UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

                      WASHINGTON, O.C. 204(0
                         DEC 12)968
                                                       OFFICE OF
                                                   THE INSPECTOR GENERAL
  MEMORANDUM
  SUBJECT:  Audit Report No. M5BFL9-11-0020-9100096
            Audit of EPA' s Interagency Agreements with the
            Department of Justice for Superfund Activities
            Fiscal 1987
  FROM:
  TO:
Kenneth D. Hockznan
Divisional Inspector General for Audit
Internal Audit Division (A-109)

Harvey G. Pippen, Director
Grants Administration Division (PM-216)
       We requested the Audit Staff, Justice Management Division,
  Department of Justice (DOJ) to perform a financial and compliance
  audit of two Superfund Interagency Agreements (IAA) entered into
  between EPA and the DOJ, Land and Natural Resources Division
  (LNRD).  The DOJ report of September 1988 is attached.  The
  report addresses obligations and expenditures during fiscal 1987.
  The audit disclosed a need for improvements in the preparation
  of expense reports, internal controls, and the methodology used
  to compute employee costs.  Specific problem areas are addressed
  below.

       Superfund cost information was not reported to EPA in a
  manner consistent with the budgetary classifications provided
  in the lAAs, or the object classes used by the DOJ to account
  for LNRD costs.  Furthermore, amounts reported on expense
  reports could not be readily traced to accounting records.  As
  a result, the financial reports did not provide sufficient cost
  data to assure that the costs incurred were within cost category
  limitations of the lAAs.

       The LNRD system of internal accounting controls needs
  strengthening to improve the quality and accuracy of financial
  representations in reports and records.  As a result of weak-
  nesses in LNRD's system of internal accounting controls,
  management was not provided with reasonable assurance that
  transactions were executed in accordance with management's
  authorization and were recorded properly.
in
                         WASHINGTON. O.C. 20460

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     Hourly employee rates used to allocate employee costs
between the various direct and indirect cost centers were not
in compliance with the terms and conditions of the lAAs.  As a
result, direct employee costs distributed to individual cost
centers may not have represented actual LNRD costs.

     DOJ, LNRD has taken corrective action by informing managers
and staff that controls must be strengthened to ensure: (1) expense
reports reconcile with accounting cost data and the format for
expense reporting is improved; (2) plans are developed to improve
internal controls on its timekeeping system and cost records manage*
ment procedures; and (3) hourly employee rate corrective measures
are instituted to ensure compliance with the requirements of the
lAAs.  EPA can take action by following up on the DOJ, LNRD's
corrective actions and obtaining corrected expense reports and
cost data for the two lAAs from the LNRD.  Accordingly, we are
making the following recommendations.

RECOMMENDATIONS

     We recommend that the Director, Grants Administration
Division:

     1.  Request a status report on the corrective measures
         instituted by the DOJ, LNRD, to ensure that costs
         reported to EPA are (1) readily reconcilable with
         amounts recorded in LNRD's accounting records, (2) and
         in a manner consistent with the budgetary limitations
         of the lAAs.

     2.  Obtain assurance from DOJ, LNRD, that hourly employee
         rates used to allocate employee costs between the
         various direct and indirect cost centers are in com-
         pliance with the terms and conditions of the lAAs.

     3.  Obtain for accounting control and accuracy purposes,
         corrected expense reports and cost data for the two
         audited lAAs.

ACTION REQUIRED

     In accordance with EPA Directive 2750, the action official
is required to provide this office with a copy of the proposed
determination on the findings within 150 days of the audit
report date.  The Director, Grants Administration Division is
the action official for this report.

     Should your staff have any questions concerning this report,
please have them contact John Walsh on 475-6753.

Attachment

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                                                  APPENDIX
                      DISTRIBUTION OF REPORT


Assistant Administrator for Solid Waste
  and Emergency Response (WH-562)

Comptroller (PM-225)

Chief, Financial and Administrative Management
  Section, Office of Emergency and Remedial
  Response  (WH-548D)

Director, Financial Management Division {PM-226)

Chief, Grants Information and Analysis Branch (PM-216F)

Agency Followup Official (PM-208)

Agency Followup Official {PM-225)
  Attn:  Resource  Management Division

Agency Followup Coordinator (PM-208)
  Attn:  Program Operations Support Staff

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U.S. DEPARTMENT OF 1USTICE
Audit
Report
              AUDIT REPORT Oil THE
        ENVIRONMENTAL PROTECTION AGENCY'S
           EJTERAGENCY AGREEMENTS WITH
          THE DEPARTMENT OF JUSTICE FOR
             suPERFUiro AcrrvmES
              FISCAL YEAR 193?

   «*«*»*«***»tt*«»**«t*ft***««*«****«»*«**ft*******
               SEPTEMBER 1988
                                     88-23
                             Prepared by
                             Audit Staff
                             Justice Management
                             Division

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                         AUDIT REPORT ON
              THE ENVIRONMENTAL PROTECTION AGENCY'S
                   INTERAGENCY AGREEMENTS WITH
                  THE DEPARTMENT OF JUSTICE FOR
                       SUPERPUND ACTIVITIES
                         FISCAL YEAR 1987
                         EXECUTIVE DIGEST

The Audit Staff, Justice Management Division (JMD), performed a
financial and compliance audit of the Environmental Protection
Agency's (EPA) Interagency Agreements (IAA) with the Department
of Justice (DOJ) Land and Natural Resources Division (LNRD) under
the Comprehensive Environmental Response, Compensation and
Liability Act of 1980 (CERCLA or Superfund), and the Superfund
Amendments and Reauthorization Act of 1986 (SARA).  The purposes
of our audit were to determine:   (1) the accuracy and reliability
of Superfund cost reports submitted by the LNRD to the EPA,
(2) the adequacy of internal controls in LNRD's system of
accounting for Superfund costs, and (3) LNRD compliance with the
terms and conditions of the lAAs and applicable Federal
regulations.

The audit covered the period October 1, 1986 through
September 30, 1987 and two lAAs, as amended, as follows:
          Jjumber
     DW 15932400-01-0
     DW 15932401-01-0
     DW 15932401-01-1*
Period of Agreement
10/01/86 - 09/30/87
10/01/86 - 09/30/87
10/01/86 - 09/30/87
              Total
  Amount
$ 1,000,000
  4,481,300
  6.068.700
S11.55Q.OQQ
     *Amends agreement no. DW 15932401-01-0
The audit disclosed a need for improvements in the preparation of
expense reports, internal controls, and the methodology used to
compute employee costs.  The weaknesses associated with the audit
recommended improvements are summarized as follows:

Expense Reports - Pace 4

Superfund cost information was not reported to EPA in a manner
consistent with the budgetary classifications provided in the
lAAs, or the object classes used by the DOJ to account for LNRD
costs.  Furthermore, the expense reports did not apply cost
information from the Expenditure and Allotment Reports uniformly.
As a result, the financial reports did not provide sufficient
cost data to assure that the costs incurred were within cost
category limitations of the lAAs.


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Internal Controls - Page 9

The LNRD system of internal accounting controls needs
strengthening to improve the quality and accuracy of financial
representations in reports and records.  As a result of
weaknesses in LNRD's system of internal accounting controls,
management was not provided with reasonable assurance that
transactions were executed in accordance with management's
authorization and were recorded properly.

