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     |     UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
    S?                 WASHINGTON. D.C. 20460
                            OCT
                                                        OFFICE Of
                                                    THE INSPECTOR GENERAL
MEMORANDUM

SUBJECT




FROM:




TO:
          Audit of  Superfund  Interagency Agreements with the
          Department of  Energy -  Fiscal  1988
          Audit Report No.  M5BFLO-11-0016-0100027
          Kenneth D. Hockman
          Divisional Inspector General  for Audit
          Internal Audit  Division  (A-109)

          Harvey G. Pippen
          Director, Grants  Administration  Division (PM-216F)
     The Office of  Inspector General,  Department of Energy
prepared the subject  report  which is required by section lll(k)
of the Superfund Amendments  and  Reauthorization Act of 1986.
We are not making any recommendations  to you and are closing this
report upon issuance.  However,  the Grants  Administration
Division may want to  emphasize to the  Department of Energy that
indirect costs can  be applied to Superfund  interagency agreements
only if a rational, defensible allocation plan is being imple-
mented.  General or Agency-wide  indirect costs are not allowable
unless specifically authorized by legislation.

     Should your staff have  any  questions concerning this report,
please have them call John Walsh on 475-6753.
cc:  Mr. Broadwell,  Department of  Energy
                                           HEADQUARTERS »!RRARY
                                           ENVIRONMENT
                                           WASHIMn.,.-
                                                              AGENCY

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

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                          Department of Energy
                             Washington, DC 20585
                            September 26, 1989
Mr, Ernest E. Bradley, III
Assistant Inspector General for Audits
Office of Inspector General (A-109)
Environmental Protection Agency
401 M Street, S.W.
Washington, D.C.  20460

Dear Mr. Bradley:

We conducted an audit of the Fiscal Year (FY)  1988 Superfund costs  incurred
by the Department of Energy (DOE) on interagency agreements.   The
Environmental Protection Agency (EPA) entered  into the agreements with
various DOE field offices for the performance  of specific services.   The
agreements were assigned to DOE contractors for actual performance.   After
reviewing the contractors' invoices for work performed,  the  appropriate DOE
field offices obtained reimbursement from EPA.

The purpose of the audit was to determine the  reasonableness,  allowability,
and allocability of costs incurred under the agreements  for  the period
October 1, 1987, through September 30, 1988.

The scope of the audit was limited to evaluating the accounting records and
other documentation supporting costs incurred  for 19 agreements with
claimed costs of $3,777,364 of which $3,763,917 was acceptable and  $13,447
was unallowable.  Details are in the enclosed  reports.  Please note that
these reports may contain proprietary information.

Our audit was performed in accordance with generally accepted government
auditing standards and included such tests of  the contractors'  data and
records and such other auditing procedures as  were considered necessary.
The Federal Acquisition Regulations, as supplemented by the  Department of
Energy Acquisition Regulations, were used as criteria in the evaluation of
the claimed costs.

As reported 1n our FY 1987 letter, we continued to find that some older
interagency agreements included both Superfund work and non-superfund work
in the same agreement.  As a result, DOE is not always maintaining  separate
records on the specific use of the Superfund funds.  This situation appears
to have been corrected on interagency agreements issued in FY 1988.


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                                    -2-
If you wish additional details on the audit, or have questions about
release of the enclosed reports, please contact David Broadwell, Assistant
Manager, Capital Regional Office, at 586-8944.
                                        Sincerely,
                                           Son W. Harvey
                                       'Assistant Inspector General
                                          for Audits
                                        Office of Inspector General
2 Enclosures

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REPORT No.:  WR-CC-89-33
                    U.S. DEPARTMENT OF ENERGY
                   OFFICE OF INSPECTOR GENERAL
                         OFFICE OF AUDITS
                          WESTERN REGION
                  ALBUQUERQUE, NEW MEXICO 87115
                  Audit of Costs Incurred on EPA

