00
ENVIRONMENTAL PROTECTION AGENCY
COOPERATIVE AGREEMENT
REPORT OF INTERIM AUDIT
OF
NEW YORK STATE DEPARTMENT OF ENVIRONMENTAL CONSERVATION
MULTI-SITE COOPERATIVE AGREEMENT NUMBER V002437-84
(FULTON TERMINALS, CLOTHIER AND VOLNEY LANDFILL SITES)
FOR THE PERIOD DECEMBER 31, 1984 TO MARCH 31, 1989
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NEW YORK STATE DEPARTMENT OF ENVIRONMENTAL CONSERVATION
MULTI-SITE COOPERATIVE AGREEMENT NUMBER V002437-84
(FULTON TERMINALS, CLOTHIER AND VOLNEY LANDFILL SITES)
CONTENTS
Page
AUDITORS' REPORT 1-2
Summary of Costs Claimed, Accepted and Questioned - Exhibit A 3
Note to Exhibit A (Scope Limitation) 4-5
Statement of Costs Claimed, Accepted and Questioned for
Fulton Terminals Site - Schedule A 6
Notes to Schedule A 7-8
Statement of Costs Claimed, Accepted and Questioned for
Clothier Site - Schedule B 9
Notes to Schedule B 10-12
Statement of Costs Claimed, Accepted and Questioned for
Volney Landfill Site - Schedule C 13
Notes to Schedule C 14-16
Statement of Costs Incurred and Determined Eligible or
Ineligible (All Sites) - Exhibit A-l 17
Notes to Exhibit A-l 18-21
Background of the Sites - Exhibit A-2 22-24
Auditors' Comments on Compliance, Performance and
Internal Control - Exhibit B 25
Summary of Grantee Comments and
Auditor Response to Comments 26-31
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SAMUEL M. FISHER COMPANY
CERTIFIED PUBLIC ACCOUNTANTS
4OI PARKWAY
BROOM ALL. PENNSYLVANIA 19O08
1219) 328-3900
FAX (2151 328-0004
Environmental Protection Agency
Divisional Inspector General for Audit
Eastern Audit Division
J.F. Kennedy Federal Building
Boston, MA 02203-1911
We have performed an interim audit of costs claimed for the period
December 31, 1984 to March 31, 1989 under New York State Multi-Site
Cooperative Agreement Number V002437-84 with Environmental Protection Agency
(EPA) under the Comprehensive, Environmental Response, Compensation, and
Liability Act of 1980 (CERCLA) as amended by the Superfund Amendments and
Reauthorization Act (SARA). The primary objectives of our examination were as
follows:
1. To determine the adequacy, effectiveness and reliability of procurement,
accounting and management controls exercised by the State in
administering the cooperative agreement.
2. To ascertain the State's compliance with provisions of the cooperative
agreement and applicable Federal regulations and instructions.
3. To determine the reasonableness, allocability and allowability of costs
claimed under the cooperative agreement.
Our examination covered costs claimed from December 31, 1984 to March 31, 1989
for remedial investigations and feasibility studies for Fulton Terminals site
in Fulton, New York, Clothier site in Granby, New York and Volney Landfill
site in Volney, New York, as presented in the summary of expenditures from the
State's accounting records.
Our audit was performed in accordance with generally accepted auditing
standards and the "Standards for Audit of Governmental Organizations,
Programs, Activities and Functions" issued by the Comptroller General of the
United States. The Environmental Protection Agency's "Audit Guide for CERCLA
Cooperative Agreements," issued in August, 1985, was also used as a guide in
our examination. Accordingly, the audit included such tests of the accounting
records and such other auditing procedures as we considered necessary in the
circumstances.
We did not carry out a substantive examination of the claimed costs that were
accepted in another EPA audit report (Note to Exhibit A). These costs were
examined by another accounting firm whose report thereon has been furnished to
us, and our opinion expressed herein insofar as it relates to these costs
claimed and accepted is based upon the report of the other auditors. However,
we did carry out a second review of the costs claimed for the Volney Landfill
site which had been accepted per the interim audit for Federal eligibility,
because of subsequent invalidation of certain analytical data used for the
selection of the remedy included in the Record of Decision.
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Environmental Protection Agency
Divisional Inspector General for Audit
Eastern Audit Division
Schedules A, B and C set forth the costs claimed by the State and the costs
which we questioned, including an explanation of the reasons such costs were
questioned.
In our opinion, subject to the effects on Exhibit A of EPA's ultimate
resolution of the questionable expenditures referred to in the preceding
paragraph, and subject to the results of litigation, if any, which may lead to
recovery of costs of remedial investigations and feasibility studies, Exhibit
A presents the financial information in accordance with generally accepted
accounting principles and financial provisions of the agreement.
In addition, Exhibit B shows our report on the review of the State's (1)
procurement, accounting and management controls (based on criteria established
by EPA and set forth in the aforementioned audit guide) and (2) compliance
with provisions of the agreement and applicable Federal regulations and
instructions.
This report is intended for use in connection with the agreement to which it
refers and should not be used for any other purpose.
r
Broomall, Pennsylvania
November 10, 1989
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EXHIBIT A
NEW YORK STATE DEPARTMENT OF ENVIRONMENTAL CONSERVATION
MULTI-SITE COOPERATIVE AGREEMENT NUMBER V002437-84
(FULTON TERMINALS, CLOTHIER AND VOLNEY LANDFILL SITES)
Summary of Costs Claimed, Accepted and Questioned
For the Period December 31, 1984 to March 31, 1989
INTERIM AUDIT
EPA Eligible Costs
Claimed Accepted
Questioned Costs
Fulton Terminals
Clothier
Volney Landfill
$ 394,169
723,069
491.934
$1.609.172
333,178
565,060
417,902
Ineligible
71,897
$71.897
Unsupported Schedule
$ 60,991
158,009
2.135
A
B
C
Multi-Site Cooperative Agreement Number V002437-84 was awarded to New York
State Department of Environmental Conservation (NYSDEC) on December 28, 1984
for 100% Federal participation in focused feasibility studies, remedial
investigations and feasibility studies at Fulton Terminals site in Fulton, New
York and Clothier Site in Granby, New York; and remedial investigation and
feasibility study at Volney Landfill site in Volney, New York. The maximum
Federal participation was as follows:
Original award
Amendment No. 1
Amendment No. 2
Date
12-28-1984
03-30-1987
06-30-1988
Fulton
Terminals
Clothier
Volney
Landfill
Total
Amendment No. 3 09-29-1989
Project and Budget Period:
$449.946 $697.393 $700.560 $1.84:
No revision in Federal participation
UQ7.884 $810.348 $629.667 $1.847.899
No revision in Federal participation
The project and budget period per the original award was December 31, 1984 to
June 30, 1986. Amendment Number 1, authorized on March 30, 1987, extended the
end of the project and budget periods to December 31, 1987, and Amendment
Number 2 further extended these periods to December 31, 1988. Amendment
Number 3 extended the project and budget period for Fulton Terminals and
Clothier Sites to March 31, 1990.
Letter-of-Credit Drawdowns:
He tested drawdowns on Letter of Credit Number 68-13-0203(Amendment Number
28) for this cooperative agreement and found them to be reasonable and in
accordance with Federal regulations, except for the questioned costs noted in
Schedules A, B and C.
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EXHIBIT A
NEW YORK STATE DEPARTMENT OF ENVIRONMENTAL CONSERVATION
MULTI-SITE COOPERATIVE AGREEMENT NUMBER V002437-84
(FULTON TERMINALS, CLOTHIER AND VOLNEY LANDFILL SITES)
Note to Exhibit A
INTERIM AUDIT
SCOPE LIMITATION
This grant had an interim audit performed by another accounting firm, which
covered the costs for the period December 31, 1984 to March 31, 1986.
The statement of costs claimed, accepted and set aside was as follows:
Claimed Accepted Set-Aside
Personnel
Fringe benefits
Indirect costs
Travel
Materials and supplies
Contractual services
$ 46,810
14,409
20,201
$81,420
1,070
240
355,604
$46,810
14,409
20,201
$81,420
1,070
240
-
$
-
-
$
_
-
355,604
The contractual service costs of $355,604 were set aside because documentary
evidence of a pre-award cost analysis of the contract was not made available
to the auditors. This evidence was subsequently made available to EPA Region
II, and EPA accepted the costs in its Audit Resolution dated January 29, 1988.
The accepted costs per the interim audit are analyzed by site as follows:
Personnel
Travel
Materials and supplies
Contractual services
Total
$ 81,420
1,070
240
355,604
Fulton
Terminals
$25,815
165
63,241
Clothier
$ 30,588
730
230,893
Volney
Landfill
$25,017
175
240
61,470
$262.211
$86.902
Our audit instructions from EPA/01G were to examine costs claimed per
Financial Status Report (FSR) as of March 31, 1989 which were in excess of the
accepted costs in the prior interim audit. Accordingly, we limited our
substantive audit of the costs as follows:
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EXHIBIT A
NEW YORK STATE DEPARTMENT OF ENVIRONMENTAL CONSERVATION
MULTI-SITE COOPERATIVE AGREEMENT NUMBER V002437-84
(FULTON TERMINALS, CLOTHIER AND VOLNEY LANDFILL SITES)
Note to Exhibit A
INTERIM AUDIT
Costs claimed per FSR as of 3-31-89
Costs accepted per prior interim audit
Costs audited per this interim audit
Fulton
Terminals
$394,169
89.221
$304.948
Clothier
$723,069
262,211
Volney
Landfill
$491,934
86,902
Total
$1,609,172
438.334
$1.170.838
However, we did carry out a second review of $405,032 (the costs of Volney
Landfill site) accepted per the interim audit for Federal eligibility because
of subsequent invalidation of certain analytical data used for the selection
of the remedy included in the Record of Decision.