Computation of Employee Costs - Page 12

Hourly employee rates used to allocate employee costs between the
various direct and indirect cost centers were not in compliance
with the terms and conditions of the lAAs.  As a result, direct
employee costs distributed to individual cost centers may not
have represented actual LNRD costs.
                              -  ii  -

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                        TABLE OF CONTENTS
INTRODUCTION	



     Audit Objectives	,



     Audit Scope	,



     Summary of Audit Results 	 ,



     Background 	 ,



FINDINGS AND RECOMMENDATIONS	,



I.    EXPENSE REPORTS 	 ,



          Recommendations 	 ,



II.   INTERNAL CONTROLS 	 ,



          Recommendations 	 ,



III.  COMPUTATION OF EMPLOYEE COSTS 	 ,



          Recommendation	



STATEMENT ON INTERNAL ACCOUNTING CONTROLS 	



STATEMENT ON COMPLIANCE WITH LAWS AND REGULATIONS . .



OTHER REPORTABLE MATTERS	,



APPENDIX I - LNRD RESPONSE	



APPENDIX II - SUMMARY OF RECOMMENDATIONS AND ACTIONS,
Pagg



  1




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  4




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 12



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                         AUDIT REPORT ON
              THE ENVIRONMENTAL PROTECTION AGENCY'S
                   INTERAGENCY AGREEMENTS WITH
                  THE DEPARTMENT OF JUSTICE FOR
                      SUPERFUND ACTIVITIES
                         FISCAL YEAR 1987
                           INTRODUCTION


The Audit Staff, Justice Management Division (JMD), has completed
a financial and compliance audit of the Environmental Protection
Agency's (EPA) Interagency Agreements (IAA) with the Department
of Justice (DOJ), Land and Natural Resources Division (LNRD)
under the Comprehensive Environmental Response, Compensation and
Liability Act of 1980 (CERCLA or Superfund), and the Superfund
Amendments and Reauthorization Act of 1986 (SARA).

Audit Objectives

The purposes of the audit were to determine:   (1) the accuracy
and reliability of Superfund cost reports submitted by the LNRD
to the EPA, (2) the adequacy of internal controls in LNRD's
system of accounting for Superfund costs, and  (3) LNRD compliance
with the terms and conditions of the lAAs and applicable Federal
regulations.

Audit Scope

Beginning with fiscal year 1987, the LNRD instituted a system
of accounting for all LNRD costs by cost center.  In this regard,
the LNRD contracted with the Certified Public Accounting firm
of Rubino & McGeehin, Chartered, (CPA firm) to develop expense
reports which summarized direct and indirect LNRD costs for
each Superfund case litigated by the LNRD.  For the purposes of
the lAAs, LNRD identified costs as belonging to one of three
major groups:  (1) direct Superfund costs, (2) direct costs other
than Superfund, and (3)  indirect costs.   Direct costs were
further broken down between direct labor costs and all other
direct costs. Indirect costs were calculated as a percentage of
total direct labor costs.  In accordance with LNRD's decisions,
the CPA firm used the proportion of direct Superfund labor to
total direct labor to allocate indirect costs to each.  EPA
approved the costing methodology used by the LNRD in IAA
No. DW 15932400-01-0.

As part of our examination, we evaluated attorney time reports
entered into the Attorney Time System (ATS), the resultant
reports from the ATS, the LNRD employee salary rates as calcu-
lated by the CPA firm, the identification and recording of direct
costs, and the indirect costing methodology.  We selected direct

                              - 1 -

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costs on a random basis to determine:  (1) the accuracy and
relationship of accounting entries vis-a-vis source documenta-
tion, (2) the allocability of direct Superfund charges, and
(3) the allowability of costs based on Federal regulations.  We
reviewed all quarterly expense reports submitted to EPA for
fiscal year 1987.  This provided the basis for the audit opinion
statements and recommendations covered by this report.

Our examination was conducted in accordance with generally
accepted government auditing standards and included such tests of
the accounting and management records as were considered neces-
sary in the circumstances.  The audit covered the financial
activities for the period October 1, 1986 through September 30,
1987 for the following lAAs:
         Number
     DW 15932400-01-0
     DW 15932401-01-0
     DW 15932401-01-1*
Period of Agreement
10/01/86 - 09/30/87
10/01/86 - 09/30/87
10/01/86 - 09/30/87
              Total
   Amount
$ 1,000,000
  4,481,300
  6.068.700
S11.550.0QQ
     *Amends agreement no. DW 15932401-01-0

Summary of Audit Results

Costs reported to the EPA were not readily reconcilable with
amounts recorded in LNRD's accounting records due to differences
in the methodology of expense classification and were not
reported in a manner consistent with the budgetary limitations of
the XAAs.  In addition, we found weaknesses in internal controls
which could result in a higher risk that material errors could
occur and not be detected in a timely manner.  Furthermore,
hourly employee rates used to allocate employee costs between the
various direct and indirect cost centers were not in compliance
with the terms and conditions of the lAAs.

Background

On December 11, 1980, CERCLA was signed into law.  It provided
for liability, compensation, cleanup, and emergency response for
hazardous substances released into the environment and
uncontrolled and abandoned hazardous waste sites.  This
legislation was subsequently amended by SARA.  Implementing
procedures were contained in the National Contingency Plan set
forth in Executive Order (EO) 12316 of August 14, 1981.  This EO
provided that the Attorney General was responsible for the
conduct and control of all litigation arising under Superfund.
To fund these activities, EO 12316 required the Administrator,
EPA, to transfer appropriation accounts to other agencies from
the Hazardous Substance Response Trust Fund.
                              - 2 -

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For fiscal year 1987, the Office of Waste Program Enforcement
(OWPE), EPA, issued two lAAs, as amended, to LNRO for conducting
litigation and other activities related to EPA Superfund as
authorized by CERCLA, SARA and EO 12316.  The lAAs authorized the
DOJ to be reimbursed for LNRD's costs based on its professional
employees' level of effort.

Accounting for LNRD costs and preparation of expense reports was
provided by the CPA firm of Rubino & McGeehin, Chartered.  The
CPA firm designed a system for distributing costs to the major
groupings discussed in the Audit Scope paragraph of this report.
This system was predicated on the identification and allocation
of direct costs to specific cases, which were subsequently
designated as either "Superfund" or "Other."  Both direct labor
and other direct costs were then subtracted from total LNRD
costs, and the balance was allocated in proportion to direct
labor costs.  This method of deriving actual and allocable costs
was generally consistent with the costing methodology stipulated
by the EPA under applicable provisions of the lAAs.

Site referrals were the primary means by which EPA authorized
other Federal organizations to incur reimbursable costs.
Accordingly, reconciliation of cost data with site referral
information is critical for determining the allocability of
incurred costs.  In fiscal year 1987 the LNRD provided cost
information on 773 Superfund related cases.  However, since the
cost information on the 773 cases could not be confirmed with EPA
site referral information, our audit is qualified to the extent
that the cases contained in the expense reports may not represent
all Superfund related cases being litigated by the LNRO.
Notwithstanding this qualification,  LNRD provided EPA cost
information on a case by case basis; thus, discrepancies between
case referrals and LNRD cost claims should have been readily
identifiable by EPA officials.
                              - 3  -

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             FINDINGS AND RECOMMENDATIONS

EXPENSE REPORTS

     Superfund cost information was not reported to EPA in
     a manner consistent with the budgetary classifications
     provided in the XAAs, or the object classes used by
     the DOJ to account for LNRD costs.  Also, the expense
     reports did not apply cost information from the
     Expenditure and Allotment (E&A) Reports uniformly.
     This occurred because the system used to accumulate
     and distribute Superfund case cost information
     compressed all direct costs into one of two
     categories:  (1) Direct Labor, and (2) Other Direct.
     The lAAs between LNRD and EPA required that cost
     reports reflect costs by object class and budget line
     item for each agreement.  Furthermore, organization-
     wide cost information used in the preparation of
     expense reports should have been obtained from the
     final E&A report, and not preliminary reports thereo'f.
     As a result, the financial reports did not provide
     sufficient cost data to assure that costs incurred
     were within the individual cost category budget
     limitations of the lAAs.

