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

-------
                                                  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

-------
                                                      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-

-------
                                                                                                    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

-------
                                                                                                               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

-------
                                  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
                                           12

-------
                                                                       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.
                                        13

-------
                                                                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

-------
                                                     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.

                                 -I-

-------