31/91 / / #12 With New Language M 005 Verification of 12/31/91 12/31/91 / / Completion Validation Process to be Used; To be determined. Corrective Action Plan Status Updates: ° September 30, 1991 Status Update: Report was just published October 1, 1991. ------- U. S. ENVIRONMENTAL PROTECTION AGENCY MATERIAL WEAKNESS/CORRECTIVE ACTIONS FISCAL YEAR 1991 ENCLOSURE D PAGE 6 OF 97 CATS Tracking Number: Assessable Unit/AU #: OERR/HSCD/1902 Title of Material Weakness: Accelerating Remedial Cleanups: Set Aggressive Cleanup Targets Description of Material Weakness and Its Impact on Agency Operations: Set aggressive cleanup targets. EPA will more aggressively pursue site completion as a target of performance. The Agency will establish national and Regional targets for FY 92 and FY 93 as well as goals for the year 2000. Those targets will represent an increase in site completions of over 100% by the end of 1992; over 200% by the end of 1993 (200 sites); and a ten-fold increase by the year 2000 (650 sites). Workplan #: To Be Determined Functional Category in Statistical Summary: Environmental Impact Appropriation/Program Element: Superfund; 68/20X8145/TFAY9A Administrative Activity/Program Activity: Program Activity Year Identified: 1991 SourceofDiscovery: The Superfund 30 Day Study Task Force Original Target Correction Date: 1993 Current Target Date: 1993 Critical Milestones in Planned Corrective Action: A. Completed Actions/Events: M/S # MILESTONE TITLE ORIG PLAN ACTUAL M 002 Establish Workgroup 09/30/91 09/30/91 09/25/91 ------- U. S. ENVIRONMENTAL PROTECTION AGENCY MATERIAL WEAKNESS/CORRECTIVE ACTIONS FISCAL YEAR 1991 ENCLOSURE D PAGE 7 OF 97 B. Planned Actions/Events (Short-Term - Next 12 Months) M/S # MILESTONE TITLE M 001 Formally Establish Targets M 003 Meet With Regions M 004 Establish Tracking System M 005 Dev. Plan and ORIG PLAN 09/30/91 10/15/91 12/31/91 12/31/91 12/31/91 12/31/91 Reallocation Strategy ' 01/31/92 01/31/92 ACTUAL / / / / / / / / C. Planned Actions/Events (Longer Term): M/S # MILESTONE TITLE ORIG PLAN ACTUAL |M 006 Elevate Site-Spec. Issues M 007 Verification of Completion 09/30/93 09/30/93 / / Validation Process to be Used: To be determined. Corrective Action Plan Status Updates: o September 30. 1991 Status Update: Report was just published October 1, 1991. ------- U. S. ENVIRONMENTAL PROTECTION AGENCY ENCLOSURE D MATERIAL WEAKNESS/CORRECTIVE ACTIONS PAGE 8 OF 97 FISCAL YEAR 1991 CATS Tracking Number: Assessable Unit/AU #: OERR/HSCD/1902 Title of Material Weakness: Accelerating Remedial Cleanups: Standardize the Remedial Planning Process Description of Material Weakness and Its Impact on Agency Operations: EPA would standardize the remedial planning process, to the extent possible given the variety of site conditions. Three types of standardization are proposed: presumptive remedy selection; development of soil cleanup levels; and development of technology-based standards. Workplan #: To be determined Functional Category in Statistical Summary: Environmental Impact Appropriation/Program Element: Superfund; 68/20X8145/TFAY9A Administrative Activity/Program Activity: Program Activity Year Identified: 1991 Source of Discovery: The Superfund 30 Day Study Task Force Original Target Correction Date: 1993 Current Target Date: 1993 Critical Milestones in Planned Corrective Action: A. Completed Actions/Events: None B. M/S # M 001 M 002 M 003 Planned Actions/Events (Short-Term - Next 12 Months) : MILESTONE Establish Analysis Determine TITLE Workgroup of Options Resource ORIG 11/30/91 02/28/92 05/31/92 PLAN ACTUAL 11/30/91 / / 02/28/92 / / 05/31/92 / / Implications M 004 Prioritize Approaches 06/30/92 06/30/92 M 005 Verification of 06/30/92 06/30/92 Completion ------- U. S. ENVIRONMENTAL PROTECTION AGENCY ENCLOSURE D MATERIAL WEAKNESS/CORRECTIVE ACTIONS PAGE 9 OF 97 FISCAL YEAR 1991 Validation Process to be Used; To Be Determined Corrective Action Plan Status Updates: o September 30. 1991 Status Update: Report was just published October 1, 1991. ------- U. S. ENVIRONMENTAL PROTECTION AGENCY ENCLOSURE D MATERIAL WEAKNESS/CORRECTIVE ACTIONS PAGE 10 OF 97 FISCAL YEAR 1991 CATS Tracking Number: Assessable Unit/AU #: OERR/HSCD/1902 Title of Material Weakness: Accelerating Remedial Cleanups: Expand Flexibility of Design/Construction Contracts Description of Material Weakness and Its Impact on Agency Operations: Expand flexibility of design/construction contracts. This project will develop and pilot methods to accelerate the pace of remedial actions by proceeding directly with on-site cleanup activities following the ROD. Methods to-limit the design effort and cost reimbursement remedial action contracting will be examined. Workplan #: To Be Determined Functional Category in Statistical Summary; Environmental Impact Appropriation/Program Element: Superfund; 68/20X8145/TFAY9A Administrative Activity/Program Activity: Program Activity Year Identified: 1991 Source of Discovery: The Superfund 30 Day Study Task Force Original Target Correction Date: 1993 Current Target Date: 1993 Critical Milestones in Planned Corrective Action: A. Completed Actions/Events; M/S # MILESTONE TITLE ORIG PLAN ACTUAL B. Planned Actions/Events (Short-Term - Next 12 Months): M/S # MILESTONE TITLE ORIG PLAN ACTUAL M 001 Establish Workgroup 11/30/91 11/30/91 / / M 002 Screen RD Candidates 01/31/92 01/31/92 / / M/S # MILESTONE TITLE ORIG PLAN ACTUAL ------- U. S. ENVIRONMENTAL PROTECTION AGENCY ENCLOSURE D MATERIAL WEAKNESS/CORRECTIVE ACTIONS PAGE 11 OF 97 FISCAL YEAR 1991 M 003 Develop 03/31/92 03/31/92 / / Des ign/Construct ion Options M 004 Initiate Work at Sites 04/30/92 04/30/92 / / C. Planned Actions/Events (Longer Term): M/S # MILESTONE TITLE ORIG PLAN ACTUAL Evaluate Effects of 09/01/93 09/01/93 / / M 005 Pilots M 006 Verification of 09/30/93 09/30/93 / / Completion Validation Process to be Used: To Be Determined Corrective Action Plan Status Updates: o September 30. 1991 Status Update; Report was just published October 1, 1991. ------- U. S. ENVIRONMENTAL PROTECTION AGENCY ENCLOSURE D MATERIAL WEAKNESS/CORRECTIVE ACTIONS PAGE 12 OF 97 FISCAL YEAR 1991 i CATS Tracking Number: Assessable Unit/AU #: OERR/HSCD/1902 Title of Material Weakness; Accelerating Remedial Cleanups: Elevate Issues Causing Delays Description of Material Weakness and Its Impact on Agency Operations: Elevate issues causing site-specific delays. The Task Force recommended more aggressive action to elevate and resolve State/EPA issues that delay progress at individual sites. Workplan #: To be determined Functional Category in StatisticalSummary: Environmental Impact Appropriation/Program Element: Superfund; 68/20X8145/TFAY9A Administrative Activity/Program Activity: Program Activity Year Identified: 1991 Source of Discovery; The Superfund 30 Day Study Task Force Original Target Correction Date: Current Target Date: Critical Milestones in Planned Corrective Action: A. Completed Actions/Events: M/S # MILESTONE TITLE ORIG PLAN ACTUAL B. Planned Actions/Events (Short-Term - Next 12 Months): M/S # MILESTONE TITLE ORIG PLAN ACTUAL M 001 Brief AA for State 11/30/91 11/30/91 / / Forum M 002 Prepare Communication 12/31/91 12/31/91 / / Strategy ------- U. S. ENVIRONMENTAL PROTECTION AGENCY ENCLOSURE D MATERIAL WEAKNESS/CORRECTIVE ACTIONS PAGE 13 OF 97 FISCAL YEAR 1991 C. Planned Actions/Events (Longer Term): M/S # MILESTONE TITLE ORIG PLAN ACTUAL M 003 Monitor Site Progress 12/31/91 12/31/91 / / M 004 Include Issues in / / / / / / Quarterly DAA Reports M 005 Verification of 09/30/93 09/30/93 / / Completion Validation Process to be Used: To be determined. Corrective Action Plan Status Updates: o September 30. 1991 Status Update; Report was just published October 1, 1991. ------- U. S. ENVIRONMENTAL PROTECTION AGENCY ENCLOSURE D MATERIAL WEAKNESS/CORRECTIVE ACTIONS PAGE 14 OF 97 FISCAL YEAR 1991 CATS Tracking Number: Assessable Unit/AU #: OERR/OPM/1911 Title of Material Weakness: Accelerating Remedial Cleanups: Expand Superfund's Measures of Success Description of Material Weakness and Its Impact on Agency Operations: Expand Superfund's measures of success. This workplan involves developing a strategy to increase public awareness of Superfund accomplishments. This will be done by broadening the scope of public information and outreach to encompass all aspects of the program. OERR and OWPE will work together to develop a communication plan to focus on Superfund program accomplishments. Both offices will work with OSWER communication staff, OCPA, and Regional offices to integrate the strategy. Workplan #: To be determined Functional Category in Statistical Summary; Environmental Impact Appropriation/Program Element: Superfund; 68/20X8145/TFAY9A Administrative Activity/Program Activity: Program Activity Year Identified: 1991 Source.of Discovery: The Superfund 30 Day Study Task Force Original Target Correction Date; 1993 Current Target Date: 1993 Critical Milestones in Planned Corrective Action: A. Completed Actions/Events; M/S # MILESTONE TITLE ORIG PLAN ACTUAL B. Planned Actions/Events (Short-Term - Next 12 Months): M/S # MILESTONE TITLE ORIG PLAN ACTUAL M 001 Release Environmental 10/30/91 10/30/91 / / Indicators Report M 002 Establish Cross-Org. 11/31/91 11/31/91 / / Team ------- U. S. ENVIRONMENTAL PROTECTION AGENCY ENCLOSURE D MATERIAL WEAKNESS/CORRECTIVE ACTIONS PAGE 15 OF 97 FISCAL YEAR 1991 M 003 Develop Draft Strategy 03/30/92 03/31/92 / / M 004 Conduct Focus Groups 05/31/92 05/31/92 M 005 Begin Implementation 06/30/92 06/30/92 / / of Strategy M 006 Verification of / / / / / / Completion Validation Process to be Used: To be determined Corrective Action Plan Status Updates: o September 30. 1991 Status Update: Report was just published October 1, 1991. ------- U. S. ENVIRONMENTAL PROTECTION AGENCY ENCLOSURE D MATERIAL WEAKNESS/CORRECTIVE ACTIONS PAGE 16 OF 97 FISCAL YEAR 1991 CATS Tracking Number: Title of Material Weakness: Elevate site-specific issues (EPA/DOJ issues): Description of Uncorrected Material Weaknesses: The Superfund 30- day Study Task Force issued its report, which recommended various ways to accelerate hazardous waste site cleanup, on July 19, 1991. An implementation plan, which outlined specific options and milestones, was released on October 1, 1991. The specific recommendations and milestones that apply directly to OWPE are as follows: Description of Material Weakness and Its Impact on Agency Operations; The Task Force recommended more aggressive action to elevate and resolve DOJ/EPA issues that delay progress at individual sites. Functional Category in Statistical Summary; Program Management Appropriation/Program Element: Superfund Trust Fund Administrative Activity/Program Activity: Environmental impact Year Identified: 1991 Source of Discovery: 30-day Study Original Target Correction Date: 9-30-92 Current Target Date: 9-30-92 Critical Milestones in Corrective Action: Schedule meetings between senior managers at DOJ and EPA Oct. 91 Schedule a meeting between DOJ, States and EPA Oct. 91 to discuss issue-resolution A. Completed Actions/Events; Schedule a meeting between mid-level managers at.DOJ Sep. 91 and EPA to discuss the issue-resolution initiative B. Planned Actions/Events (FY 1992); Use regular conference calls and Branch Chiefs' Ongoing meetings to identify case-specific EPA-DOJ issues; and have OWPE's settlement expediter review issues ------- U. S. ENVIRONMENTAL PROTECTION AGENCY ENCLOSURE D MATERIAL WEAKNESS/CORRECTIVE ACTIONS PAGE 17 OF 97 FISCAL YEAR 1991 Elevate issues, as appropriate, to the monthly EPA-DOJ Ongoing meeting for resolution Include DOJ/EPA issues in quarterly progress reports to Ongoing DAA, OSWER Validation Process to be Used: Once issues are elevated and resolved, fewer moratorium extension requests should be made to Headquarters. The number of settlements that had been languishing would be increased, and this data would be revealed in CERCLIS. At intervals of 6, 9 and 12 months, the Regions would be surveyed to ask which long-term disputes had not been elevated, and whether the DOJ/EPA meetings are achieving their purpose. Corrective Action Plan Status Updates: o September 30. 1991. Status Update: On Target ------- U. S. ENVIRONMENTAL PROTECTION AGENCY ENCLOSURE D MATERIAL WEAKNESS/CORRECTIVE ACTIONS PAGE 18 OF 97 FISCAL YEAR 1991 CATS Tracking Number; Title of Material Weakness: Accelerate Private Party Cleanups Description of Material Weakness and Its Impact on Agency Operations: In order to limit "midstream" private party takeovers, responsible parties will not be able to assume the' lead for a project while particular phases of work are underway. Functional Category in Statistical Summary: Program Management Appropriation/Program Element: Superfund Trust Fund Administrative Activity/Program Activity: Environmental Impact Year Identified: 1991 Source of Discovery: 30-day Study Original Target Correction Date: 9-30-92 Current Target Date: 9-30-92 Critical Milestones in Corrective Action: Publicly announce the initiative Oct. 91 Draft a memorandum limiting PRP takeovers Oct. 91 Circulate the draft memorandum to the Regions, OE, Oct. 91 OGC and DOJ for comment Distribute 'a final policy Nov. 91 A. Completed Actions/Events: none B. Planned Actions/Events (FY 1992) : See critical milestones in corrective action list above. Validation Process to be Used; At quarterly intervals after the guidance had been distributed to the Regions, CERCLIS data should reveal a change in "lead" for a particular phase of the cleanup process. Analysis of the data should show the number of private party takeovers to be decreasing over time. Regions will be contacted monthly to identify sites having private party takeover as issues, and whether it was resolved according to the guidance. Corrective Action Plan Status Updates; o September 30. 1991. Status Update; On Target ------- U. S. ENVIRONMENTAL PROTECTION AGENCY ENCLOSURE D MATERIAL WEAKNESS/CORRECTIVE ACTIONS PAGE 19 OF 97 FISCAL YEAR 1991 CATS Tracking Number: Title of Material Weakness: Begin Remedial Design Before Entry of Consent Decree Description of Material Weakness and Its Impact on Agency Operations; One identified source of cleanup delay is the lapse of time between the time parties enter into a cleanup agreement and the date the consent is entered. Under this option, the remedial design would begin prior to entry of the consent decree. Functional Category in Statistical Summary: Program Management Appropriation/Program Element: Superfund Trust Fund • Administrative Activity/Program Activity: Program Management Year Identified; 1991 Source of Discovery: 30-day Study Original Target Correction Date: 9-30-92 Current Target Date: 9-30-92 Critical Milestones in Corrective Action; Publicly announce the initiative Oct. 91 Draft a memorandum establishing accelerated remedial Oct. 91 design as a national "bottom line" position Circulate the draft memorandum to the Regions, OE, Oct. 91 OGC and DOJ for comment Distribute a final policy Nov. 91 A. Completed Actions/Events; none B. Planned Actions/Events (FY 1992): See critical milestones in corrective action list above Validation Process to be Used: In the past, the remedial construction work had to wait to begin until the consent decree between responsible parties and EPA was entered into the court by DOJ. The entry of the decree was further held up by a 30-day public comment period. If the lag time between receipt of the consent decree and its filing by DOJ could be eliminated, as well as the time consumed by the public comment period,'construction ------- U. S. ENVIRONMENTAL PROTECTION AGENCY ENCLOSURE D MATERIAL WEAKNESS/CORRECTIVE ACTIONS PAGE 20 OF 97 FISCAL YEAR 1991 could be started much sooner. Within a short time of distributing the final policy on accelerating cleanups, and by not waiting for these two events, CERCLIS data would show remedial construction start dates with no entry date for the consent decree, or the CERCLIS data would show construction start dates preceding consent decree entry dates. The policy will encourage the Regions to start the Remedial Design at the time of referral or even earlier. Within a year, comparisons could be made to previous years. Corrective Action Plan Status Updates; o September 30. 1991. Status Update: On Target ------- U. S. ENVIRONMENTAL PROTECTION AGENCY ENCLOSURE D MATERIAL WEAKNESS/CORRECTIVE ACTIONS PAGE 21 OF 97 FISCAL YEAR 1991 Title of Material Weakness: Federal Facilities Enforcement Description of Material Weakness and Its Impact on Agency Operations; Government-wide, environmental management (including cleanup and compliance) programs are .being reported as a material weakness in the FMFIA process. The Department of Energy and the Department of Defense are the two largest Federal agencies identifying environmental . management programs as a material weakness. As these agencies take corrective actions that will span several decades, corrective actions will include compliance with environmental statutes and regulations that EPA has responsibility for enforcing. EPA is part of the corrective action process. However, Federal Facilities for EPA is also a material weakness in another, different sense than the other Federal agencies. EPA's Federal Facilities Enforcement program has not had a sufficient resource base to perform an adequate level of oversight of other Agencies' environmental compliance and restoration plans and activities. This is a government-wide challenge that needs improved interagency attention. EPA is responsible for overseeing the cleanup of contaminated sites at numerous Federal Facilities, as well as inspecting facilities for compliance with all environmental laws and initiating appropriate enforcement for facilities out of compliance. There are almost 9,000 environmental projects within the Federal government totalling about $6.6 billion for FY 1992. The Federal Facilities resource request for FY 1992 totalled about 272 workyears and $34 million. These resources are a very small fraction of the total Federal Facilities work involved. In budget outyears, the resource requirements for Federal Facilities environmental cleanup and restoration by other Federal agencies could increase over 100 percent. EPA does not currently have anywhere near the level of resources that will allow the Agency to maintain an adequate degree and level of oversight over the other Federal agencies' environmental activities. A specific case in point is occurring in FY 1992. When the Agency and OFFE prepared its FY 1992 budget request, the Federal DOD Base Closure program was nonexistent. Now as EPA begins FY 92, initial workload estimates indicate that over 88.9 new, ------- U. S. ENVIRONMENTAL PROTECTION AGENCY ENCLOSURE D MATERIAL WEAKNESS/CORRECTIVE ACTIONS PAGE 22 OF 97 FISCAL YEAR 1991 unanticipated workyears will be required for this program during FY 1992. The sheer magnitude, impact, and political realities of the Base Closure program could easily consume the entire Federal Facilities resource base during this period. Another major resource problem is associated with the Conservation Law Foundation (CLF) decision. The Court ordered EPA to conduct Preliminary Assessments (PA) by July 1992, and if necessary, list some 1,200 Federal Facilities which are candidates for the National Priority List. At present, EPA has no resources for fulfilling these oversight responsibilities, and the progress of Federal Facility site clean up will be impeded. Functional Category in . Statistical .Summary: Regulatory Oversight/Program Execution Appropriation/Program Element: TYPY3A, AYNH3A Administrative Activity/Program Activity: Year Identified: 1991 Source of Discovery: Determination by EPA Senior management Original Target Correction Date: 1993 Current Target Date: 1993 Critical Milestones in Corrective Action: A. Completed Actions/Events: B. Planned Actions/Events (FY 1992): 1. FTE Administrative Ceiling relief requested from OMB in December 1991. 