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SCHEDULE A
NEW YORK STATE DEPARTMENT OF ENVIRONMENTAL CONSERVATION
MULTI-SITE COOPERATIVE AGREEMENT NUMBER V002437-84
FULTON TERMINALS SITE
Statement of Costs Claimed, Accepted and Questioned
For the Period December 31, 1984 to March 31, 1989
INTERIM AUDIT
EPA Eligible Costs
Claimed Accepted
(A)
Questioned Costs
Personnel costs
Travel
Equipment and supplies
Contractual services
Total
$ 84,955
1,855
946
306.413
$ 46,134
1,312
946
284,786
$333.178
Ineligible
(B)
$
Unsupported Note
(C)
$38,821 1
543 2
21,627 3
(A) This amount should not be construed as being the final determination of
the Federal share of accepted costs. The amount may vary depending upon
the resolution by EPA of the questioned costs of $60,991.
(B) Ineligible cost:
A proposed or claimed amount which should not be reimbursed by the
Government because the cost is in violation of a provision of law,
regulation, contract, grant, cooperative agreement, or other agreement or
document governing the expenditure of funds.
(C) Unsupported cost:
A proposed or claimed amount that cannot be given unqualified acceptance
by the auditor because at the time of the audit, the cost is not
supported by adequate documentation and/or has not been approved by
responsible program officials.
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NEW YORK STATE DEPARTMENT OF ENVIRONMENTAL CONSERVATION
MULTI-SITE COOPERATIVE AGREEMENT NUMBER V002437-84
FULTON TERMINALS SITE
NOTES TO SCHEDULE A
INTERIM AUDIT
Note 1. Personnel Costs
We question $38,821, being the costs claimed in excess
of the grant budget, as unsupported until an amendment
of the grant to provide for the excess. The excess is
calculated as follows:
Total costs claimed $ 84,955
Current grant amount (46,134)
Excess claimed over grant
Note 2. Travel
We question $543, being the costs claimed in excess
of the grant budget, as unsupported until an amendment
of the grant to provide for the excess. The excess is
calculated as follows:
Total costs claimed $ 1,855
Current grant amount (1,312)
Excess claimed over grant $ 543
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NEW YORK STATE DEPARTMENT OF ENVIRONMENTAL CONSERVATION
MULTI-SITE COOPERATIVE AGREEMENT NUMBER V002437-84
FULTON TERMINALS SITE
NOTES TO SCHEDULE A
INTERIM AUDIT
Note 3. Contractual Services
We question $21,627, being the costs claimed for
laboratory services for the project obtained by
the grantee's prime contractor (URS, Inc.) from
a sub-contractor, NYTEST, as unsupported for
non-availability of a written sub-agreement
between URS, Inc. and NYTEST in compliance with
40 CFR 33.005, 33.250 and 33.1015. A written
sub-agreement is required to support any contract
or sub-contract in excess of $10,000 in accordance
with the aforementioned provisions of 40 CFR Part
33. We therefore question $21,627 as unsupported
costs until the grantee achieves compliance with
the requirements.
The claimed costs of $21,627 are calculated as follows:
Costs for analysis of samples based on a
written quotation of prices (not a
sub-agreement) submitted by NYTEST to URS $26,510
Deduction for resampling costs
incurred by URS 4,883
Net costs claimed
Analytical results of the first sampling had failed
to pass quality assurance/quality control (QA/QC)
review, and the sampling process had to be done
twice. However, NYTEST did not bill URS for
resampling services.
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SCHEDULE B
NEW YORK STATE DEPARTMENT OF ENVIRONMENTAL CONSERVATION
MULTI-SITE COOPERATIVE AGREEMENT NUMBER V002437-84
CLOTHIER SITE
Statement of Costs Claimed, Accepted and Questioned
For the Period December 31, 1984 to March 31, 1989
INTERIM AUDIT
EPA Eligible Costs Questioned Costs
Claimed Accepted Ineligible Unsupported Note
(A) (B) (C)
Personnel costs $106,794 $ 69,979 $ $ 36,815 1
Travel 4,728 914 - 3,814 2
Equipment and supplies 4,606 1,500 - 3,106 3
Contractual services 606,941 492,667 - 114,274 4
Total $723.069 $565.060
(A) This amount should not be construed as being the final determination of
the Federal share of accepted costs. The amount may vary depending upon
the resolution by EPA of the questioned costs of $158,009.
(B) Ineligible cost:
A proposed or claimed amount which should not be reimbursed by the
Government because the cost is in violation of a provision of law,
regulation, contract, grant, cooperative agreement, or other agreement or
document governing the expenditure of funds.
(C) Unsupported cost:
A proposed or claimed amount that cannot be given unqualified acceptance
by the auditor because at the time of the audit, the cost is not
supported by adequate documentation and/or has not been approved by
responsible program officials.
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NEW YORK STATE DEPARTMENT OF ENVIRONMENTAL CONSERVATION
MULTI-SITE COOPERATIVE AGREEMENT NUMBER V002437-84
CLOTHIER SITE
NOTES TO SCHEDULE B
INTERIM AUDIT
Note 1. Personnel Costs
(a) We question $759 as unsupported because the
grantee could not make available to us adequate
supporting documentation such as the employee
time sheets to substantiate the costs. The
required supporting documentation was not
available according to the grantee. We therefore
question $759 as unsupported for lack of
supporting documentation as required per
40 CFR 30.500.
(b) We question $36,056, being the costs claimed
in excess of the grant budget, as unsupported
until an amendment of the grant to provide for the
excess. The excess is calculated as follows:
$ 759
Total costs claimed
Costs questioned in Note 1 (a)
Current grant amount
Excess claimed over grant
Total costs questioned as unsupported
$ 106,794
( 759)
$ 106,035
( 69.979)
36,056
Note 2. Travel
We question $3,814, being the costs claimed in excess
of the grant budget, as unsupported until an
amendment of the grant to provide for the excess.
The excess is calculated as follows:
Total costs claimed
Current grant amount
Excess claimed over grant
$ 4,728
( 914)
$ 3.814
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NEW YORK STATE DEPARTMENT OF ENVIRONMENTAL CONSERVATION
MULTI-SITE COOPERATIVE AGREEMENT NUMBER V002437-84
CLOTHIER SITE
NOTES TO SCHEDULE B
INTERIM AUDIT
Note 3. Equipment and Supplies
We question $3,106, being the costs claimed in excess
of the grant budget, as unsupported until the
amendment of the grant to provide for the excess.
The excess is calculated as follows:
Total costs claimed $ 4,606
Current grant amount (1,500)
Excess claimed over grant $ 3.106
$ 3.106
Note 4. Contractual Services
(a) We question $21,955, being the costs claimed
for laboratory services for the project
obtained by the grantee's prime contractor
(URS, Inc.) from a sub-contractor, NYTEST, as
unsupported for non-availability of a written
sub-agreement between URS, Inc. and NYTEST
in compliance with 40 CFR 33.005, 33.250 and
33.1015.
A written sub-agreement is required to support
any contract or sub-contract in excess of $10,000
in accordance with the above mentioned provisions
of 40.CFR Part 33. We therefore question $21,955
as unsupported costs until the grantee achieves
compliance with the requirements. $ 21,955
The claimed costs of $21,955 are calculated as
follows:
Costs for analysis of samples based on a
written quotation of prices (not a sub-
agreement) submitted by NYTEST to URS $26,910
Deduction for resampling costs incurred
by URS 4,955
Net costs claimed
Analytical results of the first sampling had failed
to pass QA/QC review, and the sampling process had
to be done twice. However, NYTEST did not bill
URS for resampling services.
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NEW YORK STATE DEPARTMENT OF ENVIRONMENTAL CONSERVATION
MULTI-SITE COOPERATIVE AGREEMENT NUMBER V002437-84
CLOTHIER SITE
NOTES TO SCHEDULE B
INTERIM AUDIT
Note 4. Contractual Services (continued)
(b) We question the overrun of $92,319 on a
sub-contract between the grantee's prime
contractor (URS, Inc.) and Environmental Resource
Associates, Ltd. (ERA) for sampling and waste
characterization services as unsupported costs
for lack of a supplemental agreement to revise
the original contract amount. The increase in
the costs was due to the excess of the number
of waste drums actually staged over what was
previously estimated, and additional road
stabilization and equipment costs incurred
because of adverse weather conditions at
the Clothier site.
The contract agreement between URS and ERA
provides that the maximum amount payable for
Clothier Site under the signed agreement is
$108,846. The costs actually incurred and
claimed by the grantee are $201,165. According
to the prime contractor of the grantee, no
written sub-agreement was prepared to increase
the original limit per the contract.
