HIA)
   e  /  UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
   f                     WASHINGTON, D.C. 20460


fV
                                                                OFFICE OF
                                                           THE INSPECTOR GENERAL
MEMORANDUM

SUBEJCT:  Audit Report No. P5CH6-1 1-0049- 701 18                                           J
          Report of Final Audit of Contract                                              I
          No. 68-01-6794                                                           _   \
          Total Chem Services, Inc.                                                      f
          Fol croft, Pennsylvania                                                         •
FROM:     Kenneth D. Hockman
          Divisional Inspector'General for Audit
          Internal Audit Division (A-109)

TO:       Pamela John, Chief
          Procurement Branch (Superfund)
          Procurement and Contracts Management
           Division (PM-214F)

                                                                                         b
SCOPE AND OBJECTIVES                                                                     |

A certified public accounting (CPA) firm examined the costs claimed by
Total Chem Services, Inc. (TSC) for work performed under Environmental                   ;
Protection Agency (EPA) Contract Number 68-01-6794 for the period                        '.
August 1, 1983 through June 18, 1984.  The alienability of costs claimed
under the contract was determined in accordance with the provisions of
the contract and applicable Federal regulations.                                         '
                                                                                         !
The audit was performed in accordance with generally accepted auditing                   f
standards and the Standards for Audit of Governmental Organizations.
Programs. Activities, and Functions (1981 revision) promulgated by the
U.S. Comptroller General and the Contracts for Emergency Response Cleanup
Services Audit Guide (February 1985} issued by the Environmental Protection
Agency.Accordingly, the examination Include such tests of the accounting
records and such other auditing procedures as was considered necessary in
the circumstances.                                                                       r
                              WASHINGTON, OX: 20460

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As part of the audit, transactions for contract activities were selectively
tested.  The audit objectives were:

     (!)  To determine whether costs claimed under the EPA contract are
          reasonable, allowable, and allocable to the sponsored project;

     (2)  To provide the EPA contracting officer with quantity, cost,
          rate, and other information sufficient to negotiate a final
          settlement.

SUMMARY OF FINDINGS

TCS claimed costs of $701,808 for services performed on EPA Contract
Number 68-01-6794, for the period August 1, 1983 through June 18, 1984.
The contract ceiling price, as modified, was $709,000.  Substantial
questioned and set-aside costs (see Exhibit A) were determined and are
summarized below.

                       Claimed     Accepted     Set-Aside   Questioned

Total Contract Costs   $701,808    $18,256      $670,238     $13,314
                       ===== = = =    ==s==== '     sassssss     =======

Contract costs were questioned for the following reasons:

     0 Labor and equipment usage charges were billed to EPA at rates in
       excess of those provided in the contract.

     0 A subcontracted service was invoiced to EPA twice.

     0 Several mathematical errors were made by TCS while preparing
       invoices.

In addition to the questioned costs, the audit disclosed substantial set-
aside costs for the following reasons:

     0 Labor, travel, equipment usage.and materials costs were not
       adequately supported by the accounting records of TCS.  He were
       not able to perform the necessary audit procedures to determine
       whether the costs incurred were allocable to the EPA contract.

     0 All subcontract agreements were verbal; both 1n approval by EPA
       to TCS, and in the actual agreement between TCS and the subcon-
       tractor.  Because the verbal agreements were never documented, we
       were unable to perform auditing procedures necessary to determine
       if costs were allowable or if subcontracts were in compliance with
       the Federal Procurement Regulations.

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The above costs were set-aside because of the uncertainties involved.

In addition, TCS applied a 15% handling charge to most material  and
subcontractor costs.  The handling charges were not supported by the
accounting records of TCS.  All handling charges were set-aside  or
questioned if associated with unauthorized activity due to lack  of
supporting documentation.

RECOMMENDATIONS

We recommend that the Chief, Procurement Branch (Superfund):

     1}  Not participate in the $13,314 of questioned costs;  and

     2)  Evaluate the appropriateness of participating in the $670,238
         of set-aside costs.

EXIT CONFERENCE

The management of TCS was not available to hold an exit conference to
discuss the findings because the company was no longer operating on a
daily basis.  As a result, TCS comments on audit results were not obtained,

ACTION REQUIRED

In accordance with EPA Directive 2750, the action official  1s required to
issue a final determination on the costs questioned and any other
recommendations in this report within 150 days of the audit report date.
Where the action official considers a position on the audit findings that
differs from our recommendations, we would appreciate the opportunity to
discuss management's position before the determination 1s issued to the
auditee.  A copy of the final determination should be provided to our
office when issued.