2. Develop strategy for program efficiencies. 3. Develop strategy for streamlining cleanup process. ------- U. S. ENVIRONMENTAL PROTECTION AGENCY ENCLOSURE D MATERIAL WEAKNESS/CORRECTIVE ACTIONS PAGE 23 OF 97 FISCAL YEAR 1991 C. Planned Actions/Events (FY 1993 and beyond): 1. Attempt to reach adequate resource level, both FTE and extramural dollars, for Federal Facilities program. Validation Process to be Used: To Be Determined ------- U. S. ENVIRONMENTAL PROTECTION AGENCY ENCLOSURE D MATERIAL WEAKNESS/CORRECTIVE ACTIONS PAGE 24 OF 97 FISCAL YEAR 1991 CATS Tracking Number: Assessable Unit/AU /: OERR/HSED/1901 Title of Material Weakness; Contract Lab Program Description of Material Weakness and its Impact on Agency Operations: The CLP was identified as a material weakness candidate by the OIG, and OERR concurs with the recommendation. A corrective action plan will be submitted for the first quarter CATS report. Work Plan #: In Progress Functional Category in Statistical Summary; Program Management Appropriation/Program Element: Superfund; 68/20X8145/TFAY9A Administrative Activity/Program Activity: Program Activity Year Identified: 1991 Source of Discovery; OIG Audit: FMFIA Audit of the CLP (Willis Greenstreet Report) Original Target Correction Date: In Progress Current Target Date: In Progress Critical Milestones in Planned Corrective Action: A. Completed Actions/Events; None ------- U. S. ENVIRONMENTAL PROTECTION AGENCY MATERIAL WEAKNESS/CORRECTIVE ACTIONS FISCAL YEAR 1991 ENCLOSURE D PAGE 25 OF 97 B. Planned Actions/Events (Short-Term - Next 12 Months): M/S # MILESTONE TITLE ORIG M 001 Recommendations to AOB 11/10/91 from Audit Report PLAN 11/10/91 M 002 Strategy Meeting to 11/15/91 11/15/91 Address Needed Actions 11/31/91 11/31/91 ACTUAL / / / / / / M 003 Assignment of Responsibilities and Definition of Completion Dates Validation Process to be Used; To be determined Corrective Action Plan Status Updates: o September 30. 1991 Status Update: Report was still confidential as of 09/30/91 and will not be released until mid- October. At that time, a more definite workplan will be prepared and outlined in Ql CATS update. ------- U. S. ENVIRONMENTAL PROTECTION AGENCY ENCLOSURE D MATERIAL WEAKNESS/CORRECTIVE ACTIONS PAGE 26 OF 97 FISCAL YEAR 1991 CATS Tracking Number: 90-lxl Assessable Unit/AU #: OERR/HSED/1901 Title of Material Weakness: Superfund Program: NPL Listing Consistency Description of Material Weakness and Its Impact on Agency Operations: Senator Lautenberg said that Regions are not consistent in scoring sites for listing on the National Priorities List. EPA agreed to develop guidance and tools for site scoring and quality assurance using the revised Hazard Ranking System to ensure that Regions uniformly interpret and score sites for the NPL under the revised HRS. Workplan #: 642 Functional Category in Statistical Summary; Program Management Appropriation/Program Element: Superfund; 68/20X8145/TFAY9A Administrative Activity/Program Activity; Program Activity Year Identified: 1989 Source of Discovery: Congressional Hearings on The "Management Review of the Superfund Program". Original Target Correction Date; 9/30/90 Targeted Correction Date in Last Year's Report; 9/30/90 Current Target Date; 12/31/91 Reason for Change in Date(s): The tools (including a computer program with default values) that are programmed to provide the calculations required by the model cannot be completed until the rule is approved by OMB. The rule went to OMB for review 5/9/90, and it has not yet been approved. Critical Milestones in Planned Corrective Action; A. Completed Actions/Events: The program strategy has been completed, and the computer program has been written and tested using the version of the rule which was sent to OMB. ------- U. S. ENVIRONMENTAL PROTECTION AGENCY ENCLOSURE D MATERIAL WEAKNESS/CORRECTIVE ACTIONS PAGE 27 OF 97 FISCAL YEAR 1991 e M/S # MILESTONE TITLE ORIG PLAN ACTUAL M 005 Draft PA Guidance 07/31/90 12/31/90 11/28/90 M 006 State Coop. Agr. 09/30/90 02/28/91 04/10/91 Wrkpln/Draft Strat M 004 Dist. Final Rhrs 05/30/90 10/30/90 01/15/91 Implementation Plan B. Planned Actions/Events (Short-Term - Next 12 Months): * Indicates milestones added since last year's letter. M/S # MILESTONE TITLE ORIG PLAN ACTUAL M 003* Finalize Computer 04/30/90 10/01/91 / / Program M 009* Draft SI Guidance 07/31/90 11/30/91 / / M 010* Mrs Guidance Manual 12/01/91 12/31/91 / / M Oil* Verification of 12/31/91 12/31/91 / / Completion C. Planned Actions/Events (Longer Term): HRS packages will be reviewed on a continuous basis to determine whether the tools and guidance have been effective, and what additional measures are needed to improve both quality and consistency of NPL packages. . Validation Process to be Used: Continuing review of all data' packages, determining problems, scoring the categories of problems, comparison with the baseline review. (This is a Division-level TQM project.) ------- U. S. ENVIRONMENTAL PROTECTION AGENCY ENCLOSURE D MATERIAL WEAKNESS/CORRECTIVE ACTIONS PAGE 28 OF 97 FISCAL YEAR 1991 Corrective Action Plan Status Updates; o September 30. 1991. Status Update: Preliminary Assessment guidance and Preliminary Assessment Score were issued as OSWER directives. A computer assisted directory was developed for the SA Sources of Information. SI guidance was developed, and a national workgroup was established to continue to improve the site evaluation process. Testing for PREScore Algorithm was completed, and training schedules were developed. HRS Guidance Workgroup was established and the final draft of Preliminary Resolutions for Update 11 was completed. Over 5 HRS/Site Assessment Orientations, 5 HRS Package Preparation Sessions, and a survey of Regional and State Training needs were completed. Development of the Site Assessment Video and PA/SI Training Sessions have begun. ------- U. S. ENVIRONMENTAL PROTECTION AGENCY ENCLOSURE D MATERIAL WEAKNESS/CORRECTIVE ACTIONS PAGE 29 OF 97 FISCAL YEAR 1991 CATS Tracking Number: 90-lal6 Assessable Unit/AU #: OERR/HSCD/1902 Title of Material Weakness: Superfund Program: Technical Assistance Grant (TAG) Application Process & Procurement Requirements Description of Material Weakness and Its Impact on Agency Operations: EPA should simplify the application process and simplify the procurement reguirements. EPA should address revamping the TAG application process to give more weight to the NRDC recommendation of considering health effects from site contamination that may have been suffered by TAG applicants. Workplan #-. 00592 Functional Category in Statistical Summary; Program Management Appropriation/Program Element: Superfund/68/20X8145/TFAY9A Administrative Activity/Program Activity: Program Activity Year Identified: 1989 Source of Discovery: The "Management Review of the Superfund Program" Original Target Correction Date: 09/30/90 Targeted Correction Date in Last Year's Report: 09/30/90 Current Target Date: 10/30/91 Reason for Change in Date(s): More program experience needed to test impact of final rule Critical Milestones in Planned Corrective Action: A. Completed Actions/Events: M/S # MILESTONE TITLE ORIG PLAN ACTUAL M 002 Issue Simplified 03/31/90 03/31/90 03/31/90 Materials 003 Dev Procurement 04/30/90 04/30/90 04/30/90 Procedures ------- U. S. ENVIRONMENTAL PROTECTION AGENCY ENCLOSURE D MATERIAL WEAKNESS/CORRECTIVE ACTIONS PAGE 30 OF 97 FISCAL YEAR 1991 B. Planned Actions/Events (Short-Term - Next 12 Months): * Indicates milestones added since last year's letter. M/S # MILESTONE TITLE ORIG PLAN ACTUAL M 004 Amend Tag Rule W/R/T 09/30/90 10/10/91 / / Procurement M 005* Verification of 09/30/91 10/30/91 / / Completion Validation Process to be Used: TAG application processes and procurement requirements are simplified in final TAG rule and applicants successfully follow procedures. Corrective Action Plan Status Updates: o September 30. 1991 Status Update: Rule is currently in Red Border Review (09/12/91). After Red Border, the rule will go to OMB and then be published in the Federal Register. ------- U. S. ENVIRONMENTAL PROTECTION AGENCY ENCLOSURE D MATERIAL WEAKNESS/CORRECTIVE ACTIONS PAGE 31 OF 97 FISCAL YEAR 1991 • CATS Tracking Number; 90-1x4 Assessable Unit/AU #: OERR/HSCD/1902 Title of Material Weakness: Superfund Program: Use of Expedited Cleanup Approaches Description of Material Weakness and Its Impact on Agency Operations: Identify methods to streamline the remedial design and remedial action process. Implement procedures and contract mechanism through ARCS and USAGE to optimize and expedite the RD/RA process. Workplan #: 00706 Functional Category in Statistical Summary: Program Management Appropriation/Program Element: Superfund/68/20X8145/TFAY9A Administrative Activity/Program Activity: Program Activity Year Identified: 1989 Source of Discovery: "The Management Review of the Superfund Program" Original Target Correction Date: 5/30/90 Targeted Correction Date in Last Year's Report: 5/30/90 Current Target Date: 10/31/91 Reason for Change in Date(s); Additional milestones added to evaluate effectiveness of guidance Critical Milestones in Planned Corrective Action: A. Completed Actions/Events; M/S # MILESTONE TITLE ORIG PLAN ACTUAL M 004 Finalize and Issue 05/30/90 05/30/90 06/04/90 Guidance B. Planned Actions/Events (Short-Term - Next 12 Months): * Indicates milestones added since last year's letter. M/S # MILESTONE TITLE ORIG PLAN ACTUAL ------- U. S. ENVIRONMENTAL PROTECTION AGENCY MATERIAL WEAKNESS/CORRECTIVE ACTIONS FISCAL YEAR 1991 ENCLOSURE D PAGE 32 OF 97 M 009 Evaluate Expedited Approach M/S # Milestone Title M 010* Verification of Completion 06/28/91 10/31/91 ORIG 10/31/91 PLAN 10/31/91 / / ACTUAL / / Validation Process to be Used: streamline the RD/RA process. Regions implement guidance to Corrective Action Plan Status Updates: o September 30. 1991 Status Update; DCMB is gathering a list of expedited clean-up approach sites and will write a status report during the month of October. ------- U. S. ENVIRONMENTAL PROTECTION AGENCY ENCLOSURE D MATERIAL WEAKNESS/CORRECTIVE ACTIONS PAGE 33 OF 97 FISCAL YEAR 1991 CATS Tracking Number: 90-1 Title of Material Weakness: Superfund Program: Cost Documentation Work Plan #: 90010 Description of Material Weakness and its Impact on Agency Operations: Develop a rulemaking on cost documentation. Functional Category in Statistical Summary: Program Management Appropriation/Program Element: Superfund Trust Fund Administrative Activity/Program Activity: Program Management Year Identified: 1989 Source of Discovery: Administrator's request for a major review of the Superfund Program. ^>riginal Target Correction Date: 07/31/91 Targeted Correction Date in Last Year's Report: 07/31/91 Current Target Date: Unknown Reason for Change in Date(s): Rule withdrawn from OMB by OSWER/AA's office. Critical Milestones in Corrective Action: A. Completed Actions/Events: M/S # MILESTONE TITLE ORIG PLAN ACTUAL M 004 Red Border Review 04/30/90 04/30/90 07/30/90 B. Planned Actions/Events (Short-Term-Next 12 Months); M/S # MILESTONE TITLE ORIG PLAN ACTUAL M 007 **Final Rule 07/31/91 07/31/91 / / Validation Process to be Used; Timeliness and success rate in cost recovery cases. Corrective Action Plan Status Updates: September 30, 1990 Status Update: Milestones for developing a rulemaking on cost documentation is on schedule. ------- U. S. ENVIRONMENTAL PROTECTION AGENCY ENCLOSURE D MATERIAL WEAKNESS/CORRECTIVE ACTIONS PAGE 34 OF 97 FISCAL YEAR 1991 i o December 31. 1990 Status Update: Pending OMB review. Anticipate OMB review completed by 4/1/91. Rule proposal 5/1/91 with final rule out 6/1/91. o March 31. 1991 Status Update: Still pending OMB review. o June 30. 1991 Status Update: Still pending OMB review. o September 30. 1991 Status Update: Rule withdrawn from OMB by OSWER AA's office. ------- U. S. ENVIRONMENTAL PROTECTION AGENCY ENCLOSURE D MATERIAL WEAKNESS/CORRECTIVE ACTIONS PAGE 35 OF 97 FISCAL YEAR 1991 CATS Tracking Number: 90-1 Title of Material Weakness: Superfund Program: Cost Recovery Goals Work Plan *; 90011 Description of Material Weakness and its Impact on Agency Operations: Development of analysis of cost recovery universe, method for projection of revenues, and internal and external briefing materials. Functional Category in Statistical Summary: Program Management Appropriation/Program Element: Superfund Trust Fund Administrative Activity/Program Activity; Program Management Year Identified: 1989 Source of Discovery: Administrator's request for a major review of the Superfund Program. Target Correction Date: 06/30/90 Targeted Correction Date in Last Year's Report: 06/30/90 Current Target Date: 12/31/91 Reason for Change in Date(s): Extensive comments on draft documents. Pending senior management review and approval. Critical Milestones in Corrective Action; A. Completed Actions/Events: Draft study in internal executive review. B. Planned Actions/Events (Short-Term -Next 12 Months) : Release study. Validation Process to be Used; For internal use only. Corrective Action Plan Status Updates; o September 30. 1990 Status Update: Original target correction date slipped from 06/30/90 to 12/01/90 due to extensive comment on draft documents. o December 31, 1990 Status Update; Release date slipped again from 12/1/90 to 4/1/91 based on extensive executive review comments . ------- U. S. ENVIRONMENTAL PROTECTION AGENCY ENCLOSURE D MATERIAL WEAKNESS/CORRECTIVE ACTIONS PAGE 36 OF 97 FISCAL YEAR 1991 o March 31, 1991 Status Update: Cost Recovery Goals Report pending senior management review and approval. Presently awaiting Division Director's approval before forwarding to OWPE Office Director, OSWER AA and to the Administrator for signature. o June 30. 1991 Status Update: Still pending review and approval by Division Director. o September 30. 1991 Status Update; Still pending review and approval by Division Director. ------- U. S. ENVIRONMENTAL PROTECTION AGENCY ENCLOSURE D MATERIAL WEAKNESS/CORRECTIVE ACTIONS PAGE 37 OF 97 FISCAL YEAR 1991 CATS Tracking Number: 90-1 Title of Material Weakness: Superfund Program: Case/Site management planning Work Plan i: 90013 Description of Material Weakness and its Impact on Agency Operations: Develop site management process and tools for RP search, RI/FS, RD/RA, litigation. Functional Category in Statistical Summary: Program Management Appropriation/Program Element: Superfund Trust Fund Administrative Activity/Program Activity: Program Management Year Identified: 1989 Source of Discovery: Administrator's request for a major review of the Superfund Program. Original Target Correction Date; 06/30/90 Targeted Correction Date in Last Year's Report; 06/30/90 Current Target Date: 12/31/91 Reason for Change in Date(s): Site Management Plan finalized 7/27/91. However, in response to GAO criticism regarding the lack of documentation of enforcement strategies, the Plan has not been distributed pending the OWPE Office Director's decision to make minor revisions. Critical Milestones in Corrective Action; A. Completed Actions/Events: M/S # MILESTONE TITLE ORIG PLAN ACTUAL M 003 Regional Comments Resolved 03/30/90 03/30/90 05/30/90 B. Planned Actions/Events (Short-Term -Next 12 Months): Draft Site Management Plan — 02/28/91 Final Site Management Plan — 06/30/91 Validation Process to be Used; Regional evaluation of Site Management Plan. Usefulness — 6 months - 1 year after implementation. ------- U. S. ENVIRONMENTAL PROTECTION AGENCY ENCLOSURE D MATERIAL WEAKNESS/CORRECTIVE ACTIONS PAGE 38 OF 97 FISCAL YEAR 1991 Corrective Action Plan Status Updates; o September 30. 1990 Status Update: Original target correction date slipped from 06/30/90 to 06/30/91 due to delays in final formulation of Agency policy on pre-referral negotiation procedures. o December 31. 1990 Status Update: Draft Site Management Plan date of 11/30/90 slipped to 02/28/91 due to substantial changes in organization and content of document. o March 31. 1991 Status Update: Draft Site Management Plan completed. Pending internal review and comment prior to transmitting to Regions in mid-May 1991 for their review and comment. o June 30. 1991 Status Update; Delay in receiving regional comments. Additional time needed to incorporate regional comments and to allow for OEPJR/ERD review and comment at their request. o September 30. 