                 Superfund Interagency Agreements

                With the U.S. Department of Energy

                  Grand Junction Projects Office

           October I/ 1987, through September 30, 1988

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   REPORT No.:  WR-CC-89-33
                     AUDIT OF COSTS INCURRED ON EPA
                    SUPERFUND INTERAGENCY AGREEMENTS
                   WITH THE U.S. DEPARTMENT OF ENERGY
                     GRAND JUNCTION PROJECTS OFFICE
              OCTOBER 1, 1987, THROUGH SEPTEMBER 30, 1988
                           TABLE OF CONTENTS
                                                       Page
Purpose and Scope	

Circumstances Affecting the Audit

Results of Audit   	 .
                                                1

                                                3

                                                3
Exhibit A

Schedule A-l


Exhibit B


Exhibit C


Exhibit D


Exhibit E


Exhibit F


Exhibit G


Exhibit H
Amounts Obligated and Costs Claimed  	  4

Reconciliation of EPA Disbursements to
Costs Claimed	5

Summary of Claimed Costs and Audit Results
EPA Interagency Agreements 	  6

Statement of Claimed Costs and Audit Results
EPA Interagency Agreement No. DW8993245101 . .  7

Statement of Claimed Costs and Audit Results
EPA Interagency Agreement No. DW8993273601 . .  8

Statement of Claimed Costs and Audit Results
EPA Interagency Agreement No. DW8993290801 . .  9

Statement of Claimed Costs and Audit Results
EPA Interagency Agreement No. DW8993290901 . . 10

Statement of Claimed Costs and Audit Results
EPA Interagency Agreement No. DW8993291001 . . 11

Statement of Claimed Costs and Audit Results
EPA Interagency Agreement No. DW8993291401 . . 12

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                    U.S.  DEPARTMENT OF ENERGY
                   OFFICE OF  INSPECTOR GENERAL
                          OFFICE OF AUDITS
                          WESTERN REGION
                  ALBUQUERQUE, NEW MEXICO 87115

 AUDIT OF COSTS INCURRED  ON EPA SUPERFUND INTERAGENCY AGREEMENTS
   WITH THE DEPARTMENT OF ENERGY GRAND JUNCTION PROJECTS OFFICE
            OCTOBER 1, 1987,  THROUGH SEPTEMBER 30, 1988


REPORT NO:  WR-CC-89-33

PURPOSE AND SCOPE

     As  requested by the Department  of Energy (DOE),  Office of

Inspector  General (OIG),  Capital Region,   we have completed an

audit  of costs claimed under six Environmental Protection Agency

(EPA) Superfund Interagency Agreements.  The agreements cover the

period March 30,  1987 through December 31, 1990, and provide for

DOE  to do remedial  design and action  at properties included in

operable units of the Denver Radium Superfund Site.



     Section  III of the  Superfund Amendments and Reauthorization

Act  of 1986  requires annual  audits of  payments,  obligations,

reimbursements,    and    other   uses   of   the   EPA  Superfund

appropriations   to  assure  that  the  fund  is  being  properly

administered.  The  DOE   is  authorized to  use  Superfund monies

through a series of interagency agreements with EPA.



     Work  on  the interagency  agreements  was performed  by UNC

Geotech  (formerly UNC Technical Services,  Inc.)   under Contract

No.   DE-AC07-86ID12584 with the  Grand Junction Projects Office.

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UNC  Geotech is  a DOE  integrated contractor  at Grand Junction,
Colorado.

     The  purpose of the audit  was to determine the allowability
of  costs  allocated  to the  Superfund  obligation  within these
agreements  and claimed for the period October 1,  1987,  through
September 30,  1988.  Allowable costs are those which are reason-
able,   allocable,  and according to the terms of the interagency
agreements, applicable cost principles, laws and regulations, and
generally    accepted   accounting   principles   and   practices
appropriate to the circumstances.

     The  audit  scope was  limited  to reviewing  the accounting
books and records and other documents supporting the contractor's
claimed  costs.  Specific  transactions  were  tested,   but  the
contractor's total internal control system and technical perform-
ance were not evaluated.

