UNITED STATES ENVIROIMMEIMTAL PROTECTION AGENCY
WASHINGTON, D.C. 20460
SEP I
OFFICE OF
SOLID WASTE AND EMERGENCY RESPONSE
MEMORANDOM
SUBJECT:
FROM:
TO:
Audit of Superfund Interagency Agreements with the
U. S. Coast Guard - Fiscal 1987 Audit Report
M5BFL9-11-0038-9100275
5m"sheckells, Director
Resources Management Staff (OS-240)
Scott McMoran, Acting Chief
Grants Information and Analysis Branch (PM-216F)
This is to inform you that the U.S. Coast Guard, as stated in
their memorandum of October 17, 1988, (Report No. AV-CG-8-042), has
submitted three invoices to begin reimbursement to EPA for
overstated personnel costs and unsupported costs.
To date accounts have been adjusted to restore $182,243.61 of the
$307,688 questioned in the audit report. We expect future billings
to reflect adjustments for the additional $125,444.39. The Office of
Inspector General has informed us that future audits will provide
verification of these reimbursements.
If you need additional information, please call Margret Brown on
475-8102.
cc: John Walsh, DIG
Maas, OERIT)
-------
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON. D.C. 2O460
037-5 1935
OFFICE OF
THE INSPECTOR GENERAL
MEMORANDUM
SUBJECT: Audit of Superfund Interagency Agreements with the
U.S. Coast Guard - Fiscal 1987
Audit Report M5BFL9-11-0038-9100275
FROM: Kenneth D. Hockman
Divisional Inspector General for Audit
Internal Audit Division (A-109)
TO: Harvey G. Pippen
Director, Grants Administration Division (PM-216F)
We have reviewed your September 26, 1989 response to the
report and have concluded that the corrective actions taken or
planned effectively respond to our recommendations. However, we
would like to be kept apprised of efforts to correct billings for
the remaining $125,444.39. We will ask the Office of Inspector
General, Department of Transportation to inquire about the time-
liness of Coast Guard billings during its audit of fiscal 1989
costs. Should your staff have any questions concerning this
memorandum, please have them call John Walsh on 475-6753.
cc: Acting Chief, Grants Information and Analysis
Branch (PM-216F)
Director, Office of Emergency and Remedial Response (OS-200)
vDirector, Office of Program Management (OS-240)
Mr. Bandy, Office of Inspector General, Department of
Transportation
-------
! *.
./ 1
1
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON, D.C. 20460
MAY 1 0 1989
OFFICE OF
THE INSPECTOR GENERAL
MEMORANDUM
SUBJECT: Audit of Superfund Interagency Agreements
with the U.S. Coast Guard - Fiscal 1987
- Audit Report M5BFL9-11-0038-9100275
FROM!
TO:
Kenneth D. Hockman
Divisional Inspector General for Audit
Internal Audit Division (A-109)
Harvey G. Pippen
Director, Grants Administration Division (PM-216F)
In response to section lll(k) of the Superfund Amendments
and Reauthorization Act of 1986, the Inspector General, Depart-
ment of Transportation conducted the subject audit. My office
recently received a copy of the report (see attachment 1), which
discusses inaccurate billings, unbilled and unsupported costs,
and potential duplicate billings. Attachment 2 is the Coast
Guard's response to the audit report. Attachment 3 is the DOT
Inspector General's analysis of the response. Prior audit
reports have discussed the lack of readily available documenta-
tion to support costs incurred by the Coast Guard.
We have reviewed the subject audit report, and are making
the following recommendations to EPA management.
RECOMMENDATIONS
We recommend that the Director, Grants Administration Division:
1. Not reimburse the Coast Guard for $236,385 of over-
billed personnel costs, an ineligible item under the
terms of the interagency agreements.
2. Not reimburse the Coast Guard, or adjust future
billings, for the $71,303 of unsupported costs.
-------
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 90 days of the audit repo
date. The Director, Grants Administration Division is the act
official for this report. For corrective actions planned,
reference to specific milestone dates will assist this office
closing this report.
