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- ------- |