A written sub-agreement is required to support
any contract or sub-contract in excess of
$10,000 pursuant to 40 CFR 33.005, 33.250 and
33.1015, Accordingly, we question the
unsupported overrun of $92,319, until the grantee
submits the required supplemental agreement.
Total costs questioned as unsupported
92,319
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SCHEDULE C
NEW YORK STATE DEPARTMENT OF ENVIRONMENTAL CONSERVATION
MULTI-SITE COOPERATIVE AGREEMENT NUMBER V002437-84
VOLNEY LANDFILL SITE
Statement of Costs Claimed, Accepted and Questioned
For the Period December 31, 1984 to March 31, 1989
INTERIM AUDIT
EPA Eligible Costs Questioned Costs
Claimed Accepted Ineligible Unsupported Note
(A) (B) (C)
Personnel costs $ 79,810 $ 73,146 $ 4,551 $2,113 1
Travel 1,633 914 697 22 2
Equipment and supplies 1,244 1,244
Contractual services 409.247 342.598 66,649 - 3
Total $491.934 $417.902 $71.897 $2.135
(A) This amount should not be construed as being the final determination of
the Federal share of accepted costs. The amount may vary depending upon
the resolution by EPA of the questioned costs of $74,032.
(B) Ineligible cost:
A proposed or claimed amount which should not be reimbursed by the
Government because the cost is in violation of a provision of law,
regulation, contract, grant, cooperative agreement, or other agreement or
document governing the expenditure of funds.
(C) Unsupported cost:
A proposed or claimed amount that cannot be given unqualified acceptance
by the auditor because at the time of the audit, the cost is not
supported by adequate documentation and/or has not been approved by
responsible program officials.
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NEW YORK STATE DEPARTMENT OF ENVIRONMENTAL CONSERVATION
MULTI-SITE COOPERATIVE AGREEMENT NUMBER V002437-84
VOLNEY LANDFILL SITE
NOTES TO SCHEDULE C
INTERIM AUDIT
Note 1. Personnel Costs
(a) (i) We question $3,036, being the personnel services
costs for various matters associated with the
invalidated analytical data of Volney Landfill,
as ineligible for Federal participation.
The results of the analytical data used as
a basis for selection of the remedy contained in
the Record of Decision signed on July 31, 1987
was discovered, subsequently in early 1988, to be
unacceptable. It was also noticed that the
results of the said analytical data were accepted
by NYSDEC without subjecting them to a QA/QC review as
required under General Provision M.3 of the
Cooperative Agreement and 40 CFR 30.503(e). EPA
re-evaluated the selected remedy by re-sampling
the ground water, surface water and sediments
from the Volney Landfill through its own
contractor.
The above mentioned additional costs were
incurred as a result of non-compliance with the
requirements of the cooperative agreement, and are
therefore ineligible for Federal participation. $ 3,036
(ii) We question $1,515, being the costs incurred
after the expiration date of December 31, 1988
of the grant project and budget period, as
ineligible. We question these costs as claimed
outside the scope of this cooperative agreement
pursuant to Award Condition Number 8 of the
Cooperative Agreement Amendment Number 3.
The total ineligible costs questioned
(b) (i) We question $903 as unsupported because the
grantee could not make available to us
adequate supporting documentation such as
the employee time sheets to substantiate
the costs.
The required supporting documentation was
not available according to the grantee.
We therefore question $903 as unsupported
for lack of supporting documentation as
required per 40 CFR 30.500.
1,515
$ 4.551
903
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NEW YORK STATE DEPARTMENT OF ENVIRONMENTAL CONSERVATION
MULTI-SITE COOPERATIVE AGREEMENT NUMBER V002437-84
VOLNEY LANDFILL SITE
NOTES TO SCHEDULE C
INTERIM AUDIT
Note 1. Personnel Costs (continued)
ii) We question $1,210, being the costs claimed in
excess of the grant budget, as unsupported costs
until an amendment of the grant to provide for
the excess. The excess is calculated as follows:
Total costs claimed $ 79,810
Ineligible costs questioned ( 4,551)
Unsupported costs costs questioned
in Note 1 (b) i) ( 903)
$ 74,356
Current grant amount (73,146)
Excess claimed over grant $ 1.210.
1.210
Total unsupported costs questioned $ 2.113
Note 2. Travel
(a) We question $697, being the costs incurred
after the expiration date of December 31, 1988
of the grant project and budget period, as
ineligible. We question these costs as claimed
outside the scope of this cooperative agreement
pursuant to Award Condition Number 8 of the
Cooperative Agreement Amendment Number 3. $ 697
(b) We question $22, being the costs claimed in
excess of the grant budget, as unsupported
until an amendment of the grant to provide for
the excess. The excess is calculated as
follows:
Total costs claimed $ 1,633
Ineligible costs questioned ( 697)
$ 936
Current grant amount ( 914)
Excess claimed over grant $ 22
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Note 3. Contractual Services
(a) We question $48,312, being the costs billed by the
prime contractor, URS, Inc., for laboratory services
provided by a sub-contractor, NYTEST, as ineligible
for Federal participation since the results of the
analytical data were invalidated following a
QA/QC review required under General Provision M.3 of
the Cooperative Agreement and 40 CFR 30.503(c).
URS, Inc. has agreed to give NYSDEC credit for this
amount against additional costs not yet billed to
NYSDEC. (see Note 4 to Exhibit A-l) $48,312
(b) We question $18,337, being the costs billed by
the prime contractor, URS, Inc., for various services
associated with sampling of ground water, surface
water and sediments, as ineligible for Federal
participation since the analytical results of the
sampling were invalidated following a QA/QC
review required under General Provision M.3
of the Cooperative Agreement and 40 CFR 30.503(c).
18.337
The total ineligible costs questioned $66.649
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EXHIBIT A-l
NEW YORK STATE DEPARTMENT OF ENVIRONMENTAL CONSERVATION
MULTI-SITE COOPERATIVE AGREEMENT NUMBER V002437-84
(FULTON TERMINALS, CLOTHIER AND VOLNEY LANDFILL SITES)
Statement of Costs Incurred and Determined Eligible or Ineligible
For the Period April 1, 1989 to June 30, 1989
INTERIM AUDIT
Incurred Eligible Ineligible Unsupported Note
FULTON TERMINALS
Personnel costs
Travel
Equipment and supplies
Contractual services
Total
CLOTHIER SITE
Personnel costs
Travel
Equipment and supplies
Contractual services
Total
VOLNEY LANDFILL
$ 5,623 $
$ 3,654 $
$ 7,749 $
Personnel costs
Travel
Equipment and supplies
Contractual services -
Total $ 7.749
$ 2,194
$ 2.194
$ 7,749
$ 7.7*9
$ 5,623
$ 5.623
$ 1,460
1,2
3
4
Notes: A. The above costs are not an integral part of Exhibit A
as they have not yet been claimed by NYSDEC for
Federal participation.
B. No information was available to us (as of the date of
our field audit) of any project costs incurred after
June 30, 1989.
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NEW YORK STATE DEPARTMENT OF ENVIRONMENTAL CONSERVATION
MULTI-SITE COOPERATIVE AGREEMENT NUMBER V002437-84
(FULTON TERMINALS, CLOTHIER AND VOLNEY LANDFILL SITES)
NOTES TO EXHIBIT A-l
INTERIM AUDIT
Note 1. Personnel Costs (Fulton Terminals and Clothier Sites)
Since the grant budget for personnel costs for each site
has been exceeded as of March 31, 1989 per Schedules A, B
and C, all personnel costs incurred after March 31, 1989
should be questioned as unsupported costs pending
appropriate amendment of the grant budget to include
them.
Note 2. Personnel Costs of Clothier Site
$2,194 of the total incurred was for services associated
with the proposed remedial design, and therefore, outside
the scope of the present Cooperative Agreement under audit.
Note 3. Personnel Costs of Volney Landfill
Costs incurred after the expiration of the project and
budget period per the grant are ineligible for Federal
participation.
Note 4. Contractual Services Costs (All Sites)
NYSDEC's prime contractor, URS Inc., has not yet billed
for any services rendered beyond October 30, 1987.
The unpaid retainage on the costs billed is as follows:
Fulton Terminals
Clothier Site
Volney Landfill
Total
$ 8,494
8,613
10,068
As the retainage is not yet paid, NYSDEC has not claimed
it for Federal participation. $965 of the total retainage
of $10,068 for Volney Landfill is for the costs associated
with invalidated Volney sampling results, and ineligible
for Federal participation.
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NEW YORK STATE DEPARTMENT OF ENVIRONMENTAL CONSERVATION
MULTI-SITE COOPERATIVE AGREEMENT NUMBER V002437-84
(FULTON TERMINALS, CLOTHIER AND VOLNEY LANDFILL SITES)
NOTES TO EXHIBIT A-l
INTERIM AUDIT
Note 4. Contractual Services Costs (All Sites) (continued)
The following is a list of the costs incurred by
URS, Inc. but not yet billed to the grantee as of
the date of our field audit. These costs are not
included in the costs claimed per Schedule A and B:
FULTON TERMINALS SITE
CLP data audit
Health risk assessment
7,192 This amount has not yet
been billed by URS, Inc.
and covers the audit done
to ensure the results of
re-sampling of Fulton data
to be quality assured after
the previous sampling
results were determined to
be unacceptable. NYSDEC
has informed us that they
would not claim these costs
for Federal reimbursement.