We have no objection to the further release of this report at your
discretion.  Should your staff have any questions, please have them
contact Elissa Karpf on 382-4930.

Attachments

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                     REPORT ON AUDIT
                            OF
                    COSTS CLAIMED BY
                TOTAL CHEM SERVICES, INC.
                 FOLCROFT, PENNSYLVANIA

                    IN PERFORMANCE OF
             EPA CONTRACT NUMBER 68-01-6794
   FOR THE PERIOD AUGUST 1, 1983 THROUGH JUNE 18, 1984
TICHENOR, RESLER, & EICHE
   CERTIFIED PUBLIC ACCOUNT ANTS
                                                  THE SUMMIT, SUITE 200
                                                  4350 BROWNSBORO ROAD
                                                  LOUISVILLE, KENTUCKY 40207
                                                  (502) 893-0700

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I     J
                           TOTAL CHEM SERVICES, INC.
                            FOLCROFT, PENNSYLVANIA

                         EPA CONTRACT NUMBER 68-01-6794
                FOR THE PERIOD AUGUST 1, 1983 THROUGH JUNE 18, 1984
                              TABLE OF CONTENTS
                                                               PAGE

          SCOPE AND OBJECTIVES
          SUMMARY OF FINDINGS
          RECOMMENDATIONS

          BACKGROUND

          EXIT CONFERENCE

          AUDITORS' REPORT ON EPA CONTRACT NUMBER 68-01-6794

          AUDITORS' REPORT ON INTERNAL ACCOUNTING CONTROL

          AUDITORS' REPORT ON COMPLIANCE
                                         1

                                         2

                                         2

                                         2

                                         2

                                         3

                                         4

                                         5
          EXHIBIT
            EXHIBIT A-
SUMMARY OF COSTS CLAIMED, ACCEPTED,
SET-ASIDE AND QUESTIONED FOR THE
PERIOD AUGUST 1, 1983 THROUGH JUNE 18,
1984                                     6

NOTES TO EXHIBIT A                        7
            SCHEDULE I-  SUPPORTING SCHEDULE OF QUESTIONED
                        AND SET-ASIDE COSTS BY INVOICE NUMBER
                        FOR THE PERIOD AUGUST 1, 1983 THROUGH
                        JUNE 18, 1984                             12

            SCHEDULE H- SUPPORTING SCHEDULE OF SUBCONTRACTOR
                        SET-ASIDE COSTS FOR THE PERIOD AUGUST
                        1, 1983 THROUGH JUNE  18, 1984               14

            SCHEDULE HI- SUPPORTING SCHEDULE OF QUESTIONED
                        COSTS RESULTING FROM MATHEMATICAL
                        ERRORS FOR THE PERIOD AUGUST 1,1983
                        THROUGH JUNE 18, 1984                    15

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                     TOTAL CHEM SERVICES, INC.
                      FOLCROFT, PENNSYLVANIA

                  EPA CONTRACT NUMBER 68-01-6794
        FOR THE PERIOD AUGUST 1, 1983 THROUGH JUNE 18,1984
SCOPE AND OBJECTIVES

We have examined the costs claimed by Total Chem Services, Inc. (TCS) for
work performed  on  the Environmental Protection Agency (EPA) Contract
Number 68-01-6794 for the period August 1, 1983 through June 18,1984.

The audit  was performed  in  accordance with  generally accepted auditing
standards  and  the  Standards  for  Audit  of  Governmental  Organizations.
Programs,  Activities, and Functions (1981 revision) promulgated  by the  U.S.
Comptroller General and the  Contracts  for  Emergency Response Cleanup
Services Audit jjuide (February 1985) issued  by the Environmental Protection
Agency. Accordingly, the examination included such tests of the accounting
records and such  other auditing procedures as we considered necessary in the
circumstances.  Audit fieldwork was performed  from  June 27, 1986 through
July 2,1986.

As  part of the audit,  transactions  for contract activities were  selectively
tested.  The audit objectives were:

     (1)  To determine whether costs  claimed under  the EPA contract are
         reasonable, allowable, and allocable to the sponsored project; and

     (2)  To provide the EPA contracting officer with quantity,  cost, rate,
         and other information sufficient to  negotiate  a final settlement.

SUMMARY OF FINDINGS

TCS claimed costs  of  $701,808  for  services performed on EPA Contract
Number 68-01-6794 for the period August 1,  1983 through June 18, 1984.  The
contract ceiling price, as modified, was $709,000. Substantial questioned and
set-aside costs (see Exhibit A) were determined and are summarized below.