     As  defined in the  above scope,  we  followed the generally
accepted  government auditing standards that applied and included
tests  of  the  contractor's  data and  records  and  other audit
procedures   considered  necessary   in  the  circumstances.  The
Federal Acquisition Regulation (FAR),  DOE Acquisition Regulation
(DEAR),    and  the  terms  and  conditions  of  the  interagency
agreements were used as criteria to evaluate incurred costs.

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CIRCUMSTANCES  AFFECTING THE  AUDIT
               «
     The    contract  between DOE  and  the  contractor  required
negotiation of annual  indirect cost rates.  Negotiated rates were
not available  for  fiscal year 1988 because the contractor had not
prepared    a  final  overhead   rate  submission.  However,   the
contractor  did adjust  claimed costs to actual as of September 30,
1988   (fiscal  year end).   Costs claimed may  need to be adjusted
when   the   indirect  expense  rates  for  fiscal  year  1988  are
negotiated.

AUDIT  RESULTS
     The audit disclosed no questioned, unsupported or unresolved
costs.  However,   DOE did  not claim  the added  factor cost for
administration and depreciation as required in DOE Order 2110.1A.
Applying this  Order would have led to an additional cost recovery
of   $449,234  for  administration   in  fiscal  year  1988.  The
additional   cost  recovery  for depreciation  was  not determined
because  a depreciation factor  had not been  established for the
Grand  Junction Projects Office.   The audit results,   detailed in
the Exhibits,  were discussed with representatives of UNC Geotech
and the Grand  Junction Projects Office,  who agreed with the data
presented.
                                  ADC, LTD.
                                  ACCEPTED BYt
                                  ^^V
                                3

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REPORT No.:  WR-CC-89-33                                      EXHIBIT A
                        GRAND JUNCTION PROJECTS OFFICE
                           GRAND JUNCTION, COLORADO

                          EPA Interagency Agreements
                      Amounts Obligated and Costs Claimed
                               Fiscal Year 1988


Agreement           Amounts Obligated           	Costs Claimed	
 Number         PriorFY1988     Total       Prior     FY1988     Total
                                    Note 1                Note 2

DW8993245101  $349,000 $2,625,000  $2,974,000  $166,786 $1,554,059  $1,720,845


DW8993273601    76,015  1,630,985   1,707,000     4,957    457,249     462,206


DW8993290801     -0-      431,000     431,000      -0-     133,094     133,094


DW8993290901     -0-      301,000     301,000      -0-      50,592      50,59:


  8993291001     -0-      578,300     578,300      -0-     240,224     240,224


DW8993291401     -0-      436,000     436,000      -0-     207,334     207,334

Notes:

     1.   These amounts represent  total obligations under interagency
agreements  through fiscal year 1988.  A  difference of $300 was noted
between  the amount obligated under  agreement number DW8993291001 and
EPA records.

     Interagency Agreement          $578,300
     EPA Records                     578,000

     Difference                      $   300


     2.  See  Schedule A-l for reconciliation  of EPA disbursements to
costs claimed.

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REPORT No.:  WR-CC-89-33
SCHEDULE A-l
                      GRAND JUNCTION PROJECTS OFFICE
                         GRAND JUNCTION, COLORADO

            Reconciliation of EPA Disbursements to Cost Claimed
                        EPA Interagency Agreements
                             Fiscal Year 1988
                            Audit   Adjustments
Agreement EPA
Number Disbursements
DW8993245101
DW8993273601
DW8993290801
DW8993290901
DW8993291001
t
^8993291401
$1,354,171
315,092
102,452
41,888
215,789
183,392
Sept. 1987 Sept. 1988
Billing Billing
Note l Note l
$(74,179) $274,068
(4,957) 147,114
24,146
5,435
24,440
23,941
Claimed
Other Costs
Note 2
$ (1) $1,55
45
6,496 13
3,269 5
(5) 24
1 20
                                                                       50,592
Note;

     1.  EPA  disbursement  records  included  timing  differences.  A
one-month  lag  of posting  billed amounts  created a  year-end cutoff
difference.  September  1987  billings were  subtracted  and September
1988  billings added  to the recorded  EPA disbursements  to arrive at
fiscal year 1988 cost claimed.

