£ PA X
TABLE OF CONTENTS
Pace
SUMMARY OF RESULTS 1
SCOPE AND OBJECTIVES 2
DETAILS OF REVIEW 4
Annual Report Chapter 3.0 Responses At Sites
; With Hazardous Substances Releases 4
Annual Report Chapter 4.0 Site Discovery And
Assessment 8
Annual Report Chapters 3.0 and 4.0 Additional
Comments 9
Annual Report Chapter 5.0 The National
Priorities List of Sites . . 11
Annual Report Chapter 6.0 Enforcement
Program Activities 11
Annual Report Chapter 11.0 Technology-
Related Research And Development 12
Annual Report Chapter 14.0 Executive Branch
Estimate Of Resources Needed To Complete
Superfund Implementation 13
Annual Report Preparation Process 13
EXHIBIT
Review of Regional Records 15
WDQUARTERS LIBRARY
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1 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
/ WASHINGTON. D.C. 20460
m 28 1990
THE INSPECTOR GENERAL
MEMORANDUM
SUBJECT: Audit Report No. E1SFF9-11-0015-0100227
Review of the Fiscal Year 1988
Super fund RejMrt to Congress
FROM: John C.
Inspector^ General (A-109)
TO: William K. Reilly
Administrator (A-100)
SUMMARY OF RESULTS
We have completed our review of the Environmental Protection
Agency's (EPA) report to Congress on Progress Toward Implementing
Super fund: Fiscal Year 1988 (Annual Report). We found that while
some sections of the Annual Report were accurate and reasonable,
others were not. Further/ the process the Agency used to prepare
the Annual Report was not timely. The problems we identified with
the accuracy and timeliness of this Annual Report were essentially
the same as those we identified for fiscal year 1987 (FY87).
However, due to the length of time taken to prepare the FY87 Annual
Report, EPA was not able to take corrective action on our FY87
findings in time to affect the quality of the FY88 data or
timeliness of the report. EPA has now established a work group to
improve the Comprehensive Environmental Response, Compensation and
Liability Information System (CERCLIS) input controls, and is
performing monthly data quality audits. Further, actions have been
taken to improve the process for preparing future Annual Reports
in a more timely manner.
Some sections of the Annual Report, such as key information
presented in Chapter 5.0 on sites deleted from the National
Priorities List (NPL), Chapter 6.0 on the enforcement program, and
Chapter 11.0 on the Superfund Innovative Technology Evaluation
(SITE) Program, were generally reasonable and accurate.
However, certain information presented in Chapters 3.0 and 4.0 was
not reasonable or accurate. Significant portions of the
accomplishments claimed by the regions were not supported by valid
source documents (see the exhibit at the end of this report), for
several reasons. In some cases the source documentation indicated
the action either did not meet Agency definitions or did not occur
in fiscal year 1988 ("invalid actions"). In other instances, we
were unable to locate adequate supporting documentation to
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determine whether or when the action occurred ("source documents
not located"). Also, program accomplishments figures in the Annual
Report were not always complete because CERCLIS is routinely
updated months after the fiscal year end.
Appendix A does not always show the original estimated
completion dates for Remedial Investigations/Feasibility Studies
(Rl/FSs) and Remedial Actions (RAs) in-process at the end of FY87.
While it identifies delays that occurred during FY88, it does not
identify any delays which may have occurred in prior years.
The process used to prepare the FY88 Annual Report was not
fully effective, due to many of the same problems that occurred
with the FY87 Annual Report. For example, the Annual Report
coordinator's resources were limited, and he had difficulty
obtaining some key end of fiscal year data. Also, the tracking
system available for the signatory officials was not complete and
accurate, thus hindering their monitoring of the process. Finally,
the report coordinator was still working on the FY87 Annual Report
when this one was past due. As a result, the FY88 Annual Report
was submitted to the Office of Management and Budget (OMB) for
review one month later than last year's report. And this Annual
Report was not completed until December 1989, even though it was
due to Congress in January 1989.