Identification of Costs bv Expense Categories

The governing lAAs required the LNRD to report expenses
both by IAA and object class,  our review of the two lAAs,
as amended, disclosed that cost estimates were established
by budget category,  and no provision had been made for
indirect costs.  By special condition to DW 15932400-01-0,
however, direct costs allocable to the EPA were to be
determined by the proportion of direct labor expended on
Superfund related activities.  Accordingly, to comply with
these agreements LNRD should have accounted for all direct
costs by budget line item, then allocate costs on a line by
line item basis, not by indirect cost pool.  The LNRD,
however, established procedures to account for all direct
labor, expert witness, automated litigation support,
transcript, and travel costs.  All other costs were
included in an indirect cost pool.

The governing lAAs required the reporting of expenses by
ten separate object classes, as appropriate to the
individual IAA.  The expense report for fiscal year 1987,
on the other hand, was comprised of direct labor, other
direct costs, indirect costs, and unpaid obligations.  As a
result, the following differences were noted between the
reporting categories required by the lAAs and the LNRD
fourth quarter expense report.
                        - 4 -

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  Budgeted Costs Per lAAs
                                      Amount
                               IAA
  Exense
   (a) Personnel
   (b) Fringe
      Benefits
   (c) Travel
   (d) Equipment
   (e) Supplies
   (f ) Pl'm .i tt qfl itfj tt
      Assistance
   (g) oaa»ttucticn
   (h) Other
   (i) Total Direct
   (j) Indirect
      Costs
                  DW15932400-01   CW159324Q1-O1

                  $        0   $ 4,952,000
                           0
                           0
                           0
                           0

                    1,000,000
                           0
                           0
                           0
  681,000
  709,000
   45,000
   65,000

3,067,000
       0
1,031,000
       0
  Ccnbjjied

$ 4,952,000

   681,000
   709,000
    45,000
    65,000

  4,067,000
         0
  1,031,000
         0
                    S 1.000.000   610.S50.QQQ
 (k) Total

    I/ As amended

Reimbursable Superfund Costs  Per Expense Reports
         Category
         Direct Labor        9/
         Other Direct Costs  **
         Indirect Costs
            Subtotal
         Unpaid Obligations
            Total Superfund Allocation of
            fiscal year 1987  LNRD obliga-
            tions
                                         Amount
                                         $ 2,517,609
                                           2,325,929
                                           6.306.723
                                         $11,150,261
                                           1.160.850
                                         gl3.311.lll
                     a/
             2J Includes Expert  Witness Costs,
                Automated Litigation Support
                Costs, Transcripts,  and Travel.
             3_/ From case cost summary.
                Per page 1 of 2  of the September 30,
                Expense Report.
                                                     1987
Although the EPA has reimbursed LNRD without requiring
additional  IAA or object class  identification, the
reporting format used by LNRD was not responsive  to the
requirements of the lAAs.

Reporting of LNRD Costs

Amounts could not be readily traced from the accounting
records constructed by the CPA  firm to the expense reports
sent to EPA.  This occurred because costs were not reported
                         - 5  -

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    by the sane cost categories used  in the DOJ accounting
    records.   In addition,  contrary to the design for
    reporting, the  expense  reports did not reflect all  non-
    Superfund costs.   Because the expense reports used  LNRD's
    total  expenses  and obligations for allocating costs,  all
    direct costs should have been identified in order to
    support indirect cost pool determinations.   Since the
    expense report  did not  reflect all direct expenses,  there
    existed an unreconciled difference of $6,180,480 in costs
    between the accounting  records and the report.  These
    differences are summarized as follows:

                            	As of September 30.  1987	
Expense
I.   Direct labor
      Superfund
      Other Cases
       Total Part I

II.  Other Direct
      Superfund
      other Cases
      Adjustments
       Total Part H

III. Section 1595 *f.
     Section 1596 *f.
     Section 1598 **
       Total Part HI

IV.  indirect
      labor
      fringe Benefits
      Indirect Travel
      Freight
      Space, Lights,
      Utilities
      Printing
      Training
      Supplies
      Non-capital
      Equipment
      Other
       Total Part IV
Total
                            Accounting
$ 2,517,546
  7.257.038
S 9.774.584
$ 1,045,439
  1,047,977
     10.451
$ 3,230,232
    476,454
  2.695.856
S 6.402.542
$ 8,954,626
  2,406,682
     59,299
    319,572

  3,397,903
    260,076
  1,309,293
    367,042

    304,007
 	286
S17.378.786
$ 2,517,546
  7.257.038
S 9.774.584
$ 2,325,929
         0
 	Q
S 2.103.867    6 2.325.929
         0
         0
         0
$ 8,954,626
  2,406,682
     59,299
    319,572

  3,397,903
    260,076
  1,309,293
    367,042

    304,293
 	Q
S17.378.786
$2
                              Difference
                         0
                         0
               $ (1,280,490)
                  1,047,977
                    10.451
               S   (222.0621


               $  3,230,232
                   476,454
                  2.695.856
               S  6.402.542
               $         0
                         0
                         0
                         0


                         0
                         0
                         0
                         0


                      (286)
                	286
               $	Q
               fi  6.180.480
    This amount, used in the computation of the proportion of Superfund
    direct labor to INRD direct labor, does not agree with the amount
       reported in the case cost summary.
                               - 6 -

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            Section 1595 relates to reimbursable  amounts from
            agencies other than EPA.
            Section 1596 relates to non-Superfund litigation support
            and office automation.
        I/ Section 1598 relates to charges which are Superfund
            specific.

        As a result, the report did not provide  either a complete
        summary of all costs  incurred  by the LNRD or a systematic
        means of determining  the allocability of those costs
        charged to the EPA as Superfund related.