14,101 Costs associated with this
service were billed but were
rejected by NYSDEC as they
exceeded the contract limit.
The contractor claims that
these additional services
are due to additional
requirements under SARA,
which were not included
in the scope of the previous
contract. NYSDEC was unable
to furnish us a detailed
analysis of work performed
by URS, Inc.
-19-
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NEW YORK STATE DEPARTMENT OF ENVIRONMENTAL CONSERVATION
MULTI-SITE COOPERATIVE AGREEMENT NUMBER V002437-84
(FULTON TERMINALS, CLOTHIER AND VOLNEY LANDFILL SITES)
NOTES TO EXHIBIT A-l
INTERIM AUDIT
NOTES 4. Contractual Services Costs (All Sites) (continued)
Report revisions
24,213 The contractor claims that
revisions to the RI/FS
report were necessary to
include the results of
additional soil sampling,
which was not included in
the original contract.
NYSDEC was unable to furnish
us an analysis of $24,213 by
specific item revised by URS
for our verification.
Total
CLOTHIER SITE
Health risk assessment
$ 45,506
11,927
Report revisions
41,344
The contractor claims that
these additional services
are due to additional
requirements under SARA,
which were not included in
the scope of the previous
contract. NYSDEC was unable
to furnish us a detailed
analysis of work performed
by URS, Inc.
The contractor claims that
revisions to the RI/FS
report was necessary to
include the results of
additional soil sampling,
which was not included in
the original contract. Also
the report was re-written
to conform to the new
guidelines of SARA. NYSDEC
was unable to furnish us an
analysis of $41,344 by
specific item as revised by
URS for our verification.
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NEW YORK STATE DEPARTMENT OF ENVIRONMENTAL CONSERVATION
MULTI-SITE COOPERATIVE AGREEMENT NUMBER V002437-84
(FULTON TERMINALS, CLOTHIER AND VOLNEY LANDFILL SITES)
NOTES TO EXHIBIT A-l
INTERIM AUDIT
Note 4. Contractual Services Costs (All Sites) (continued)
Total
$ 53,271
GRAND TOTAL
URS, Inc. has also agreed to give NYSDEC a credit of $48,312 for costs
associated with invalid sampling results for Volney Landfill Site.
See Note 3 (a) to Schedule C.
-21-
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EXHIBIT A-2
NEW YORK STATE DEPARTMENT OF ENVIRONMENTAL CONSERVATION
MULTI-SITE COOPERATIVE AGREEMENT NUMBER V002437-84
(FULTON TERMINALS, CLOTHIER AND VOLNEY LANDFILL SITES)
Background of the Sites
INTERIM AUDIT
Fulton Terminals
The Fulton Terminals Site is a two-acre abandoned former chemical waste
and petroleum product storage facility located in the City of Fulton,
Oswego County, New York. From 1972 to 1979, this site was used to store
hazardous wastes. Wastes were stored in both above-ground and underground
tanks.
In late 1981, the principals of Fulton Terminals, Inc. agreed to
cooperate with NYSDEC in a voluntary cleanup program. The voluntary
cleanup lasted until March, 1983, when the principals were fined by
NYSDEC for using an unlicensed handler of PCB waste.
Remedial investigation and feasibility study (RI/FS) at Fulton Terminals
were commenced in early 1985. Timely completion of RI/FS work was
delayed due to certain quality assurance problems associated with the
technical data collected from the site, and RI/FS reports requiring
revision because of the new requirements under SARA. The initial RI/FS
report prepared by NYSDEC's contractor was not acceptable to EPA, and as
a result, EPA prepared a supplemental RI/FS report through its own
contractor. A Record of Decision is planned to be issued in the near
future.
Clothier
The Clothier site is located in the Town of Granby, Oswego County, New
York. The site is bounded on the West by Ox Creek.
This site was used as disposal site for wastes from a pollution abatement
services facility. Inspection of the site revealed that the deposited
drums of waste were in poor condition and leaking. NYSDEC sued the owner
of the site in 1976 for operating an illegal landfill. As a result of
this suit, a temporary operating permit was given to the owner, and he
was ordered to clean up the site within one year. Work was done in 1977
to cover the drums dumped on the site. This action caused the drums to
rupture. The owner was cited for failing to meet the conditions of the
lawsuit.
The New York State Department of Health analyzed one soil and two surface
water samples from the site. The soil sample was found to contain PCB.
PCB and other organic compounds were not detected from the surface water
samples.
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NEW YORK STATE DEPARTMENT OF ENVIRONMENTAL CONSERVATION
MULTI-SITE COOPERATIVE AGREEMENT NUMBER V002437-84
(FULTON TERMINALS, CLOTHIER AND VOLNEY LANDFILL SITES)
Background of the Sites
INTERIM AUDIT
2. Clothier (continued)
RI/FS at Clothier site were commenced in early 1985. Timely completion
of RI/FS work was delayed due to certain quality assurance problems
associated with the technical data collected from the site, and RI/FS
reports requiring revision because of the new requirements under SARA.
The initial RI/FS report prepared by NYSDEC's contractor was not
acceptable to EPA, and as a result, EPA (through its own contractor)
revised and supplemented the RI/FS report prepared by NYSDEC's
contractor. NYSDEC's contractor also revised the previously prepared
RI/FS report to meet the acceptable format. EPA released both reports
for public review. A Record of Decision was signed on December 28, 1988.
3. Volney Landfill
Volney Landfill, also known as the Oswego Valley Sanitary Landfill, is
located on the west side of Silk Road in the Town of Volney, Oswego
County, New York. The landfill is situated on the site of a former sand
and gravel pit operated by the Oswego County Highway Department. The
landfill site covers approximately 58 acres.
Oswego County acquired the Volney Landfill between 1975 and 1976. Prior
to that time, it was privately owned and served the communities of
Granby, Volney and Fulton. The landfill was started in 1968 to handle
municipal refuse only. Pollution Abatement Services of Oswego dumped
approximately 8,000 barrels of waste, said to be sludge, at the site
during the 1970's under an agreement with the previous operator. A
number of barrels leaked during disposal, and the workers of the landfill
suspected that some barrels contained industrial chemicals.
Subsequently, concern arose that leachate from the landfill may be
contaminating the ground and surface waters with the hazardous chemicals.
In 1979, NYSDEC and Oswego County closed the landfill and developed a
program for ground water monitoring and leachate treatment. Hazardous
organic chemicals were detected from surface and ground water samples
collected from the landfill and its immediate vicinity.
RI/FS at Volney Landfill site were commenced in early 1985. NYSDEC's
contractor completed the RI/FS report in May, 1987, and a Record of
Decision (ROD) was signed on July 31, 1987. In early 1988, it was
noticed that NYSDEC had not performed a quality assurance/quality control
review of the analytical data used in the RI/FS report. A quality
assurance/quality control review of the data was then performed, and the
results indicated the data (analytical results of the ground water
samples) were invalid. This raised a doubt on the validity of the
remedial measure selected in the ROD. To rectify the situation, EPA
(through its own contractor) re-evaluated the remedy selected in the ROD
by re-sampling the ground water, surface water and sediments.
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NEW YORK STATE DEPARTMENT OF ENVIRONMENTAL CONSERVATION
MULTI-SITE COOPERATIVE AGREEMENT NUMBER V002437-84
(FULTON TERMINALS, CLOTHIER AND VOLNEY LANDFILL SITES)
Background of the Sites
INTERIM AUDIT
3. Volney Landfill (continued)
Based upon the results of the re-sampling and re-evaluation of RI/FS
report, EPA has concluded that the remedy selected in the ROD does not
require significant alteration.
-24-
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EXHIBIT B
NEW YORK STATE DEPARTMENT OF ENVIRONMENTAL CONSERVATION
MULTI-SITE COOPERATIVE AGREEMENT NUMBER V 002437-84
(FULTON TERMINALS, CLOTHIER AND VOLNEY LANDFILL SITES)
Comments on Compliance, Performance and Internal Controls
INTERIM AUDIT
As a part of our examination, we reviewed and tested the Grantee's system of
internal accounting controls to the extent we considered necessary to evaluate
the system as required by generally accepted auditing standards. This
evaluation established a basis for reliance on the Grantee's accounting
control system in determining the nature, timing and extent of other auditing
procedures necessary for expressing an opinion on the financial reports.
The objective of internal accounting control is to provide reasonable, but not
absolute, assurance that the (1) assets are safeguarded against loss from
unauthorized use or disposition and (2) financial records are reliable for
preparing financial statements and maintaining accountability for assets. The
concept of reasonable assurance recognizes that the cost of a system of
internal accounting controls should not exceed the benefits derived and also
recognizes that the evaluation of these factors necessarily requires estimates
and judgements by management.