Should your staff have any questions concerning this repo
please have them call John Walsh on 475-6753.
Attachments
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APPENDIX
DISTRIBUTION OF REPORT
Director, Office of Emergency and Remedial Response (OS-200)
Director, Office of Program Management (OS-240)
Director, Financial Management Division (PM-226)
Comptroller (PM-225)
Chief, Grants Information and Analysis Branch (PM-216F)
Agency Followup Official (PM-208)
Audit Followup Coordinator {PM-208)
Attn: Program Operations Support Staff
Agency Followup Official (PM-225)
Attn: Director, Resources Management Division
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ATTACHMENT 1
AUDIT OF SUPERFUND ACTIVITIES
FISCAL YEAR 1987
UNITED STATES COAST GUARD
REPORT NUMBER: AV-CG-8-042
DATE ISSUED: September 16, 1988
.D
'
CO
Cvl
Of.
ENVIRONME HWL PROTECTTOH AGENCY
WASHINGTON. D.C. 20460
-------
Memorandum
US. Deportment of
Off ice of me Secretory
of Transportation
Office o' msoector Genera:
ACTION: Report on Audit of
Su°'ecl Superfund Activities (Fiscal Year 1987)
United States Coast Guara
Report No. AV-CG-8-0*2
Raymond J. DeCarli _
Assistant Inspector General fo^ Auditing
: Chief of Staff, United States Coast Guard
zvt September 16, 1988
JA-20:366-4165
I. INTRODUCTION
This is our final report on the audit of the Hazardous Substance
Response Trust Fund (Superfund) Activities in the United States Coast
Guard. The audit was requested by the Environmental Protection Agency
(EPA). The objective of the audit was to determine the reason-
ableness, alienability, and allocability of costs incurred and claimed
by the Coast Guard in accordance with interagency agreements.
A. Background
The Comprehensive Environmental Response, Compensation, and
Liability Act of 1980, as amended, hereinafter referred to as
CERCLA, established authority and funding to respond to hazardous
substance releases into the environment. Section III(K) of the
Act requires the Inspector General of each Department having
duties under the Act to conduct an annual audit to assure that the
fund is being properly administered and that claims are being
appropriately and expeditiously considered. The President dele-
gated authority to the EPA and the Department of Transportation to
carry out the requirements of the Act. EPA has entered into
agreements with the Coast Guard to perform oversight and cleanup
duties for hazardous substance releases.
B. Scope of Audit
We reviewed 86 percent of the $3.4 million of expenditures
incurred during Fiscal Year (FY) 1987. In testing for supporting
documentation for Superfund expenditures at the Pacific Strike
Team, we limited our review to 55 percent of costs incurred
($423,763) due to time constraints. We reviewed all costs
incurred, however, in testing for all other attributes. He held
interviews and reviewed internal controls which related to
recognizing, recording, and billing CERCLA costs and assuring that
1
-------
applicable reimbursements were received. The audit was performed
at Coast Guard Headquarters, the Eighth and Eleventh Districts,
the Pacific Maintenance Logistics Command (MLC), and at the
Atlantic Area and Pacific Strike Teams. The audit was performed
in accordance with the "Standards for Audit of Governmental
Organizations, Programs, Activities, and Functions" as prescribed
by the Comptroller General and included such tests of policies,
procedures, records, reports, and other documents as considered
necessary in the circumstances.
C. Prior Audit Coverage
Our prior audit report (AV-CG-8-007, December 30, 1987) covered
Superfund expenditures of $7.4 million incurred during FYs 1984
through 1986. The report recommended that Coast Guard: (i) locate
and retain the required documentation for the unsupported costs,
(ii) implement procedures to retain documentation for all CERCLA
costs incurred, (iii) return the $12,500 to EPA or adjust future
billings for ineligible costs reimbursed to Coast Guard, (iv) bill
EPA for $581,213 of unbilled costs, and (v) establish and
implement procedures requiring the timely billing of all CERCLA
costs to EPA. During the current audit, the Coast Guard was In
the process of implementing corrective actions of the deficiencies
noted in our prior audit report concerning unbilled and
unsupported costs. Because of the short time period between the
two audits, we will review the actions taken by the Coast Guard at
a later date to determine its effectiveness in resolving the prior
audit findings as well as similar ones contained 1n this report.