1991 Status Update: Plan finalized 7/27/91. However, in response to the GAO criticism regarding the lack of documentation of enforcement strategies, the Plan is pending the Office Director's decision to make minor revisions prior to distribution. ------- U. S. ENVIRONMENTAL PROTECTION AGENCY ENCLOSURE D MATERIAL WEAKNESS/CORRECTIVE ACTIONS PAGE 39 OF 97 FISCAL YEAR 1991 CATS Tracking Number; 90-1R Assessable Unit/AU #: OEPJR\ERD\1900 Title of Material Weakness: Superfund Program: Removal Assessments at NPL Sites, Phase I Description of Material Weakness and Its Impact on Agency Operations; The Superfund Management Review identified the need to perform removal assessments at each NPL site. Workplan #: 607 Functional Category in Statistical Summary; Program Management Appropriation/Program Element; Superfund; 68/20X8145/TFAY9A Administrative Activity/Program Activity; Program Activity Year Identified: FY 1989 Source of Discovery; The "Management Review of the Superfund Program" Original Target Correction Date; 9/30/90 Targeted Correction Date in Last Year's Report; 9/90 Actual Completion Date; 10/19/90 Corrective Actions Taken; * Indicates milestones added since last year's letter. M/S # MILESTONE TITLE ORIG PLAN ACTUAL M 001 Send Memo to Regions 07/06/89 07/06/89 07/06/89 M 002 Regions Submit Assessment Schedule 07/31/89 07/31/89 07/31/89 M 003 Regions Complete Assessments 09/30/89 09/30/89 11/30/89 M 007 Compile NPL Response Action Plan 11/30/89 11/30/89 11/30/89 M 008 Regional Progress Report 03/30/90 03/30/90 03/10/90 M 009 Regional Progress Report 06/29/90 06/29/90 06/19/90 M Oil Start Removals at Unaddressed Sites 09/30/90 09/30/90 08/30/90 M 012 Regions Complete All NPL Assessment 09/30/90 09/30/90 09/27/90 ------- U. S. ENVIRONMENTAL PROTECTION AGENCY ENCLOSURE D MATERIAL WEAKNESS/CORRECTIVE ACTIONS PAGE 40 OF 97 FISCAL YEAR 1991 M 014 Documentation Memo Fran Regions 09/30/90 09/30/90 10/19/90 M 015* Verification of Conpletion 09/30/90 09/30/90 10/19/90 Results of Validation Actions: Receipt of Regional documentation letters. September 30. 1991 Status Update: Workplan Complete. ------- U. S. ENVIRONMENTAL PROTECTION AGENCY ENCLOSURE D MATERIAL WEAKNESS/CORRECTIVE ACTIONS PAGE 41 OF 97 FISCAL YEAR 1991 CATS Tracking Number: 90-1R (continued) Assessable Unit/AU /: OERR\ERD\1900 f* Title of Material Weakness: Superfund Program: Removal Actions at NPL Sites, Phase II Description of Material Weakness and Its Impact on Agency Operations: ERD conducted removal assessments at previously unaddressed sites and stabilized the sites and/or eliminated dangers at the 23 sites where immediate threats were identified. The "Management Review of the Superfund Program" identified the need to render each site safe from immediate hazards to public health and the environment. Workplan I: 647 Functional Category in Statistical Summary: Program Management Appropriation/Program Element: Superfund; 68/20X8145/TFAY9A Administrative Activity/Program Activity: Program Activity Year Identified: 1989 Source of Discovery: The "Management Review of the Superfund Program" Original Target Correction Date; 9/30/90 Targeted Correction Date in Last Year's Report; 9/90 Actual Completion Date: 11/30/90 Corrective Actions Taken: * Indicates milestones added since last year's letter. M/S # MILESTONE TITLE ORIG PLAN ACTUAL M 003 Draft Goal Memo Prepared 08/30/89 08/30/89 08/30/89 M 004 Final Goal Memo Ready 09/15/89 09/15/89 09/14/89 M 005 OSWER Corcurrence 09/29/89 09/29/89 09/18/89 M 001 Memo to Regional Administrators 09/18/89 09/30/89 09/18/89 M 015 Removal Action Update 11/30/90 11/30/90 11/30/90 M 014* Verification of Completion 11/30/90 11/30/90 11/30/90 ------- U. S. ENVIRONMENTAL PROTECTION AGENCY ENCLOSURE D MATERIAL WEAKNESS/CORRECTIVE ACTIONS PAGE 42 OF 97 FISCAL YEAR 1991 Results of Validation Actions: Response actions have been started at the 23 sites as recorded in CERCLIS, September 30. 1991 Status Update; Workplan Complete. ------- U. S. ENVIRONMENTAL PROTECTION AGENCY MATERIAL WEAKNESS/CORRECTIVE ACTIONS FISCAL YEAR 1991 ENCLOSURE D PAGE 43 OF 97 CATS Tracking Number: 90-la7 Assessable Uhit/AU /: OERR\HSCD\1902 Title of Material weakness; Superfund Program: Increase citizen involvement Description of Material Weakness and Its Impact on Agency Operations.: The Administrator should strongly support increased citizen involvement in Superfund decisions, by dedicating resources necessary for greater citizen involvement and accepting occasional delays as a result. Also supports 47.F Workolan #: 00582 Functional Category in Statistical Summary: Program Management Appropriation/Program Element; Superfund/68/20X8145/TFAY9A Administrative Activity/Program Activity: Program Activity Year Identified: 1989 Source of Discovery; The "Management Review of the Superfund Program" Original Target Correction Date; 12/31/89 Targeted Correction Date in Last Year's Report; 11/30/90 Actual Completion Date; 11/30790 Reason for Change in Date(s); EPA administration was not available to video during planned time frame. Corrective Actions Taken: M/S # MILESTONE TITLE M 005 Select Projects M 006 Workplans for Selected Projects M 007 Workplan to Revise Handbook. M 012 Method to Measure Progress M 003 Training Video by Admin. M 008 **Short Sheet on Public Invol. M 009 Verification of Completion ORIG PLAN ACTUAL 03/31/90 03/31/90 03/30/90 05/15/90 05/15/90 05/15/90 08/31/90 08/31/90 08/30/90 08/31/50 08/31/90 09/10/90 12/31/89 09/30/90 10/22/90 11/30/90 11/30/90 11/30/90 11/30/90 11/30/90 11/30/90 ------- U. S. ENVIRONMENTAL PROTECTION AGENCY ENCLOSURE D MATERIAL WEAKNESS/CORRECTIVE ACTIONS PAGE 44 OF 97 FISCAL YEAR 1991 Results of Validation Actions: Regions document increased citizen involvement using milestone as a method to measure progress. September 30. 1991 Status Update: Workplan complete. ------- U. S. ENVIRONMENTAL PROTECTION AGENCY ENCLOSURE D MATERIAL WEAKNESS/CORRECTIVE ACTIONS PAGE 45 OF 97 FISCAL YEAR 1991 CATS Tracking Number: 90-1x2 Assessable Unit/AU #: OERR\HSCD\1902 Title of Material Weakness: Superfund Program: Listen to Citizens/Change Actions Where Merited Description of Material Weakness and Its Impact on Agency Operations: EPA managers and staff should listen carefully to what citizens are saying, take the time necessary to deal with their concerns, change planned actions where citizen suggestions have merit, and then explain to citizens what EPA has done and why. Workplan i: 00583 Functional Category in Statistical Summary: Program Management Appropriation/Program Element: Superfund/68/20X8145/TFAY9a Administrative Activity/Program Activity: Program Activity Year Identified: 1989 Source of Discovery: The "Management Review of the Superfund Program" Original Target Correction Date; 12/31/90 Targeted Correction Date in Last Year's Report: 12/31/90 Actual Completion Date: 01/22/91 Corrective Actions Taken: M/S # MILESTONE TITLE ORIG PLAN ACTUAL M 003 Report on Training Needs 04/30/90 04/30/90 04/30/90 M 004 Draft "SS" on Techniques 07/31/90 07/31/90 08/14/90 M 005 Wrkpln to meet Trng. Needs 08/31/90 08/31/90 08/30/90 M 006 **FiJTal Short Sheet 12/31/90 12/31/90 01/22/91 M 007 Verification of Completion 01/22/91 01/22/91 01/22/91 Results of Validation Actions; EPA managers and staff use techniques in milestone short sheet to improve communications with citizens. September 30, 1991 Status Update; Workplan complete. ------- U. S. ENVIRONMENTAL PROTECTION AGENCY ENCLOSURE D MATERIAL WEAKNESS/CORRECTIVE ACTIONS PAGE 46 OF 97 FISCAL YEAR 1991 CATS Tracking Number: 90-lall Assessable Unit/AU #: OERR\HSCD\1902 Title of Material Weakness; Superfund Program; Discuss Site Early/Make Docu. More Readily Avail. Description of Material Weakness and Its Impact on Agency Operations; EPA should discuss site findings and decisions as they are developed, not only at the end of the feasibility study. While a formal comment period is required only at the proposed plan stage, EPA should make documents available to citizens and to PRPs throughout the cleanup process, and be open to continually receiving comments. EPA should be more aggressive about supplying information to citizens and their technical advisors. Citizens' access to information should be comparable to that of PRPs. Neither citizens nor PRPs should have to wait until the end of the remedial investigation and feasibility study to learn the results of the studies. EPA should ensure access to information by (1) establishing information repositories that are convenient to the affected public; (2) completing any necessary review of documents quickly, so the documents can be released; (3) placing documents in the administrative record and the information repositories as soon as possible; and (4) notifying citizens of the availability of that information through fact sheets and other mailings. Workplan #: 586 Functional Category in Statistical Summary; Program. Management Appropriation/Program Element; Superfund/68/20X8145/TFAY9A Administrative Activity/Program Activity; Program Activity Year Identified; 1989 Source of Discovery; The "Management Review of the Superfund Program" Original Target Correction Date; 10/31/90 Targeted Correction Date in .Last Year's Report; 10/31/90 Actual Completion Date; 11/02/90 ------- U. S. ENVIRONMENTAL PROTECTION AGENCY MATERIAL WEAKNESS/CORRECTIVE ACTIONS FISCAL YEAR 1991 ENCLOSURE D PAGE 47 OF 97 Corrective Actions Taken: M/S # MILESTONE TITLE M 004 Conduct Survey M 005 Report on Survey Results M 009 Issue Draft SS W/Recxmmendations M 006 **Final SS and Recommendations M 007 Verification ORIG PLAN ACTUAL 05/24/90 05/24/90 05/23/90 06/30/90 06/30/90 06/29/90 07/31/90 07/31/90 08/02/90 10/31/90 10/31/90 11/02/90 11/02/90 11/02/90 11/02/90 Results of Validation Actions; Regions apply guidance on discussing site findings early to provide citizens and PRPs access to information. September 30. 1991 Status Update; Workplan complete. ------- U. S. ENVIRONMENTAL PROTECTION AGENCY ENCLOSURE D MATERIAL WEAKNESS/CORRECTIVE ACTIONS PAGE 48 OF 97 FISCAL YEAR 1991 CATS Trackincr Number: 90-lal4 Assessable Unit/AU /: OERR\HSCD\1902 Title of Material Weakness; Superfund Program: Problems Staff Turnover Creates for Community Description of Material Weakness and Its Impact on Agency Operations: EPA should be sensitive to the problems that staff turnover create for a community and should preserve the continuity of staff assignments as much as possible. For example, these problems should be considered as costs in deciding whether to reorganize. EPA managers should try to keep continuity and site history on the team if one tpam member must: be replaced. For example, if the site manager is new, the community relations coordinator probably should riot be switched. EPA should educate new staff about the site's history, the community's involvement and concerns, and the importance of these concerns. EPA should communicate staff changes to the community and demonstrate that their concerns are understood. Workplan *: 590 Functional Category in Statistical Summary: Program Management Appropriation/Program Element: Superfund/68/20X8145/TFAY9A Administrative Activity/Program Activity: Program Activity Year Identified; 1989 Source of Discovery: The "Management Review of the Superfund Program" • Original Target Correction Date: 12/31/90 Targeted Correction Date in Last Year's Report: 12/31/90 Actual Completion Date; 12/19/90 Corrective Actions Taken: M/S # MILESTONE TTTLE ORIG PLAN ACTUAL M 002 Draft "SS" 05/21/90 05/21/90 05/18/90 M 003 Receive Comments on SS 07/02/90 07/02/90 06/25/90 M 004 **Final "SS" 12/31/90 12/31/90 12/19/90 M 005 Verification of Completion 12/19/90 12/19/90 12/19/90 ------- U. S. ENVIRONMENTAL PROTECTION AGENCY ENCLOSURE D MATERIAL WEAKNESS/CORRECTIVE ACTIONS PAGE 49 OF 97 FISCAL YEAR 1991 Results of Validation Actions: Regions follow suggestions in memo to minimize staff turnover and to increase continuity of personnel on teams. September 30. 1991 Status Update: Workplan complete. ------- U. S. ENVIRONMENTAL PROTECTION AGENCY ENCLOSURE D MATERIAL WEAKNESS/CORRECTIVE ACTIONS PAGE 50 OF 97 FISCAL YEAR 1991 CATS Tracking Number: 90-1x3 Assessable Uhit/AU #: OERR\HSCD\1902 Title of Material Weakness: Superfund Program: Conmitment to Communication Description of Material Weakness and Its Impact on Agency Operations: Obtain introduction by Administrator to replace cxmmunity relations video introduction by Lee Thomas. Workplan #: 00626 Functional Category in Statistical Summary: Program Management Appropriation/Program Element: Superfund/68/20X8145/TFAY9A Administrative Activity/Program Activity: Program Activity Year Identified; 1989 Source of Discovery: The "Management Review of the Superfund Program" Original Target Correction Date: 12/31/89 Targeted Correction Date in Last Year's Report: 12/31/89 Actual Completion Date: 10/22/90 Reason for Change in Date(s): The Administrator has agreed, his time permitting, to make introductory remarks for a CR training video. HSCD staff is working closely with the Administrator's staff to develop a schedule. The video is part of the CR training skills course and provides a useful introduction to CR and SF. Corrective Actions Taken: M/S # MILESTONE TITLE ORIG PLAN ACTUAL 'M 002 **Ccnplete Training Video W/Admin 12/31/89 09/30/90 10/22/9.0 M 003 Verification of Completion 10/22/90 10/22/90 10/22/90 Results of Validation Actions; "Community Relations Video" available to public September 30. 1991 Status Update: Workplan Complete ------- U. S. ENVIRONMENTAL PROTECTION AGENCY MATERIAL WEAKNESS/CORRECTIVE ACTIONS FISCAL YEAR 1991 ENCLOSURE D PAGE 51 OF 97 CATS Tracking Number: 90-la5 Assessable Unit/AU if: OERR\HSCD\1902 Title of Material Weakness: Superfund Program: Regulatory/policy barriers on the use of treatment technologies Description of Material Weakness and Its Impact on Agency Operations: The impact of RCRA land ban or other rules on use of alternative technologies should be carefully evaluated to identify technologies that may be precluded by the rules. OSWER should explore ways to apply these rules that preserve their intent and spirit without restricting use of viable treatment approaches for Superfund sites. Workplan t\ 564 Functional Category in Statistical Summary: Program Management Appropriation/Program Element: 68/20X8145/TFAY9A Administrative Activity/Program Activity: Program Activity Year Identified: 1989 Source of Discovery: The "Management Review of the Superfund Program" Original Target Correction Date; 09/30/91 Targeted Correction Date in Last Year's Report: 09/30/91 Actual Completion Date: 09/30/91 Reason for Change in Date(s): All activities transferred to workplan 01027. Corrective Actions Taken: M/S # MILESTONE TITLE ORIG PLAN ACTUAL M 003 Support OSW Soil and Debris Reg 09/30/91 09/30/91 09/30/91 M 004 Verification of Completion 09/30/91 09/30/91 09/30/91 ------- U. S. ENVIRONMENTAL PROTECTION AGENCY ENCLOSURE D MATERIAL WEAKNESS/CORRECTIVE ACTIONS PAGE 52 OF 97 FISCAL YEAR 1991 Results of Validation Actions: Regions use treatability variance to develop treatment standards for contaminated soil and debris until treatment standards are promulgated. Evaluation of short-sheets will be done on a case-by-case basis within the Regions. September 30. 1991 Status Update: Workplan Complete ------- U. S. ENVIRONMENTAL PROTECTION AGENCY ENCLOSURE D MATERIAL WEAKNESS/CORRECTIVE ACTIONS PAGE 53 OF 97 FISCAL YEAR 1991 CATS 'Tracking Number: 90-1X Assessable Unit/AU #: OERR/HSCD/1902 Title of Material Weakness: Superfund Program: Five-Year Review of Sites Description of Material Weakness and Its Impact on Agency Operations: As part of EPA's long term effort to monitor site conditions, EPA will conduct a review of all sites at least every five years after the initiation of the remedial action where hazardous substances remain on site. This will ensure that the remedy at each site is fully protective of human health and the environment. EPA will also maintain the effectiveness of the remedy over the long-term by promptly correcting any additional problems that may arise at sites where our monitoring indicates that further response actions are necessary to protect human health and the environment. To assure the public that EPA is carefully monitoring and maintaining each site, EPA will report annually the results of all five-year reviews that were conducted during the preceding twelve month period. EPA will also create a "monitoring list" of sites at which it will conduct reviews. Workolan *: 00570 Functional Category in Statistical Summary: Program Management Appropriation/Program Element: Superfund/68/20X8145/TFAY9A Administrative Activity/Program Activity: Program Activity Year Identified: 1989 Source of Discovery: The "Management Review of the Superfund Program" Original Target Correction Date: 01/31/91 Targeted Correction Date in Last Year's Report; 03/30/91 Current Target Date: 07/15/91 Critical Milestones in Planned Corrective Action: A. Completed Actions/Events: * Indicates milestones added since last year's letter. M/S # MILESTONE TITLE ORIG PLAN ACTUAL M 005 Issue Draft Guidance 01/31/91 01/31/91 11/13/90 ------- U. S. ENVIRONMENTAL PROTECTION AGENCY ENCLOSURE D MATERIAL WEAKNESS/CORRECTIVE ACTIONS PAGE 54 OF 97 FISCAL YEAR 1991 M/S # M 006 M 009* B. M/S # M MILESTONE TITLE Issue Short Sheet/Guidance Issue Short Sheet Planned Act ions/ Events MILESTONE TITLE 007* Verification of ORIG 03/30/91 07/15/91 (Short-Term ORIG 07/15/91 PLAN 04/12/91 07/15/91 - Next 12 PLAN 07/15/91 •ACTUAL 05/23/91 08/19/91 Months): ACTUAL 09/30/91 Completion Validation Process to be Used: Regions use guidance to conduct 5-year reviews. Corrective Action Plan Status Updates: o September 30. 