There are inherent limitations that should be recognized in considering the
potential effectiveness of any system of internal accounting controls. In the
performance of most control procedures, errors can result from misunderstanding
of instructions, mistakes of judgement, carelessness or other personal
factors. Control procedures whose effectiveness depends upon segregation of
duties can be circumvented by collusion. Similarly, control procedures can be
circumvented intentionally by management, either with respect to the execution
and recording of transactions or with respect to the estimates and judgments
required in the preparation of financial statements. Further, projection of
any evaluation of internal accounting control to future periods is subject to
the risks that the procedures may become inadequate because of changes in
conditions and that the degree of compliance with the procedures may
deteriorate.
The EPA "Audit Guide for CERCLA Cooperative Agreement, issued on August 13,
1985, requires a review and evaluation of the adequacy of the controls
exercised by the State through its financial management, accounting,
procurement, contract administration, and property management systems to
provide assurance that costs claimed are reasonable, allowable and allocable
to the sponsored project. We understand that EPA considers procedures
conforming to the criteria in its audit guide to be adequate for EPA purposes.
Procedures that are not in conformity with the audit guide indicate some
inadequacy for EPA purposes. Based on this understanding and on our study, we
believe that the State's procedures were adequate for EPA purposes.
-25-
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NEW YORK STATE DEPARTMENT OF ENVIRONMENTAL CONSERVATION
Multi-Site Cooperative Agreement Number V002437-84
(Fulton Terminals, Clothier and Volney Landfill Sites)
INTERIM AUDIT
The contents of the draft audit report were discussed with the grantee during
a preliminary exit conference held on November 10, 1989 in Albany, New York.
The grantee responded in a letter dated January 19, 1990, a copy of which is
attached. We offered to hold a final exit conference but the grantee believed
there was no need therefor since mutual agreement has been reached on all
significant aspects of the audit.The following summarizes the grantee's
comments with our response to their comments.
FULTON TERMINAL SITES
Personnel Costs (Note 1 to Schedule A)
We questioned $38,821, being the costs claimed in excess of the grant budget,
as unsupported. Of these questioned costs $1,281 was incurred after the
expiration date of December 31, 1988 of the grant budget and project period
per Grant Amendment Number 2.
Grantee Comment:
Auditor Response:
The grantee states that USEPA awarded an amendment to this
grant on September 9, 1989, which extended the Fulton
Terminals budget period to March 31, 1990. However, since
the budget for personnel costs was not increased, they
accept the auditor's finding of the excess cost ($38,821)
and request that this amount be set aside until such time
as an amendment is awarded to increase the budget for
personnel costs.
We continue to question $38,821 as unsupported costs until
EPA amends the grant to provide for these additional
costs.
Travel (Note 2 to Schedule A)
We questioned $769 as unsupported costs as they were incurred after the
expiration date of December 31, 1988 of the grant budget and project period
per the Grant Amendment Number 2. $543 of the questioned costs is in excess
of the grant budget for travel costs.
Grantee Comment:
Auditor Response:
The grantee states that the budget period for this portion
of the grant was extended to March 31, 1990. However, the
budget was not increased. They, therefore, request
reinstatement of travel costs in the amount of $226 up to
the current budget, and set aside the auditor's finding of
$543 in costs exceeding the grant budget until such
time as an amendment is awarded to increase the budget for
travel costs.
We now accept $226 in our audit report, and continue to
question the balance of $543 (the costs claimed in excess
of the budget) as unsupported until the grant budget is
amended by EPA to provide for the excess.
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Contractural Services (Note 3 to Schedule A)
(a) We questioned $21,627, being the costs for laboratory services for the
project obtained by the grantee's prime contractor (URS, Inc.) from
NYTEST, as unsupported for lack of a written sub-agreement between URS,
Inc. and NYTEST in compliance with 40 CFR 33.005, 33.250 and 33.1015.
Grantee Comment: The grantee states that the prime contractor, URS
Consultants has submitted a sub-agreement with NYTEST for
the project engineer's review. It is, therefore,
requested that $21,627 be set aside pending the project
engineers review of the sub-agreement.
Auditor Response: We continue to question $21, 627 as unsupported until the
grantee submits the required written sub-agreement.
(b) We questioned $18,235 paid to URS, Inc. for removal of waste samples,
drums and cuttings, which tasks were outside the scope of the contract
with URS, Inc. at the time of our field audit.
Grantee Comments: The grantee states that Supplemental Agreement No. 3 dated
June 19, 1989 (approved by the State Comptroller's Office
on November 8, 1989) with URS, Inc. increases the scope of
the contract to include the removal of waste samples,
drums and drill cuttings. Based on that approval, it is
requested that the costs be accepted. A copy of the
approved contract is attached.
Auditor Response: We have now reinstated $18,235 previously questioned as
unsupported per the draft audit report.
CLOTHIER SITE
Personnel Costs (Note 1 to Schedule B)
(a) We questioned $759 as unsupported for lack of adequate supporting
documentation, such as the employee time sheets, to substantiate the
costs.
Grantee Comment: The grantee states that since $759 was based on accruals
rather than time records, the auditor's finding is
accepted.
Auditor Response: Our finding stands affirmed.
(b) We questioned $36,056, being the costs claimed in excess of the grant
budget, as unsupported. Of these questioned costs $5,014 was incurred
after the expiration date of December 31, 1988 of the grant budget and
project period per Grant Amendment Number 2.
Grantee Comment: The grantee states that USEPA awarded an amendment to this
grant on September 9, 1989, which extended the budget
period to March 31, 1990. However, since the budget for
personnel costs was not increased, the grantee accepts the
auditor's finding of the excess cost ($36,056) and
requests that this amount be set aside until such time as
an amendment is awarded to increase the budget for
personnel costs.
-27-
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Personnel Costs (Note 1 to Schedule B) (Continued)
Auditor Response:
We continue to question $36,056 as unsupported costs until
EPA amends the grant to allow these additional costs.
Travel (Note 2 to Schedule B)
We questioned $3,814 as unsupported costs claimed in excess of the grant
budget. Of these questioned costs $2,405 was incurred after the expiration
date of December 31, 1988 of the grant budget and project period per Grant
Amendment Number 2.
Grantee Comment:
Auditor Response:
The grantee states that the budget period was extended by
USEPA to March 31, 1990. However, since the travel budget
was not increased, the grantee accepts the auditor's
findings of excess costs ($3,814) and requests that this
amount be set aside until such time as an amendment is
awarded to increase the budget for travel costs.
We continue to question $3,814 as unsupported costs until
EPA amends the grant to allow these additional costs.
Equipment And Supplies (Note 3 to Schedule B)
We questioned $3,106 as unsupported costs since they were claimed in excess of
the grant budget.
Grantee Comment:
The grantee accepts the auditor's findings of excess costs
and requests that $3,106 be set aside until such time as
an amendment is awarded to increase the budget for
equipment and supplies.
Auditor Response: We continue to question $3,106 as unsupported costs until
EPA amends the grant to allow these additional costs.
Contractual Services (Note 4 to Schedule B)
(a) We questioned $21,955, being the costs for laboratory services for the
project obtained by the grantee's prime contractor (URS, Inc.) from
NYTEST, as unsupported for lack of a written sub-agreement between URS,
Inc. and NYTEST in compliance with 40 CFR 33.005, 33.250 and 33.1015.
Grantee Comment:
Auditor Response:
The grantee states that the prime contractor, URS
Consultants has submitted a sub-agreement with NYTEST for
the project engineer's review. It is, therefore,
requested that $21,955 be set aside pending the project
engineer's review of the sub-agreement.
We continue to question $21,955 as unsupported until the
grantee submits the required written sub-agreement.
-28-
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Contractual Service (Note 4 to Schedule B) (Continued)
(b) We questioned an overrun of $92,319 on a sub-contract between the
grantee's prime contractor (URS, Inc.) and Environmental Resource
associates. Ltd. (ERA) as unsupported costs for lack of a supplemental
agreement to revise the original contract amount.
Grantee Comment:
Auditor Response;
The grantee states that URS has submitted a supplemental
agreement with ERA for the project engineer's review and
approval. It is, therefore, requested that the costs be
set aside pending the project engineer's review of the
sub-agreement.
We continue to question $92,319 as unsupported until the
grantee submits the required supplemental agreement
between URS, Inc. and ERA.
(c) We questioned $24,773 paid to URS, Inc. for removal of waste samples,
drums and cuttings ($19,638) and soil sampling ($5,135), which tasks were
outside the scope of the contract with URS, Inc. at the time of our field
audit.
Grantee Comment:
Auditor Response;
The grantee states that Supplemental Agreement No. 3 dated
June 29, 1989 (approved by the State Comptroller's Office
on November 8, 1989) with URS, Inc. increases the scope of
the contract to include the removal of waste samples,
drums, drill cuttings and soil sampling. It is,
therefore, requested that the costs be accepted now.
We have now reinstated $24,773 previously questioned as
unsupported per the draft audit report.
VOLNEY LANDFILL SITE
Personnel Costs (Note 1 to Schedule C)
(a) We questioned $3,036, being the personnel costs associated with the
invalidated analytical data of Volney Landfill, as ineligible.
Grantee Comment: The grantee accepts the auditor's findings.
Auditor Response: Our findings stand affirmed.
(b) (i) We questioned $903 as unsupported for lack of adequate supporting
documentation, such as the employee time sheets, to substantiate the
costs.