II. FINDING AND RECOMMENDATIONS
Finding. Documenting and Recouping CERCLA Costs
Controls over CERCLA transactions during FY 1987 were generally
adequate to assure their reasonableness, allowability, and
al 1 ocability. We reviewed $2.9 million of the $3.4 million of
expenditures and identified personnel costs totaling $236,385 that
were billed to EPA although the Coast Guard had not filled the
positions. We also questioned costs of $1,182,669 (Exhibit A) that
were not billed to EPA and $71,303 that were unsupported. In
addition, the Coast Guard inadvertently recorded $93,372 (other than
personnel costs) in two different accounts. Unless the duplicate
entries are corrected, they may result in duplicate billings to EPA.
A. Overbllled Personnel Costs
The Coast Guard billed EPA and was reimbursed $236,385 for
personnel costs when the positions were not filled and the costs
not incurred. This resulted in over charges to the Superfund.
For the first quarter of FY 1987, EPA allocated 20 reimbursable
positions to the Coast Guard to perform CERCLA duties. In
February 1987, an additional 25 reimbursable positions were
-------
approved, although the positions were not filled until the fourth
quarter. The latter positions were billed to EPA from the date
approved rather than the dates they were actually filled. This
resulted in overbillings to the Superfund of $236,385. The
positions were filled on an average of 3 months during the entire
fiscal year instead of the 6 months billed to EPA. Details of the
correct reimbursement for the 25 additional positions and the
amounts actually billed and reimbursed are shown in Exhibit B to
this report. We discussed this condition with Coast Guard
officials who agreed to return the overbilled personnel costs to
EPA.
B. Unbilled Costs
As of March 28, 1988, the Coast Guard had not billed EPA for
$1,182,669 of CERCLA costs (Exhibit C). Personnel costs
constituted $559,746 of the unbilled amount. Such billings are
required by the Memorandum of Understanding (MOU) and the
Interagency Agreements (IAG) between the Coast Guard and EPA, as
as Part 4, Chapter 11 of the Coast Guard Comptroller Manual.
result, all expenditures applicable to Superfund transactions
not forwarded to EPA for reimbursement.
wel 1
As a
were
The MOU, lAGs,
for obtaining
reimbursed for
and the Comptroller Manual prescribe the process
reimbursement for all CERCLA costs. Funds
personnel costs are not generally retained by an
agency since such costs are already funded and paid from its own
appropriation. These costs and other CERCLA expenses should be
accurately recorded in accounting records and billed to EPA as
expenditures of the Superfund.
The issue of unbilled costs
officials during the audit.
unbilled CERCLA costs incurred
work is completed.
was discussed with Coast Guard
They agreed to bill EPA for all
as soon as their higher priority
The Coast Guard stated in their March 23, 1988 response to our
previous audit report (AV-CG-8-007) that they were in the process
of billing EPA for unbilled costs totaling $581,213. Considering
the significant increase in unbilled costs in this report
($1.2 million), we believe that the Coast Guard should place a
higher priority on billing EPA.
C. Unsupported Costs
Costs totaling $71,303 incurred for CERCLA response actions during
FY 1987 were not supported (Exhibit D) in accordance with the
documentation requirements of the MOU, lAGs, and the Comptroller
Manual. Without the required documentation, the validity of the
costs could not be verified.
The MOU, lAGs, and Comptroller Manual
current information on CERCLA funded
related costs. CERCLA authorizes EPA
establish a requirement for
response actions and their
to recover from responsible
3
-------
parties all Government costs incurred during a response action.
To ensure successful recovery of CERCLA funds by EPA, these
guidelines require the Coast Guard to maintain documentation for
all personnel and other costs incurred during CERCLA response
actions. This information and documentation must be available for
audit or verification by the EPA Inspector General.
The Coast Guard Districts, Pacific MLC, and Strike Teams we
visited during the audit did not always retain documentation in
their case files to support costs incurred for CERCLA activities.