        Use of Expenditure and Allotment Cost Information

        Amounts of unliquidated obligations presented in the
        expense report were not extracted consistently from LNRD's
        E&A Report.  Two E&A  Reports,  one printed October  8,  1987
        and the other on October 23, 1987, were  used to compute
        "Net Unliquidated Obligations," as depicted below:
"EPA Billing
                    Pace 2 of 2
IKRD Fiscal Year 1987 unliquidated
  obligations at September 30,  1987
Less - unliquidated obligations:
  Section 1595
  Section 1596
  Section 1598
Net unliquidated obligations -
  IKRD (a)
Superfund percentage -^ (b)
Superfund portion of unliquidated
  obligations (a) x (b)
Add * Section 1598
  unliquidated obligations
Total Super fund unliquidated
  obligations
Adjustment for Superfund portion  of
  payments on prior fiscal years'
  unliquidated obligations
Total Superfund unliquidated
  obligations
less:  Amounts previously billed
Met Superfund unliquidated
  obligations - fourth quarter
Per Expense
  Report
               Corrected Per
               10/23/87 Recort
$ 5,952,590

 (2,468,685)
 (  375,848)
 fl.322.2281
                                             2/

                                              I/
                                              I/
$ 5,952,590

 (2,481,131)
 (  659,161)
 fl.323.4711
                         2/

                         2/
                                  S 1.785.829    6 1.488.827
                                  $   459,959

                                    1.322.228

                                    1,782,187



                                     (621.3371


                                    1,160,850
                                   (1.900.9611
              $  383,462

                1.323.471

                1,706,933



                 (621.3371

                1,085,596
               fl.900.9611
                                  S  r740.1111    S  (815.3651
I/ FY 1987 E&A Report printed 10/08/87

2/ FY 1987 E&A Report printed 10/23/87
Difference


$     0

  12,446
 283,313
   1.243

S297.0Q2



$ 76,497

  fl.2431

  75,254
                             S 75.554
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I/ Superfund 's percentage of unliquidated obligations was
   calculated by dividing year to date Superfund direct labor
   as of September 30, 1987 by the total direct labor for the
   period ($2,517,608 / $9,744,584 - 25.7561).

      Because the expense report was not prepared from the most
      recent E&A Report, both "Net Superfund unliquidated
      obligations - fourth quarter" shown above and the
      $12,311,111 reported for "Total Superfund Allocation of
      fiscal year 1987 LNRD Obligations" (See page 5 of this
      Report)  were overstated by $75,254.
      The Audit Staff recommends that the LNRD:

      1.  Revise the system used to accumulate Superfund costs to
          permit the reporting of costs in a manner consistent
          with the budgetary categories of the lAAs.

      2.  Prepare an amended final report using E&A Report
          information that identifies costs in a manner
          consistent with the accounting records, and include
          sufficient information to permit the reconciliation of
          all costs claimed to LNRO's E&A Reports.
                              - 8 -

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II.
INTERNAL
    The LNRD system of internal accounting controls needs
    strengthening to improve the quality and accuracy of
    financial representations in reports and records.  The
    system weaknesses vere:  (1) the attorney time
    reporting system lacking effective quality and
    supervisory controls, (2) direct costs being allocated
    among Superfund cases on a computed rather than actual
    basis, and (3) adjusting entries not providing adequate
    referencing to locate source documentation.
    Accordingly, the LNRD's system of internal accounting
    controls did not provide management with reasonable
    assurance that transactions vere executed in accordance
    with management's authorization and were recorded
    properly.

The Budget and Accounting Procedures Act of 1950
established the principles and standards governing the -
accounting of governmental activities.  The standards vere
promulgated by the General Accounting Office's Policies and
Procedures Manual for Guidance of Federal Agencies, and set
forth guidance pertaining to technical compliance elements
and the usefulness of financial data.  The Office of
Management and Budget circular No. A-123 further defines
the responsibilities of administering agencies to include
the development and use of systems of internal control.
The policies and standards set forth under this circular
make it incumbent upon individual organizations within an
executive agency to ensure that:  (1) all transactions and
other significant events are documented and readily
available for examination, and  (2) transactions and
significant events are accurately recorded.  In addition,
Generally Accepted Accounting Principles require the
accurate and complete reporting of financial information.

Attorney Time Reports

Allocation of direct labor costs vas based upon attorney
time reports vhich identify hours worked by specific case.
Time reports were adjusted for mathematical and case number
errors, if any, by LNRD system analysts then entered into
the Attorney Time System by contract data entry personnel.
Attorney case hours were subsequently entered into the cost
accounting system for computation of direct and indirect
labor costs.

LNRD supervisory personnel did not approve individual
attorney time reports, and attorneys charged with the
overall responsibility for cases did not verify case hours
reported on the attorney time reports.  Also, time report
corrections made by systems analysts were not returned to

                        - 9 -

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and approved by responsible  case  attorneys before their
input into the data base.  These  weaknesses precluded LNRD
from having the necessary  assurance that case hours
represented in attorney time reports were an accurate
reflection of the attorneys1  work.

Allocation of Direct Costs

Direct costs other than personnel were not allocated on a
basis consistent with  actual effort or actual cost.  For
example, one-third of  the  dollar  amount of Batch Number
2170IX - Voucher Number 017,  or $333.17, was incorrectly
allocated to case 90-11-2-156.  This occurred because the
total voucher amount was allocated  evenly among the three
cases initially authorized on the travel request without
regard to the fact that travel  in relation to case 90-11-2-
156 had been subsequently  cancelled.  Allocation of direct
costs by this method did not provide LNRD with accurate
Superfund case specific costs although total Superfund
direct costs may have  been stated fairly.

Adjusting Entries

Adjusting entries for  direct costs  other than personnel did
not provide adequate referencing  to source documents.  For
example, in our sample of  105 adjusting vouchers, five
could not be traced to source documents due to inadequate
referencing.  These are identified  as follows:
           Batch
 Kefr
 1031
 1065
 1121
 1128

 3099
42301V
52601V
6290LR
62901R

91806H
Voucher
Number

 005
 001
 on
 022

 051

  Total
  Amount

$   (27.90)
 (3,796.88)
 (1,667.25)
 71,324.29

   f763.991

S65.068.27
Travel
Expert witness
ADP services
Automated litigation
Court reporter/tran-
script
Each of the above vouchers was an adjusting voucher used to
reclassify expenses between object classes.  Because of
inadequate referencing,  we were unable to examine the
original voucher or the  original obligation document to
determine the allowability or allocability of these
charges.
                        - 10 -

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Recommendations
The Audit Staff recommends that LNRD:
3.
4.
5.
    Develop and implement procedures for the strengthening
    of supervisory controls to include:  (a) approval of
    attorney time reports by supervisory personnel, (b)
    requiring attorneys with overall responsibility for
    Superfund cases to verify case hours represented on
    attorney time reports, and (c) returning time reports
    corrected by LNRD systems analysts for approval by case
    attorneys.

    Adopt procedures for allocating direct costs other than
    personnel on a basis consistent with actual effort or
    actual costs.

    Provide assurance that adjusting entries are adequately
    referenced and supported with documentation evidencing
    authorization and approval.
                       - 11 -

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III.  COMPUTATION OF EMPLOYEE COSTS

            Hourly employee rates used to allocate employee costs
            between the various direct and indirect cost centers
            vere not in compliance with the terms and conditions
            of the lAAs.  This was because:  (1) costs for
            attorneys vere based on rates of pay, and not actual
            earnings; and (2) hours worked were adjusted to
            reflect a minimum average of 8 hours for each work
            day during a given month.  The costing methodology
            set forth in the governing lAAs required that actual
            costs be used as the basis for reimbursement.  As a
            result, direct employee costs distributed to
            individual cost centers may not have represented
            actual LNRD costs.

      The EPA approved costing methodology for determining
      reimbursable costs required that the LNRD use the level of
      effort expended by its professional employees, as deter-
      mined by comparing Superfund case hours to total case
      hours, to allocate all LNRD costs.  To implement, a costing
      methodology which would comply with the lAAs while provid-
      ing the most accurate accounting of direct costs possible,
      the LNRD decided to weight the hours worked by professional
      employees by their respective levels of remuneration.  This
      was accomplished by applying an employee's rate of pay to
      the hours worked in a given month.  This procedure may
      result in incorrect rate computations whenever changes
      occur in employee salary rates, or where employees are on
      work schedules which do not result in an average of 8 hours
      worked for each workday in a given month.  In either
      circumstance, the use of employee pay rates and not actual
      remuneration may result in incorrect cost allocations.  In
      computing rates for the month of December 1986, for
      example, the LNRD appeared to have used January 1987 salary
      rates which included a 3 percent cost of living adjustment
      not applicable to the December period.