     2.  These amounts represented rounding and recording differences.
On  agreement  DW8993290801,   the  $6,496 was  an  amount  billed and
collected  from EPA,   but not  shown on  EPA's records.  On agreement
DW8993290901,   the  $3,269  was an  amount  billed by  DOE,   but not
collected from EPA.

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REPORT NO.:  WR-CC-89-33                                        EXHIBIT


                    GRAND JUNCTION PROJECTS OFFICE
                       GRAND JUNCTION, COLORADO

              Summary of Claimed Costs and Audit Results
                      EPA Interagency Agreements
                           Fiscal Year 1988

                                    	Audit Results
                      Claimed       QuestionedUnresolved
                       Costs          Costs         Costs
Direct Labor          $525,025
Overhead               348,228
Common Support         233,661
Material                63,879
Purchased Services     124,069
Subcontracts           700,250
Other Direct           196,195

Subtotal            $2,191,307
General and Admin-
 istrative Expense     451,245

Total Costs         $2,642,552         - 0 -        - 0 -
                    xmmmmmmmmm         *nmm*        s*==z

Note:

     DOE Order 2110.1A, Pricing of Departmental Material and Services,
dated July 14,  1988, established DOE policy for pricing materials and
services provided to non-DOE organizations, either directly or through
operating  contractors.  The  Order  required  charging  other Federal
agencies the Department's full cost when the other agency passes costs
to  organizations  outside  the Federal  Government.  Full  cost would
include   the  integrated  contractor's  cost  and  fee,   plus  DOE's
depreciation and administration cost.

     The Superfund Act authorized enforcement action and cost recovery
from  those responsible for a hazardous waste problem,  based upon the
principle that "the polluter should pay."  These recoveries,  plus tax
revenues, were  the  main source  of funds  for cleaning  up hazardous
waste  sites.  Recoveries could play a  major role in replenishing the
Superfund.

     The costs billed to EPA in fiscal year 1988 did not include DOE's
administrative  and depreciation costs.  The costs were understated by
$449,234  ($2,642,552 X 17%) for administration.  The understated costs
for  depreciation were not determined  because Idaho Operations Office
had  not  established a  depreciation  factor for  the  Grand Junction
Projects Office.

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REPORT No.:  WR-CC-89-33
                                                                 EXHIBI'
                     GRAND  JUNCTION  PROJECTS OFFICE
                        GRAND  JUNCTION, COLORADO

             Statement  of  Claimed Costs and Audit Results
            '  EPA  Interagency Agreement No. DW8993245101
                            Fiscal Year 1988
                      Claimed
                       Costs
                                         Audit Results
                Questioned
                  Costs
          Unresolved
             Costs
Direct Labor

Overhead

Common Support

Material

Purchased Services

Subcontracts

Other Direct

Subtotal

General & Admin-
  istrative Expense

Total Costs "  "
  $231,367

   165,823

    98,867

    20,673

    49,698

   651,011

    71,355

$1,288,794


   265,265

$1,554,059
- 0 -
- 0 -

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REPORT No.:  WR-CC-89-33
                                                                EXHIBIT
                    GRAND JUNCTION PROJECTS OFFICE
                       GRAND JUNCTION, COLORADO
             Statement of Claimed Costs and Audit Results
            '  EPA Interagency Agreement No. DW8993273601
                           Fiscal Year 1988
                      Claimed
                       Costs
                                         Audit Results
              Questioned
                Costs
          Unresolved
             Costs
Direct Labor
Overhead
Common Support
Material
Purchased Services
Subcontracts
Other Direct
Subtotal
General & Admin-
  istrative Expense
Total Costs
 121,418
  74,885
  53,828
  20,722
  14,736
  49,239
  44,186
$379,014