In addition, payment schedules or unit voucher files that did
contain such documentation often were not referenced to the
applicable case files and therefore, could not be identified with
any particular response action. We found instances in which
payment and voucher files contained no documentation. By not
maintaining the documentation required to support CERCLA costs
incurred, the validity of the costs cannot be verified.
0. Potential Duplicate Billings
The Coast Guard charged $93,371 of Superfund costs both to lAGs
and to its Account OG-88.66.00, CERCLA Trust Fund. Since this
account and the lAGs are sources from which Superfund costs are
billed to EPA, the costs may be billed twice. See Exhibit E of
this report for specific cases and amounts.
At the time of our review, no IAG costs had been billed. When
advised of the potential for duplicate billings, Coast Guard
officials agreed to review all lAGs and identify those Superfund
costs that were also charged to Account OG-88.66.00, and assure
that they are not billed twice to EPA. In order to preclude
recurrence of this situation, the expenditures on the lAGs should
be annotated to show which costs had already been charged to EPA.
Recoimendations
We recommend that the Coast Guard:
1. Reimburse EPA or adjust future billings for the $236,385 of
overstated personnel costs.
2. Bill EPA for all unbilled costs and maintain such billings on a
current basis.
3. Locate and retain the required documentation for the unsupported
costs.
4. Implement procedures to retain documentation for all CERCLA costs
incurred. The documentation should be kept in the applicable
CERCLA case files. If it is maintained with payment schedules or
voucher case files, there should be appropriate cross-referencing
to facilitate retrieval of the documentation.
-------
5. Review all lAGs and identify those Superfund costs that were also
charged to Account OG-88.66.00 and assure that these costs are not
billed to EP4 twice. Future expenditures on lAGs should be
annotated to show costs previously charged to EPA.
Management Response
The Coast Guard was asked to provide written comments within 60 days
of the draft report which was issued May 13, 1988. Contacts with the
Coast Guard were made by memorandums on August 8 and September 13,
1988 and several telephone calls were also made to obtain the
response. Since the response has not been received, this final report
is issued without the Coast Guard's formal written response. However,
during the exit conference on March 28, 1988, Coast Guard officials
did concur with the findings and recommendations included in the draft
report, and indicated that the necessary corrective actions would be
taken,
III. ACTION REQUIRED
Please advise our office within 45 days concerning the specific
corrective actions taken or planned. The cooperation and assistance
provided by Coast Guard employees during the audit were greatly
appreciated.
Attachments
-I-
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EWIBIT
AUDIT OF SUPERFUTC
SIMWY OF COSTS' ftgVI&EP AW Ql£STICf€D
FISCAL YEAR I5B7
Costs Questioned
Coast Guard Ihit
Eighth Coast Guard
District
Eleventh Cost Guard
District
Atlantic Strike Team if
Atlantic Area Strike
Tean i/
Pacific Strike Team
Headquarters
TOTAL
Total Cost
Reviews
S 18,012.50
46,322.63
90,398.93
315,822.90
776,006.69
1,660,517.00
$2,907,080.65
Personnel
Costs
Overstated
-0-
-0-
-0-
-0-
-0-
236,385.00
$236,385.00
Lhsupported
S 5,844.73
12,546.09
15,122.48
1,222.11
36,167.54
400.00
$71,302.95
Uhbilled
$ 18,012.50
42,481.23
90,398.93
315,822.90
715,953.35
-0-
Sl,182,66a91 21
fbtentia
Dupl icati
Billing
-0
-0-
-0
$66,084.6^
27,286.9
-0-
$93,371.S
II The Atlantic Strike Team v*s disbanded in mid FY 1987; also at that time the Gulf Strike Team «s reorganized
~" renamed as the Atlantic Area Strike Team.
2J Includes $66,071.99 that MS ursupported.
