UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
                        WASHINGTON, D.C. 20460
                                          TH£
                                                              OF

                                                               GENERAL
 MEMORANDUM

 SUBJECT:
Superfund Interagency  Agreements
with the National Bureau  of
Standards, Department  of  Commerce
Audit Report No. M5BH8-11-Q032-80571
 FROM:     Ernest E.  Bradley  III
           Assistant  Inspector  General for Audit

 TO:       J. Winston Porter
           Assistant  Administrator for Solid
             Waste  and Emergency  Response (WH-562A)
      At our request, the Office  of  Inspector General, U.S.
 Department of Commerce  (DOC),  performed the subject audit.
 The final report is attached.  The  report does not present any
 information which would warrant  corrective action by EPA officials
 Accordingly,  we are closing  this report in our Audit Tracking and
 Control System upon issuance.

      The Inspector General,  DOC,  informed us in a separate
 memorandum that the National  Bureau of  Standards (NBS) can
 provide site-specific cost information  which can be verified to
 NBS'  accounting system.  This  can be done if (1) EPA establishes
 separate interagency agreements  for work to be performed at each
 site and (2)  requires cost reporting by agreement.

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

 Attachment
to
CVJ
              HEADQUARTERS LIBRARY
              ENVIRONMENTAL PROTECTION AGENCY
              WASHINGTON. D.C ?0460

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                              DISTRIBUTION
Associate Enforcement Counsel for
  Hazardous Waste Enforcement (LE-L34S)

Director, Financial  Management Division  (PM-226)

Chief, Superfund Accounting Branch (PM-226)

Agency Followup Official (PM-225)
  Attn:  Resource Management Staff

Director, Grants Administration  Division  (PM-216)

Chief, Grants Information and Analysis Branch  {PM-216}

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    \
                        **»!•<»•'
                                 UNITED STATES DEPARTMENT OF COMMERCE
                                 Office of Inspector General
                                 Wasnmgton Q C 20230
JAN 2 7 1988
 MEMORANDUM  FOR:
 FROM:
SUBJECT:
Dr .  Ernest Ambler
Director, National
  Bureau of Standard^,
Frank
Acting
                                    General
Audit of Two Interagency
Agreements with EPA
Report No. 1-176-8-002
Through  the  use  of  interagency  agreements,  the  National  Bureau
of Standards  (NBS)  performs  work  on  a  reimbursable  basis for
various  federal  agencies,  including  the  Environmental  Protection
Agency  (EPA).  In response to EPA's  request,  we have completed
an audit of  NBS  costs  charged against  two of  the reimbursable
agreements with  EPA.   We  found  that  NBS's charges,  totaling
about $62,300 under  the  two  agreements,  were  adequately
supported.   However, under one  of the  agreements, NBS  incurred
approximately $3,900 of  costs which  were charged to NBS's
appropriation rather than  to the  EPA agreement,  thereby
resulting  in  a corresponding underbilling to  EPA.

Purpose  and  Scope of Audit

Our audit  focused on the  following two interagency  agreements
between  EPA  and  NBS: agreement  numbers AD13F2A245 and  DW13038301.
EPA advised  that these agreements were funded with  money
provided under the  superfund legislation.   The  purpose of our
audit was  to  identify  the  amounts which  NBS charged to these
agreements during fiscal years  1984  through 1986 and to
ascertain  whether these  costs were determined in accordance
with policies and requirements  applicable to  reimbursable
work performed for  other  agencies.

We evaluated  the adequacy  of internal  controls  applicable to
the identification  and assignment of costs  to specific
agreements.   Also,  our work  included tests  to establish  the
appropriateness  of  costs  actually charged under the terms of
the two  agreements.  During  our review,  we  examined pertinent
records  and  interviewed  selected  personnel  at NBS's offices
in Gaithersburg, Maryland.

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Two issues regarding the scope of our review should be noted:

    In reviewing indirect costs, we limited the scope of our
    work to determining whether these costs were charged in
    accordance with established NBS overhead rates and on a
    basis consistent with the rates charged to NBS units and
    other agencies.  We did not assess the accuracy of N'BS's
    various overhead rate components because such a review
    would require a major commitment of audit resources, and
    we could not divert such resources from higher priority
    audits at this time.

    We have not determined whether the provisions of the two
    interagency agreements were consistent with the statutory
    authority governing EPA's expenditure of superfund monies.
    We believe such determinations are more appropriate for
    EPA's Inspector General.

Our audit was performed under the authority of the Inspector
General Act of 1978 and Department Organization Order 10-13,
dated May 22, 1980.  The audit was conducted in accordance
with generally accepted government auditing standards.'

                 FINDINGS AND RECOMMENDATIONS

Pertinent facts about the two agreements are provided below:

Agreement Number AD13F2A245

Under this agreement, NBS was to provide a computer readable,
digitized data base pertaining to an automated chemical
information system.  Before project work began, EPA transferred
550,000 to NBS's Working Capital Fund to provide financing
for this reimbursable project.  Actual NBS charges to the
project totaled $50,000.