  78,235
$457,249
- 0 -
- 0 -

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REPORT No.:  WR-CC-89-33
                    GRAND JUNCTION PROJECTS OFFICE
                       GRAND JUNCTION, COLORADO

             Statement of Claimed Costs and Audit Results
            '  EPA Interagency Agreement No. DW8993290801
                           Fiscal Year 1988
                                                                EXHIBIT
                      Claimed
                       Costs
                                         Audit Results
Questioned
  Costs
Unresolved
   Costs
Direct Labor          $ 34,303

Overhead                20,155

Common Support          15,793

Material    »             5,115

Purchased Services       8,719

Subcontracts              —

Other Direct            26,292

Subtotal              $110,377

General & Admin-
  istrative Expense     22,717

Total Costs           $133,094
   - 0 -
   - 0 -

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REPORT No.:  WR-CC-89-33
                    GRAND JUNCTION PROJECTS OFFICE
                       GRAND JUNCTION, COLORADO

             Statement of Claimed Costs and Audit Results
              EPA Interagency Agreement No. DW8993290901
                           Fiscal Year 1988
                            EXHIBIT
                      Claimed
                       Costs
                                         Audit Results
Questionea
  Costs
Unresolved
   Costs
Direct Labor          $ 14,994

Overhead                 9,852

Common Support           7,205

Material                   161

Purchased Services       7,468

Subcontracts              —

Other Direct             2,277

Subtotal              $ 41,957

General & Admin-
  istrative Expense      8,635

Total Costs           $ 50,592
   - 0 -
   - 0 -
                                10

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 REPORT  No.:   WR-CC-89-33
                                          EXHIBIT
                     GRAND JUNCTION PROJECTS OFFICE
                        GRAND JUNCTION,  COLORADO

             Statement  of  Claimed  Costs and Audit Results
              EPA  Interagency Agreement No. DW8993291001
                           Fiscal  Year 1988
                      Claimed
                       Costs
                                         Audit Results
              Questioned
                Costs
          Unresolved
             Costs
Direct Labor

Overhead

Common Support

Material

Purchased Services

Subcontracts

Other Direct

Subtotal

General & Admin-
  istrative Expense

Total Costs
$ 64,824

  40,700

  30,602

   5,254

  22,900



  34,942

$199,222


  41,002

$240,224
- 0 -
- 0 -
                                11

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REPORT No.:  WR-CC-89-33
                    GRAND JUNCTION PROJECTS OFFICE
                       GRAND JUNCTION, COLORADO

             Statement of Claimed Costs and Audit Results
             1 EPA Interagency Agreement No. DW8993291401
                           Fiscal Year 1988
                            EXHIBIT
                      Claimed
                       Costs
                                         Audit Results
Questioned
  Costs
Unresolved
   Costs
Direct Labor          $ 58,119

Overhead                36,813

Common Support          27,366

Material                11,954

Purchased Services      20,548

Subcontracts              —

Other Direct            17,143

Subtotal              $171,943

General & Admin-
  istrative Expense     35,391

Total Costs           $207,334
   - 0 -
   - 0 -
                                12

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REPORT NUMBER: ER-C-89-06
                    U.S. DEPARTMENT OF ENERGY
                   OFFICE OF INSPECTOR GENERAL
                         OFFICE OF AUDITS
                     EASTERN REGIONAL OFFICE
                   Oak Ridge, Tennessee  37830
                  Interim Audit of Costs Claimed

                by the Oak Ridge Operations Office

              Under Selected Interagency Agreements

             With the Environmental Protection Agency

                      for Work Performed by

               Martin Marietta Energy Systems, Inc.

              October 1, 1987, to September 30, 1988
Contractor  information   contained  in  this  audit report  may be
confidential.  The   restrictions   of  18   USC  1905  should  be
considered before this information  is released to the public.