-------
AUDIT OFSUPERRJFC
0\ERB ILLED
N-INCIDENT SPECIFIC
EWIBIT B
2 Pages
Coast Guam bhit
Marine Safety Office,
Honolulu
Marine Safety Office,
Honolulu
terine Safety Office,
Honolulu
Marine Safety Office,
Honolulu
terine Safety Office,
Honolulu
Safety Office,
H>nol ul u
few
Personnel
Positions
Lieutenant
Damage Control
1st Class
Boatswains tote
2nd Class
torine Science
Technician 2nd
techinery Tech.
3rd Class
techinery Tech.
3rd Class
Salaries Billed
to ERA
Apr. - Sept.
Anount
$ 20,400
13,000
11,000
11,000
11,000
9,000
Salaries that Should Have
Been Billed to EPA
Period
Anount
Sept. 1-Sept. 30 2,167
Sept. 1-Sept. 30 1,833
Sept. 1-Sept. 30 1,833
Total
Cvertilled
Ajg.-Sept. 30 S 6,800 $ 13,600
JUly-Sept. 30
4,500
10,833
9,167
9,167
11,000
4,500
^ferine Safety Office,
San Juan
Safety Office,
San Juan
Safety Office,
San Juan
Safety Office,
I San Juan
Lieutenant
ine Science
Tech. 1st Gass
^ferine Science
Tech. 2nd Gass
Oanage Controlman
2nj Class
20,400
July-Sept. 30
13,000 tey-Sept. 30
11,000 Aug.-Sept. 30
11,000
10,200
10,833
1,833
-0-
10,200
2,167
9,167
11,000
-------
DHIBIT 8
ALPITOFSUPRK)
OVERBILLED
FISCAL YEAR 1967
Coast Guard Unit
terine Safety Office,
San Juan
terine Safety Office,
San Juan
National Response
Center
itional Response
r
terine Environment
Response Fbllution
Salaries Billed
to EFK
Apr. - Sept.
Anoint
11,000
Positions
Damage Controlman
2nd Class
Marine Science
Tech. 3rd Class
Lieutenant Junior
Q-ade
terine Science Tech.
2nd Class 11,000
Salaries that Should teve
Been Billed to Ef*
Period
Jbly-Sept. 30
Anoint
-0-
12,833
Total (
0/erbilled
ll.OJO
9,000
16,300
Apr.-Sept. 30
July-Sept. 30
9,000
8,150
-0-
8,150
( 1,833)
Branch
District 1
District 2
District 5
District 7
District 8
District 9
District 11
District 13
District 14
H^rict 17
TOTAL
Lieutenant
Lieutenant Coimander
Lieutenant Comiander
Lieutenant Cormander
Lieutenant Caimander
Lieutenant Cormander
Lieutenant
Lieutenant Caimander
Lieutenant
Lieutenant
Lieutenant Carmander
20,400
24,400
24,400
24,400
24,400
24,400
20,400
24,400
20,400
20,400
24.400
$430,500
July-Sept. 30
July-Sept. 30
July-Sept. 30
June-Sept. 30
July-Sept. 30
Aug.-Sept. 30
Sept.-Sept. 30
ty-Sept. 30
July-tog. 30
Aug.-Sept. 30
July-Sept. 30
10,200
12,200
12,200
16,267
12,200
8,133
3,400
20,333
10,200
6,800
12.200
$194,115
10,200
12,200
12,200
8,133
12,200
16,267
17,000
4,067
10,200
13,600
12.200
$236,385
8
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3 page-.