                         Claimed   Accepted  Set-Aside    Questioned

Total Contract Costs      $701,808   $18,256     $670,238      $13,314


Contract costs were questioned for the following reasons:

     1)  Labor and equipment usage  charges  were billed to EPA  at rates in
        excess of  those provided in the contract (see Exhibit A, Notes 2 and 4).

     2)  A subcontracted service was invoiced to EPA twice (see Exhibit A,
        Note 6).

     3)  Several mathematical errors  were  made  by TCS  while  preparing
        invoices (see  Exhibit A, Note 7).

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 In addition to the questioned costs, our audit disclosed substantial set-aside
 costs for the following reasons.

     1) Labor,  travel,  equipment  usage  and  materials  costs were  not
        adequately supported by the accounting records of TCS. We were not
        able to perform  the necessary audit procedures to determine whether
        the costs incurred were allocable to the EPA contract (see Exhibit A,
        Notes 2, 3, 4 and 5).

     2) All subcontract agreements were verbal; both in approval by EPA to
        TCS,  and  in   the   actual  agreement   between  TCS  and  the
        subcontractor.   Because   the   verbal   agreements   were   never
        documented, we  were unable to perform auditing procedures necessary
        to determine  if costs were allowable or  if subcontracts were in
        compliance with the  Federal Procurement Regulations (see Exhibit A,
        Note 6).

 The  above costs  were set-aside because of the uncertainties involved.

 In addition, TCS applied  a  15% handling  charge to  most  material  and
 subcontractor costs.  The  handling charges  were  not supported by  the
 accounting records of TCS. All handling charges were set-aside or questioned
 if  associated  with  unauthorized  activity   due  to   lack  of  supporting
 documentation (see Exhibit A, Note 8).

 RECOMMENDATIONS

 1.   We recommend that  the Chief, Procurement Branch (Superfund):

     a)  Not participate in the $13,314 of questioned costs; and

     b)  Evaluate  the appropriateness  of participating  in  the  $670,238  of
        set-aside costs.
BACKGROUND

On August 1, 1983, EPA awarded TCS Contract Number 68-01-6794.  The
contract had nine modifications.  The performance period was 323 days, and
the cost ceiling was $709,000.

TCS  was required to  furnish the  necessary  services  connected with the
location and removal of hazardous waste from the specified location in Berks
County, Pennsylvania.  Contract efforts were completed within the period  of
performance.  Subsequent to contract completion, but prior to audit fieldwork,
TCS essentially ceased  operations.

EXIT CONFERENCE

The  management of TCS was not available to hold an exit conference  to
discuss the findings because the company was no longer operating on a daily
basis. As a result, TCS comments on audit results were not obtained.

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     TICHENOR,  RESLER. & EICHE
        CERTIFIED PUBLIC ACCOUNTANTS
                                                             THE SUMMIT. SUITE 200
                                                             4350 BROWNSBORO ROAD
                                                             LOUISVILLE. KENTUCKY 40207
                                                             (502) 893-0700
Mr. Kenneth D. Hockman
U.S. Environmental Protection Agency
Divisional Inspector General for Audit
Internal Audit Division
Office of the Inspector General
Washington, D.C.
      AUDITORS' REPORT ON EPA CONTRACT NUMBER 68-01-6794
We have examined  the Summary of Costs Claimed, Accepted, Set-Aside and
Questioned by Total Chem  Services, Inc.  Folcroft, Pennsylvania, under EPA
Contract Number 68-01-6794 for the period August 1, 1983 through June 18,
1984.  Except as set forth  in the following paragraph, our examination was
made in accordance with generally accepted auditing standards, the Standards
for Audit of Governmental Organizations, Programs, Activities, and Functions
(1981  revision),  promulgated  by  the U.S.  Comptroller General  and the
Contracts for Emergency Response Cleanup Services Audit Guide, (February
1985), issued by the U.S. Environmental  Protection Agency and accordingly
included such  tests  of the  accounting  records  and such   other  auditing
procedures as we considered necessary in the circumstances.

Total  Chem  Services, Inc., did not  retain adequate  evidential matter to
support contract costs in the amount of  $670,238.  The Company's available
records do not  permit the  application of  adequate  alternative procedures
regarding support of contract costs.  Contract costs in the amount of $670,238
were set-aside as a result of inadequate support. In addition, contract costs of
$13,314 were questioned because of errors in invoices and because costs were
not charged in accordance with the contract provisions.