Grantee Comment: The grantee accepts the auditor's findings since $903 was
based on accruals rather than time records.
Auditor Response: Our findings stand affirmed.
-29-
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Personnel Costs (Note 1 to Schedule C) (Continued)
(ii) We questioned $2,725, being the costs claimed in excess of the grant
budget, as unsupported. Of these questioned costs $1,515 was
incurred after the expiration date of December 31, 1988 of the grant
budget and project period per the grant.
Grantee Comment:
Auditor Response:
The grantee states that since the budget period for this
portion of the grant was not extended, the auditor's
findings of the excess costs in the amount of $1,515 are
accepted. However, it is requested that the remainder,
$1,210, be set aside until such time as an amendment is
awarded to increase the budget for personnel costs.
We have reclassified $1,515 from unsupported questioned
costs to ineligible questioned costs. As for the remainder
of $1,210, we continue to question it as unsupported costs
until EPA amends the grant to allow it.
Travel (Note 2 to Schedule C)
We questioned $719, being the costs claimed in excess of the grant budget, as
unsupported. Of these questioned costs $697 was incurred after the expiration
date of December 31, 1988 of the grant budget and project period per the
grant.
Grantee Comment:
Auditor Response:
The grantee accepts the auditor's findings of excess costs
in the amount of $697 since the budget period for this
portion of the grant was not extended. However, it is
requested that the remainder of $22 be set aside until
such time as an amendment is awarded to increase the
travel costs budget.
We have reclassified $697 from unsupported questioned
costs to ineligible questioned costs. As for the
remainder of $22, we continue to question it as
unsupported costs until EPA amends the grant to allow it.
Contractual Services (Note 3 to Schedule C)
(a) We questioned $48,312, being the costs billed by the prime contractor,
URS, Inc., for laboratory services provided by a sub-contractor, NYTEST,
as ineligible since the results of the analytical data were invalidated
following a QA/QC review required under General Provision M.3 of the
Cooperative Agreement and 40 CFR 30.503 (c).
Grantee Comment: The grantee accepts the auditor's findings.
Auditor Response: Our findings stand affirmed.
-30-
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Contractual Services (Note 3 to Schedule C) (Continued)
(b) We questioned $18,337, being the costs billed by the prime contractor,
URS, Inc., for sampling of ground water, surface water and sediments, as
ineligible since the analytical results of the sampling were invalidated
following a QA/QC review required under General Provision M.3 of the
Cooperative Agreement and 40 CFR 30.503 (c).
Grantee Comment: The grantee accepts the auditor's findings.
Auditor Response: Our findings stand affirmed.
(c) We questioned as unsupported $3,991 ($4,201 less 5% retainage) paid to
URS, Inc., for health risk assessment services, which were not within the
scope of the contract with URS, Inc.
Grantee Comment:
The grantee states that Supplemental Agreement No. 3 dated
June 29, 1989 (approved by the State Comptroller's Office
on November 8, 1989) with URS, Inc. increases the scope of
the contract to include the said services. It is,
therefore, requested that $3,991 be accepted.
Auditor Response: We have now accepted the costs in our audit report,
-31-
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GRANTEE COMMENTS
-------
New York State Department of Environmental Conservation
50 Wolf Road, Albany, N»w York 12233
Thomas C. Jorilng
Commissioner
January 19, 1990
Mr. Paul D. McKechnie
Divisional Inspector General for Audit
U.S. Environmental Protection Agency
Office of the Inspector General
Eastern Audit Division
J.F. Kennedy Federal Building - Room 1911
Boston, Massachusetts 02203-1911
Re: Grant No. V002437-84
Draft Report No.
P5BQ9-02-0366
Dear Mr. McKechnie:
Enclosed is the response of the New York State Department of Environmental
Conservation addressing the above referenced draft report on the interim audit
of the multi-site cooperative agreement for Fulton Terminals, Clothier and
Volney Landfill Sites.
Thank you for the opportunity to review and comment on this draft report.
Sincerely,
Charles J. Papa
Director of Internal Audit
Enclosure
cc: Samuel N. Fisher Company, CPA'
bcc: M. O'Toole
R. Lynch
R. Lupe
D. Norvik
W. Wilson
-------
New York State Department of Environmental Conservation
Grant No. V002437-84
Following are the Department of Environmental Conservation's comments on
the draft interim audit for the Fulton Terminals, Clothier and Volney Landfill
Sites. The comments are presented in the same order as in the draft audit.
Fulton Terminals Site
Note 1. Personnel Costs - The auditors questioned $38,821 as claimed in
excess of the grant. It was also noted that $1,281 of these
costs were incurred after the expiration date of the budget
period. On September 29, 1989 the USEPA awarded an amendment to
this grant which extended the Fulton Terminals budget period to
March 31, 1990. However, since the budget for personnel costs was
not increased, we accept the auditors' finding of the excess cost
($38,821) and request that this amount be set aside until such time
as an amendment is awarded to increase the budget for personnel
costs.
Note 2. Travel - The auditors questioned $769 as being unsupported since
they were incurred after the expiration of the budget period.
The auditors also noted that $543 of that amount was in excess of
the grant budget. As stated in Note 1 above, the budget period for
this portion of the grant was extended to March 31, 1990. However,
the budget was not increased. We therefore request reinstatement of
travel costs in the amount of $226 up to the current budget, and set
aside the auditors' finding of $543 in costs in excess of the grant
budget until such time as an amendment is awarded to increase the
budget for travel costs.
Note 3. Contractual Services -
a) The auditors questioned $21,627 in laboratory costs for NYTEST,
a subcontractor, because the costs are in excess of $10,000 and
no subagreement was on file. On January 9, 1990 the prime
contractor, URS Consultants submitted a subagreement with
NYTEST for the project engineer's review. He therefore request
that these costs be set aside pending the project engineer's
review of the subagreement.
b) The auditors questioned $18,235 paid to URS, Inc. for tasks
outside the scope of the contract. However Supplemental
Agreement No. 3 dated June 29, 1989 of the URS' New York State
Contract No. D001173 was approved by the State Comptroller's
Office on November 8, 1989. This amendment increases the scope
of the contract to include the removal of waste samples, drums
and drill cuttings, which are the tasks the auditors had
determined to be outside the scope of the contract. Based on
that approval we request that the costs be accepted. A copy of
the approved contract is attached.
-------
Comments on Draft Interim Audit Report No.
New York State Department of Environmental Conservation
Grant No. V002437-84
(page ^ or 4;
Clothier Site
Note 1. Personnel Costs
a) The auditors questioned $759 as unsupported because time sheets
were not available to substantiate the costs. Since this
amount was based on accruals rather than time records, we
accept the auditors' finding.
b) The auditors questioned $36,056 in personnel costs claimed as
being in excess of the grant budget. Also, the auditors noted
that $5,014 of those costs were incurred between January 1 and
March 31, 1989, after the expiration of the budget period. On
September 9, 1989 the USEPA awarded an amendment to this grant
which extended the budget period to March 31, 1990. However
since the budget for personnel costs was not increased we
accept the auditors' finding of excess costs ($36,056) and
request that amount be set aside until such tine as an
amendment is awarded to increase the budget for personnel
costs.
Note 2. Travel - The auditors questioned $3,814 in travel costs as being
in excess of the grant budget. The auditors also noted that $2,405
was incurred between January 1 and March 31, 1989 which was after
the expiration of the budget period. As stated in Note 1 b above,
the budget period was extended to March 31, 1990. However, since
the travel budget was not increased, we accept the auditors'
findings of excess costs ($3,814) and request that amount be set
aside until such time as an amendment is awarded to increase the
budget for travel costs.
s
Note 3. Equipment and Supplies - The auditors questioned $3,106 in
equipment and supplies1 costs as being in excess of the grant
budget. We accept the auditors' findings of excess costs and
request that $3,106 be set aside until such time as an amendment is
awarded to increase the budget for equipment and supplies
Note 4. Contractual Services
a) The auditors questioned $21,955 in laboratory services costs for
NYTEST, a subcontractor, because the costs were in excess of $10,000
and no subagreement was on file. On January 9, 1990 the prime
contractor, URS Consultants, submitted a subagreement with NYTEST
for the project engineer's review and approval. We therefore
request that these costs be set aside pending the project engineer's
review.
b) The auditors questioned the $92,319 overrun on a URS subcontractor,
Environmental Resource Associates, Ltd., because there was no
subagreement to revise the original contract amount. On January 9,
1990 URS submitted a supplemental agreement for that work for the
project engineer's review and approval. We therefore request that
the costs be set aside pending the project engineer's review of the
subagreement.
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Comments on Draft Interim Audit Report No. P5BQ9-02-0366 (page 3 of 4)
New York State Department of Environmental Conservation
Grant No. V002437-84
>***«**»***«***
Clothier Site
Note 4. Contractual Services (continued)
c) The auditors questioned $25,043 paid to URS Inc. for tasks outside
the scope of the contract. However, Supplemental Agreement No. 3
as described in Note 3-b. under Fulton Terminals also covers the
Clothier Site. We, therefore, request that the costs now be
accepted.