Case File
Eighth Coast Guard District
Non-Incident Specific
Sdstotal
Eleventh Coast &jard District
ton-Incident Specific
Stbtotal
Atlantic Strike Team
Nan-Incident Specific
^05-87
R06-87
011-87
014-67
015-87
Subtotal
Atlantic Area Strike Team
Nan-Incident Specific
005-87
003-87
Stbtotal
Pacific Strike Team
Non-Incident Specific
6860-09-033
68-01-7334
AUDIT OF SUPERFUN3
Location
Sharon, PA
Elton, M3
Androscoggin River
Norfolk, VA
Shelter, CT
Hastings, TX
Jacksonville, AR
Rigel St. Site,
San Diego
Sites
SCHEDULE OF UNBILLED
FISCAL VEflR 196-
Total
«BMMtaW
S 18,012.50
18,012.50
42,481.23
42,481.23
7,672.28
21,821.47
22,435.39
iver 21,664.74
1,362.30
15,442.75
90,398.93
96,102.74
78,661.09
AR 141,059.07
315,822.90
22,051.12
9,246.49
ssnent
20,851.59
COSTS
7
Unbilled Costs
Salaries
S -0-
-0-
-0-
-0-
13,720.60
14,356.00
2,422.50
1,000.50
7,056.00
38,555.60
-0-
48,040.00
88,653.00
136,693.00
-0-
5,224.00
9,152.00
-
Other
S 18,012.50
18,012.50
42,481.23
42,481.23
7,672.28
8,100.87
8,079.39
19,242.24
361.80
8,386.75
51,843.33
96,102.74
30,621.09
52,405.07
179,129.90
22,051.12
4,022.49
11,699.59
Lhbllled Cb<.
Nat Supportt
S 5.844.
5,844.
66.
14,976.
35.
44.
15,122.
1,222.
1,222.
6,750.
-------
EWIBIT
AUDIT OF SUPERFUO
SO£DULE OF IfBILLH) COSTS
FISCAL YEAR 1987
Case File
tot Assigned
Nat Assigned
7334-09-004
66X31-7334
7334-10-001
86752
M85403
CW69932455-01-0
1
6860-10-018
6860-09-033
M85-403
6850-09-033
Project* N86225
Project! 78-01-6860
6860-09-030
Project* N862Z5
Project* 68-01-6860
Project* 6860-08-019
Location
Blackhaw Site
Westcnem Agr.
Warehouse Fire, f€
Monrovia, CA
California Creative
Dynamics
Pal lister Paint
Casper, Wyoning
Butte, Kxitana
Hixson ffetal
Finishing Site
Chechalis, MA
Anerican Crossami
Rigel St. Site
Wblterville, MT
Rigel St. Site
V^ffxlwtt, ND
Coolidge, AZ
E.G. fraener Site
WynJnere, ^C
Garden Valley
Asbestos Site
Canax Site, Denver, CO
Unbilled Cost
Uhbilled Costs Fbt Suwnrtor
Total
11,277.93
54,179.34
31,975.19
24,234.54
43,542.41
15,470.04
4,549.59
10,342.37
58,041.01
1,499.31
7,702.22
13,719.15
3,377.23
15,312.17
27,130.46
15,22138
8,052.48
3,489.50
Salaries
6,520.00
17,259.00
18,419.00
13,972.00
24,939.00
10,320.00
1,995.00
6,083.00
41,416.50
880.00
3,826.00
7,755.00
1,272.80
9,236.00
15,785.00
8,743.10
4,773.00
1,188.00
Other
4,757.93
36,920.34 1,142.,
13,556.19 3,643..'
10,262.54- 3,214.-
18,603.41 793.:
5,150.04
2,554.59
4,259.37
16,624.51
619.31
3,876.22
5,964.15
2,104.43
6,076.17
11,345.46 1,261.;
6,480.28
3,279.48
2,301.50
10
-------
ewer
AUDIT OF SUPERFUG
Case File
Project* PSFA08-C76
N854Q3
C86606
Project* 68-01-7334
Project* 68-01-7334
7334-08-006
68-01-7334
^334
-09-008
Project* 68-01-7334
Project! 68-01-7334
Project! 68-01-7334
QB7571
010
7334-09-007
68-01-7334
68-01-7334
Subtotal
TOTAL
SCHEDULE
OF UBIIIED Cudlb 1
FtSAL YEAR 1937 I
Location
South AJans Couuy
Water District
Nsntana Pole and Tie
Blackhawk Cyanide
Release Threat
Ccver D'Alene
Cresent City, CA
Poly-Carb, Wells, NV
Standard Steel -
Anchorage, AK
South Bay Asbestos
Site
Yuna, AriaDna Site 2
Spokane, MA
Caimerce City, CO
Rocky Mt. Custan
Oiron, DV
San Jbse, Drun
Site, CA
Aero Ojjal ity
Plating Site
Yuna, An ana Site 1
Lona Colorado
$1
Total
26,053.67
50,225.14
8,389.87
42,882.85
4,619.91
13,586.84
86,593.91
2,954.62
893.81
35,889.33
3,175.05
3,753.57
8,115.08
21,366.32
4,473.18
1.712.68
715,953.35
,182,668.91
IrtjiHed Costs
Salaries
14,963.00
32,017.00
4,015.00
23,353.00
2,608.00
8,332.00
39,618.50
2,079.00
808.00
18,633.00
1,831.50
1,725.00
5,286.50
17,886.00
2,137.00
396.00
334,496.90
$559,745.50
Uhbilled Go;
tot Support;
Other
j
11,090.67
18,208.14
4,374.87
19,529.85
2,011.91
5,204.84 1,229.