Since  the Company did not provide us with adequate evidential matter to
support all costs, and we were unable to apply adequate alternative procedures
regarding contract cost support as noted in the preceding paragraph, the scope
of our work was not sufficient to enable us to express, and we  do not express,
an opinion on the financial statement referred to above.

This report is intended for use in  connection with the contract to  which it
refers and should not be used for any other purpose.
Tichenor, Resler & Eiche
Louisville, Kentucky
July 1, 1986

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.TG
TICHENOR, RESLER, & EICHE
   CERTIFIED PUBLIC ACCOUNTANTS                              THE SUMMIT. SUITE 200
                                                       4350 BROWNSBORO ROAD
                                                       LOUISVILLE. KENTUCKY 40207
                                                       (502) 893-0700
         Mr. Kenneth D. Hockman
         U.S. Environmental Protection Agency
         Divisional Inspector General for Audit
         Internal Audit Division
         Office of the Inspector General
         Washington, D.C.
                AUDITORS' REPORT ON INTERNAL ACCOUNTING CONTROL
         We have examined the Summary of Costs Claimed, Accepted, Set-Aside and
         Questioned by Total Chem Services, Inc. for the period August 1, 1983 through
         June 18, 1984, and have issued our report thereon dated July 2, 1986, in which
         an  opinion was disclaimed because of  significant  scope limitations.  Our
         examination  was  made in accordance with generally  accepted auditing
         standards, the Standards for Audit  of Governmental Organizations! Programs,
         Activities, and Functions (1981 revision), promulgated by the U.S. Comptroller
         General and  the Contracts for Emergency Response Cleanup Services Audit
         Guide, (February 1985) issued by the UJS. Environmental Protection Agency.

         Solely  to assist us in planning and performing our examination,  we made a
         study and evaluation of  the  internal accounting  controls  of Total  Chem
         Services, Inc. That study and evaluation was limited to a preliminary review
         of the system to obtain an understanding of the control environment and the
         flow of transactions  through the accounting system.  Because management of
         Total Chem Services, Inc. was not available to substantiate the accounting
         systems in adequate detail  to allow us to rely on the accounting controls, our
         study and evaluation of the internal accounting controls did not extend beyond
         this preliminary review  phase. Accordingly, we do not express an opinion on
         the system of internal accounting controls taken  as a whole.  Also, our
         examination, made in accordance with  the standards mentioned above, would
         not  necessarily disclose  material  weaknesses  in the  system   of  internal
         accounting control.  However, during our examination we did note  several
         conditions, as presented in the Notes  to  the Summary  of  Costs Claimed,
         Accepted, Set-Aside  and  Questioned,  that  we  believe  to be material
         weaknesses.

         This report is intended for use  in connection with the contract  to which it
         refers and should not be used for any other purpose.
         Tichenor, Resler & Eiche
         Louisville, Kentucky
         July 2, 1986

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.TG
TICHENOR, RESLER, & EICHE
   CERTIFIED PUBLIC ACCOUNTANTS                              THE SUMMIT. SUITE 200
                                                       4350 BROWNSBORO ROAD
                                                       LOUISVILLE, KENTUCKY 40207
                                                       (502) 893-0700
         Mr. Kenneth D. Hockman
         U.S. Environmental Protection Agency
         Divisional Inspector General for Audit
         Internal Audit Division
         Office of the Inspector General
         Washington, D.C.
                             AUDITORS' REPORT ON COMPLIANCE
         We have  examined  the Summary of Costs  Claimed, Accepted,  Set-Aside and
         Questioned by Total Chem Services, Ihc, for the period August 1, 1983 through June
         18, 1984, and have issued our report thereon dated July 2, 1986,  in which an opinion
         was disclaimed  because of  significant  scope limitations.  Our  examination of
         compliance  features,  which  was  limited to the provisions of the contract and
         applicable laws and regulations, was made in accordance with  generally accepted
         auditing  standards,  the Standards  for  Audit  of  Governmental  Ogranizations,
         Programs,  Activities,  and Functions "(1981  revision),  promulgated  by the  U.S.
         Comptroller General and the Contracts for Emergency Response Cleanup Services
         Audit Guide, (February  1985), issued by the U.S. Environmental  Protection Agency,
         and accordingly, our examination included such tests of the accounting records and
         such other auditing procedures as we considered necessary in the  circumstances.