SCOPS AMD OBJECTIVES
The objectives of our review were to determine whether the
Annual Report is reasonable and accurate, as required by Section
301(h)(2) of the Comprehensive Environmental Response, Compen-
sation, and Liability Act (CERCLA).
We began our review on January 30, 1989, at EPA Headquarters
and in Regions 4 and 5. We completed virtually all of our work by
September 28, 1989, when EPA sent the Annual Report to OMB for
review. However, we also reviewed the final changes made to the
Annual Report in December 1989, after OMB's review had been
completed.
Our work focused on FY88 activities. Numerous auditors
familiar with the Superfund program reviewed the entire Annual
Report to determine if there were any sections which did not appear
to be reasonable and accurate.
We performed detailed audit work in Headquarters and Regions
4 and 5 to verify the accuracy of selected key information
presented in the following Annual Report chapters and related
appendices:
3.0: "Responses At Sites With Hazardous Substance
Releases";
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4.0: "Site Discovery and Assessment";
5.0: "The National Priorities List of Sites";
6.0: "Enforcement Program Activities";
11.0: "Technology-Related Research and Development"; and
14.0: "Executive Branch Estimate of Resources Needed
To Complete Superfund Implementation".
As previously stated, some of the information in the Annual
Report was not finalized until December 1989. In order that our
review would not delay the Annual Report any further, we began our
field work by using an October 1988 draft, and used updated drafts
as they became available. We focused our field work on those items
CERCLA specifically required to be included in the Annual Report.
We performed detailed audit work in Regions 4 and 5 because of
their volume of Superfund activity. Recognizing regional differen-
ces, we hoped in this manner to obtain a balanced, nationwide
perspective in our review.
For the information in Chapters 3.0, 4.0, 5.0, and 6.0, we
obtained CERCLIS printouts in January 1989, and matched the nation-
wide summary totals to the totals in the Annual Report. We also
selected samples of cases for review in the pre-remedial, removal,
remedial and enforcement programs. We did not secure the printouts
from the CERCLIS database ourselves. Instead, we relied on those
provided by the Office of Solid Waste and Emergency Response
(OSWER) to define our universe of cases.
For our sample cases, we reviewed the source documentation in
Regions 4 and 5 to determine whether the activities claimed met the
definitions for valid FY88 actions. The specific source docu-
mentation reviewed varied from activity to activity. For example,
for Preliminary Assessment (PA) completions, the official Agency
definition states that "a PA is complete when the report is review-
ed and accepted by the region and the PA completion date is enter-
ed into CERCLIS." In accordance with this definition, we reviewed
source documents showing the review and acceptance of the PA report
by the region, such as the PA report itself and regional logs; we
also reviewed the CERCLIS printout showing the entry of the action
into the database. We performed this same type of review for each
of the pre-remedial, removal, remedial, and enforcement actions
selected for review. Although virtually every one of our sample
items was selected at random, we did not select a statistically
valid sample. Therefore, the results of our review should not be
projected throughout EPA.
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During our review of the FY87 Annual Report, we identified
four FA Completions and one RI/FS Start in Region 5 that were
claimed in FY87, but should have been counted in FY88. Because
of this, we reviewed these five cases specifically to determine
whether they were counted again in the FY88 statistics.
r
We reviewed the information presented in the Agency's report
on the SITE Program. Concurrent with our review of the Annual
Report, the Office of Inspector General (OIG) was conducting a
survey of the SITE Program to ascertain whether an audit was
warranted. To determine if the information presented on the SITE
Program was reasonable and accurate, we asked the OIG auditors
surveying the SITE Program to review this chapter.
We did not perform in-depth audit work on Chapter 14.0, for
two reasons. First, most of it is budget information that is
readily available within the Agency. Second, Section 14.3 was not
added to the report until the July 1989 draft, after we had
completed our field work.
Throughout the course of our review, we brought the concerns
which we identified to the Agency's attention. The Agency correct-
ed most of these concerns.