46,975.41 13,286.
875.62
85.81
17,256.33
1,34155
2,028.57
2,828.58
3,480.32 15.
2,336.18
1,316.68
331,456.45 31,336.'
$622,983.41 $66,0n.
11
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AUDIT OF' SUPERFUND
SCHEDULE OF UNSUPPORTED COSTS
EXHIBIT D
Case File
Eighth Coast Guard District
Non-Incident Specific
Eleventh Coast Guard District
Non-Incident Specific
Headquarters
Non-Incident Specific
Atlantic AreaStrike Team
Non-Incident Specific
Atlantic Strike Team
006-87
011-87
014-87
015-87
Subtotal
Pacific Strike Team
68-01-7334
Not Assigned
7334-09-004
68-01-7334
7334-10-001
6860-09-30
7334-09-006
68-01-7334
7334-09-007
Non-Incident Specific
Subtotal
TOTAL
Total
Unsupported Cost
$ 5.844.73
12.546.09
400.00
Location
1.222.11
66.74
14,976.24
35.50
44.00
15.122.48
6,750.79
1,142.29
3,643.87
3,214.43
793.25
1,261.20
1,229.20
13,286.55
15.00
4.830.96
36.167.54
$71,302.95
S8S333SS8
Elton, MO
Androscoggin River, Maine
Norfo'lk, VA
Shelton, CT
TTPI Haz. Assessment Site
Westchem
Monrovia, CA
Creative Dynamics
Pal lister Paint
Kraemer Site
Poly Carb. Wells, NV
Standard Steel, Alaska
Aero Quality Plating
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EXHIBIT E
AUDIT OF SUPERFUND
SCHEDULE OF POTENTIAL DUPLICATE BILLINGS
FISCAL
Case No.
Atlantic Area Strike Team
GCN005-87
GCN003-87
Subtotal
Pacific Strike Team
6860-09-033
08-01-7334
Not Assigned
7334-09-004
68-01-7334
7334-10-001
DW69932455-01-Q
6860-10-018
6860-09-033
6860-09-033
68-01-6860
6860-09-30
6860-08-019
C86606
68-01-7334
68-01-7334
7334-09-006
68-01-7334
7334-09-008
68-01-7334
68-01-7334
C87571
010
7334-09-007
68-01-7334
68-01-7334
Subtotal
TOTAL
Coast Guard Unit
Hastings RAO Site
VERTAC
Total I/
Site
Assessment Site
Rig el St
TTPI Haz
Westchem
Monrovia, CA
Creative Dynamics
Pallister Paint
Hixson Metal Plant
Chehalis, WA
Rigel St. Site
Rigel St. Site
Coolidge, AZ
Kraemer Site
Camax Site, Denver
Blackhawk Cyanide
Couer D'Alene
Cresent City, CA
Poly-Carb. Wells, NV
Standard Steel, AL
South Bay Asbestos
Yuma Arizona Site 2
Spokane, WA
Custom Chrome, Denver
San Jose, Drum Site
Aero Quality Plating
Yuma Arizona, Site 1
Loma, Colorado
S30.189.49
35.895.18
S66.084.67
757.30
3,161.30
978.16
2,170.00
1,253.43
1,331.80
554.82
813.75
106.80
1,431.75
444.09
2,057.00
335.91
791.94
3,322.02
98.24
959.90
2,491.12
155.40
25.81
719.90
324.96
668.78
1,916.73
176.78
239.22
27.286.91
$93,371.58
I/ Totals were charged to both the Interagency Agreements and Account
OG-88.66.00 CERCLA Trust Fund.