Volney Landfill Site
Note 1. Personnel Costs
a) The auditors disallowed $3,036 in personnel costs associated with
invalidated analytical data of Volney Landfill. We accept the
auditors' finding.
b)(i)The auditors questioned $903 in personnel costs as unsupported
because the time sheets were unavailable to substantiate the
costs. Since this amount was based on accruals rather than time
records, we accept the auditors' finding.
(ii) The auditors questioned $2,725 in personnel costs as being in
excess of the grant budget-. $1,515 of that amount was incurred
between January 1 and March 31, 1989, after expiration of the
grant budget period. Since the budget period for this portion of
the grant was not extended, we accept the auditors' finding of
excess costs in the amount of $1,515. However, we request that the
remainder, $1,210, be set aside until such time as an amendment is
awarded to increase the budget for personnel costs.
Note 2. Travel - The auditors questioned $719 in travel costs as being in
excess of the travel budget. The auditors also noted that $697 of
that amount was incurred between January 1 and March 31, 1989, after
expiration of the grant budget period. Since the budget period for
this portion of the grant was not extended, we accept the auditors'
finding of excess costs in the amount of $697. However, we request
that the remainder, $22, be set aside until such time as an
amendment is awarded to increase the travel costs budget.
Note 3. Contractual Services
a) The auditors questioned $48,312 in costs billed by URS, Inc.
for laboratory services provided by a subcontractor, NYTEST, as
ineligible since the costs were associated with invalidated
analytical data. We accept the auditors' finding.
-------
Comments on -
Hew York State Department of Environmental Conservation
Grant No. V002437-84
Vplney Landfill Site
Note 3. Contractual Services (continued)
b) The auditors questioned $18,337 in costs billed by URS, Inc.
for sampling services in connection with invalidated analytical
data as ineligible for Federal participation. We accept the
auditors' finding.
c) The auditors questioned $3,991 paid to URS Inc. for health risk
assessment services which were not within the scope of the
existing subagreement. However, Supplemental Agreement
No. 3 as described in Note 3b. under Fulton Terminal
increases the scope to include those services. We therefore
request that these costs be accepted.
-------
fHIS AGREEMENT entered into this "p / day of /* , 1939, by
and betveen the NEW YORK STATE DEPARTMENT OF ENVIRONMENTAL CONSERVATION
(hereinafter referred to as the DEPARTMENT) and URS CORPORATION (herein-
after referred to as the ENGINEER)
WITNESS:
WHEREAS the parties hereto entered into a prior agreement which was
duly assigned Contract No. D001173 by the Comptroller of the State of Nev
York and amended by Supplemental Agreement No. 1 vhich vas approved by the
Comptroller on 7/1/86 and by Supplemental Agreement No. 2 approved by the
Comptroller on 8/18/86.
WHEREAS the parties desire to amend said Agreement; and
WHEREAS the DEPARTMENT is empowered by lav to obtain technical and
professional services; and
WHEREAS the performance of this service is essential to the
DEPARTMENT; and
WHEREAS the DEPARTMENT has fully examined all of its internal
capabilities and has thoroughly investigated all possible alternative
methods of accomplishing this project within the DEPARTMENT, and has
determined that it must accomplish this vork through consultant services;
and
WHEREAS the ENGINEER hereby represents that it is professionally
capable of providing the desired technical and professional services vhich
are the subject matter of this AGREEMENT, and is licensed to practice
engineering in the State of Nev York.
Nov therefore, the parties agree as follows:
1. The ENGINEER vill be reimbursed for costs incurred to perform the
additional services associated vith the contract modifications
detailed in 'Description of Additional Services', attached hereto
and Bade a part hereof.
2. The amount of the lump sum fixed fee described in ITEM V of ARTICLE
10 of the prior Agreement is hereby revised to $10.711 for the
-------
Fulton Terminals site, $11,519 for the Clothier site, and $12.958
for the Volney Landfill.
3. The maximum amount payable described in ITEM IX of ARTICLE 10 of the
prior Agreement is hereby revised to $352,496 at the Fulton
Terminals site, $569,978 at the Clothier site, and $418,115 at the
Volney Landfill site, unless there is an additional change in the
scope, character, or complexity of the work contained in an executed
Supplemental Agreement.
4. All other terms and conditions of the prior Agreement remain in full
force and effect.
5. Revised Exhibits C, D-l, D-2 and D-3, attached hereto, replace the
corresponding original exhibits in Schedule 2 of the prior
Agreement.
The term of this Contract is extended to January 31, 1990.
-------
IN WITNESS WHEREOF, representatives of the Department and the
Engineer have executed this Contract on the day and year written beneath
their respective signatures.
Recommended:
T i 11 e: ~j
Date:
^FORJJEPARTMENT
[By:
Title: Director of Fiscal
Date:
FOR ENGINEER
By: Virgnjra Sinoh. P.E.
Title: Vice President
Date: \D^P Q_ft
Approved as to Form:
By:
Attorney General
Date:
STATE
.."SSaBW?""
O ,
COUNTY OFr> _*_ j
Qn thai
I/V A-L*i
) SS:
., 19**V&5We~me personally
,known, who being duly sworn,
came
did depose and say that
New York; that (s)he is
the corporation described in and which executed the above instrument;
that (s)he knows the seal of said corporation; that the seal affixed to
said instrument is such corporate seal; that it was so affixed by
authority of the Board of Directors of said corporation and that (s)he
signed his/her name thereto by the same authority.
Notary Public
DEBORAH 1 MOOT
Nowy Public
^j»Hr«d in Eric but*
'
-------
EXHIBIT C
ESTIMATED COST SUMMARY
Item IA - Direct Technical Salaries
TR - Direct Technical Salaries
l Premium Portion of Overtime
Item II - Direct Non-Salary Costs
Expenses
Item III - Overhead
Item IV - Fixed Fee
Item II - Direct Non-Salary Costs
Subcontractors
Total Estimated Cost
MAXIMUM AMOUNT PAYABLE:
Fulton Terminals
Clothier
Volney Landfill
All 3 sites
Fulton Terminals
Clothier
Volney Landfill
All 3 sites
Fulton Terminals
Clothier
Volney Landfill
All 3 sites
Fulton Terminals
Clothier
Volney Landfill
All 3 sites
Fulton Terminals
Clothier
Volney Landfill
All 3 sites
Fulton Terminals
Clothier
Volney Landfill
- All 3 sites
Fulton Terminals
Clothier
Volney Landfill
All 3 sites
$ 72,999
74,022
79,338
226,359
-0-
-0-
-0-
-0-
30,079
37,129
30,617
97,825
90,838
92,109
98,727
281,674
10,711
11,755
12,958
35,424
147,869
355,199
196,475
699,543
352,496
570,214
418,115
1,340,825
$1,340.825
-------
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-------
Patcriotion of Additional Service!
I.
- ASK 3 SITE
A)
Ktmoval of vmstt samples, drums and drill cuttings
The field activities associated vitb the remedial investigation at the
Fulton Terminals and Clothier sites have generated containers of
contaminated wastes and soils which require disposal at permitted
Treatment, Storage and Disposal Facilities (TSDF). The disposal of these
materials vas not specified in the original contract scope of services.
The cost for the disposal of wastes from the Fulton Terminals site was
$18,235.00 and the cost for disposal of wastes from the Clothier site was
$19.637.57. (See Exhibits 1 and 2.)
8) Additional Clothier soil sampling
In order to characterize the extent of soil contamination present at the
Clothier site, an additional round of soil samples was collected by the
ENGINEER. The collection of these samples was not specified in the
original contract scope. The following is a breakdown of costs associated
with the collection of these samples
Staff Title
Salary Hate
Hours
Total Cost
Senior Technician $13.00
Surveyor 8.43
84.0
76.5
Total Direct Labor
Overhead (1124.4*1)
Fixed Fee (|10Z)
Subtotal
Other Direct Co^tt
Travel
Heals and Lodging
equipment & Samples
Grand Total
$ 1.092.00
644.90
$ 1,736.90
2.161.40
389.83
$ 4,288.13
$ 230.66
560.90
325.51
S 5,405.20
-------
Exhibit 1
Manaf •'"•nt, Inc.
41. IS
N^
201/443-flOO
,, A<
07103
TO' TOS ,IHC.
570 DEUVAIZ AVZNUt
BUfTAW , HW T0« U202
ATTH: DAM I0THMAM
INVOICE E-N!
INVOICE DATE
PROJECT NO. -
CUSTOMER ORDER
TtftMSi NIT II «AYS_
DESCMFnON
TO wmci TOU fotwtt m»i«D octom u A» i*. «M
ALSO , DtCEKUl 2A, 1916
KATIIZAL/nODOCTS
Tuistomnoi
DlSKJIAl
AttACHD.*
*SZX COIM Of BAUT
-------
Exhibit 2
i y v n i r c
4MCUKTS «iv..