1991. Status Update: Issuance of the short sheet in August 1991, represented the final milestone for this activity. While HSCD plans to issue supplementary guidance, follow-up with the Regions on schedule for actual reviews, and concur in initial Regional reviews, these are merely inplementation steps of the above policy. ------- U. S. ENVIRONMENTAL PROTECTION AGENCY ENCLOSURE D MATERIAL WEAKNESS/CORRECTIVE ACTIONS PAGE 55 OF 97 FISCAL YEAR 1991 CATS Tracking Number: 90-1A51 Assessable Unit/AU *: OERR\OPM\1902 r* Title of Material Weakness: Superfund Program: Timely and accurate dissemination of information, Phase I Description of Material Weakness and its Impact on Agency Operations; In response to weaknesses identified in the 90-day Study with respect to the program's ability to quickly disseminate consistently formatted and managed guidance and policy direction to the regional users, a variety of remedies were proposed and have been completed as planned. These included: development of a Publications Standard Handbook which presents acceptable standards for planning, controlling, designing, formatting, obtaining concurrence, and managing distribution of ALL documents required to perform the work of the Superfund program. development and transmittal of the Office Director-level directives that require usage of same, and development, testing and utilization of software, including a centrally managed PC label system to control distribution and an inventory management software system. These tools were essential to the development and maintenance of a controlled system to ensure that all Superfund information is readily available to the users. Work Plan f: 00557 * Functional Category in Statistical Summary; Program Management Appropriation/Program Element: Superfund; 68/20X8145/TFAY9A Administrative Activity/Program Activity: Program Activity Year Identified: 1989 Source of Discovery; The "Management Review of the Superfund Program" Original Target Correction Date: 01/31/89 Targeted Correction Date in Last Year's Report: 01/31/89 Actual Completion Date: 09/30/91 Reason for Change in Date; Activity was expanded. ------- U. S. ENVIRONMENTAL PROTECTION AGENCY MATERIAL WEAKNESS/CORRECTIVE ACTIONS FISCAL YEAR 1991 ENCLOSURE D PAGE 56 OF 97 Corrective Actions Taken: *Milestones added since last year's letter. M/S # MILESTONE TITLE M 001 Establish Vforkgroup and Hold 1st Mtg. M 002 Define Mechanism for Automating M 003 Identify and Formalize Distrib. Sys. M 004 Develop Draft Forrrats/Procedures M 007 Finalize Lists and Agreements M 006 Test Automated System M 008 Finalize Format and Procedures M 009 System in Place and Operational M 010 Validate and Fine-Tune System M 011*Verification of Completion ORIG PLAN ACTUAL 10/15/89 10/15/89 10/15/89 11/15/89 11/15/89 11/15/89 01/30/90 01/30/90 01/30/90 03/01/90 03/01/90 03/01/90 06/30/90 06/30/90 06/30/90 05/01/90 07/30/90 07/30/90 08/15/90 08/15/90 08/15/90 09/30/90 09/30/90 09/30/90 09/30/91 09/30/91 09/30/91 09/30/91 09/30/91 09/30/91 Results of Validation Actions: Publications Standard Handbook and associated document development controls have already cut 3-6 weeks and as much as 20 percent from the costs associated with developing and printing a major guidance or technical document. More measurable saving is expected in FY 1992 and will be carefully examined. The centralized PC label system, when fully operational, is expected to save 2-3 clerical FTEs and will reduce document distribution time by as much as one week. Validation will occur in FY 1991. ------- U. S. ENVIRONMENTAL PROTECTION AGENCY ENCLOSURE D MATERIAL WEAKNESS/CORRECTIVE ACTIONS PAGE 57 OF 97 FISCAL YEAR 1991 Title of Material Weakness: Timely and Accurate Dissemination of Information, Phase II Work Plan /; 00568 Description of Material Weakness and its Impact on Agency Operations: Develop mailing list of key constituents; communications plan; and information kit on the program. Functional Category in Statistical Summary: Program Management Appropriation/Program Element: Superfund; 68/20X8145/TFAY9A Administrative Activity/Program Activity: Program Activity Year Identified: 1989 Source of Discovery: The "Management Review of the Superfund Program" Original Target Correction Date: 11/30/89 Targeted Correction Date in T>st Year's Report: 08/31/89 Actual Completion Date: 11/19/90 Reason for Change in Date(s): Activity was expanded. Corrective Actions Taken; * Milestone added since last year's letter. M/S # MILESTONE TITLE ORIG PLAN ACTUAL M 001 Determine Interim Distribution System 06/28/89 06/28/90 06/28/90 M 002 Circ. Draft Mailing List for Comment 07/07/89 07/07/89 07/07/89 M 005 Circulate Possible Info, for Comment 07/19/89 07/19/89 07/19/89 M 006 Distrib Mailing List and Instructions 08/31/89 08/31/89 08/21/89 M 007 Complete Interim Information Kit 11/30/89 12/21/89 01/18/90 M 009 Issue Revised Communication Plan 01/31/89 11/19/90 11/19/90 M 010* Verification of Completion 11/19/90 11/19/90 11/19/90 ------- U. S. ENVIRONMENTAL PROTECTION AGENCY ENCLOSURE D MATERIAL WEAKNESS/CORRECTIVE ACTIONS PAGE 58 OF 97 FISCAL YEAR 1991 Results of Validation Actions: Information Kit is frequently requested, therefore fills the gap. f* September 30. 1991 Status Update: Workplan complete. ------- U. S. ENVIRONMENTAL PROTECTION AGENCY ENCLOSURE D MATERIAL WEAKNESS/CORRECTIVE ACTIONS PAGE 59 OF 97 FISCAL YEAR 1991 CATS Tracking Number: 90-1x5 Assessable Unit/AU #: OERR\OPM\1911 Title of Material Weakness: Superfund Program: Eliminate Jargon from Superfund Lexicon Description of Material Weakness and its Impact on Agency Operations: Issue matrix of alternative terms to be used. Work Plan #: 00569 Functional Category in Statistical Summary: Program Management Appropriation/Program Element: Superfund; 68/20X8145/TFAY9A Administrative Activity/Program Activity: Program Activity Year Identified: 1989 Source of Discovery: The "Management Review of the Superfund Program" Original Target Correction Date: 03/31/90 Targeted Correction Date in Last Year's Report; 03/31/90 Actual Completion Date: 11/30/90 Reason for Change in Date(s): Delayed due to need for senior management to sign off. Corrective Actions Taken; * Milestones added since last year's letter. M/S # MILESTONE TITLE ORIG PLAN ACTUAL M 002* Issue Jargon Matrix 03/31/90 05/31/91 06/04/91 M 005* . Verification of Completion 07/04/91 07/04/91 06/10/91 Results of Validation Actions; Office Director has noted the importance of speaking clearly and writing in an understandable fashion at OERR-wide staff meetings and in memos to staff. In addition, the staff that reviews correspondence has been empowered to return responses if they are "jargony". September 30. 1991 Status Update; Workplan complete. ------- U. S. ENVIRONMENTAL PROTECTION AGENCY ENCLOSURE D MATERIAL WEAKNESS/CORRECTIVE ACTIONS PAGE 60 OF 97 FISCAL YEAR 1991 CATS Tracking Number: 90-1A26 Assessable Unit/AU #: OERR\OPM\1911 Title of Material Weakness: Superfund Program; Environmental Results Indicators Description of Material Weakness and its Impact on Agency Operations: Inadequate attention has been paid to developing and ccranunicating a meaningful national picture of the Superfund program's accomplishments. Moreover, the language that has been used to discuss progress has not conveyed progress in a way the public could understand. Ineffective communication of the program's accomplishments reduced the public credibility of the program, and placed impediments on program progress due to the need to respond to frequent program criticisms. By October 1, 1989, begin collection of data to report environmental results indicators for: the number of sites where exposure from air, surface water and/or ground water releases of hazardous substances have been controlled; progress towards meeting the human health and/or ecological goals at sites; the amount of hazardous materials treated or removed and area of material contained. Workplan #: 00548 Functional Category in Statistical Summary: Program Management Appropriation/Program Element? Superfund; 68/20X8145/TFAY9a Administrative Activity/Program Activity: Program Activity Year Identified: 1989 Source of Discovery; The "Management Review of the Superfund Program" Original Target Correction Date; 4/30/90 Targeted Correction Date in Last Year's Report; 4/30/90 Actual Completion Date: 09/15/91 Reason for Change in Date(s): Scope of data collection, quality assurance, and analytic review work was substantially larger than originally planned. Draft final report has gone through extensive structural,and editorial changes which have significantly delayed its completion. Critical Milestones in FY 1991 Planned Corrective Action: A. Completed Act ions/Events; * Indicates milestones added since last year's letter. ------- U. S. ENVIRONMENTAL PROTECTION AGENCY ENCLOSURE D MATERIAL WEAKNESS/CORRECTIVE ACTIONS PAGE 61 OF 97 FISCAL YEAR 1991 M/S # MILESTONE TITLE ORIG PLAN ACTUAL M 021 Complete Regional Quality Assurance 04/27/90 04/30/90 06/28/90 M 028 Contaminant Groupings 05/18/90 05/18/90 05/18/90 M 026 Meet With Regions on FY 91 Rqmts. 05/24/90 05/24/90 05/24/90 M 029 Groundwater Pump and Treat 05/31/90 05/31/90 06/11/90 M 023 Draft Final Report 06/10/90 06/10/90 06/08/90 M 027 Population Data Analysis 06/10/90 06/10/90 06/05/90 M 024 Ccmnunications Strategy 06/20/90 06/20/90 06/20/90 M 020 Work With HSCD on El Data Reporting 07/01/90 07/01/90 07/01/90 M 022 Resolve Issues from QA 05/18/90 07/10/90 07/26/90 M 008 **Final FY 1990 El Report 04/30/90 10/12/90 10/26/90 M 009 Regional El Procedures in Place 07/01/90 11/08/90 11/20/90 M 010 Issue Semi-Annual El Report 11/30/90 04/30/91 / / M Oil* Verification of Completion 09/30/91 09/30/91 09/15/91 Results of Validation Process: Management has used a variety of CERCLIS data analyses to validate the accuracy and completeness of the environmental indicators data that have been collected. Similar analytic techniques will be used to assess the completeness of El data reporting by the Regions in the coming year. Corrective Action Plan Status Updates; o September 30. 1991. Status Update; Data collection for the initial environmental indicator report was completed in March 1990. Data analysis and quality assurance proceeded through Summer 1990. The final report was completed in October 1990 and released by the Administrator in December 1990. Work is underway to prepare an updated Superfund environmental indicator report with progress information through the end of 1990. Current schedule calls for completion in April 1991. The FY 1991 report, entitled "Superfund: Reporting Progress Through Environmental Indicators, FY91 Update" was approved by the Assistant Adininistrator and sent to the Deputy Administrator on August 2, 1991. On August 29, 1991, the Assistant Administrator held a brainstorming/strategy session to ------- U. S. ENVIRONMENTAL PROTECTION AGENCY ENCLOSURE D MATERIAL WEAKNESS/CORRECTIVE ACTIONS PAGE 62 OF 97 FISCAL YEAR 1991 discuss the El messages and how best to make them known to the public. It was decided that fact sheets of El progress should be developed and made available to many offices within the Agency, with the hope that Superfund progress would be incorporated into other Agency papers and briefings. No formal announcement of this second El report is expected. Future reports will be issued on an annual basis. This completes the workplan. ------- U. S. ENVIRONMENTAL PROTECTION AGENCY ENCLOSURE D MATERIAL WEAKNESS/CORRECTIVE ACTIONS PAGE 63 OF 97 FISCAL YEAR 1991 CATS Tracking Number: 90-1 Title of Material Weakness: Superfund Program: Settlement Tools - Provide training Work Plan #: 90002 Description of Material Weakness and its Iinpact on Agency Operations: Establish clearinghouse of information on use of settlement tools, and develop case-method training for RPMs and regional attorneys. Functional Category in Statistical Summary; Program Management Appropriation/Program Element: Superfund Trust Fund Administrative Activity/Program Activity: Program Management Year Identified: 1989 Source of Discovery: The Administrator's request for a major review of the Superfund Program. Original Target Correction Date: 09/30/90 Targeted Correction Date in Last Year's Report; 09/30/90 Actual Completion Date: 12/30/90 Reason for Change in Date(s): Travel restrictions on regional training and extensive comment/revision of training materials. Corrective Actions Taken: Course developed; pilot test in Wash., DC on 8/15- 16/90 Settlement Tools training course completed 12/3/90 and incorporated into the Superfund Academy. Regional offerings — 10/90 - 3/91 Repeated offerings of course as needed Results of Validation Actions: 1) Student evaluations (short/long term); 2) improvement in program performance. ------- U. S. ENVIRONMENTAL PROTECTION AGENCY ENCLOSURE D MATERIAL WEAKNESS/CORRECTIVE ACTIONS PAGE 64 OF 97 FISCAL YEAR 1991 CATS Tracking Number: 90-1 Title of Material Weakness: Superfund Program: Info. Release to Potentially Responsible Parties Work Plan t: 90008 Description of Material Weakness and its Impact on Agency Operations: Prepare directive on importance of releasing information; develop guidance, databases and other resources; develop policy statement; and follow with a practical memorandum on systems for information release. Functional Category in Statistical Summary: Program Management Appropriation/Program Element: Superfund Trust Fund Administrative Activity/Program Activity: Program Management Year Identified; 1989 Source of Discovery: The Administrator's request for a major review of the Superfund Program. Original Target Correction Date: 06/30/90 Targeted Correction Date in Last Year's Report: 06/30/90 Actual Completion Date: 02/28/91 Reason for Change in Date(s): Expansion of types of models available for use required more time for compilation. Corrective Actions Taken: Waste-in Guidance signed and transmitted to Regions 02/22/91. Specific guidance and models on waste-in lists and volumetric rankings. Results of Validation Actions: Regional Comment - Responses from Regions 1, 3, 5, 6, and 9 have been positive thus far on usefulness of guidance. No formal feedback system other than regional reviews contemplated at this time. ------- U. S. ENVIRONMENTAL PROTECTION AGENCY ENCLOSURE D MATERIAL WEAKNESS/CORRECTIVE ACTIONS PAGE 65 OF 97 FISCAL YEAR 1991 CATS Tracking Number: 90-1 Title of Material Weakness: Superfurd Program: Responsible Party Search Enhancement Work Plan #; 90019 Description of Material Weakness and its Impact on Agency Operations: Establish national criteria for re-doing RP searches. Functional Category in Statistical Summary; Program Management Appropriation/Program Element: Superfund Trust Fund Administrative Activity/Program Activity: Program Activity Year Identified: 1989 Source of Discovery: Administrator's request for a major review of the Superfund Program. Original Target Correction Date: 09/30/90 Targeted Correction Date in Last Year's Report; 09/30/90 Actual Completion Date: 06/01/91 Reason for Change in Datefs): March 1991 Regional/Headquarters agreement to update the 12/28/89 guidance. This 12/89 guidance was too resource intensive on Regions. Corrective Actions Taken: Memo to Regions establishing ground rules on 12/28/89. Follow-up meetings with individual Regions. Criteria established. FY 91 Strategy was issued by 3/1/91. Meetings with Regions were held on 3/25/91. Results of Validation Actions; Evaluation of quality of PRP search. A recently concluded series of PRP search audits revealed a better quality of PRP searches from the contractors and better oversight by Regional offices. ------- U. S. ENVIRONMENTAL PROTECTION AGENCY ENCLOSURE D MATERIAL WEAKNESS/CORRECTIVE ACTIONS PAGE 66 OF 97 FISCAL YEAR 1991 Title of Material Weakness: Data Integrity for Pesticides and Toxic Substances Description of Material Weakness and Its Impact on Agency Operations: Office of Compliance Monitoring (OCM) has determined that its laboratory data integrity program constitutes a material weakness. Several factors have been identified by management that require corrective actions. For instance, inspectors lack training in fraud detection in a laboratory setting. Currently, OCM cannot offer its inspectors this specialized training because there is no known Federal entity or contractor with the required expertise. The OIG is conducting a survey of laboratories, industry, and Federal agencies to determine if there is any expertise which could be utilized to train OCM's inspectors. The findings of this survey should become available in FY 92 when the OIG publishes its final report of the Good laboratory Practice Program review. The effectiveness of the program is weakened by the advance notice that laboratories are given (2-weeks) prior to an inspection. OCM plans to revise on a pilot basis the notification procedures within the first quarter of FY 92. The program also lacks the means to identify laboratories based on the specified studies that they are contracted to conduct. OCM is reviewing the need to prepare a new regulation for periodic reporting of this information. Currently, the identification of the authorizing laboratory is required to be on its published studies. There is, however, no mechanism to funnel this information on completed studies and studles-in-process to OCM. The reporting requirement will not only require the identification of the laboratories and the studies they are conducting, but also the identification of the chemicals associated with the studies. This will enable better oversight and management of the studies done by the laboratories. This program is further exacerbated by the fact that there is no consistency in the training of Headquarters, Regional, and NEIC inspectors. OCM is already planning a major training program in September, 1992. This training will incorporate new information and techniques based on the results and recommendations presented in the OIG's final. GLP report, and the revised Enforcement Response Policy (ERP) for the FIFRA GLP regulations. Functional Category in Statistical Summary: Program Execution Appropriation/Program Element; Pesticides Enforcement Administrative Activity/Program Activity: Program Activity Year Identified; 1991 Source of Discovery: AICR Original Target Correction Date: 1992 ------- U. S. ENVIRONMENTAL PROTECTION AGENCY ENCLOSURE D MATERIAL WEAKNESS/CORRECTIVE ACTIONS PAGE 67 OF 97 FISCAL YEAR 1991 Current Target Date: 1992 Critical Milestones in Corrective Action: A. Completed Actions/Events: OCM has taken action on the recommendations presented in the OIG's special review of the GLP Program discussed earlier in this report. For instance, OCM was instrumental in preparing the Agency's proposed legislation that would recognize GLP violations as FIFRA violations. Also, an interim Enforcement Response Policy (ERP) for the FIFRA GLP regulations was completed in September 1991. This policy provided guidance for determining whether to assess a GLP violation under FIFRA section 12 (a) (2) (Q) as a high, middle, or low level violation. OCM has requested additional resources in.the President's FY 1993 budget to expand its coverage of the regulated community as recommended by the OIG. OCM has also completed the initial planning in the development of a corrective action plan as outlined below. B. Planned Actions/Events (FY 1992): Initiate, on a pilot basis, a revision of the inspection notification procedures 12/91 Implement a revised neutral administrative scheme for laboratory selection procedures 2/92 Initiate an inspector training program which incorporates results/recommendations of OIG and IF a source is found, fraud detection in a laboratory setting 9/92 C. Planned Act ions/Events (FY 1993 and beyond); OCM will expand its coverage of the regulated community when it conducts laboratory inspections and data audits. Validation Process to be Used: Management will verify completion and effectiveness of the above corrective actions based on evaluations of the training programs and the performance of the inspectors. ------- U. S. ENVIRONMENTAL PROTECTION AGENCY ENCLOSURE D MATERIAL WEAKNESS/CORRECTIVE ACTIONS PAGE 68 OF 97 FISCAL YEAR 1991 Title of Material Weakness: Growing Backlog of Requests for Audits of EPA Contractors Description of Material Weakness and Its Impact on Agency