Except as noted below, our work was performed in accordance
with the Government Auditing Standards (1988 revision) issued by the
Comptroller General of the United States. We did not perform a
full scope audit to determine if the Superfund program is achieving
the results required by CERCLA, nor did we perform extensive tests
to determine if internal controls are adequate. We performed audit
work we believed necessary to determine if key information included
in the Annual Report is reasonable and accurate. Furthermore, for
the items not tested, nothing came to our attention which warranted
more detailed audit work than that described in the DETAILS OF
REVIEW section.
DETAILS OF REVIEW
Annual Report Chapter 3.0 - Responses At
Sites With Hazardous Substance Releases
Removal Program
The Annual Report's nationwide and Region 4 and 5 totals for
Removal Starts and Removal Completions differed slightly from those
on the CERCLIS printouts provided to us. Nationwide Removal Starts
totaled 328 in the Annual Report and 326 in CERCLIS. Nationwide
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Removal Completions totaled 282 in the Annual Report, but only 277
in CERCLIS. Region 4 and 5 Removal Starts totaled 96 in the Annual
Report and 95 in CERCLIS, while Region 4 and 5 Removal Completions
totaled 87 in the Annual Report and 85 in CERCLIS. OSWER officials
attributed these differences to the fact that the larger numbers
take into account sites with more than one removal action, whereas
the CERCLIS totals equate each site with only one such action.
Of the 47 Removal Starts and 11 Removal Completions we
reviewed, 51 (88 percent) were valid FY88 actions. However, seven
of the actions were not valid FY88 accomplishments.
Four of these seven actions were not valid because, based on
official Agency definitions, they should have been recorded in a
different fiscal year. In fact, one of these four was actually an
FY87 Removal Start that was counted in both FY87 and FY88.
For the other three actions, the source documentation did not
show any evidence that the Agency definitions of a start or a com-
pletion were met, regardless of the fiscal year involved. For
example, the Marietta Mercury Spill site in Region 4 was counted
as both an EPA-lead first Removal Start and first Removal Comple-
tion, even though the definition was never entirely met in either
case. Specifically, EPA received notification of "about a six
ounce mercury spill" on the floor of a personal residence in
Marietta, Georgia. The On-Scene Coordinator (OSC) first mobilized
a contractor to assist in removing the mercury' The OSC then went
to the residence and was told EPA's assistance was not required.
The resident of the home said that a relative would help in remov-
ing the mercury. The OSC subsequently stated in a memorandum to
his file that EPA did not use the contractor to do any removal
actions at the residence. EPA paid $1,000 to mobilize the contrac-
tor, even though the contractor's services were not needed.
OSWER Directive 9200.3-1A states that a first Removal Start
occurs when removal activity has begun. Furthermore, the directive
states that a first Removal Completion is counted on the day the
on-site removal action is completed. We believe that the Marietta
Mercury Spill site does not meet the Agency definition of a Removal
Start or a Removal Completion. In addition, our review of CERCLIS
revealed that this site was also counted as a responsible party-
lead subsequent Removal Start and Removal Completion, because the
resident of the house stated she would clean up the mercury.
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Figure 1 provides the detailed results of our removal program
review.
Number in the
Annual Report
Universe per
CERCLIS
Sample Size
Valid FY88
Actions
Source Documents
Not Located
Invalid FY88
Actions
FIGURE 1
REMOVAL PROGRAM
Removal Starts
Regions:
4 5 Total
62 34
62
29
26
0
33
18
16
0
96
95
47
42
0
Removal Completions
Regions:
4 5 Total
55 32
55
7
6
0
30
4
3
0
87
85
11
9
0
Remedial Program
Both the Annual Report and the CERCLIS printouts listed 150
RI/FS Starts nationwide in FY88. For the two regions which we
reviewed, CERCLIS reported 42 RI/FS Starts. We sampled 13 RI/FS
Starts and determined that all 13 were valid FY88 actions.
We found that the number of Records of Decision (RODs) listed
in the Annual Report as completed nationwide during FY88 was almost
identical to CERCLIS. The Annual Report listed 152 and CERCLIS
listed 154 RODs in FY88. CERCLIS identified 37 RODs for Regions
4 and 5, and all 15 RODs we reviewed were valid FY88 actions.