      Compounding this problem, the LNRD engaged in a practice of
      adjusting employee time reports to reflect hours normally
      charged for a month.  For instance, the hours worked in
      June by employee number 302 appear to have been increased
      from 114 hours to the 176 hours normally charged by an
      employee for that month.  The addition of indirect work
      hours to compensate for unreported time had the dual effect
      of lowering the employee rates used to determine direct
      time charges while increasing costs retained as indirect
      costs.  Because the quarterly expense reports used actual
      LNRD costs reported on the E&A Reports as a basis for
      determining total costs, and derived indirect costs by
      deducting direct costs from total LNRD costs, variances in
      direct charges were offset by corresponding changes in the

                              - 12 -

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indirect cost pool.  Since both direct Superfund and direct
non-Superfund costs were treated in a like manner, this
practice should have had no material effect on the total
costs reported to the EPA.  This practice, however, may
have had some effect on the allocation of costs among the
individual cases.

Although rates determined by use of employee earnings
varied only marginally from those rates developed by LNRD
from employee salary rates, our test of 93 computations
disclosed variances in 49.  In each instance the variance
appeared to have been due to either the rate or hours
adjustment issues disclosed herein.  Since the governing
ZAAs required the LNRD to use actual costs, actual employee
earnings and actual hours should be used to allocate
employee costs.

Recommendation

The Audit Staff recommends that LNRD:

6.  Ensure that actual employee earnings and hours are used
    for computing distributable direct labor costs.
                        -  13 -

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            STATEMENT ON INTERNAL ACCOUNTING CONTROLS

He have reviewed the system of internal accounting controls as
required by the Standards for Audit of Governmental Organiza-
tions. Programs. Activities and Functions, issued by the
Comptroller General of the United States.  Accounting control
comprises the procedures and records that are concerned with the
safeguarding of assets and the reliability of financial records.

LKRD is responsible for establishing and maintaining a system of
internal controls.  The objectives of a system of internal
controls are to provide the management of LKRD with reasonable,
but not absolute, assurance that assets are safeguarded against
loss, unauthorized use or disposition, and that transactions are
executed in accordance with management's authorization and are
recorded properly.  Because of inherent limitations in any system
of internal controls, errors and irregularities may nevertheless
occur and not be detected.  Also, projection of any evaluation of
the system to future periods is subject to the risk that proce-
dures may become inadequate because of changes in conditions or
that the degree of compliance with the procedures may deterio-
rate.

Our study and evaluation, made for the limited purpose described
previously, would not necessarily disclose all material weak-
nesses in the system.  Accordingly, we do not express an opinion
on LNRD's system of internal controls taken as a whole.  However,
our study and evaluation disclosed conditions that could result
in a higher risk that material errors or irregularities may occur
and not be detected within a timely period.  These conditions are
discussed in the Findings and Recommendations section of this
report.
                              - 14  -

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In our opinion, the LNRD complied with the applicable laws and
regulations for the transactions tested which could have a
material effect on the cost of litigative services provided to
the EPA.

For those transactions not tested, nothing came to our attention
during the examination that caused us to believe that the LNRD
was not in compliance with applicable laws and regulations.
                             - 15 -

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                    OTHER REPQRTAPLE MATTERS

1.  Cost centers have been established for the accumulation of
    LNRD costs which are related to the provision of legal
    services to the EPA, but which are not related to ongoing
    Superfund litigation.  As these costs are not treated as
    overhead expenses, they may not be recovered by the EPA
    through subsequent litigation.

2.  Beginning with the fiscal year ended September 30, 1987, the
    indirect rate calculation included all indirect costs paid
    (liquidated obligations) during the current fiscal year in
    lieu of obligations to calculate the indirect cost rate.
    Payments were used instead of obligations because the CPA
    firm determined that payments of obligated amounts were often
    made significantly later than when obligated.  As a result,
    when calculating the indirect cost rate for the current
    fiscal year, the payments made on the prior year's
    obligations were included as part of the indirect cost pool
    for the current year.

    For fiscal years ending September 30, 1986 and prior,  LNRD
    used all obligated amounts, whether paid or unliquidated, to
    calculate the cost associated with work performed by the LNRD
    for the EPA.  For 1987 and subsequent years, LNRD needs to
    credit the Superfund account to reduce the amount requested
    for obligations paid in one year but already charged in those
    prior years when unliquidated obligations were used in the
    billing formula.  With respect to EPA reimbursement, this
    credit is reported on page 2 of 2 of the EPA Billing Summary,
    and is described as "Adjustment for Superfund Portion of
    Payments on Prior Fiscal Years' Unliquidated Obligations."
    In submitting claims against responsible parties under
    CERCLA, the entire issue of how past costs would be handled
    was being explored between LNRD and the CPA firm.  In the
    interim, a credit was being applied based on a charged hours
    percentage for the prior years relating to a particular case.
                             - 16 -

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                                                            APPENDIX I
                                    U.S. Department of Justice

                                    Land and Natural Resources Division
 Executive Office
                             , D.C 20530
   MEMORANDUM
   TO:
   FROM:
   SUBJECT:
Guy K. Zimmerman
Director
Audit staff
Justice Management  Division

vRoger J. Marzulla
  sistant Attorney  General
Land and Natural Resources Division

Draft Audit Report  on the Environmental Protection
Agency's Interagency Agreements with the Department of
Justice for Superfund Activities
             Thank you  for the opportunity to respond to the subject
   audit.  Audits of  this  nature are useful and constructive, and
   significantly benefit the government's efforts to recover from
   polluters federal  funds spent to clean the environment.  I am
   particularly pleased that corrective actions for the audit's
   findings can be implemented quickly,  and that our system of
   accounting  for cost  recovery cases has passed this critical first
   test.

             For your convenience,  our detailed responses to the six
   recommendations are  attached. However, I would like to respond
   briefly to  the summary  of audit  results.  The Land and Natural
   Resources Division agrees with the audit about the need to
   better reconcile expense reports with accounting data, and our
/  format for  expense reporting has been revised accordingly.  In
   addition, the internal  control issues outlined in the audit are
   basically accurate,  and the Division has developed plans to
   improve internal controls on its timekeeping system and cost
   records management procedures.  Our position on the issue of
   hourly employee rates was made known to your staff at a meeting
   held Wednesday September 7, 1988, and we have instituted
   corrective  measures  for those few calculation errors noted in the
   audit.

             Overall, I believe that this audit is best read in
   light of the problems which were not found to be present — no
   major internal control  weakness  which would prejudice an
   independent opinion  about the costs was identified, nor were
                                - 17 -

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Mr. Guy K. Zimmerman
Page 2
flaws in the accounting system design unearthed.  While this was
an "exception* audit, and thus its mandate was limited to
preclude an opinion about the reasonableness of costs, the report
would nonetheless have included a negative statement about the
overall cost system had your audit discovered major flaws.  The
lack of a negative statement of this ilk can be read as an
endorsement of the Lands Division's systems for cost accounting.