Operations; Audits have shown potentially millions of dollars in questioned costs and major internal control weaknesses with accounting and time keeping systems. At present, the limited number of contract incurred cost audits and system reviews does not represent adequate audit coverage of EPA contracts. Almost 90 percent of EPA's contracting dollars are spent on cost reimbursable contracts. This type of contract provides few incentives for contractors to control costs. The responsibility and associated risk rests with 'the Government and places the Government in the position of assuming a proportionately greater risk. Therefore, it is critical that incurred cost audits of contracts be conducted in a timely manner. In addition, there is a substantial and growing backlog of requests for audits of EPA contractors, including at least 390 unmet requests for incurred costs audits. The lack of timely contract audit coverage leaves the Agency vulnerable. The OIG cannot currently provide strong oversight to the Agency's contract funds and cannot fulfill the Agency's demands for contract audits. Audits of the Agency's contractors are needed to provide the Agency's contracting officials with information necessary to effectively: (1) award a contract, (2) substantiate the claims submitted for payment, (3) determine conpliance with legal and administrative conditions, and (4) identify potential indicators of fraud, illegal acts or irregularities. The OIG has identified in the current and future budget requests, the level of additional resources needed to meet the Agency's demand for contract audits. Functional Category in Statistical Summary: Procurement Appropriation/Program Element: 6810112/S&E N3AS5A and Superfund NWAY5A Year Identified: Fiscal 1989 and 1991 Source of Discovery: Fiscal 1989 and 1991 FMFIA Review Process and the ongoing review by the Office of Audit's Contract Task Force. Current Target Date: Ongoing Critical Milestones in Corrective Action; A. Completed Actions/Events; To provide additional audit coverage, the OIG has several initiatives underway, including, formally assuming cognizance for 12 major EPA contractors, hiring auditors with extensive financial auditing experience and implementing an expanded contract audit strategy including closer coordination with the Defense Contract Audit Agency. However, OIG non-Superfund resources have not kept pace with EPA's increased contract workload. Funding for audits of non-Superfund contracts was substantially reduced; therefore, only high ------- U. S. ENVIRONMENTAL PROTECTION AGENCY ENCLOSURE D MATERIAL WEAKNESS/CORRECTIVE ACTIONS PAGE 69 OF 97 FISCAL YEAR 1991 priority assignments (preaward audits) could be performed. Accordingly, we have requested additional resources for contract audit work in the fiscal 1992 & 1993 budgets. B. Planned Act ions/Events (FY 1992): We will request additional resources for contract audits in the fiscal 1994 budget. C. Planned Act ions/Events (FY 1993 and beyond): Justify to the Office of Management and Budget and the Congress the need for additional resources to provide coverage of the Agency's contracts. A request for additional resources has been considered in the current and future budget submissions. Validation Process to be Used: To corpare the budget request, the actual resources received, and the Agency's demand for contract audits. Corrective Action Plan Status Updates: o September 30. 1991. Status Update: Requested additional contract resources in the fiscal 1992 and 1993 budgets. ------- U. S. ENVIRONMENTAL PROTECTION AGENCY ENCLOSURE D MATERIAL WEAKNESS/CORRECTIVE ACTIONS PAGE 70 OF 97 FISCAL YEAR 1991 Title of Material Weakness: Implementation of Storm Water Permitting Requirements Under the Clean Water Act. Description of Material Weakness and Its Impact on Agency Operations: The Clean Water Act amendments of 1987 included requirements and deadlines for storm water permits under the NPDES program (deadlines and requirements for EPA application regulations, submission of applications by the regulated contiunity, issuance of permits, study and reports on unregulated universe of storm water discharges, and development of regulatory approach for unregulated universe (moratorium sources)). EPA has worked to meet these requirements, but has missed deadlines in the law and is substantially behind in dealing with the moratorium of unregulated discharges of storm water (the moratorium on coverage of this universe by the NPDES program expires in October 1992). Storm water permitting requirements (before dealing with the moratorium sources) will more than triple the universe of NPDES dischargers. All of the above create potential material weakness in the NPDES program (and other water programs) due to the magnitude of the universe to be regulated and the resource burden associated with such an increase in the universe. Functional Category in Statistical Summary; Program Management:—Program Execution. Appropriation/Program Element: Salaries and Expenses and Abatement and Control appropriations; Permit Issuance, Section 106 Grants, and Construction Grants Appropriation; Section 104(b)(3) Grants program elements. Administrative Activity/Program Activity: Year Identified; 1991 Source of Discovery; Informal assessment of progress in meeting 1987 CWA requirements for storm water; also, implementation issues raised at Headquarters, regional and state levels. Original Target Correction Date; Not applicable. This is a newly identified material weakness. Current Target Date: No date yet. Will be developed as part of corrective action plan. Reason for Change in Date(s); Critical Milestones in Corrective Action; Not applicable. A. Completed Actions/Events: B. Planned Actions/Events (FY 1992): 1/15/92 Complete corrective action plan. ------- U. S. ENVIRONMENTAL PROTECTION AGENCY ENCLOSURE D MATERIAL WEAKNESS/CORRECTIVE ACTIONS PAGE 71 OF 97 FISCAL YEAR 1991 C. Planned Act ions/Events (FY 1993 and beyond): To be developed as part of the corrective action plan. Validation Process to be Used: The validation process management will use to verify completion and effectiveness of the corrective actions will be developed as part of the corrective action plan. ------- U. S. ENVIRONMENTAL PROTECTION AGENCY ENCLOSURE D MATERIAL WEAKNESS/CORRECTIVE ACTIONS PAGE 72 OF 97 FISCAL YEAR 1991 Title of Material Weakness: Management of R&D Extramural Resources Description of Material Weakness and Its Impact on Agency Operations; Almost 70% of ORD's total research budget is used to fund extramural activities, i.e., contracts, grants, cooperative agreements and interagency agreements. With increases in R&D funding and limitations on FTEs, increasing demands and strains are being placed on our ability to adequately manage our extramural resources and related instruments such as contracts, research grants, cooperative agreements, and interagency agreements. The growing disparity between program size and human resources creates a material weakness in extramural management with a vulnerability for potential fraud, waste, and mismanagement of federal funds. Functional Categories in Statistical Summary: Procurement and Grants Management. Appropriation/Program Element: Environmental Protection Agency-Salaries and Expense, Research and Development, and Superfund Appropriations. Administrative Activity/Program Activity: Administrative Activity. Year Identified: FY 1990 Source of Discovery: ORD conducted a comprehensive assessment of its work force during the latter part of FY 1989. This analysis was conducted in response to a request from Congressman Scheuer, chairman of the House Sub-Committee on Natural Resources, Agriculture Research and Environment, to assess the skills and talents required to accomplish ORD's scientific mission. One of the five strategic areas of iirportance the work force study addressed was "Is that portion of the work force charged with "extramural" management adequate and appropriate to the mission?" The results of the work force analysis along with the expressed concerns from the Inspector General prompted ORD to conduct an assessment of extramural management. A questionnaire was developed to assess the adequacy of procedures and resources for each extramural management instrument. Each ORD assessable unit completed the set of questionnaires. According to the work force study and the subsequent lab questionnaire, ORD allocates approximately 300-400 FTEs to extramural activities which translates to. 16%-22% of ORD's work force managing nearly 70% of ORD's resources. The reports have indicated a definite weakness in several areas. The highest rated problems were identified as: o adequacy of extramural management training; o sufficient number of people to perform contract management; o conduct of inspections of contractor work at site; o adequacy of contract administration files; ------- U. S. ENVIRONMENTAL PROTECTION AGENCY ENCLOSURE D MATERIAL WEAKNESS/CORRECTIVE ACTIONS PAGE 73 OF 97 FISCAL YEAR 1991 o performance of yearly inventories of government furnished property; o monitoring expenditures to determine if they are reasonable in terms of the work performed; and o monitoring expenditures to ensure individual ceilings are not exceeded. These data are considered a base line for use by an ORD/Agency task force to achieve process improvements, establish adequate training, establish management controls and identification of resource shortages. This task force will use a TQ# approach and is expected to visit each ORD laboratory in FY 1992. Original Target Correction Date: June 1992 Targeted Correction Date in Last Year's Report: June 1992 Current Target Date: 1994 Critical Milestones in Corrective Action: 1. Conplete analysis of data gathered by questionnaires on extramural management instruments and issue report. Planned Completion Date: December 1990 Completed: December 1990 2. Ccnplete data collection and analysis of work force '90 data. Planned Conpletion Date: March 1991 Completed: 3. Develop event cycle documentation for each extramural management instrument to be included in each assessable unit's documentation for FY 1991. Planned Conpletion Date: March 1991 Completed: August 1991 4. Identify additional manpower required to adequately manage ORD's extramural resources. Planned Conpletion Date: May 1991 Conpleted: May 1991 5. Integrate identified requirements into the budget and planning process for FY 1993. Planned Conpletion Date: May 1991 Completed: June 1991 ------- U. S. ENVIRONMENTAL PROTECTION AGENCY ENCLOSURE D MATERIAL WEAKNESS/CORRECTIVE ACTIONS PAGE 74 OF 97 FISCAL YEAR 1991 6. Develop schedule of training for personnel with extramural management responsibilities. Planned Completion Date: September 1991 Revised Completion Date: June 1992 7. Develop policy and procedures for extramural management activities within ORD. Planned Completion Date: December 1991 8. Conduct on-site reviews, and analysis of the management of ORD's extramural resources. Planned Completion Date: June 1992 A. Completed Act ions/Events: Briefly describe actions taken since the last report to OMB. Corrective Action milestones 1 through 5 completed. ORD established a Senior Council on Management Controls that has focused on providing guidance on correcting extramural management issues. B. Planned Actions/Events (Short-Term - Next 12 Months): 1. Corrective Action Milestones 6 through 8 to be completed within the next 12 months. 2. Request Agency approval to establish a Senior level Acquisition Manager to provide oversight and guidance for extramural activities. 3. In January 1992, begin an on-site review of each Laboratory's extramural management processes and controls and develop corrective action plans where necessary. C. Planned Actions/Events (Longer Term): Maintain a Senior level of management oversight of extramural activities throughout ORD and provide a proactive approach in identifying and correcting problems. Validation Process to be Used: An on-site review of each laboratory's extramural management processes will be conducted to ensure appropriate controls and control techniques are in place and are effective. These reviews will be conducted jointly with the Contracts Management Divisions in RTF and Cincinnati. ORD has established a Senior level Council on Management Controls that will advise and oversee the extramural management review process. ------- U. S. ENVIRONMENTAL PROTECTION AGENCY ENCLOSURE D MATERIAL WEAKNESS/CORRECTIVE ACTIONS PAGE 75 OF 97 FISCAL YEAR 1991 Corrective Action Plan Status Updates: o September 30. 1991. Status Update: 1. ORD assigned a Senior level position to serve as an Acquisition Manager to oversee ORD's extramural program. 2. ORD Senior Managers were briefed on the findings of the studies that were conducted and documented during FY 1991. 3. ORD and the Contracts Management Divisions in RTP and Cincinnati have agreed to a joint review, using a TC# approach, of ORD's extramural management program. ------- U. S. ENVIRONMENTAL PROTECTION AGENCY ENCLOSURE D MATERIAL WEAKNESS/CORRECTIVE ACTIONS PAGE 76 OF 97 FISCAL YEAR 1991 Title of Material Weakness: ORD Laboratory Buildings and Facilities Description of Material Weakness and Its Impact on Agency Operations: The Office of Research and Development is responsible for providing high quality, timely, scientific and technical information in the service of Agency goals. This research program is conducted through twelve environmental laboratories across the country, employing some 2000 people with an annual budget of $380 million. A majority of these facilities are over 20 years old and are in a serious state of disrepair. Some labs have, been cited for OSHA violations, and for being out of compliance with other Federal/State regulations. In addition, Congressionally approved research initiatives are postponed or delayed beyond the time frame needed because necessary facilities modifications are not funded. Without adequate facilities to perform the Agency's research, the base on which the development of policy, guidance, standards, regulations, and the appropriate tools for implementing pollution abatement strategies is seriously weakened. Functional Category in Statistical Summary: Property and Inventory Management Appropriation/Program Element: Environmental Protection Agency -Salaries and Expenses, Research and Development, and Buildings and Facilities Appropriations. Administrative Activity/Program Activity: Program Activity Year Identified; FY 1989 Source of Discovery: An effort to coordinate and improve the quality of ORD's annual buildings and facilities budget submission resulted in an onslaught of project proposals that painted a dismal picture of the research and developments, particularly the remote laboratories. A more in-depth review was conducted to determine the magnitude of the problem. Management visits to various laboratories resulted in "horror stories" of deficiencies that were impairing ORD's research program and situations that were potentially harmful to laboratory staff. In addition, EPA Health and Safety Audits, and Environmental Compliance Audits identified areas needing immediate attention. Original Target Correction Date; December 1990 Targeted Correction Date in Last Year's Report: December 1990 Current Target Date: June 1993 Reason for Change in Date(s): The targeted date relies on the Agency's effort to develop a master plan for all EPA facilities. The effort began in FY 1991 and is scheduled for completion in FY 1993. The master plan will provide Agency- level base data to be used in establishing funding requirements for facility improvements to support the Agency's mission. Critical Milestones in Corrective Action: ------- U. S. ENVIRONMENTAL PROTECTION AGENCY ENCLOSURE D MATERIAL WEAKNESS/CORRECTIVE ACTIONS PAGE 77 OF 97 FISCAL YEAR 1991 1. Develop a Facilities Management Plan to collect data to adequately document ORD's research facility needs. Planned' Conpletion Date: July 1990 Completion Date: August 1991 2. Develop procedures to systematically link B&F budgeting with ORD and Agency long-term strategic planning. Planned Conpletion Date: October 1990 Revised Conpletion Date: September 19.93 3. Develop prioritization methodology to determine B&F priorities based on short-term and long-term strategic planning. Planned Conpletion Date: January 1990 Conpletion Date: January 1990 4. Develop Agency level budget initiatives to address critical B&F needs. Planned Ccnpletion Date: Annual Activity 5. Develop systematic methodology to acconplish required repair and improvement projects to ensure conpliance with OSHA and other Federal/State regulations. Planned Conpletion Date: December 1990 Ccnpletion Date: June 1991 6. Develop Policies and Procedures to direct ORD's B&F activities. » Planned Conpletion Date: October 1990 Revised Conpletion Date: June 1992 • A. Completed Actions/Events: Milestone # 1: 1. The Facilities Management Plan was fully implemented in FY 1991. 2. EPA's Environmental Health and Safety Office audited several of the ORD laboratories for Fire Protection and Life Safety. The audits identified and quantified health and safety deficiencies that EPA has committed to correcting using a time-phased approach. Milestone # 2: 1. In FY 1990, ORD requested that the Facilities Management and Services Division, QARM, provide a master plan for each ORD facility to link physical plant needs, strategic research needs and B&F budgeting to support ORD and Agency ------- U. S. ENVIRONMENTAL PROTECTION AGENCY ENCLOSURE D MATERIAL WEAKNESS/CORRECTIVE ACTIONS PAGE 78 OF 97 FISCAL YEAR 1991 long-term planning. OARM approved this request and expanded it into an Agency- wide initiative to develop a master plan that includes all Agency facilities. The effort began in FY 1991. Milestone # 3: 1. Developed an automated methodology that was used to rank the FY 1992 B&F budget submission. This methodology has been institutionalized in the ORD B&F process. Milestone # 4: 1. ORD annually submits initiatives for the outyear budget submissions to provide increased resources for repair and upkeep under $75K (our annual needs exceed $3.5 million), and initiatives for projects over $75K. In 1991, EPA provided ORD with $200K for minor repair and improvement projects and ORD was able to divert an additional $500K toward these needs. Milestone # 5: 1. Provide follow-up to Environmental Compliance Audits on each of the ORD laboratories to ensure a corrective action plan is prepared that addresses the appropriate issues and projects requiring B&F resources are included in the budget request. Milestone #6: 1. Prepared draft policy .and procedure. C. Planned Actions/Events: Milestone # 2: 1. Work with the Agency to complete the master plan and to ensure that ORD's physical plant needs and research needs are incorporated into the final document and that the B&F budget requests adequately represent the needs identified. 