This  report may not be  released to anyone outside the Department
of  Energy without the approval of  Headquarters Office.of Audits,
except  to an Agency involved in negotiating or administering the
contract.  Furthermore,   the  information contained in this report
should not be used for purposes other than those intended without
prior consultation  with the Department  of Energy's   Office of
Inspector General regarding its applicability.


                                       Date: July 19, 1989

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REPORT NUMBER: ER-C-89-06
                  INTERIM AUDIT OF COSTS CLAIMED
                BY THE OAK RIDGE OPERATIONS OFFICE
              UNDER SELECTED INTERAGENCY AGREEMENTS
             WITH THE ENVIRONMENTAL PROTECTION AGENCY
                      FOR WORK PERFORMED BY
               MARTIN MARIETTA ENERGY SYSTEMS, INC.
              OCTOBER 1, 1987, TO SEPTEMBER 30, 1988
                        TABLE OF CONTENTS
Purpose and Scope  ................................... '. ....... 1

Circumstances Affecting the Audit  ........................... 2

Audit Results ............................................... 3

Statement of the Department of Energy's costs
  Claimed and Audit Results Fiscal Year 1988 -
  Exhibit A .................................................. 6

Statement of Amounts  Obligated and
  Costs Claimed Fiscal Year 1988 - Exhibit  B ................. 8

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                    U.S. DEPARTMENT OF ENERGY
                   OFFICE OF INSPECTOR GENERAL
                         OFFICE OF AUDITS
                    Oak Ridge, Tennessee 37830
                  INTERIM AUDIT OF COSTS CLAIMED
                BY THE OAK RIDGE OPERATIONS OFFICE
              UNDER SELECTED INTERAGENCY AGREEMENTS
             WITH THE ENVIRONMENTAL PROTECTION AGENCY
                      FOR WORK PERFORMED BY
               MARTIN MARIETTA ENERGY SYSTEMS, INC.
              OCTOBER 1, 1987, TO SEPTEMBER 30, 1988


REPORT NO. ER-C-89-06                                  July 19, 1989


PCTRPOSE AND SCOPE

     As  required by the Superfund Amendments and Reauthorization
Act of 1986, we have performed an interim audit of costs incurred
under   13  interagency  agreements  between  the  Department  of
Energy's  (DOE)   Oak  Ridge  Operations  Office   (ORO)   and the
Environmental  Protection  Agency (EPA).  Martin  Marietta Energy
Systems   (Energy Systems)   performs the work  requested in these
agreements   under  the  existing  contract  with  ORO.   The  13
interagency agreements and related work descriptions are:


Agreement                         Description

DW890341     Assistance in genetic toxicology and carcinogenicity
             studies.

DW890793     Technical   assistance   in   implementing   a   new
             analytical methodology for health risk assessments.

DW891215     Development  of  a hazardous waste control technology
             data base.

DW891258     Development of methods to interpret metabolism data.

DW891475     Information   support  to  EPA's   Office   of  Waste
             Programs Enforcement.

DW892002     Establishment  of   holding  times  for environmental
             samples.

DW892147     Perform risk assessments of toxic substances.

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Agreement                         Description

DW892633     Modeling   support  for   the  EPA's   Reduction  of
             Uncertainties in Risk Assessments project.

DW392701     Evaluation  of  toxic  effects  and  development  of
             methods   for  risk   assessments  of  environmental
             pollutants.

DW893015     Development of potential carcinogenicity profiles.

DW893082     Research assistance for remedial action decisions at
             superfund sites.

DW893252     Assistance in superfund local cost sharing.

DW893278     Development of a prototype telemetry locator system.
      The  purpose  of the audit was to determine the allowability
of  costs  incurred  under these interagency agreements and claimed
for the   period  October   1,   1987,   to  September  30,  1988.
Allowable   costs   are   costs  incurred   that  are  reasonable,
allocable, and  in accordance with the terms and conditions of the
interagency   agreements,  applicable  cost principles,   laws and
regulations,    and  generally  accepted accounting  principles and
practices  appropriate to the particular circumstances.