          Please pass along our thanks to the audit team for
their fine work and cooperation.  We look forward to working with
you and your staff in the future.
Attachment
                              - 18 -

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            D«tail«d Responses to Audit Recommendations
 I. Expense Reports
 1.   Consistent with the budgetary estimates listed in each of
 the Superfund Interagency Agreements, the Land and Natural
 Resources Division's format for Superfund expense reporting to
 the EPA will be revised to include summary expense information
 listed by object classification (see Appendix A).

 2.   An emended final report for fiscal 1987 will be prepared by
 September 30, 1988, and a copy forwarded to the Audit Staff for
 review.  This final report, and all subsequent expense reports
 prepared by the Division, will include a new schedule designed to
 facilitate the reconciliation of the Superfund expense reports
 with the Department of Justice's 'Expenditure and Allotment*
 accounting reports (see Appendix A).

 II. Internal Controls
 3.   The Lands Division intends to take several steps over the
 next six months to strengthen and improve internal controls over
 it's time keeping system (see Appendix B).   In sum,  these
 measures will provide additional quality control over the time
 data,  and supervisory review of the reported information.

 4.   For the allocation of direct travel to cases,  the Division
 now requires staff to list on their travel  vouchers (as well as
 the travel authorizations)  the proper allocation of costs when
 multiple cases are involved (see Appendix C).   The allocation
 information provided  on the actual payment  voucher will be used
 as the basis for allocating costs to individual cases.   An
 adjusting entry has been made to correct the  erroneous allocation
 identified by the audit for batch number 21701X voucher 17.

 5.   The problem identified by the audit involves record keeping
 practices when adjusting entries which affect direct charges  are
 made within the Department  of Justice accounting system.   Most
 of these adjusting entries  involve corrections  to the  sub-object
 classification or the accounting classification,  and thus have
 little  impact  on the cost system.   With the cooperation of the
 Justice Management Division's  Finance Staff, the  Lands  Division
 will collect copies of  all  paper documents related to both the
 adjusting entry,  and to the source  document which was adjusted,
 and maintain these records  to  support costs.

 II. Computation  of Employee Cost^s
 6.   The  Lands Division's views  and supporting papers on  employee
 earnings were provided  to the Audit Staff on September 7,  1988.
 The emended final expense report for  1987 will include
 corrections for each of the computations which were erroneous,
 and a copy of the final report will be provided to the Audit
Staff for review.
                              - 19 -

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                           Appendix A
   Page 1 of 2
                       EPA Billing Summary
              Reconciliation of Total LHRD Expenses
Total LNRD expenses per Expenditure and Allotment
Report dated September 30. 1987
Less:
     Total direct Superfund labor
     Total direct non-Superfund labor

                         Subtotal
$
$"
     Total other direct Superfund costs      $_
     Total other direct non-Superfund costs  $~
                         Subtotal            $_

                         Net direct expenses

                         Net indirect expenses
     Overhead payments - prior f/y obligations
                         Total Indirect Expenses
                               - 20 -

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                  Appendix A
Page 2 of 2
             EPA Billing Suamary
   Superfuad Coats  by object classification
Object
Class
11
12
21
22
23
24
25
26
31
Description
Salaries
Benefits
Travel
Freight
Rent
Printing
Services
Supplies
Equipment
Direct
Expenses
$
$
$
$
$
$
$
$
$
Indirect
Expenses
$
$
$
$
$
$
$
S
$
Total
$
$
$ .
$
$
$
$
$
$
Total
                   - 21 -

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                              Appendix B
Page 1 of 6
Our comments on the attorney tine system internal controls consist of
three parts:  (1) suggested clarifications to the audit report, (2)
our statement of intention regarding compliance with the
recommendations in the report, and (3) a timetable setting forth the
compliance schedule.

I. Suggested chancesi

Page 15,  Attorney Time Reports, third line, reads:
  Time reports were adjusted for mathematical and case number
  errors, if any, and entered into the Attorney Time System by
  systems analysts.

We suggest:
  Time reports were adjusted for mathematical and case number
  errors, if any, by systems analysts in the Lands Division and
  entered into the Attorney Time System by contract data entry
  personnel.

Page 15,  Attorney Time Reports, second paragraph, reads:
  LNRD supervisory personnel did not approve individual attorney
  time reports,  and attorneys charged with the overall
  responsibility for cases did not verify case hours reported on
  the attorney time reports.  Also, time report corrections made by
  systems analysts were not returned to and approved by responsible
  case attorneys before their input into the data base.

We suggest:
  LNRD supervisory personnel did not approve individual attorney
  time reports prior to data entry.  However, after data entry,
  each section chief was furnished with computer generated reports
  which indicated the total case and category hours reported by
  each attorney and paralegal in his or her section. Also, time
  report corrections made by systems analysts were not returned to
  and approved by the timekeeper before their input into the data
  base under the following circumstances:

       date was incorrect
       timekeeper's ID number was incorrect
       section ID was incorrect
  -    name was incorrect
  -    math was incorrect
       decimals  were added to whole numbers
       decimals  .2, .7 were changed to .25, .75
       decimals  .3, .8, .9 were changed to .25, .75, 1.00
       overtime  was not recorded for hours in excess of normal
       work week
       corrections were made for clarity, i.e., handwriting was
       illegible,  hours were written above or below the box
                              - 22 -

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                               Appendix B
Page 2 of 6
        provided, case hours were written in the lines provided
        for categories
   -    file number was incorrect, i.e., dash was omitted, '9" was
        written instead of *90,» »5* was written instead of *s,'
        numbers were omitted in file number
   -    when a zero was listed for a case or category,it was
        eliminated so that it would not be keyed
        DJ file number was reported with no hours
   -    total column was blank but time was noted per day (time was
        written in the total column.)
   -    wrong color timesheet was used (Timesheet was copied on the
        appropriate colored paper.)

   However, time reports were returned for corrections or
   corrections were verified by telephone or electronic mail when:

   -    case name was noted instead of DJ file number
   -    file number was incorrect
   -    hours were reported with no DJ file number
   -    one timesheet was received instead of the two that are
        required when the month does not end on Saturday
        timesheet was unsigned
   -    holiday was not noted
   -    40 hours were not reported by full time employees

   After data entry,  reports containing any incorrect DJ file
   numbers used were produced and forwarded to the attorneys  or
   paralegals for correction.   The corrected reports  were
   subsequently returned to the Systems Group for entry into  the
   data base.

Page  17-18,  Recommendations.  reads:
   3.   Develop and implement  procedures for the strengthening of
   supervisory controls   to include:   (a)  approval  of attorney time
   reports by supervisory personnel,  (b)  requiring  attorneys  with
   overall responsibility for Superfund cases to verify case  hours
   represented on  attorney time reports,  and (c)  returning time
   reports corrected  by  LNRD  systems  analysts for approval by case
   attorneys.

We suggest:
   Develop and implement procedures for the  strengthening of
   supervisory  controls to  include:   (a)  approval of  attorney  and
   paralegal timesheets by  supervisory  personnel, and (b) returning
   time  reports corrected by LNRD systems analysts  for approval by
   case  attorneys.

yi. Statement ofintention:
In its  report, the Audit Staff of the Justice Management Division
concludes that the Division needs to implement procedures for
                             - 23 -

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                              Appendix  B
Page 3 of 6
strengthening internal controls over the timekeeping forms, and that
time reported must be verified by a supervisory person.