2. Provide the Agency with critical data necessary to gaining additional B&F resources for the B&F projects that cost less than $75K as well as for the projects that cost more than $75K. 3. Work with the Agency to determine the methodology to manage B&F projects that cost less than $75K. Milestone # 6: 1. Complete the policies .and procedures and submit them for internal review. ------- U. S. ENVIRONMENTAL PROTECTION AGENCY ENCLOSURE D MATERIAL WEAKNESS/CORRECTIVE ACTIONS PAGE 79 OF 97 FISCAL YEAR 1991 Budget Implications. If Any: The above corrective action plan provided for the development and implementation of a facilities management plan. This plan addresses the total requirements of the research and development laboratories, identifying needs of both the physical plant and the research program. In FY 1991, ORD did not have any authority to fund minor repair and improvement projects costing $75K and under. In FY 1992, ORD has been given the authority to fund these projects, but has not been given resources for these projects. Any funding in FY 1992 will come from the R&D expenses which is already critically under-funded. ORD has an average annual need of approximately $3.5M for project costing $75K and less. ORD was provided with $700K to fund these projects. The lack of funding for basic repair and maintenance and for laboratory modification for research activities is exacerbating previously identified health and safety problems and unduly delaying critical research projects. In addition, the Agency's B&F appropriation that covers the greater than $75K projects is not adequate to mitigate the effects of long-term neglect for the EPA-owned laboratories. ORD's annual Repair and Improvement request in the B&F submission averages approximately $12M which is primarily for the EPA-owned laboratories. Without additional funding the physical condition of the research and development laboratories will deteriorate even further, greatly impairing EPA's research program. Validation Process to be Used: The data that was generated from the database and from the B&F submissions led ORD to request that the Agency provide a master plan of each ORD facility. The master plan will provide Agency-level validation of ORD's needs and link these needs to the Agency's B&F request. Corrective Action Plan Status Updates: o September 30. 1991. Status Update: Milestone # 2: The Agency's initiative to develop an Agency-wide master plan will provide the B&F budgeting link with ORD and Agency long-term strategic planning. This effort began in FY 1991 and will continue through FY 1993. Milestone # 6: The draft policies and procedures is under internal ORPM review. The remaining milestones have been completed. ------- U. S. ENVIRONMENTAL PROTECTION AGENCY ENCLOSURE D MATERIAL WEAKNESS/CORRECTIVE ACTIONS PAGE 80 OF 97 FISCAL YEAR 1991 Title of Material Weakness: Agency-wide Audit Follow-up Description of Material Weakness and Its Impact on Agency Operations: EPA offices' compliance with, audit management practices are not adequate to ensure that management's corrective actions taken in response to audit findings and recommendations are implemented fully. Inaccurate data entered in the Agency's Management Audit Tracking System (MATS) by EPA offices results in the reporting of inaccurate information in the "Semiannual Management Report to Congress," as required by the IG Act Amendments of 1988. Without strong audit management practices, offices may not be implementing follow-up actions fully and effectively. Functional Category in Statistical Summary; Program Management/Program Execution Appropriation/Program Element: Environmental Protection Agency/All Appropriations Administrative Activity /Program Activity: Administrative Activity Year Identified: 1989 Source of Discovery; 1989 OIG Special Review on Audit Follow-up Original Target Correction Date: 9/90 Targeted Correction Date in Last Year's Report: 9/90 Current Target Date: 4th qtr FY 1992 • Reason for Change in Date(s): The Resource Management Division made significant progress in correcting many of the problems in audit follow-up. The central database was completed and a reporting process put in place which allowed EPA to meet the reporting requirements of the IG Act Amendments of 1988. However, our analysis and the 1990 Inspector General Special Review of EPA's Audit Follow-up indicated that significant additional work was required in EPA offices to correct the weakness. Critical Milestones in Corrective Action: A. Completed Act ions/Events: (actions taken since the last report to OMB) 1. Develop an audit follow-up on-site review protocol and establish audit follow-up as a standard item to be included in Management Assistance Reviews. Beginning date: 3rd qtr FY 1991 Completion date: May 1991 M ------- U. S. ENVIRONMENTAL PROTECTION AGENCY ENCLOSURE D MATERIAL WEAKNESS/CORRECTIVE ACTIONS PAGE 81 OF 97 FISCAL YEAR 1991 2. Modify the existing Management Audit Tracking System (MATS) to expand its capabilities and enhance its user friendliness. Beginning date: February 1991 Conpletion date: July 1991 B. Planned Actions/Events (Short-Term - Next 12 Months): 1. Survey MATS users on their issues and concerns with the system. Build these concerns into planning process for any future, ongoing MATS enhancement efforts. Beginning date: 1st qtr FY 1992 Conpletion date: 4th qtr FY 1992 2. Develop an Audit Quality Assurance program to establish forms, policies and procedures to ensure the highest quality of data entered into MATS. Beginning date: May 1991 Ccnpletion date: 4th qtr FY 1992 (revised) 3. Develop additional Audit follow-up guidance that will update the EPA orders and directives on audit management and provide for greater uniformity of audit follow-up procedures. Beginning date: 1st qtr FY 1991 Conpletion date: FY 1992 although activities will be ongoing 4. Conduct Quality Assurance reviews in several EPA locations to assess tri*e accuracy of data entered in MATS. Beginning date: May 1991 Conpletion date: FY 1992 although activities will be ongoing C. Planned Act ions/Events (Longer Term): The short-term, planned corrective actions for FY 1991 and FY 1992 are anticipated to remedy the weakness in FY 1992. Validation Process to be Used: The Quality Assurance reviews begun in FY 1991 will test transactions, evaluate controls, and result in a written report. These reports will validate the effectiveness of actions or identify additional actions needed. In addition, we anticipate that the OIG will perform a Special Review of Audit Follow-up again in 1992. ------- U. S. ENVIRONMENTAL PROTECTION AGENCY MATERIAL WEAKNESS/CORRECTIVE ACTIONS FISCAL YEAR 1991 ENCLOSURE D PAGE 82 OF 97 Corrective Action Plan Status Updates: September 30. 1991. Status Update; Milestone A-l Milestone A-2 Milestone B-l Completed in May 1991 MATS contractor delivered MATS 2.0 on July 15, 1991 with a number of refinements to broaden its usefulness and reduce the need for shadow systems. On-site reviews have identified users' concerns with MATS. 1992. These reviews will continue in FY Milestone B-2 Milestone B-3 Milestone B-4 Contractor has completed five site reviews in preparation for drafting the QA manual. Expected delivery of the manual is 2nd quarter 1992. MATS Bulletins are planned for release in the 2nd quarter 1992. These bulletins will provide technical updates on audit tracking and follow- up. QA reviews have been conducted in several locations. Reviews have been conducted in RTF and Regions II, V, VII, and IX. ------- U. S. ENVIRONMENTAL PROTECTION AGENCY ENCLOSURE D MATERIAL WEAKNESS/CORRECTIVE ACTIONS PAGE 83 OF 97 FISCAL YEAR 1991 Title of Material Weakness; R&D Laboratory Operating Expenses Description of Material Weakness and Its Impact on Agency Operations: A lack of sufficient resources for laboratory operating expenses has created a material weakness in our research programs. The lack of resources could significantly inpair the fulfillment of ORD's laboratory research mission if left uncorrected. The shortage of resources for laboratory operating expenses has adversely affected activities such as teleconinunications, mail services, janitorial services, computer operations, warehouse operations, training and the ability to purchase specialized laboratory supplies for ORD's research projects. The amount of shortfall to fund laboratory operating expenses increased over the past several years because a disproportionate share of those dollars were needed to fund PC&B. In many cases, the shortfall in S&E operating expenses was partially funded by diverting funds from other high priority programs. Authority for use of the Research and Development (R&D) appropriation for the financing of expenses was provided in the FY 1991 Appropriations Act. Congress also established a ceiling in the R&D account for operating expenses, however a comprehensive definition of operating expenses was not provided. This may have resulted in an inconsistent application of the use of the R&D appropriation for expenses across the ORD contunity. Functional Category in Statistical Summary: Program execution. Appropriation/Program Element; Environmental Protection Agency-Research and Development Appropriation, Program Elements CA2H1A for Field and Laboratory Expenses and CA3H1A «for Headquarters Expenses. Superfund Appropriation, Administrative Ceiling Administrative Activity/Proofam Activity: Program Activity. Year Identified: FY 1990, Revised FY 1991 Source of Discovery: The increasing costs for personnel compensation and benefits (PC&B) over the past several years has eroded the base of available funds to operate the Research and Development laboratories. This inadequate purchasing base has resulted in a reduction in the amount of specialized supplies that scientists are able to purchase. One laboratory reported that supply dollars are currently only 10% of those needed to conduct planned experiments. To identify and quantify the problem, ORD conducted a comprehensive review of laboratory infrastructure and resource needs. Preliminary results indicate a requirement for resources for laboratory operating expenses far in excess of currently available or anticipated funds. A recent management review of the Environmental Monitoring and Assessment Program identified a possible inconsistency in the use of the R&D appropriation to fund laboratory operating expenses. ------- U. S. ENVIRONMENTAL PROTECTION AGENCY ENCLOSURE D MATERIAL WEAKNESS/CORRECTIVE ACTIONS PAGE 84 OF 97 FISCAL YEAR 1991 Original Target Correction Date: December 1992. Current Target Date: December 1992: Internal ORD management improvement actions. December 1995: Completion of proposed 5-year phased plan for addressing operating expense funding shortfall. Will require support from outside ORD. Critical Milestones in Corrective Action: 1. Complete analysis of data gathered in the comprehensive review of laboratory operating expenses to include an analysis of direct and indirect cost, one-time costs, and a shortfall analysis by comparison of data with operating plans. Completed Date: November -1990 2. Issue final report on laboratory operating expenses. Completed Date: December 1990 3. Develop ORD strategies and priorities to address laboratory operation expense requirements. Completed Date: April 1991 Milestone Revised: (a) Develop ORD process for operating expense budgeting to provide for laboratory input and Office Director review and prioritization. Completed date: April 1991 (b) Develop ORD strategies and priorities to address laboratory operating expense requirement through planning and execution. Planned completion date: December 1991 # 4 Addition to Milestones: 4. Develop comprehensive definition of operating expenses and appropriate use of appropriations. Planned completion date: December 1991 5. Develop a mechanism to ensure full capture of direct/indirect research project costs. Planned Completion Date: To be determined after completion of "4." above ------- U. S. ENVIRONMENTAL PROTECTION AGENCY ENCLOSURE D MATERIAL WEAKNESS/CORRECTIVE ACTIONS PAGE 85 OF 97 FISCAL YEAR 1991 6. Integrate laboratory operating expense requirements into the ORD planning and budgeting process. Planned Completion Date: June 1991 Revised planned completion date: March 1992 7. Develop techniques for analyzing the application and achievement of plans against utilization Planned Completion Date: To be determined after completion of "5." above 8. Conduct a follow-up review of laboratory operating expense requirements. Planned Completion Date: December 1992 Critical Milestones in Corrective Action: A. Completed Actions/Events; A comprehensive analysis was conducted of identified laboratory requirements against available funding. The results of this analysis indicate a requirement far in excess of available funding. Identified needs were used to establish the FY 1992 operating plans, providing funding for critical needs. The data was also used in developing budget justifications and issue papers for the FY 1993 submission to the Agency and OMB. A process was established for the laboratories to have input into the ORD planning and budget process to identify and prioritize their needs, allow for review by ORD Office Directors and overall prioritization for input into the budget submission. ------- U. S. ENVIRONMENTAL PROTECTION AGENCY ENCLOSURE D MATERIAL WEAKNESS/CORRECTIVE ACTIONS PAGE 86 OF 97 FISCAL YEAR 1991 B. Planned Actions/Events (Short-Term - Next 12 Months): A workshop on laboratory budgeting is scheduled for October 1991 to develop strategies to enhance the process and to identify indirect vs direct costs for better accounting of needs based on the research program vs administrative overhead. This workshop will also help to refine a definition of operating expenses and appropriateness of funding mechanisms for laboratory operating expenses. The FY 1994 process will begin earlier this year to provide timeliness for input into the budget submission. Strategies and formats will be developed at the October workshop and will be refined in later working sessions. C. Planned Actions/Events (Longer Term): Corrective Action Milestone 6, a review of the process and its effectiveness is to be completed in December 1992. Validation Process to be Used: A follow-up analysis of ORD laboratory operating expenses will be conducted to assess progress on reducing the deficiency. Corrective Action Plan Status Updates; . o September 30. 1991. Status Update: Milestone # 1 - Completed November 1990 Milestone # 2 - Completed December 1990 Milestone # 3 - (a) Completed April 1991 (b) Workshop on Lab Budgeting scheduled for October 1991 to develop strategies for laboratory budgeting. Milestone # 4 New Milestone added based on identified need. Workgroup established to develop and obtain necessary concurrences on definition of operating expenses. Milestone # 5 - Revised date of March 1992. Changes in the FY 1993 budget process require an earlier submission of needs to have impact on actual budget submission. Milestone # 6 Follow-up review to be done by December 1992. ------- U. S. ENVIRONMENTAL PROTECTION AGENCY ENCLOSURE D MATERIAL WEAKNESS/CORRECTIVE ACTIONS PAGE 87 OF 97 FISCAL YEAR 1991 Title of Material Weakness: Lack of effectiveness and productivity in the Chemical Testing Program. Description of Material Weakness and Its Impact on Agency Operations: Perhaps the most fundamental aspect of the Agency's toxic substances regulatory effort is the need to obtain accurate and reliable data, particularly scientific data, on chemical substances so that the Agency can, with confidence, make appropriate regulatory decisions on their manufacture, distribution, use and disposal. To the degree that chemical test data do not exist and cannot readily be obtained, the Agency may be prevented from, or at lease impeded in, taking appropriate regulatory action. For many existing chemicals and most new chemicals, such data are often not available and must be generated through chemical testing activities on the part of industry. Where data must be produced, EPA must encourage or demand the production of such data. In some cases, industry will voluntarily perform the necessary testing, but in other cases EPA must take regulatory action to insure that testing takes place and that test data are generated and provided to the Agency. Section 4 of TSCA given EPA the authority to require such testing. Rulemaking in general, and test rules are no exception, is often a slow and resource-intensive process. While this may, in part, explain the performance to date of the OTS chemical testing program, the fact remains that OTS has promulgated only a few section 4 test rules. As a consequence, only a limited number of the many thousands of chemicals that could or should be tested have undergone the testing necessary to yield the test data on which further regulatory rulemaking decisions must be based. In response to the acknowledged shortcoming of the chemical testing program as it has operated in the past, OTS has instituted a series of corrective measures to improve the program. These actions emphasize the purpose of the program as not simply to promulgate test rules, but rather to encourage testing of all chemicals for which testing is needed by whatever means are at EPA's disposal. In particular, the program will: encourage voluntary testing on the part of industry; enlist greater numbers of chemical industry testing efforts, through the OECD; and implement multi-chemical rules that will more efficiently and more rapidly put the industry on notice as to the chemicals that the Agency has an interest in. Functional Category in Statistical Summary: Program Execution Appropriation/Program Element: Appropriations: 6810200 and 681/20108 Program Element: JNL2S Administrative Activity/Program Activity; Program Activity Year Identified: 1990 ------- U. S. ENVIRONMENTAL PROTECTION AGENCY ENCLOSURE D MATERIAL WEAKNESS/CORRECTIVE ACTIONS PAGE 88 OF 97 FISCAL YEAR 1991 Source of Discovery; The material weakness came to light through several different sources over a period of time. They include the GAO audit of the program, a planned AICR review, the August 15, 1990, meeting of the Agency's Senior Council on Management Controls; and general discussions internal to OTS and OPTS. These developments taken together led OTS management to identify the chemical testing program as a material weakness. In June 1991, GAO issued a second report, Toxic Substances: EPA's Chemical Testing Program Has Not Resolved Safety Concerns (RCED-91-136). This report recommended that EPA establish and implement criteria and a methodology for determining when chemicals present risks that would trigger implementation of TSCA regulatory provisions. GAO also recommended that the Agency implement an information system to track the status of chemicals being tested and identify ways to make TSCA test results more readily available to other regulatory agencies, researchers, and other interested parties. Original Target Correction Date: September 1992 Targeted Correction Date in T>gt Year's Report; September 1992 Current Target Date; September 1992 Critical Milestones in Corrective Action; A. Completed Act ions/Events: In March 1991, OTS developed and issued proposed generic test rules for obtaining neurotoxicity data, and developmental and reproductive toxicity data. Work is almost complete on 1) developing and issuing a proposed multi-chemical test rule for glycidols; 2) developing and issuing a proposed multi-chemical test rule for aryl phosphates; and 3) fully implementing the process for producing, reviewing, publishing and annually updating the Master Testing List. B. Planned Actions/Events (FY 1992): Develop and issue proposed multi-chemical test rule for aryl phosphates 10/91 Issue final generic test rule for obtaining neurotoxicity data 11/91 Issue final generic test rule for obtaining developmental and reproductive toxicity data.... 6/92 Issue final multi-chemical test rule for glyvifold 9/92 Material weakness judged to be corrected 9/92 ------- U. S. ENVIRONMENTAL PROTECTION AGENCY ENCLOSURE D MATERIAL WEAKNESS/CORRECTIVE ACTIONS PAGE 89 OF 97 FISCAL YEAR 1991 C. Planned Actions/Events (FY 1993 and beyond): Conduct AICR of revised Chemical Testing Program 12/92. Validation Process to be Used; OTS will conduct an AICR to evaluate the newly iirplemented process, procedures, rules and other features of revisions to the chemical testing program. The AICR will determine whether these changes and improvements are functioning in an optimal manner. OTS will judge the success of correcting the lack of efficiency and productivity in the program by evaluating whether appropriate processes are in place which we can reasonably expect will lead, in time, to the anticipated increase in the amount of chemical testing that is necessary to support an effective TSCA regulatory program. Corrective Action Plan Status Updates: o September 30. 