      The  audit scope  was limited  to reviewing  the accounting
records   and  other documentation  supporting  Energy  System's
claimed   costs.  Specific  transactions  were  tested.  However,
Energy  System's entire cost control system and technical aspects
of  Energy  System's  performance were not evaluated.

      As   defined in the above  scope,   the  audit was conducted
according  to the   sections of the  generally accepted Government
auditing   standards that   applied  and   included  tests  of  the
contractor's    data and  records   and   other  audit  procedures
considered   necessary  under  the  circumstances.  The  contract
between ORO  and Energy Systems, the DOE  Acquisition Regulations,
and  the terms  and  conditions  of the  interagency  agreements were
used as criteria to evaluate costs.




       We   did not   perform technical   reviews of   the  interagency
 agreements.   Accordingly,   our  recommendations for acceptance  of
 costs  are qualified pending  the  contracting officer's technical
 review of Energy System's performance.

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    On  five of the agreements  audited,  superfund costs claimed
did   not  represent  actual   superfund  costs  incurred.  These
agreements  contained superfund obligations as  veil as other EPA
program obligations.   EPA did not require separate accounting or
billing  of  superfund  costs.  Thus,   costs  incurred  for  the
superfund  portion of two of  these agreements were not accounted
for  separately.  For  three other  agreements,   superfund costs
were separately accounted but not billed to the EPA by individual
program obligations.

     On  September 22,  1988,  ORO  formally requested the Grants
Administration  Division  to segregate  the superfund  portion of
these    agreements   from   other   EPA   program   obligations.
Henceforth,   ORO agreed to account  for and bill superfund costs
separately.


AUDIT RESULTS

      The audit results showing Energy System's costs claimed are
detailed in exhibit A and are summarized below:

           Costs Claimed             $1,134,812


           Costs Unallowed              $13,447
      In  our opinion,   except for the  instances of unallowable
costs   described   in  the   notes  to   exhibit  A,    and  the
effects,    if any,  of the internal control weakness disclosed in
"Other  Matters to be Reported," Energy Systems complied with the
terms   and  conditions  of   the  interagency   agreements  for
transactions tested.  Nothing came to our attention in connection
with  our   examination  that  would cause  us  to  believe Energy
Systems  was not in  compliance with any  terms and provisions of
laws and regulations pertaining to the interagency agreements for
transactions not tested.

      As  a result of not accumulating superfund costs separately
as  explained under "Circumstances Affecting the Audit," agreement
numbers  DW890793 and  DW891215 reflect total  costs incurred and
billed  for the  entire  agreement  rather  than  the  superfund
portions.

      Similarly,   for three  other agreements,.   although Energy
Systems accounted for superfund costs separately,  the costs were
billed  for the total  interagency agreement  (as required) rather

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than  the  individual   program obligations.  The  following  is a
comparison  of the   actual  superfund  costs incurred  and related
billings to the EPA:
AGREEMENT

 NUMBER         COSTS  1HCUMED                     COSTS  •ILLEO	

          SUPE^PUHO   OTHER     TOTAL       SUPESEUMO    OTHEft     TOTAL


OWS92002   S274.227   S 56,853  S  331,060      S32B.830  S 2,250 $  331,080

OV892147    535,307    US,103     683,410       574,660   108,750    683,410

OWS93015     63,630    11,191      74.821       56,708    18,113     74.821


  TOTAL                      *1,089,311                      11,089,311
For all other agreements audited,   superfund costs were accounted
for and billed separately.

     The   audit   results  were  discussed  with  Ms.   Christine
Travaglini   and Mr.   John  Hickey of Energy  System's Finance and
Materials  Department on July 5,    1989.  They concurred with the
amount of costs unallowed and stated that corrective actions were
taken on June 27,  1989.
OTHER MATTERS TO BE REPORTED

      In   planning and performing  our audit,   we considered the
internal   control structure  in order  to determine  our auditing
procedures for  the purpose of expressing our opinion, but not for
providing  assurance  on  the  internal  control structure.   The
significant  internal  accounting  controls  that  Energy Systems
should    maintain  to  administer  these  interagency  agreements
include controls to ensure that:

      o     Direct  costs  are  adequately  documented,  equitably
            allocated, and properly accounted for,

      o     Indirect costs are properly applied,

      o     Allowable   and   unallowable   costs   are  routinely
            identified  and segregated  in the  accounting system,
            and

      o     Assets  are safeguarded  against loss  or unauthorized
            use.