         Total Chem Services, Inc. did not provide pertinent accounting records or adequate
         alternative documentation  to allow  for  testing  of  certain significant compliance
         features. The inability to test such compliance features restricted the scope of our
         work to the extent that we are unable to express, and we do not express, an opinion
         in accordance with the guidelines referred to above.

         This report is intended for use in connection with  the contract to which it refers and
         should not be used for any other purpose.
         Tichenor, Resler & Eiche
         Louisville, Kentucky
         July 2, 1986

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                                                         EXHIBIT A
  SUMMARY OF COSTS CLAIMED. ACCEPTED. SET-ASIDE AND QUESTIONED
        FOR THE PERIOD AUGUST 1, 1983 THROUGH JUNE 18, 1984
                    EPA CONTRACT NO. 68-01-6794
                     TOTAL CHEM SERVICES. INC.
                      FOLCROFT, PENNSYLVANIA
DESCRIPTION

Labor

Travel

Equipment Usage

Materials Expended

Subcontractors

Other
CLAIMED
 (Note 1)  ACCEPTED SET-ASIDE QUESTIONED NOTE
$102,015
15,950
45,523
44,974
489,478
3,868
$701,808
$ -0-
-0-
-0-
16,750
1,506
—0—
$18,256
$100,787
15,950
40,122
28,224
485,155
-0-
$670,238
$1,228
-0-
5,401
-0-
2,817
3,868
$13,314
2
3
4
5 and
6 and
7




8
8


The accompanying notes to this exhibit are an integral part of this summary.
                                 6

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                         NOTES TO EXHIBIT A

                    EPA CONTRACT NO. 68-01-6794
                     TOTAL CHEM SERVICES, INC.
                      FOLCROFT, PENNSYLVANIA
All of TCS travel costs were claimed on a per diem basis as follows:

    Quantity                 Rate                 Amount

    319 man/days             $50 per man/day      $15,950

The per diem rates of $50 were not paid  to  employees for reimbursement of
costs incurred.  TCS provided their employees with lodging and a  daily cash
allotment for subsistence. We  were unable to determine the amount of cash
given  to  employees  or that TCS expended amounts equal to $50 per  day on
employee travel related activities.  Even  though documentation  could  be
presented to support that employees were in travel status on the  respective
dates  of  claims, additional cost documentation must be presented  to support
that TCS incurred costs of $50 per diem.

Failure for TCS to maintain documentation of travel costs incurred, result in
$15,950 of set-aside costs. For details, refer to Schedule I.

NOTE 4 - EQUIPMENT USAGE

a. TCS  did  not maintain any  type  of property management  system  to
substantiate the type of equipment used or the amount of use. The absence of
equipment use documentation prevented the application of auditing procedures
to verify the amount  of use allocable  to  the  EPA contract.  Inadequate
documentation of equipment usage  indicates noncompliance with the contract
Article IV, Paragraph C.  However,  had proper supporting documentation been
present,  we  would  have accepted the  costs as they were  invoiced  in
accordance with the contract terms.

Failure to maintain equipment use records results in all equipment use claims
($40,122) being set-aside, except the $.20 per mile charge which is questioned
below.  For details, refer to Schedule I.
                                        8

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                         NOTES TO EXHIBIT A

                    EPA CONTRACT NO. 68-01-6794
                     TOTAL CHEM SERVICES. INC.
                      FOLCROFT. PENNSYLVANIA
NOTE 1 - BASIS OF ACCOUNTING

The Summary of Costs Claimed, Accepted, Set-Aside and  Questioned  is a
compilation of the invoices prepared by Total Chem Services, Inc. for services
rendered to EPA under the contract.

NOTE 2 - LABOR COSTS

a. TCS maintained no  time and labor  distribution records  (timesheets) for
employees to substantiate the hours allocable to the EPA contract. No payroll
system was available for examination with the exception of cancelled payroll
checks.  EPA Form 1900/55 (Hazardous Substance Response Fund Contractor
Cost Report)  could not be  relied upon to substantiate labor costs because the
hours reported  on the  1900/55's did not agree to the hours charged on  the
invoices.