1991. Status Update: We have a delay in issuing the multi- chemical test rule for glycidols because 1) OGC identified numerous issues during streamlined review that necessitated substantial redrafting of the package; and 2) OMB's review period covered 90-days rather than the 15-30 days as planned. We received substantial new information and technical and policy issues associated with the multi-chemical test rule for aryl phosphates and the OMB review period added two months to the original schedule thereby delaying the issuance. ------- U. S. ENVIRONMENTAL PROTECTION AGENCY ENCLOSURE D MATERIAL WEAKNESS/CORRECTIVE ACTIONS PAGE 90 OF 97 FISCAL YEAR 1991 Title of Material Weakness: R&D Scientific and Technical Equipment Description of Material Weakness and Its Impact on Agency Operations; A large portion of ORD's scientific/technical equipment is old, technologically antiquated, and needs to be replaced. The Agency is in danger of not being able to carry out its research responsibilities required by Federal statutes. EPA has no plan for equipment planning, conducting proper forecasting, or planning for sufficient budgetary support to reach an acceptable state of scientific equipment in the next five years. Functional Category in Statistical Summary; Property and Inventory Management. Appropriation/Program Element: Environmental Protection Agency - Research and Development and Superfund Appropriations Administrative Activity/Program Activity; Program Activity Year Identified: FY 1988 Source of Discovery: In FY 1986, ORD experienced an extreme shortage of Salaries and Expense funds; therefore, sufficient funds were not available in any one account to allow for the acquisition of major scientific equipment. However, by pooling a part of ORD's resources to create a capital equipment escrow, some items of equipment could be purchased. The Assistant Administrator for ORD established a Capital Equipment Committee to manage these resources. During this process, a complete inventory of ORD's scientific equipment was conducted. An analysis of this inventory identified the majority of ORD's scientific equipment to be antiquated and technologically obsolete. Original Target Correction Date: March 30, 1990 Targeted Correction Date in Last Year's Report: September 30, 1994 Current Target Date: September 30, 1994 Reason for Change in Datefs): The material weakness is a more complex issue than initially described in FY 1988. The broadened plan for the revised corrective actions will be implemented over a five-year period based on availability of resources. Critical Milestones in Corrective Action: A. Completed Actions/Events: The inventory of ORD's scientific equipment was updated in April 1990. Based on the current inventory a five-year plan was developed to replace equipment over 7 years old and to purchase state-of-the-art equipment for new research initiatives. A budget initiative for the FY 1993 budget submission was prepared requesting resources for the five-year plan to upgrade ORD's scientific equipment base. ------- U. S. ENVIRONMENTAL PROTECTION AGENCY ENCLOSURE D MATERIAL WEAKNESS/CORRECTIVE ACTIONS PAGE 91 OF 97 FISCAL YEAR 1991 B. Planned Act ions/Events (Short-Term - Next 12 Months): Planned actions for FY 1992 include recertifying that prior years' replacement needs are still un- met. The inventory "will be updated annually and we will continue to submit budget initiatives to request resources to meet the plan to upgrade ORD's scientific equipment. C. Planned Actions/Events (Longer Term): 1. ORD will update the inventory of scientific equipment annually to determine un-met needs. 2. Based on emerging research initiatives, we will forecast needs for new equipment. 3. A review will be conducted of the equipment replacement program and revisions made as necessary. 4. Budget initiatives will be prepared to seek prior years' un-met needs and current needs as identified in the five-year plan. 5. A new five-year plan to cover fiscal years 95 through 99 will be prepared. Budget Implications. If Any; The corrective action plan to upgrade ORD's scientific and technical equipment is dependent upon resources appropriated through the budget process. Validation Process to be Used: A complete analysis of ORD's equipment inventory and review of the corrective action plan will be" conducted each year over the life of the five-year plan. Revisions will be made as necessary and incorporated into the budget initiative prepared for the next years' submission. Corrective Action Plan Status Updates: o September 30. 1991 Status Update; 1. A budget initiative was submitted in ORD's FY 1993 budget submission requesting additional funds for the equipment upgrade. ------- U. S. ENVIRONMENTAL PROTECTION AGENCY ENCLOSURE D MATERIAL WEAKNESS/CORRECTIVE ACTIONS PAGE 92 OF 97 FISCAL YEAR 1991 Title of Material Weakness: Antimicrobial Program Description of Material Weakness and Its Iinpact on Agency Operations: A GAD audit identified a material weakness in the program's data integrity assurance process, system support, and enforcement follow-up. OPP has responded specifically in Congressional hearings to issues raised by GAO. Functional Category in Statistical Summary: Program Execution Appropriation/Program Element.: Registration Administrative Activity/Program Activity: Registration Year Identified: 1990 Source of Discovery: GAO Audit Original Target Correction Date: 1992 Targeted Correction Date in last Year's Report; 1992 Current Target Date; 1992 Critical Milestones in Corrective Action; A. Completed Actions/Events: In September 1990, EPA signed an Interagency Agreement with the Food and Drug Administration (FDA) to test samples of suspect products used on medical instruments and to test products prior to registration if the registration data appears questionable. FDA agreed to conduct efficacy testing for all products bearing sporicidal claims, except gaseous sterilants. FDA received samples for all products designated for testing. FDA has completed testing on three products. EPA has reviewed the data on these products and plans to extend the Interagency Agreement for an additional year to complete the planned testing. On January 21, 1991, OPP officially responded to GAO's recommendations. B. Planned Actions/Events (FY 1992): Finalize the strategy for Agency action if failing data is submitted 12/91 Develop a comprehensive inspection scheme to target laboratories testing high volume disinfectants 12/91 C. Planned Act ions/Events (FY 1993 and beyond); Fund proposals to conduct research and development work on the AOAC Sporicidal Test Method. Prepare ------- U. S. ENVIRONMENTAL PROTECTION AGENCY ENCLOSURE D MATERIAL WEAKNESS/CORRECTIVE ACTIONS PAGE 93 OF 97 FISCAL YEAR 1991 written guidance for data auditors. Develop an ongoing national disinfectant strategy. Validation Process to be Used: Science Advisory Panel Sub-Panel Review, among others still to be determined. Corrective Action Plan Status Updates: o September 30. 1991. Status Update: Test Method Research and Development - A cooperative agreement for statistical support was awarded to Dr. Martin Hamilton, Montana State University. The agreement for research on the AOAC sporicidal test is under review within the Grants Office. Product Testing and Agency Response to Failing Data - The Agency received failing data on sporicidal claims for two products. The Agency has developed a follow-up strategy where OCM will issue a stop sale and civil penalty for every batch found to fail the screening tests being conducted by FDA. OCM will proceed with enforcement testing, using the same standards and test procedures required for the original registration of the product. OCM will issue a stop sale and civil complaint against the two products concurrent with a public notice/press release information users of the failure and the enforcement action. Laboratory Testing Capability - OPP has established its laboratory needs for antimicrobial product testing and is exploring the availability of facilities to conduct the various tests used to determine antimicrobial product effectiveness. ------- U. S. ENVIRONMENTAL PROTECTION AGENCY ENCLOSURE D MATERIAL WEAKNESS/CORRECTIVE ACTIONS PAGE 94 OF 97 FISCAL YEAR 1991 Title of Material Weakness; Disposal Program Description of Material Weakness and Its Inpact on Agency Operations: OPP has a process in place to effectively implement the disposal program and manage the resources involved. However, the disposal program is subject to the influence of many factors outside of OPP's control. These outside factors have the potential to create a material weakness in the program. The full range of these factors and their potential for impacting the program need to be assessed. Functional Category in Statistical Summary: Program Execution Appropriation/Program Element; Disposal Administrative Activity/Program Activity; Program Activity Year Identified: 1990 Source of Discovery: Management Review Original Target Correction Date; 1992 Targeted Correction Date in Last Year's Report: 1992 Current Target Date: 1992 Critical Milestones in Corrective Action; A. Completed Actions/Events: Compiled list of sites requiring disposal action. Began reconciling this list with appropriate State lists. Pesticide Management and Disposal Regulations: Phase 1, procedural regulations for suspended and canceled pesticides received work group closure at the end of May 1991. B. Planned Actions/Events (FY 1992): Receive work group closure on Phase 2, container regulations, including container design, residue removal and bulk containment 11/91 Reactivate work group on Phase 3, pesticide management regulations; 12/91 Design a tracking system to determine compliance and completion of disposal activities: Dinoseb 12/91 Silvex 3/92 ------- U. S. ENVIRONMENTAL PROTECTION AGENCY ENCLOSURE D MATERIAL WEAKNESS/CORRECTIVE ACTIONS PAGE 95 OF 97 FISCAL YEAR 1991 i Finalize Report to Congress 6/92 C. Planned Actions/Events (FY 1993 and beyond): Closeout investigation to verify conpleted corrective actions. Validation Process to be Used: Closeout investigation. Corrective Action Plan Status Updates: o September 30, 1991. Status Update: Phase 1, procedural regulations are in red border review. OPP is participating in an Inter-agency conmittee on hazardous materials listings and is evaluating pesticides listed, and those that would be listed if the listing criteria were broadened. ------- U. S. ENVIRONMENTAL PROTECTION AGENCY ENCLOSURE D MATERIAL WEAKNESS/CORRECTIVE ACTIONS PAGE 96 OF 97 FISCAL YEAR 1991 PART THREE. DESCRIPTION OF CORRECTED MATERIAL WEAKNESS; CATS Tracking Number: 90-1 Title of Material Weakness: Inability to Associate Data on Compliance and Enforcement Activities From Various Offices' Data Bases. Description of Material Weakness and its Impact on Agency Operations; The Office of Enforcement was seriously hampered in its ability to develop enforcement actions, set enforcement priorities and target enforcement, respond to crises, and conduct program oversight because of the inability to associate data on compliance and enforcement activities from the various program offices data bases. Functional Category in Statistical Summary: Program Execution and Systems Development and Implementation Appropriation/Program Element: 6820200/AJAH3A Administrative Activity/Program Activity: Enforcement Year Identified: FY 1989 Source of Discovery; IG Audit and OE Senior Management Original Target Correction Date: 12/90 Targeted Correction Date in Last Year's Report: 12/90 Actual Completion Date: 2/21/91 Reason for change in Date: Delays occurred in the initial development of IDEA because of the inability to quickly resolve with the National Computer Center (NCC) how direct access to the data systems running in ADABAS would be provided. As a result, several of the milestone dates were achieved two months later than originally planned. Corrective Actions Taken: Validation of the effectiveness of the corrective action is tied to the use of the capability. All headquarters and regional offices have been trained on. the use of IDEA and currently several offices are incorporating analysis using IDEA in enforcement screening, enforcement targeting, and strategic planning. Procedures have been developed requiring that before individual can use IDEA and gain access to enforcement sensitive data, authorization must be granted at the DAA or DRA level. Additional procedures are being developed to provide access to nonsensitive data. ------- U. S. ENVIRONMENTAL PROTECTION AGENCY ENCLOSURE D MATERIAL WEAKNESS/CORRECTIVE ACTIONS PAGE 97 OF 97 FISCAL YEAR 1991 Critical Milestones Completion Date 1. Form workgroup to develop linking mechanism, resource requirements and schedule for implementation. 11/89 2. Define linking approach and system to be linked 11/89 3. Develop resource requirements and construct a strategy for implementation, including a project plan (review projected milestones and revise as appropriate) 3/2/90 4. Modify systems where necessary to accommodate link ID number. 9/30-90 5. Complete update of systems with link ID number for current records. 1/91 6. Develop automated ID number assignments procedures and programs. 2/21/91 7. Final implementation of linkage capability including ongoing operations and maintenance. 2/21/91 Results of Validation Actions: Validation of the effectiveness of the corrective action is tied to the use of the capability. All headquarters and regional offices have been trained on the use of IDEA and currently several offices are incorporating analysis using IDEA in enforcement screening, enforcement targeting, and strategic planning. Procedures have been developed requiring that before individuals can use IDEA and gain access to enforcement sensitive data, authorization must be granted at the DAA or DRA level. Additional procedures are being developed to provide access to nonsensitive data. ------- ------- U.S ENVIRONMENTAL PROTECTION AGENCY ENCOLSURE E REVIEW PROCESS PAGE 1 OF 15 FISCAL YEAR 1991 SECTION 4 ASSURANCE AND SUPPORTING DOCUMENTATION We reviewed our accounting system in use during FY 1991, in accordance with the Guidelines for Evaluating Financial Management/Accounting Systems issued by the Office of Management and Budget (OMB), and based on the principles and standards developed by the Comptroller General and implemented through OMB Circular A-127. We continued our evaluation of all system functions during this past year as part of an on-going Quality Assurance Program. The completed evaluations included tests of transactions and certifications from financial management offices as to the adequacy of their internal and accounting controls. There is no assurance, of course, that the system operates at all times in accordance with the test results. The results of the review described above, assurance given by Agency officials, and other information provided indicate that our accounting system, taken as a whole, generally conforms to the principles and standards developed by the Comptroller General and implemented through OMB Circular A-127. Exceptions to overall compliance with applicable principles and standards are the material nonconformances identified in this enclosure. During FY 1991, we continued monitoring, implementing and enhancing our accounting system, the Integrated Financial Management System (IFMS). Our implementation is a multi-year effort, which will result in a modern, efficient, economical and effective accounting system. As part of this system implementation, we have identified problems and developed appropriate action plans to resolve them. We have revised the implementation dates for different IFMS functions based on our experiences. We have developed procedures to ensure adequate testing is performed to meet users' needs prior to implementing the functions. At the end of FY 1991, there were five instances of accounting system material nonconformances that continue to exist. These nonconformances are accounts receivable; reconciliation to Treasury reports; property and accounting records reconciliation; general ledger adjustments;, and interfaces between IFMS and other administrative systems. Further details on these nonconformances, together with plans and schedules for corrective action are contained in this enclosure. ------- U.S ENVIRONMENTAL PROTECTION AGENCY ENCOLSURE E REVIEW PROCESS PAGE 2 OF 15 FISCAL YEAR 1991 ACCOUNTING SYSTEM COMPONENTS EPA has one primary accounting system which is the Integrated Financial Management System (IFMS). Three subsidiary systems provide substantial accounting information to IFMS. They are Payroll/Personnel System (EPAYS), Contract Payment System (CPS), and Automated Document Control Register (ADCR). In addition, four administrative systems contain accounting data. These systems are Contract Information System (CIS), Grants Information and Control System (GIGS), Personal Property Accountability System (PPAS), and Resources Management Information System (RMIS). ------- U.S ENVIRONMENTAL PROTECTION AGENCY ENCOLSURE E REVIEW PROCESS PAGE 3 OF 15 FISCAL YEAR 1991 Part 1. Summary of Pending Material Nonconformances Year Target for Current Title (s) of First Correction Target for nonconformances Reported in FY 1990 Correction Page Regional accounts receivable recording, documentation, and collection problems have impacted the accuracy of the general ledger accounts receivable balances. 