      We   noted no conditions,  except for those described  in the
 following paragraph, involving the internal control structure and
 its  operation   that   we   consider   reportable   under  the
 auditing  standards.  Reportable conditions involve matters  coming

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to  our  attention relating  to  significant deficiencies  in the
design  or operation of the  internal control structure that,  in
our   judgement,   could  adversely   affect  the  organization's
ability to record, process, summarize, report, and bill financial
data consistent with the interagency agreements.

     An  Energy System's internal audit  report dated January 22,
1988,  disclosed several weaknesses in internal time distribution
practices,   including  the  allocation  of  employee compensated
absences  to final cost objectives during  the month in which the
absences  occur.  Cost  accounting standards  require  that these
absences  be  allocated  during the  period  when earned.  Energy
System's management concurred with findings in the internal audit
report and implemented corrective actions on October 1, 1988.
                                  xc*-  d c&rvM*taJfo*>

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REPORT NUMBER: ER-C-89-06                                 Exhibit A
NOTES TO SCHEDULE A                                   Page 2 of 2
1.    Represents total costs incurred under this agreement.

2.    Unallowed costs of $13,447 were as follows:

      a.   Subcontract  costs of $12,905 were accrued and charged
           to this agreement.  These costs exceeded the amount of
           the  subcontract and  were not paid,   but the accrued
           costs were never reversed.

      b.   Overhead  costs  of  $542 were  applied  to  the above
           costs.  This  overhead  was  the  off-site subcontract
           surcharge  of  3.7  percent  and  the  work-for-others
           office charge of 0.5 percent.

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REPORT MUHitt:  ER-C-89-06
EXHIBIT B
                                          EPA INTERAGENCY AGREEMENTS
                               STATEMENT OF AMOUNTS OBLIGATED AND COSTS  INCURRED
                                               FISCAL TEAR 1988
AGREEMENT
NUMBER
BUS90341
OU890773
OU89121S
DU891258
OU891475
OU892002
OU892147
&U892633
DU892701
W893015
OU893082
OW893232
OU893278
TOTAL
SUPERFUNO
OBLIGATIONS
STARTING DURING
BALANCE FT 1988
1*0,000 S
94,000
130.079
70,000
19,980 (271)
450,000
315.000 345,650
155,000
400,000
95,713
60,000
. . 110.000
50,000
S918.980 11.416,171
COSTS INCURRED BY DOE
TOTAL
AVAILABLE
S40.000
94,000
130,079
70,000
19,709
450,000
660,650
155,000
400,000
95,713
60,000
110,000
50,000
S2.335.151
PRIOR
TEARS FT 1988
S8.152 S18.214
39,205 48,194
112.211

19,709
107,226 274,227
128,778 535,307

34,254
63,630
48,775


1303,070 SI, 134,812
TOTAL MOTES
$26,366
87,399 1
112.211 2

19.709
381,453
664,085

34,254
63,630
48,775


SI, 437,882
 Net* 1:  Rapraaonta total obligation* and total  eaata  Incurred undar this agraoaant.
          Tha ««)arfu«d portion of thla obligation ia 119,000.

 Nota 2:  lapraaanta total obllgatlona and total  eaata  Incurrad wdar
          thU acraoaant.  Tha aucwrfuid portion of this obligation ia
          S90.000.  Of ttw S112.211 of eaata Incurrad,  only S95.462 ttaa
          all lad to tfta EM during Flaeal Taar 1988 dua to an overnight.
          Tha raMlning S16.749 MOO billad in Juia 1989 aa a  raault of
          our audit.
                                                        8

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