The extent to which labor records were absent precluded the application of
auditing procedures to verify that labor costs allocated to the EPA contract
were  proper.  Failure  to  maintain time and  labor  distribution records to
support costs indicates noncompliance with the contract Article IV, Paragraph
B. Our review did,  however, determine that  labor  rates were invoiced at
contract terms. As a result, all labor costs claimed by  TCS that were  not
questioned costs are hereby set-aside in the amount of $100,787. For details
refer to Schedule I.

b. TCS claimed overtime on Sundays at 200%  of regular  time.  Exhibit D of
the contract  between  EPA  and  TCS prescribes  overtime rates for  all
employees at 150% of regular time. Overclaims resulting from overtime being
billed in excess of 150% of regular time is detailed below:

                                      Rate in Excess of      Amount of
Invoice       Position         Hours   150% of Regular Time   Overclaim

9559     Project Manager       8.5           $20               $  170
9559     Laborer             117.5           $9                 1,058

         Total Questioned Costs


NOTE 3 - TRAVEL COSTS

TCS presented  no supporting  documentation to substantiate any travel costs
claimed. We were unable to determine any of the following:

    1) Existence of costs.
    2) Necessity of costs.
    3) Evidence that per diem rates were paid to employees for the amount
       invoiced to EPA.

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                         NOTES TO EXHIBIT A

                    EPA CONTRACT NO. 68-01-6794
                     TOTAL CHEM SERVICES, INC.
                      FOLCROFT, PENNSYLVANIA
b. TCS claimed $.20 per mile for vehicle usage. The EPA contract with TCS
defines a fixed rate of $50 and $75 per day for automobiles and pick-up trucks
respectively. TCS claimed $.20 per mile in addition to the daily charge.  TCS
was  unable to substantiate that  costs in  excess  of  the  daily  rates were
incurred.  Vehicle mileage charges are detailed below:

Invoice             Miles         Rate             Overclaim

9559                 11,242       $.20
9561                 4,894         .20
9564                 3,535         .20
9576                 3,030         .20
9577                 2,785         .20
9581                   670         .20
9599                   250         .20
9623                   600         .20

Total               27,006


Vehicle use charges at rates in excess of those provided in the contract result
in questioned costs of $5,401.

NOTE 5 - MATERIALS EXPENDED

a. TCS did not consistently maintain invoices to support material purchases
related to the EPA contract. The invoices that TCS did retain were examined
and the related costs were determined to  be  reasonable and necessary  for
contract completion. As a result, all costs supported by an  invoice were
accepted. These are detailed as follows:

Invoice To
EPA                Item Description                Amount

9561                PVC Pipe Materials              $ 1,489
9564                Gravel                           5,618
9564                PVC Pipe Materials                  14
9577                Drinking Water Storage Tank       9,629

                    Total Accepted

b. The above represents the only invoices  for materials presented by TCS for
examination.  TCS  claimed an additional  $28,224 for  reimbursement  of
materials purchased.  Because there was no supporting documentation of these
costs, auditing procedures could not be applied to verify the amount or validity
of costs.   However, had proper supporting  documentation been present, we
would have accepted the costs as they were invoiced in accordance with the
contract terms. Failure to retain invoices  for  material purchases indicates
noncompliance  with the contract  Article IV,  Paragraph H and  resulted in
set-aside costs of $28,224, as detailed in Schedule I.

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                          NOTES TO EXHIBIT A

                    EPA CONTRACT NO. 68-01-6794
                      TOTAL CHEM SERVICES, INC.
                      FOLCROFT. PENNSYLVANIA
NOTE 6 - SUBCONTRACT COSTS

a. Utility charges for electric service and telephone installation and monthly
service  were accepted because the costs were specified in the contract, the
costs were  reasonable,  and  the  limited  applicability  of  procurement
regulations  to  utilities.   Charges for long  distance  service,  however, are
set-aside because there was no documentation that costs were  allocable to the
EPA contract. The resultant accepted and set-aside costs are as follows:
                                             Accepted      Set-Aside
Vendor                                         Costs          Costs

Conestoga Telephone                          $   601        $4,889
Metropolitan Edison                               905           267

Total Accepted and Set- Aside
  Utilities Costs                              $ 1.506        $5,156


b. TCS did not maintain records to support that the Federal Procurement
Regulations  were followed when obtaining subcontractor services  as required
by Article  IV,  Paragraph G of the contract.  We have scheduled set-aside
subcontract costs in the amount of $479,999, as detailed in Schedule n .

The costs identified above would have not been necessarily accepted  if there
had  been records  to support  compliance  with  the  Federal  Procurement
Regulations. Other uncertainties were involved in some of the subcontractor
costs such as lack of a supporting invoice or cancelled  check.  In addition, the
subcontractors were not required to maintain supporting accounting records of
invoices submitted to TCS, nor were we authorized to review  such records, if
available, of subcontractors.

c. Our review of subcontractor costs disclosed  that trailer rental provided by
a subcontractor had been billed to EPA twice. A receipt for $2,450 plus a 15%
handling charge of $367 (see Note 8) was billed on Invoice 9581 and again on
Invoice  9599.  Double billing  resulted in  total questioned costs related to
subcontracts of $2,817.