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ATTACHMENT 2
US. Deportment
of Transportation
United States
Coast Guard
Memorandum
REPORT ON AUDIT OF SUPERFUND ACTIVITIES
(FISCAL YEAR 1987) UNITED STATES COAST GUARD
REPORT NO. A7-CG-8-042
Commandant, U. S. Coast Guard
Dare
17 OCT
7000
to G-MER-RF
*»" o' A. R. THURING
TO Inspector General
Ref: (a) Report dated 9/16/33
1. We have reviewed the Audit Report and generally concur with its findings
and recommendations. As stated during the audit and noted in the audit
report, we have already taken steps to ensure that no duplicate billing of EPA
takes place for costs noted on both lAGs and the OG-88.66.00 account. We will
adjust future billings for the $236,385 you identified as overstated personnel
costs. Finally, we will endeavor within the scope of existing resources to
maintain billings on a current basis.
2. Superfund is a complex program, and the Coast Guard appreciates the
careful approach that your office has taken in these audits. A source of
continuing difficulty to CS units performing Superfund activity is the
extensive documentation associated with such actions, and the issue of who
keeps it. For the Coast Guard to be reimbursed, much of this documentation
must be sent to EPA Regional Offices, which, are not within the scope of your
audit. Nevertheless, we understand why you need to at least be able to verify
such original documentation to perform the audit. Is it possible that you
could develop through the EPA IG a way to track this inter-agency
documentation? If so, it would be of great assistance to the small CG field
units who will otherwise be required to prepare and maintain extensive
duplicate copies of documentation for future audits.
3. I would also like to correct a possible misperception on page 2 of your
report- In Section A, second paragraph, you state in part "...EPA allocated
20 reimbursable positions to the Coast Guard to perform CERCLA duties." This
is incorrect. EPA has never provided FTE or positions to the Coast Guard.
They provide the funding for such positions. It is the Coast Guard's
responsibility to provide such positions as are needed. The 20 were in fact
provided by Congress in FY85, and we are currently requesting the additional
25 through the budget process. If CERCLA/SUPERFUND support for these FTE ever
ends, they will still remain Coast Guard FTE.
•
A. BRUCE EERAN
Real Adnurcl, U.S. Coast Guaid
Chief of Staff
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ATTACHMENT 3
UJLOtportimntof
Memorandum
Office or the Secmory
of nonspooonon
Office of Inspector General
INFORMATION; Report on Audit of Superfund
Activities Fiscal Year 1987, U.S. Coast Guard oaie: Wfiy ?3 iop;-
Report Number AV-CG-8-042 V c J wso
Wilbur L. Daniels, Director AtiK JA-20:366-4165
Office of Aviation, Marine, and Research Programs
Chief of Staff, United States Coast Guard
We reviewed your October 17, 1988 response to the subject audit report in
which you generally concurred with the findings and recommendations. The
actions you have promised/taken on the recommendations are generally
responsive to the report. However, you suggested that our office, with
the assistance of the EPA-OIG, develop a tracking system for interagency
documentation. We believe that this action is unnecessary since responsi-
bility to maintain such documentation is assigned to the U.S. Coast Guard
by both the Interagency Agreements between the Coast Guard and EPA and
Section IV-6-B of the Coast Guard's Comptroller's Manual. The Coast Guard
should immediately implement procedures to ensure that records and documen-
tation required to support Superfund costs incurred are retained in
accordance with these requirements.
We will follow-up on the implementation of the actions promised/taken to
implement the audit recommendations during our upcoming audit of Fiscal
Year 1988 Superfund costs. This will include implementation of the
requirement for retaining documentation for all Superfund expenditures. In
accordance with DOT Order 8000.IB, the audit report is considered closed
and no further response is required.
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