.•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

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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.

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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

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     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

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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.

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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.

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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.

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                                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

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              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

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              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)

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              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.

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              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

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              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.

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              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

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              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.

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              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.

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              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.

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              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.

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              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.

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              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

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              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.

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              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.

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              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.

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              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.

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              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.

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              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

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              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.

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              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.

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              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

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              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.

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              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

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              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.

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              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

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              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.

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              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.

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              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.

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               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

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           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

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           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.

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           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

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           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.

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           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

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            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

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       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

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           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.

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           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

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           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

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           U. S. ENVIRONMENTAL PROTECTION AGENCY      ENCLOSURE  D
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                      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.

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       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

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       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

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       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

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       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

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       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

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       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,

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       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.

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       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

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       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

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           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.

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       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.

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           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.)

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       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.

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           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

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           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.

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           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

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           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.

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            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.

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            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.

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            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 .

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       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.

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       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.

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       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.

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        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

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        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.

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        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

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        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.

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         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

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        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.

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        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.

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        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

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        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.

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        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

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        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.

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         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

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        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

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        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

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             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

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        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.

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        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.

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        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.

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                      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

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        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.

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        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.

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        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.

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        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

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        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.

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        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.

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        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.

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        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.

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        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

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                      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.

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        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

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                     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.

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        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.

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        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.

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        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;

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        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

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        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.

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        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.

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        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:

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        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

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        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.

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        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.

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        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

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        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.

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        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.

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        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.

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        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

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        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.

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        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.

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         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

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        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

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        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.

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        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.

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        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.

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        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

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        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.

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        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

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        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.

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        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.

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        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.

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               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.

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               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).

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               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

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               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.

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               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

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               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.

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               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.

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               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.

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               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.

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               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.

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               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.

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               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.

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               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

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               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.

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               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.

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