Total subcontract costs are summarized below:

                                Accepted  Set- Aside    Questioned

Utilities Costs                    $1,506    $   5,156
Other Subcontract Costs           ._-^"0"     479.999
Total Subcontract Costs           $1.506    $485.155       $ 2,817
                                   10

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                          NOTES TO EXHIBIT A

                    EPA CONTRACT NO. 68-01-6794
                     TOTAL CHEM SERVICES. INC.
                      FOLCROFT. PENNSYLVANIA
NOTE 7 - MATHEMATICAL ERRORS

Several mathematical errors were disclosed in our review of invoices.  The
overclaims and underclaims resulting from these errors were  categorized as
Other Costs  because errors were not always exclusively associated  with a
particular cost category.  The  mathematical errors in invoice preparation
resulted in questioned costs of $3,868, as detailed in Schedule HI.
NOTE 8 - HANDLING CHARGES

The  following handling  charges  were questioned or set-aside in association
with their respective cost categories in Notes 5  and 6. TCS applied handling
charges to most Subcontractor and Material  costs. The contractor did not
present adequate accounting records to support the handling charges.  All
handling charges associated  with accepted  and  set-aside  Materials  and
Subcontractor  costs   were  set-aside   due  to  a  lack  of  supporting
documentation. Set-aside handling charges are as follows:

                 Handling Charge Associated With
Invoice           Material         Subcontractor             Total

9559              $ 1,996            $23,123               $ 25,119
9561                 237             17,344                 17,581
9564                 963               6,956                  7,919
9576                 569               6,935                  7,504
9577               2,044               4,967                  7,011
9581                  34                967                  1,001
9599                  57               2,215                  2,272
9623                 -0-                797                    797

Total             $ 5,900            $63,304               $ 69,204
AH handling charges associated  with  Material and  Subcontractor questioned
costs were also questioned. This resulted in questioned subcontractor handling
charges of $367 on Invoice 9599 (See Note 6).
                                  11

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r
                                                               SCHEDULE I
                   SUPPORTING SCHEDULE OF QUESTIONED AND SET ASIDE COSTS
                                       BY INVOICE NUMBER
                      FOR THE PERIOD AUGUST 1, 1983 THROUGH JUNE 18. 1984
                                EPA CONTRACT NUMBER 68-01-6794
                                    TOTAL CHEM  SERVICES, INC.
                                    FOLCROFT. PENNSYLVANIA
                Description

                LABOR CHARGES
                       Questioned   Set-Aside
                      Invoice
                      Invoice
                      Invoice
                      Invoice
                      Invoice
                      Invoice
                      Invoice
                      Invoice

                      Total
#9559
19561
#9564
#9576
#9577
#9581
#9599
#9623
>  41,039
  15,907
  14,708
  12,576
  10,621
  2,000
  1,200
  2.736

100.787
               TRAVEL CHARGES
                      Invoice
                      Invoice
                      Invoice
                      Invoice
                      Invoice
                      Invoice
                      Invoice
                      Invoice

                      Total
#9559
#9561
#9564
#9576
#9577
#9581
#9599
#9623
                EQUIPMENT USAGE

                      Invoice #9559
                      Invoice #9561
                      Invoice #9564
                      Invoice #9576
                      Invoice #9577
                      Invoice #9581
                      Invoice #9599
                      Invoice #9623

                      Total
                          -0-
                         5,401
  7,400
  1,800
  2,500
  1,950
  1,650
    150
     50
    450

  15,950
 22,947
  7,035
  3,190
  3,255
  2,670
    375
    150
    500

 40,122
                                               12

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                                                       SCHEDULE I
                                                       (Continued)
    SUPPORTING SCHEDULE OF QUESTIONED AND SET ASIDE COSTS
                        BY INVOICE NUMBER
       FOR THE PERIOD AUGUST 1. 1983 THROUGH JUNE 18, 1984
                 EPA CONTRACT NUMBER 68-01-6794
                     TOTAL CHEM SERVICES.  INC.
                     FOLCROFT. PENNSYLVANIA
Description

MATERIALS EXPENDED
                       Questioned    Set-Aside
       Invoice
       Invoice
       Invoice
       Invoice
       Invoice
       Invoice
       Invoice
       Invoice