•|«IST AT TWO MOCINT Ml «C
**T|
URS
S70 0«!w*rt Strttt
Syffilo. Ntw torj U202
ATTENTION: *. 0. ROTHMAN
A. Clotftltr Slta
1. 22 F1btr OruM of SMplts for Inc1rwtt1on Prof 11t No. G07787
B. Pulton Siu
1. 61 Orun Profllt Not 6077M. G07700, GQ77U,. 8077I§-
2. IS Ovtrpack OHJM '
(For mort
pins,
Utur dat^ MarcH 2. 1987,
1 Mf MIT TO
k
P.O. Boi 8000 Dipt. WO
• • ».«. «.~ ¥«•* 149*7
S28.07S.CC
-------
C) Additions! Volnty groundveter sampling
In ordtr to confirm the prestnct of contamination discovered in previous
groundwater samples, » second round of staples is necessary. The costs
for the ENGINEER to collect these samples is as followss
s§i»rf Rate,
Total Cost
Engineer -Level 2
Technician
$16.01 44.5
6.56 42.5
Total Direct Labor
Overhead (C124.44Z)
Fixed Pee (|10Z)
Subtotal
Other Direct Cost!
Travel (300 ai. I $0.23/ai)
Tolls
Meals and Lodging
Grand Total
5 712.44
279.80
$ 991.24
1,233.50
$ 2,447.21
69.00
6.70
S 2,753.47
D)
CLP Data Audit (Pulton)
The nev Pulton Terminals chemical data (groundwater, surface water.
sediment) was given a detailed CLP data audit. This audit was not
specified in the original contract scope. The following is a breakdown
of costs associated with the audit.
Stiff Tltlt
S»l»r»
Houri
Total Cost
Scientist -Level 4 $20.63
Scientist -Level 4 20.04
Scientist -Level 3 17.29
39.0
47.5
53.0
Total Direct Labor
Overhead (1124.441)
Pee
Subtotal
Other Direct Coste
Travel
Meals and Lodging
Grand Total
804.57
951.90
$ 2,672.84
3.326.08
$ S, 998. 92
$ 753.53
440.00
$ 7.192.45
credit for invalid data (Volney)
URS Invoice Mo. 3776 (for the period 11/29/86 through 12/26/86} included
charges of $48,312.00 by MYTCST Environmental, Inc. for Volney cheaical
analyses which subsequently proved to be invalid. An equal reduction in
the Volney Landfill upset budget is credited.
P)
tebudget costs among sites
-------
actions at Fulton Terminals and Clothier sites by USEPA, and partly by
implementation of the Superfund Amendments and leauthorization Act of
1986. Both of these actions, which vere not anticipated or provided for
in the initial contract, required restructuring and reallocation of
resources among the three sites, and also among the labor and direct non-
salary cost categories. In addition, a number of project functions vere
performed simultaneously and/or jointly for the different sites, making
the delineation of costs betveen the three in some cases relatively
arbitrary. For the reasons above, and based upon actual project costs
incurred, the following rebudgeting of costs among sites is appropriate.
This rebudgeting has. for the sake of convenience, been applied entirely
to Task 3. Site Investigation.
Budget Additions (+) and/or Subtractions (-)
Clothier
Volnev
Total
Labor
Overhead (1124.44Z)
Subcontractor
Total
•o.
.Q.
.34,589.00
-34, 5tft. 00
.0.
.0.
-6,769.00
-6,769.00
+18,427.20
+22. 930. BO
•0-
+4 1,3 SB. 00
+ 18, 427. 20
+22,930.80
.41,358.00
-0-
XX.
WMEDIAL INVESTIGATION - TASK 4 SIT! INVESTIGATION ANALYSIS
A)
Health tisk Assessment
Amendments to the Federal Superfund program promulgated under the
Super fund Amendments and leauthorization Act of 1986 (SA1A) have required
the development of a health risk assessment for the Fulton Terminals,
Clothier and Volney Landfill sites. The original contract scope was
developed in 1985 and did not include a health risk assessment. The costs
to perform the health risk assessment aret Fulton Terminals $14,101.26;
Clothier $11,926.97; and Volney Landfill $4,200.51. A breakdown of these
costs is as followst
Fulton Terminals Site
St«f* Title
Salarr !•»•
Hours
Total Cost.
Engineer -Level 4 $26.44
Engineer -Level 2 14.62
Engineer -Level 2 13.94
24.0
169.5
40.0
Total Direct Labor
Overhead (1124.44Z)
Fixed Fee (|10Z)
Subtotal
Other Direct Cost,*
Subconsultant
Grand Total
$ 634.56
2.478.09
557.60
$ 3,670.25
4,567.26
823.75
9.061.26
S 5.040.00
$14.101.26
-------
Enginetr -Level 4
Engineer -Level 2
Scientist -Level 2
$28.67 108.0
14.88 36.0
14.62 82.0
Total Direct Labor
Overhead ((124.44Z)
Fiztd Fee (flOI)
Grand Total
Total Coit
$ 3,096.52
535.64
1.198.84
$ 4,831.00
6,011.70
1.084.27
$11,926.97
Voln*v Lapd^ijl
Ltle Salirr Rate
$26.44
14.62
13.94
Engineer -Level 4
Engineer -Level 2
Engineer -Level 2
8.0
82.5
16.0
Total Direct Labor
Overhead (1124.441)
Fixed Ftt (1101)
Grand Total
tal Coat
$ 211.52
1,206.15
223.04
$ 1,640.71
2,041.70
168.24
$11,926.97
Other Diret
Subcontultant
Computer Literature Search
Grand Total
III.
MEDIAL
TICATIOM
REPORTS
A) Eeport reviaioni
$ 125.00
24.86
$ 4,200.51
The Fulton Teminali and Clothier RI/FS report* were both revised to
include the retultt of extentive additional soil sampling which *as
perforned by, or at the direction of, USEPA. (At Fulton Terminal«, the
number of toil aaaplet increased fron 4, in the original contract scope,
to 19» at Clothier, the number increased from 4 to 69.) In addition, the
Clothier Ft report was, at the direction of USEPA, entirely restructured
and rewritten to conform with the new SARA guidelines, which were enacted
after ta« initial report had been prepared. The costs for these revisions
art at followst
-------
Fulton Terminals
StaffJltlft
Salary Rate
Hours
Total Cost
Engineer -Level 4
Geologist -Level 4
Engineer -Level 3
Scientist -Level 3
Engineer -Level 2
Scientist -Level 2
Geologist -Level 2
Engineer -Level 1
Scientist -Level 1
Draftsman
lord Processor
Clothier Site
Stiff Title
Engineer -Level 4
Engineer -Level 3
Engineer -Level 2
Scientist -Level 2
Scientist -Level 1
Chief Draftsman
Draftsman
Word Processor
$27.91
24.04
17.18
16.27
14.42
15.98
12.45
8.14
10.31
7.46
7.26
Salarr Hat*
$27.18
18.17
14.72
14.84
11.89
16.31
8.54
9.41
203.0
3.0
18.0
38.0
152.0
45.0
4.0
29.0
3.0
64.5
57.0
Total Direct Labor
Overhead (1124.441)
Fee
Grand Total
Hours
286.0
5.0
560.0
21.5
14.0
2.0
87.0
112.0
Total Direct Labor
Overhead (I124.44X)
Fee
Grand Total
$ 5,666.69
72.12
309.18
618.32
2,191.13
718.92
49.80
236.12
30.94
481.24
413.84
$10,788.30
13,424.95
-0-
$24.213.25
Total Cost
$ 7,772.28
90.86
8.243.59
319.11
166.44
32.62
742.78
1.033.46
$18,421.14
22,923.27
-0-
S41.344.41
-------
Suau&ftrv of Additional Costs
Remedial
Pylton
Clohier
Removal of waste staples.
druas and cuttings $18.235.00 $19,637.57
Clothier soil sampling
Volney groundvater
sampling
CLP data audit
Invalid data credit
Rebudgeting
Taak Total
Taek 4
.0.
-0-
7.192.45
5.405.20
-0-
• 0-
-0- $37,872.57
.0- 5,405.20
2.753.47 2.753.47
.0. 7.192.45
-0- .0- .48,312.00 -48,312.00
-34.589.00 -6.769.00 41.358.00 -0-
-$9.161.55 $18.273.77 .$4.200.33 $ 4.911.69
Health risk assessment $14.101.26 $11.926.97 $ 4,200.51 $30,228.74
Report Revision*
$24.213.25 $41.344.41
-0- $65.557.66
61AID TOTAL
$29.132.96 $71.343.13 -$ 0.02 $100,698.09
-------
Summit"? of Additional Costa * Continued
• ft
F
Di :ect Labor
<;<7*rhe»d
Fixed Fee
Subtotal
Other Direct Cottl
Travel fc Tolls
Heals & Lodging
Equip. & Supplies
Subcontractor
Subtotal
CEAK) TOTAL
Ful^op
$17,131.39
21,318.29
S23.73
$39,273.43
$ 733.33
440.00
-0-
-V^.. 314. 00
-10.120.47
$29,152.96
Clothier
$24,989.04
31,096.37
1.474.10
$57,559.51
$ 230.66
560.90
323.31
12.868.57
13,985.64
$71,545.15
Vainer
$21,059.13
26,206.00
590.71
$47,155.86
$ 73.70
230.56
24.86
.48.187.00
.47.655.89
-$ 0.02
Tofril
$ 63,179.58
78,620.66
2. 888. 56
$144,668.60
$ 1,059.89
1,231.46
330.37
-46.63Z.43
-43,990.71
$100,698.09
------- |