Agreement Number DW13038301

This agreement provided for NBS to perform on-site work at
two landfill sites near Bloomington, Indiana.  Specifically,
NBS personnel were to assess the possibility that buried
electric capacitors containing PCB could be perforated
by corrosion.  The interagency agreement authorized NBS to
incur costs up to $25,000 for this work, with payments to be
made as costs were incurred by NBS and billed to EPA.  Actual
NBS billings totaled $12,300.

Project Costs were Adequately Supported

Based on our evaluations and tests, we concluded that the two
agreements were adequately controlled by NBS to ensure that
r•(~lo^e i~harrteH *• n fho an r oomon t-c uo r p Hirar«h1v rAl^hoH t-o work
costs
nents were adequately controlled by NBS to ensur
 charged  to the agreements were directly related

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performed.  We found no evidence of improper charges.  We
noted, however, that NBS did not identify and bill about
53,900 of costs incurred under one of the agreements, as
described later in this report.

NBS's controls include separate accountability for funds
under each reimbursable agreement.  This includes appropriate
general ledger accounts for recording both obligations and
costs.  Entries in the accounts are required to be supported
by records showing the basis for charging costs to the agree-
ments.  For example, the controls provide for direct labor
costs to be charged on the basis of staff time expended on
the projects, as reported by employees and certified by
supervisors.
We tested costs charged under
that:
       the two agreements and found
    The labor charges were supported by appropriate work-
    sheets and timecards.
    Charges for travel,
    were substantiated
 materials, and other direct costs
by supporting documentation.
    Indirect costs were charged in accordance with established
    NBS overhead rates and on a basis consistent with the
    rates charged to NBS units and other agencies.

Costs Not Billed

Under agreement number DW13038301, NBS incurred about $3,900
of costs which were never charged to the project or billed to
EPA.  This underbilling resulted because, at the beginning of
the project, three NBS personnel traveled to the work site in
Bloomington, Indiana but, at that time, an NBS cost center
number for the reimbursable project had not yet been established
Lacking a cost center number, the costs of direct labor, travel,
and overhead applicable to this initial trip were charged to
NBS's appropriated funds, rather than to the EPA reimbursable
project.  This is contrary to NBS's policy which requires
that costs be identified with and charged to specific cost
centers authorized to cover clearly defined activities.  We
believe it is important for NBS to ensure that its personnel
understand the importance of not performing reimbursable work
until a cost center number has been assigned so that costs
can be charged to the appropriate organization.

Final Billings Not Submitted for Small Amounts

In some cases, final project billings are not sent to the
reimbursing agency because the amounts due are relatively
small.  We noted that for agreement number DW13038301, NBS

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 personnel did  not  issue  a  final  bill  for  $30  that  was due
 from EPA.   In  response to  our  inquiry on  this point, N'BS
 personnel advised  that,  when the amounts  owed are  for rela-
 tively small amounts  (under $50), a final billing  is waived.
 However, NBS has no written procedures or other formal
 approvals governing such waivers.  Written procedures should
 be established to  ensure that  there is a  clear understanding
 about this matter  and to provide for consistency of approach
 by the current and future  employees who may be involved in
 administering the  billing  function.

 Recommendations

 We recommend that  the Director, NBS, provide for the following
 actions:

 1.  Emphasize to  NBS personnel  that no reimbursable project
     work  is  to  be performed for another  organization until
     NBS's Office  of the  Comptroller has  established a  cost
     center number.

 2.  Provide  NBS personnel with  written guidance  explaining
     when  it  is  appropriate  to waive  the  issuance of billings
     to other  organizations.

 NBS  Response  -- In  reply  to our draft  report,  NBS  agreed with
 our  recommendations and described specific implementing
 act ions.
We appreciate the cooperation and courtesies extended by  NBS
officials during our review.  NBS's complete response to  our
draft report is attached as Appendix I.  As required by
Department Administrative Order 213-5, please provide us
within 90 days an action plan for each of our recommendations.

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K
                                                      UNITED STATES DEPARTMENT OF COMMERCE
                                                      National Bureau of Standards
                                                                      ana 2CS3S      APPENDIX I
                      OFC I I tgo,;
                     MEMORANDUM FOR John R. Stpanka
                                    Assistant..Inspector General for Auditing
                                             '  /^  ^
                     Froa:  Guy W. Chamberlin,\ J^r/'
                            Director of Administration
                                             "
                     Subject:  Audit of Z?A n
                     In response to the draft audit report, ?TB3 agrees with both
                     recommendations made.

                     Recommendation 1.  Emphasize to NBS personnel that no reimbursable
                     project work is to be performed for another organization until NBS's
                     Office of the Comptroller has provided a cost center number to be used
                     in assigning all applicable costs to  the reimbursable project.

                     '/e recormend that the word ''provided" be replaced with the words
                     "established in the accounting systen."

                     We will send a ™ezor«iflun to TB3 Executive Officers reninrlir.g thes  of
                     this r«quirenent.

                     Recori'Tindation 2.  Provide ''33 persor_r:^l with written guidance regarding
                     the circunstances when it is appropriate to waive the issuance of
                     billins documents to other organisations for anounts due under
                     reimbursable agreements.

                     Procedures have been drafted for the  Billing and Collections Group
                     regarding the circumstances when it is appropriate to waive the issuance
                     of invoices to other organizations for snail anounts of cost due under
                     reimbursable agreements.  These draft procedures are being reviewed.

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