       Total
#9559
#9561
#9564
#9576
#9577
#9581
#9599
#9623
 -0-
 -0-
 -0-
 -0-
 -0-
 -0-
 -0-
 -0-
^^-^^^—

 -0-
15,276
   329
 1,752
 4,369
 5,802
  261
  435
  -0-

28.224
SUBCONTRACTORS
       Invoice
       Invoice
       Invoice
       Invoice
       Invoice
       Invoice
       Invoice
       Invoice

       Total
#9559
#9561
#9564
#9576
#9577
#9581
#9599
#9623
            176,901
            132,451
            53,326
            53,042
            46,814
             7,413
             9,096
             6.112

            485.155
OTHER
       Invoice
       Invoice
       Invoice
       Invoice
       Invoice
       Invoice
       Invoice
       Invoice

       Total
#9559
#9561
#9564
#9576
#9577
#9581
#9599
#9623
Total Questioned and Set-Aside
  Costs
 -0-
3,234
 -0-
  48
 -0-
 -0-
   86
  500

3.868
                        $13.314
  -0-
  -0-
  -0-
  -0-
  -0-
  -0-
  -0-
  -0-
                                       -0-
           $670.238
                                 13

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                                                          SCHEDULE

              SUPPORTING SCHEDULE OF SUBCONTRACTOR
                            SET-ASIDE COSTS
                    FOR THE PERIOD AUGUST 1, 1983
                        THROUGH JUNE 18. 1984
                   EPA CONTRACT NUMBER 68-01-6794
                      TOTAL CHEM SERVICES INC.
                      FOLCROFT, PENNSYLVANIA
                                              Total Contract
Subcontractor                                     Costs

Charley Frank                                     $137,546
SJ Transportation                                     2,286
Allied Electric                                      18,113
Mobile Field Office                                   1,658
Woodward Clyde                                    158,234
Mid Atlantic Inland                                      66
A and A Rentals                                        763
Authorized Business Machines                            488
Rental World                                           319
Aeronautics                                            135
Waste Conversion                                     8,200
Foxboro Instruments                                  2,731
Mike Attrichter                                        614
Aid Instruments                                        247
Dealers Service                                        512
Dolore Associates                                    17,860
Western Sandfill                                     20,547
Hanes and Kibblehouse                               69,426
Pottstown Power                                       128
Light man Drum                                        955
Powers and Simon Inc.                                15,077
Urwiler and Walder                                   3,865
Geosight                                            2,558
Explo-Craft, Inc.                                     7,531
Viking Welding                                          81
Harry Nusbaum                                      5,250
Garber Drilling                                      2,945
Barney's Electric                                     1,645
Delaware Container                                	219

Set-Aside Subcontractor Costs                      $479,999
                                  14

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                                                              SCHEDULE HI
                 SUPPORTING SCHEDULE OF QUESTIONED COSTS
                   RESULTING FROM MATHEMATICAL ERRORS
                       EPA CONTRACT NUMBER 68-01-6794
                          TOTAL CHEM SERVICES INC.
                          FOLCROFT, PENNSYLVANIA
Invoice
Number   	Description	             Amount of Error


 9561    Labor and per diem of $184.50 and $50.00, respectively,                 $  234.50
         were invoiced twice. The overstated daily amount for
         September 13,1983 was carried forward to the 9561 invoice.

 9561    The daily total for September 29, 1983 is $3,000.00 greater               3,000.00
         than sum of the various components of cost.  The total was
         6,531.58, however, the sum of the individual costs was $3,531.58.

 9576    Subcontractor costs were incorrectly added on the                          92.00
         November 7,1983 daily detail and carried forward to the
         invoice. This caused a overstatement of $92.00.

 9576    An addition error in the personnel costs made up of labor                    (44.00)
         and per diem resulted in the understatement of costs of $44.00.

 9599    Subcontractor use of a truck at $75.00 plus 15% handling                    86.25
         charge was not itemized but was included in the total daily
         detail on February 15, 1984.

 9599    A  $.20 subcontractor cost footing error occurred on the                      (.20)
         February 15,1984 daily detail.

 9623    A  $1.00 footing error was found on the June 6,1984 daily                    (1.00)
         detail.

 9623    Overstatement of the June 7, 1984 daily detail of $500.25                  500.25
         due to the inclusion of the same subcontractor cost twice.
         Costs were $435.00 plus 15% handling charge.


          TOTAL  MATHEMATICAL ERRORS                                 $ 3,867.80
                                       15

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