We intend to comply with the recommendations for strengthening
supervisory controls by establishing levels of review for the
timekeeping forms.  As a first step, the Division will implement a
procedure whereby the Section Chiefs will delegate authority to
review and correct timesheets to the Case Management Specialists and
designated supervisory person(s).  Second, the Assistant Attorney
General or Deputy Assistant Attorney General will delegate to the
Systems Group limited authority to review and correct timesheets for
the entire Division.  After these delegations have been established,
the following review process will be implemented:

A. Case Management Specialist Responsibilities
  The Case Management Specialist in each section will collect
  timesheets every Monday, review each timesheet    for
  completeness and accuracy, and be authorized to independently
  make the following changes to assure that the:

     - timesheet is legible
     - timekeeper used the proper color timesheet
     - timekeeper's ID number is correct
     - timekeeper's name is correct
     - section indicator is correct
     - week ending date is correct
     - DJ case numbers are correct
     - math is correct
     _ decimals are indicated for whole hours (8.0)
     - time is reported in 15-minute segments
     - overtime is recorded for hours in excess of
        normal work week
     - holiday is recorded under leave category
     - zero or blank hours are not reported for any case or
       category
     - daily time also appears in the total column

  The following problems will be returned to the timekeeper for
  correction, and then re-submitted to the Case Management
  Specialists:

     - time sheet is not signed
     - case name is noted instead of DJ file number
     - file number is incorrect and Case Management
       Specialist is unable to determine correct number
     - hours are reported with no DJ file number
     - one month-end timesheet is submitted instead of two
       when the month does not end on Saturday
     - holiday is not noted

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                             Appendix  B
Page 4 of 6
     - total hours are less than the timekeeper's normal work
       week (40.0 hours if full time employee)

  The Case Management Specialist will review time sheets for
  completeness and accuracy.1

  The Case Management Specialist will sort and batch the timesheets.
  A check-sheet will accompany the timesheets and will be placed on
  top of the verified timesheets, specifying the name of each
  attorney or paralegal who is required to submit a timesheet and,
  indicating those who have submitted a timesheet for the current
  week and those who have submitted delinquent timesheets for prior
  weeks.

  The Case Management Specialist will submit the batched
  timesheets to a designated supervisory person(s) for review and
  approval.

B. Supervisory responsibility
  After review, designated supervisory person(s)  in each section
  will sign the cover sheet and return the package to the Case
  Management Specialist for submission top the Systems Group by
  noon each Wednesday.
     1    Verification of the accuracy of time reports includes
 assurance that:

       1. Total hours are filled in and represent "at least* the
       number of hours that a particular employee normally works
       during the work week (i.e., 40.0 hours for full time).

       2. The employee's name, section, ID number and week ending
       date are correct.

       3. The case numbers reported on the timesheet are assigned to
       the timekeeper. If the case is not assigned to the timekeeper,
       the Case Management Specialist will verify that the timekeeper
       is working on the case.

       4. The timesheet is signed by the timekeeper.

    The verifier is not responsible for attesting to the number of
hours reported for each case nor the total time worked if it is
beyond the normal work week.

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                              Appendix B
       Page 5 of 6
 C.  Systems Group  responsibility
  The  Systems Group will perform a  second quality assurance review,
  and  may independently correct  timesheets within the  limits
  established for Case Management Specialists in paragraph A.

  The  Systems Group will submit  the timesheets for Keypunching,
  verify their  return, and maintain locked files for the timesheets
  until they are  permanently stored on microfilm.

 III. Timetable;
 The timetable for implementing the  new review procedures for the
 timesheets is below:
      Milestones

 Draft delegation of authority  from
 Section  Chiefs to Case Management
 Specialists  and other supervisory
 person(s) to review and correct
 timesheets.

 Forward  draft to Section Chiefs  for
 review and comments.

 Incorporate  comments of Section  Chiefs.

 Forward  final delegation of authority
 to Section Chiefs for signature.

 Draft delegation of authority  from
 Deputy Assistant Attorney General
 or Assistant Attorney General  to
 Systems  Group to review and correct
 timesheets for the entire Division.
 (Include copy of signed delegation
 from  Section Chiefs.)

 Forward  draft to Deputy Assistant
 Attorney General for review and  comments.

 Incorporate  comments of Deputy
 Assistant Attorney General.

 Forward  final delegation of authority
 to Deputy or Assistant Attorney General
 for signature.

 Contact  sections to establish supervisory
processing points.
Completion Date

        9/30/88
        10/3/88



        10/2/88

        10/24/88



        10/31/88
        11/1/88



        11/18/88



        11/21/88




        11/30/88
                                - 26 -

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                              Appendix B
Page 6 of 6
Draft list of supervisory processing points,

Forward list to Section Chiefs for review.

Incorporate comments of Section Chiefs.

Draft new timekeeping policy guidelines
setting forth the above delegations, new
supervisory review functions, and how
amendments to timekeeping form will be
handled.

Forward draft of policy guidelines
to Section Chiefs for review and
comments.

Incorporate comments of Section Chiefs.

Forward draft of policy guidelines to
Deputy Assistant Attorney General for
review and comments.

Incorporate comments of Deputy Assistant
Attorney General.

Forward final of policy guidelines to
Deputy Assistant Attorney General for
approval.

Forward guidelines to Assistant Attorney
General as a Division directive.

Review process with Case Management
Specialists.

Implement new procedures.
 12/7/88

 12/8/88

 12/19/88

 12/30/88
 1/3/89




 1/20/89

 1/30/89




 2/13/89



 2/20/89




 2/27/89



 3/6/89



 3/13/89
                               - 21 -

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                                   U.S. Department of Justice

                                   Land and Natural Resources Division
                                   WaiftinfTon.D.C. 20530

                              Appendix C
Page l of l
MEMORANDUM

From:  Gary M. Peterson
       Executive Assistant

To:         All Employees
       Land and Natural Resources Division

Subject:    Allocating Costs for Multi-case  Travel


  Effective immediately, all personnel  in the  Land  and Natural
Resources Division are required to list on each  travel voucher  an
allocation of the total amount claimed  to each of the cases  or
projects for which you traveled.  You may make this allocation  based
on any of the folowing criteria:

  Number of hours worked on each case or prelect
  This would be appropriate if you visit one city,  but work  on
  several cases.  If you work 10 hours  on Case A and 20 hours on Case
  B, the allocation would be 33% for Case A  and  67% for Case B.

  Cost of airfare when separate cites are visited
  If you visit Philadelphia for Case C  (airfare  is  20% of total
  cost), then fly to San Francisco to work on  Case  D (airfare is 80%
  of total cost), the allocation could  be  20% for  Case C and 80% for
  Case D.

  Cost of airfare and number of hours worked
  Should you visit New York for six days, and  Los Angeles for one
  day, a hybrid approach might be appropriate, counting the  costs of
  airfare as well as the number of hours worked.

  Primary purpose of travel
  If you must fly to San Fransisco for  Case  E, and  then stop by
  Denver for Case F as an afterthought,  you  might allocate 90%  of the
  trip's costs to Case E and 10% to Case F.

Your allocation is not intended to be an exercise in higher
mathematics; you are asked only to provide a good faith estimate of
the costs allocable to each case or project.   Should you have any
questions about cost allocations on travel vouchers,  please  call Kyra
O'Kieffe in the Financial Management Group on  272-5977.
                              - 28 -

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                                                      APPENDIX II
             SUMMARY OP RECOMMENDATIONS AND ACTIONS
Recommendation Number:
X.