1989 1993 1993 4 Comprehensive reconciliation between Treasury reports and IFMS needs to be performed. 1988 1993 1993 7 Reconciliation with property and accounting records for FY 1989 and 1990 needs to be performed. 1983 1992 1992 9 General ledger accounts adjustments as the result of the implementation of IFMS need to be accomplished. ' 1989 1993 1992 11 Opportunities exist for greater interface between the accounting system and other administrative systems. 1985 1992 1993 13 ------- U.S ENVIRONMENTAL PROTECTION AGENCY ENCOLSURE E REVIEW PROCESS PAGE 4 OF 15 FISCAL YEAR 1991 Part 2. Description of Non-conformances Name of System; Integrated Financial Management System Title of Material Nonconformance: Regional accounts receivable recording, documentation, and collection problems have impacted the accuracy of the general ledger accounts receivable balances. System Type: Core Financial Functional Category in Statistical Summary: General Ledger Control Appropriation: All appropriations Administrative Activity/Program Activity: Administrative Pace of Corrective Action: Year Identified: FY 1989 Original Targeted Correction Date: March 1990 Targeted Correction Date in Last Year's Report: June 1993 Current Target Date: June 1993 Reason for Change in Date(s): Does not apply Description of Material Nonconformance and Its Impact on Agency Operations: In FY 1990, we identified several potential unrecorded accounts receivable in the regional offices. These unrecorded receivables were the result of program officials not promptly notifying the servicing finance office of the creation and disposition of the receivables. Also, inadequate policies and procedures contributed to the problem. Because of this problem, the accuracy of the general ledger accounts receivable balances was questionable. To correct this deficiency, during FY 1991, we issued new policies and procedures for accounts receivable. Also, regional finance offices were required to perform a reconciliation of all open IFMS receivables. In addition, we created an Agency-wide Accounts Receivable Task Force (ARTF) that is visiting each region to identify and resolve problems with accounts receivable. The ARTF visited four regions in FY 1991. The remaining regions will be visited in FY 1992 and 1993. ------- U.S ENVIRONMENTAL PROTECTION AGENCY ENCOLSURE E REVIEW PROCESS PAGE 5 OF 15 FISCAL YEAR 1991 Source of Discovery of Material Nonconformance: FY 1989 transaction testing, Regional FMFIA Certification, Report of Assurance from Component System Manager for IFMS, and OIG Audit Report E1SJF9-05-0274-0100207 Review of Superfund Cost Recovery Accounts Receivable Establishment and Collection. Critical Milestones in Corrective Action: Completion Date Critical Milestones Original Plan Current Plan Actual A. Completed actions/events MILESTONE TITLE Automated calculation of interest, penalties and handling. 06/89 03/90 03/90 Demand and Billing Letters. 06/89 03/90 03/90 Issue policy and procedures to track enforcement actions that result in accounts receivable. 02/90 01/91 11/90 Implement IFMS on-line write-off of uncollectible accounts. 06/89 04/91 03/91 First round of on-site verification reviews. 10/90 06/91 07/91 B. Planned actions/events (short term - next 12 months) Enhance on-line write-off capability. 04/91 03/92 Second round of on-site verification reviews, 06/92 06/92 Provide additional capabilities in the calculation of interest, penalties and handling charges. 09/92 09/92 C. Planned actions/events (longer term) Third round of on-site verification reviews. 06/93 06/93 ------- U.S ENVIRONMENTAL PROTECTION AGENCY ENCOLSURE E REVIEW PROCESS PAGE 6 OF 15 FISCAL YEAR 1991 Validation Process to be Used: A task force has been created that will review accounts receivable at each finance office. The task force visited four regional finance offices in FY 1991. The Financial Compliance and Quality Assurance Staff will follow-up on issues raised by the task force during Quality Assurance Reviews of the regions. la FY *1991, the OIG conducted a follow-up review of corrective actions taken since their initial review of accounts receivable. The OIG concluded that current corrective actions by EPA appropriately address the issue of accounts receivable. ------- U.S ENVIRONMENTAL PROTECTION AGENCY ENCOLSURE E REVIEW PROCESS PAGE 7 OF 15 FISCAL YEAR 1991 Name of System: Integrated Financial Management System Title of Material Nonconformance: Comprehensive reconciliation between Treasury reports and IFMS needs to 'be performed. System Type: Core Financial Functional Category in Statistical Summary: Data accuracy, timeliness, comparability, usefulness Appropriation: All appropriations Administrative Activity/Program Activity: Administrative Pace of Corrective Action; Year Identified: FY 1988 Original Targeted Correction Date: December 1988 Targeted Correction Date in Last Year's Report: June 1993 Current Target Date: June 1993 Reason for Change in Date(s): Does not apply Description of Material Nonconformance and Its Impact on Agency Operations; During the initial implementation of IFMS, cash reconciliation reports were not available. Therefore, reconciliation between the Agency's general ledger and external Treasury reports could not be accomplished in a timely manner. In addition, revised procedures for assuring reconciliation of cash balances were inadequate to address the problem. During FY 1991, detailed reports needed to perform the cash reconciliation were produced. Monthly cash reconciliations between the Agency and Treasury are now being performed. Source of Discovery of Material Nonconformance; FY 1989 Report of Assurance from Component System Manager for IFMS. ------- U.S ENVIRONMENTAL PROTECTION AGENCY ENCOLSURE E REVIEW PROCESS PAGE 8 OF 15 FISCAL YEAR 1991 Critical Milestones in Corrective Action: Completion Date Critical Milestones Original Plan Current Plan Actual A. Completed actions/events MILESTONE TITLE Develop necessary reports to facilitate the Treasury reconciliation process. 09/89 06/91 06/91 B. Planned actions/events (short term - next 12 months) None C. Planned actions/events (longer term) Perform a comprehensive review of Treasury records and the Agency's general ledger on 9/30/92 to ensure reconciliation of balances. 09/89 06/93 Validation Process to be Used; With the availability of detailed cash reports, the Financial Reports and Analysis Branch (FRAB) has and will continue to review the monthly cash reconciliations made by the regional offices. The Financial Compliance and Quality Assurance Staff (FCQAS) will coordinate with FRAB to identify regional problems with the cash reconciliation'. If required, FCQAS will review this item as part of their visits to regional financial management offices. ------- U.S ENVIRONMENTAL PROTECTION AGENCY ENCOLSURE E REVIEW PROCESS PAGE 9 OF 15 FISCAL YEAR 1991 Name of System: Integrated Financial Management System/Personal Property Accountability System Title of Material Nonconformance: Reconciliation with property and accounting records for FY 1989 and 1990 needs to be performed. System Type: Core Financial Subsidiary System and Personal Property Accountability System Functional Category in Statistical Summary: Property Bureau/Appropriation: All appropriations Administrative Activity/Program Activity: Administrative Pace of Corrective Action: Year Identified: FY 1983 Original Targeted Correction Date: December 1989 Targeted Correction Date in Last Year's Report: May 1992 Current Target Date: May 1992 Reason for Change in Date(s); Does not apply Description of Material Nonconformance and Its Impact on Agency Operations: In the past, property values were recorded in the Agency's General Ledger accounts based upon the data contained in the Personal Property Accountability System (PPAS). Procedure's for assuring that all property acquisitions were reflected in the PPAS have been inadequate. For an interface between the Integrated Financial Management System (IFMS) and PPAS to operate properly, the Financial Management Division (FMD) must be assured of the accuracy of property values maintained in PPAS. In FY 1991, we initiated revised procedures for capitalization of property. These procedures require the regional finance offices to coordinate with the regional property offices to ensure that items capitalized are in PPAS and the financial data is reconciled. Further, we have provided items capitalized in FY 1989 and FY 1990 to the system manager for PPAS. The information will be reconciled with PPAS. ------- U.S ENVIRONMENTAL PROTECTION AGENCY REVIEW PROCESS FISCAL YEAR 1991 ENCOLSURE E PAGE 10 OF 15 Source of Discovery of Material Nonconformance: EPA OIG Audit P5EH7-11-0022-80028 dated October 7, 1987 and GAO Report AFMD 90- 20. Critical Milestones in Corrective Action: Completion Date Critical Milestones Original Plan Current Plan Actual A. Completed actions/events MILESTONE TITLE Define requirements to reconcile data between FMS and PPAS. 03/87 03/87 08/87 Develop a reconciliation process (interim procedure until new system is implemented). 07/88 07/88 07/88 Implement the reconciliation process (interim procedure until new system is implemented). 10/88 10/88 12/88 Implement distributed data entry PPAS network and a national PPAS. 04/88 04/89 06/89 Require comprehensive inventories be conducted in all accountable areas. 05/89 12/89 05/90 Implement modified reconciliation process that does not rely totally on PPAS. 06/91 06/91 07/91 B. Planned actions/events (short term - next 12 months) Perform reconciliation based on modified procedures using FY 1989 and 1990 data. 05/92 05/92 Validation Process to be Used; On a monthly basis, the Financial Reports and Analysis Branch (FRAB) is reviewing the regional capitalization reports submitted based on the revised reconciliation procedures issued. If problems are identified, FRAB will work with the Financial Compliance and Quality Assurance Staff to include this item as part of a Quality Assurance Review of a specific regional financial management office. In addition, we will request that regional finance offices conduct transaction testing of property for FY 1992. ------- U.S ENVIRONMENTAL PROTECTION AGENCY ENCOLSURE E REVIEW PROCESS PAGE 11 OF 15 FISCAL YEAR 1991 Name of System: Integrated Financial Management System Title of Material Nonconformance: General ledger account adjustments as the result of the implementation of IFMS need to be accomplished. System Type: Core Financial Functional Category in Statistical Summary: General Ledger Control Bureau/Appropriation: All appropriations Administrative Activity/Program Activity; Administrative Pace of Corrective Action; * Year Identified; FY 1989 Original Targeted Correction Date; February 1990 Targeted Correction Date in Last Year's Report; February 1992 Current Target Date: October 1992 Reasons for Change in Datefs); The completion date has been revised to reflect the extensive work to identify the detailed corrective actions required. Description of Material Nonconformance and Its Impact on Agency Operations: Although the system has been accurately recording transactions for FY 1990 and 1991, the validity of certain closing balances for FY 1989 is questionable. In FY 1989, we converted our accounting data from our former Financial Management System (FMS) to IFMS. During this conversion, some transactions were improperly classified, affecting the closing balances in certain accounts. We have identified the differences in the FY 1989 closing balances. Our next step is to validate and verify the composition of the differences. Once this task has been completed, we will make the necessary adjusting entries in IFMS. ------- U.S ENVIRONMENTAL PROTECTION AGENCY ENCOLSURE E REVIEW PROCESS PAGE 12 OF 15 FISCAL YEAR 1991 Source of Discovery of Material Nonconformance: FY 1989 transaction testing, Regional FMFIA Certification, and Report of Assurance from Component System Manager for IFMS. Critical Milestones in Corrective Action: Completion Date Critical Milestones Original Plan Current Plan Actual A. Completed actions/events MILESTONE TITLE Automatically perform month-end and year-end closing and roll over General Ledger account balances. 01/90 02/92 11/90 Install Enhanced General Ledger edits in IFMS. 03/91 06/91 06/91 B. Planned actions/events (short term - next 12 months) None C. Planned actions/events (longer term) Correct FY 1989 FMS to IFMS conversion errors. 02/92 10/92 Adjust beginning account balances. 02/92 1*0/92 Adjust and reclassify transactions, as appropriate. 02/92 10/92 Update policies and procedures for recording transactions in IFMS. 10/90 10/92 Validation Process to be Used: The supporting documentation of the adjustments will be maintained for review. FCQAS will conduct a review to ensure adequate documentation has been developed to support the accuracy of the adjustments. ------- U.S ENVIRONMENTAL PROTECTION AGENCY ENCOLSURE E REVIEW PROCESS PAGE 13 OF 15 FISCAL YEAR 1991 Name of System: Integrated Financial Management System Title of Material Nonconformance: Opportunities exist for greater interface between the accounting system and other administrative systems. System Type: Core Financial Functional Category in Statistical Summary: Interfaces with subsidiary/program systems Bureau/Appropriation: All appropriations. Administrative Activity/Program Activity: Administrative Pace of Corrective Action: Year Identified: FY 1985 Original Targeted Correction Date: June 1990 Targeted Correction Date in Last Year's Report: September 1993 Current Target Date: September 1993 Reason for Change in Date(s); Does not apply Description of Material Nonconformance and Its Impact on Agency Operations: Data maintained in the accounting system and used by other key administrative systems could be transferred between the respective systems more efficiently and effectively. OMB Financial Management System Objectives require electronic communications between systems to avoid duplication of data entry. During FY 1991 we continued to work toward developing the necessary electronic interfaces. Critical Milestone in Corrective Action; Completion Date Critical Milestones Original Plan Current Plan Actual A. Completed actions/events MILESTONE TITLE Install interface (IFMS/GICS). 09/88 06/89 06/89 ------- U.S ENVIRONMENTAL PROTECTION AGENCY REVIEW PROCESS FISCAL YEAR 1991 ENCOLSURE E PAGE 14 OF 15 Implement a national PPAS. 12/88 06/89 06/89 B. Planned actions/events (short term - next 12 months) Define requirements for IFMS and PPAS. 01/91 04/92 Detailed Design (IFMS/PPAS). 03/92 03/92 Analyze for further enhancements (IFMS/GICS). 03/92 03/92 C. Planned actions/events (longer term) Implementation (IFMS/PPAS). 10/92 10/92 Define requirements (IFMS/GICS). 01/93 01/93 Detailed design (IFMS/GICS). 06/93 06/93 Install new interface (IFMS/GICS). 09/93 09/93 Additional milestones will be added as new systems are developed, such as the Integrated Contract Management System which will replace the Contract Information System. Source of Discovery of Material Nonconformance: This issue was reconfirmed with the implementation of IFMS in FY 1989 and reported in the Report of Assurance from Component System Manager for IFMS. Prior to FY 1989, EPA had identified this nonconformance as it related to EPA's Financial Management System which IFMS replaced. Validation Process to be Used; The Financial Compliance and Quality Assurance Staff will review this item as part of their work on IFMS and FMFIA. In addition, we expect that GAO, OIG, and Superfund auditors to be actively involved with auditing various portions of IFMS along with other administrative systems. ------- U.S ENVIRONMENTAL PROTECTION AGENCY ENCOLSURE E REVIEW PROCESS PAGE 15 OF 15 FISCAL YEAR 1991 Part 3. Material Nonconformances Corrected Name of System; Integrated Financial Management System Title of Material Nonconformance:(s) Financial reporting under the Integrated Financial Management System (IFMS) is incomplete. System Type: Core Financial Functional Category in Statistical Summary; Data accuracy timeliness, comparability, and usefulness Appropriation; All appropriations Year Identified; FY 1989 OriginalTargeted Correction Date; September 1990 Corrective Actions Taken: For the short-term, we relied on ad hoc reporting capabilities of the former system and developed special reports. After reviewing the needs of the users, we decided to develop and implement an ad hoc reporting system called the Management and Accounting Report System (MARS). Results of Validation Actions Taken: The Financial Compliance and Quality Assurance Staff attended training in MARS to ensure that the system would provide information needed by users. In addition, we monitored general MARS D-Mail announcements concerning the issues raised by users'. As a last step in our validation, we reviewed the MARS Hotline Reports for the type of questions and issues being raised by users. We also contacted users who had reported errors. ------- |