2.
4.

5.

6.
Resolved.  No further action required.

Resolved.  Subsequent to our receipt and review of the
amended final Fiscal Year 1987 financial report, we shall
consider this recommendation for closure.

Resolved.  Closure of this recommendation is dependent upon
successful completion of the scheduled corrective actions.

Resolved.  No further action required.

Resolved.  No further action required.

Resolved.  No further action required.  The information
provided to the Audit Staff on September 7, 1988, by the
contractual CPA firm was sufficient to remedy the finding and
recommendation.  The information demonstrated that the CPA
firm was using a methodology which appeared to compute and
allocate actual labor costs on a fair and equitable basis.
Though alternatives exist, the method used by the CPA firm,
thus LNRO, appears reasonable.
                              - 29 -

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I t«*7 1 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
                        WASHINGTON, D.C. 20460

                             APR I  I 1988
                                                   THE INSPECTOR GENERAL
  MEMORANDUM

  SUBJECT:  Audit Report Summaries for Semiannual Report
            to Congress

  TO:       See Attached List

       The Office of Inspector General is required to provide  a
  semiannual report to Congress.  In this report, we provide
  summaries of some of the significant audits which we have
  performed.

       Attached are copies of report summaries relating to your
  office which we plan to include in the next semiannual report.
  These summaries are as close as possible to the final versions
  that will appear in .the semiannual report to be issued to the
  Administrator cgT'^gril 29, 19QB.^

       Should you or your staff have any comments regarding the
  factual content of the report summaries, please submit your
  comments in writing to Ernest E. Bradley III. ^Assistant
  Inspector General for~~A~ucTit^  To consider youiT comments, we
  must receive them no later than April 20, 1988.  We appreciate
  your prompt attention to this matter.
                                Jo

  Attachment
o»i OL Martin

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 Addressees:

 A.  James  Barnes
 Deputy  Administrator

 Robert  S. Cahill
 Associate Administrator for
  Regional  Operations

 Charles L.  Grizzle
 Assistant Administrator for
  Administration and Resources Management

 Sheldon Meyers
 Acting  Associate Administrator for
  International Activities

 John  A. Moore
 Assistant Administrator for
  Pesticides and Toxic Substances

 Rebecca W.  Hanmer
 Acting  Assistant Administrator for Water

 Thomas  L. Adams, Jr.
 Assistant Administrator for Enforcement
  and Compliance Monitoring

 J.  Craig Potter
 Assistant Administrator for Air
  and Radiation

 J.  Winston  Porter
 Assistant Administrator for
  Solid Waste and Emergency Response

 David Kling, Acting Director
 Asbestos Action Program

 Charles W.  Elkins, Director
 Office of Toxic Substances

 David P. Ryan, Comptroller
 Office of the Comptroller

 Harvey Pippen, Director
 Grants Administration Division

 Vincette L. Goerl, Director
 Financial Management Division

 Nelson Hallman, Acting Director
Facilities Management and
  Services Division
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Gerald A. Byran, Director
Office of Compliance Analysis and
  Program Operations

John Seitz, Director
Stationary Source Compliance Division

Paul F. Nadeau, Acting Director
Hazardous Site Control Division

James R. Elder, Director
Office of Water Enforcement
  and Permits

Gene A. Lucero, Director
Office of Waste Programs Enforcement

John Chamber1in, Director
Office of Administration

Lloyd Guerci,  Director
CERCLA Enforcement Division

Henry L.  Longest II, Director
Office of Emergency and
  Remedial Response (Superfund)

Joseph Carra,  Director
Waste Management Division

Steve Allbee,  Acting Director
Municipal Construction Division

Michael R. Deland
Regional Administrator, Region 1

Christopher J. Daggett
Regional Administrator, Region 2

James M.  Self
Regional Administrator, Region 3

Greer C.  Tidwell
Regional Administrator, Region 4

Valdas V.  Adamkus
Regional Administrator, Region 5

Robert E.  Layton, Jr.
Regional Administrator, Region 6

Daniel W.  McGovern
Regional Administrator, Region 9

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         MORE  IMPROVEMENTS ARE NEEDED TO ENSURE
                       SUPERFUND ACCOUNTING
Problem

Although Agency guidance on accounting for Superfund costs has
significantly improved, further improvements are needed to ensure
accurate accounting  for property management, cost allocations,
receivables, obligations, disbursements and personnel compensation.

We Found That

Humerous weaknesses  existed in property controls.  For example:

o 140 items purchased in fiscal 1986, costing about $736,000,
  were not recorded  in the Personal Property Accounting System.

o 103 sample items,  valued at about $252,000, that were selected
  for physical inspection could not be located.

A significant procedural weakness contributing to these deficiencies
was the lack of Agency policies and procedures requiring the
reconciliation of property and equipment purchases recorded in
the Financial Management System with items entered into the Personal
Property Accounting  System.

We also found that the Agency's procedures for allocating general
support services costs to Superfund were not clearly defined.  At
Headquarters, disbursements were allocated improperly, and at
Region 3,  general support services cost allocations were overstated
because an incorrect personnel ratio was used.   In addition, the
Superfund program was not always charged its proportionate share
of support services  costs due to cost and personnel ceilings.  As
a result,  distribution of support services costs between Superfund
and EPA's other program was inaccurate.

Additionally, we found that amounts due Superfund from cost
recovery decrees and State cost-sharing agreements were not being
recorded timely.   This occurred because various EPA offices failed
to properly coordinate and communicate cost recovery decrees and
agreements as required by existing Agency guidance.  This precluded
the Agency from adequately managing receivables  and collections
and could result in  a material amount of lost interest.

While we accepted the majority of fiscal 1986 recorded obligations
of $393,272,582 and  disbursements of $416,685,493, a statistical
analysis of key internal control and compliance  attributes dis-
closed a higher than expected error rate of nonpayroll obligations,
nonpayroll disbursements, and personnel compensation transactions.
This could result in:  unauthorized or misstated obligations
being recorded, improper or duplicate disbursements, and misstated
personnel  compensation costs.

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We Recommended Thr.t

The Acting Assistant Administrator for Administration and Resources
Management:

o Establish policies and procedures requiring (1) reconciliation
  of the personal property account in the Financial Management
  System with property recorded in the Personal Property Account-
  ing System, and (2) annual physical inventories.

o Clarify cost allocation procedures and ensure that appropriate
  adjustments are made to reflect proper allocations.

o Require cost settlement documents and State cost-sharing agree-
  ments be forwarded immediately to the appropriate finance office.

o Reconcile receivables with the Office of Waste Program Enforce-
  ment's Case Management System to ensure that all settlement
  documents are recorded.

What Action Was Taken

The final audit report was issued to the Acting Assistant Admini-
strator for Administration and Resources Management on QctLgber 7,
1987.  On January 15, 1968, the Acting Assistant Administrator
yruvided a btatus report on corrective actions that were underway
when we issued the draft audit report, and responses to the final
audit report's recommendations.  The status report and the response
indicated that the Assistant Administrator implemented our
recommendations.

As part of our audit of EPA's fiscal year 1987 portion of the
hazardous Substance Superfund, we will follow up on these findings
and recommendations to determine the adequacy of the corrective
actions implemented.

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