The nationwide totals for Remedial Design (RD) Starts and RA
Starts contained in the Annual Report agreed with those on the
CERCLIS printouts provided to us. Of the 99 RD Starts during FY88,
28 were in Regions 4 and 5. For RA Starts, these regions accounted
for 18 of the 72 nationwide.
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Of the 15 RD Starts and 15 RA Starts we reviewed, 29 (97 per-
cent) were valid FY88 actions. The one invalid action was due to
the funds not being obligated on an EPA-lead site as of the end of
FY88. The definition of an RD Start for this type of site includes
obligating the funds. Figure 2 provides the detailed results of
our RD and RA" Starts review.
FIGURE 2
RD AND RA STARTS
Universe in
CERCLIS
Sample Size
Valid FY88
Actions
Source Documents
Not Located
Invalid FY88
Actions
RD Starts
Regions:
Total
10 18 28
4 11 15
4 10 14
000
Oil
RA Starts
Regions:
4 5 Total
8
8
8
0
0
10
7
7
0
0
18
15
15
0
0
CERCLA Section 301(h)(l)(c) requires the Agency to include in
the Annual Report "notice of each (feasibility) study which will
not meet a previously published schedule for completion and the new
estimated date for completion." The Annual Report addresses this
requirement in Appendix A. It is important for the reader to
understand that this appendix shows "previously published" comple-
tion dates which were estimated no earlier than the beginning of
FY88. For projects in-process at that time, these dates were taken
from the column 9/30/87 Est. Completion included in Appendix D of
the FY87 Annual Report. So for these projects, lengthy delays
which may have occurred prior to the beginning of FY88 are not
shown (see Figure 3 for RI/FS examples). OSWER officials stated
that the revised estimated dates of completion contained in the
FY87 Annual Report constituted a "previously published schedule,"
so comparing these dates with the new 1988 estimates satisfied the
statutory intent of CERCLA.
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FIGURE 3
STATUS OF RI/FSB ON 9/30/88
Per FY87 Per FY88
Annual Report; Annual Report;
Site Name
Kellogg-Deering Well Field
Groveland Wells
New Bedford Site
"1/1/87 Est.
Completion"
2/88
1/88
2/88
"Previously Pub.
Completion Sch.
2/89
4/89
2/89
Annual Report Chapter 4.0 -
Site Discovery And Asseeament
Pre-Remedial Program
The nationwide totals for PAs and Site Inspections (Sis)
contained in the Annual Report agreed with those on the CERCLIS
printouts provided to us. Of the 2,884 PAs completed during FY88,
784 were in Regions 4 and 5. For Sis, these regions completed 413
of the 1,237 nationwide.
Of the 44 PA completions and 31 SI completions we reviewed,
25 (33 percent) were valid FY88 actions. Five were not valid FY88
actions; instead, according to official Agency definitions, they
should have been recorded in a different fiscal year. Three of
these five were part of a batch of 74 PA reports actually input to
CERCLIS on November 4, 1988 (FY89), but which were erroneously
recorded as November 4, 1987 (FY88).
In addition, we were unable to locate adequate source docu-
mentation for 45 (60 percent) of the 75 sample cases. Specifi-
cally, in Region 4 we located all of the reports, but there was no
evidence on the reports, such as a date and signature, to show that
they had been reviewed and accepted by the Agency. A log was main-
tained of approximately 60 percent of the reports, but it did not
show review and acceptance. Further, some of the reports themsel-
ves were undated, and others were very old, in one case dating back
to FY81. Region 4 officials stated that they did not document the
review and acceptance on the reports because they entered the dates
into a computer database instead. In Region 5, regional personnel
could not locate some of the reports. The regional log was spora-
dically maintained during FY88, and as a result, in some cases
there were no entries for these reports documenting Agency review
and acceptance. Figure 4 provides the detailed results of our
review.
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Universe in
CERCLIS
Sample Size
Valid FY88
Actions
Source Documents
Not Located
Invalid FY88
Actions
FIGURE 4
PRI-REKEDIAL PROGRAM
PA Completions
Regions:
4 5 Total
170 614 784
16 28 44
0 13 13
16 12 28
033
SI Completions
Regions m.
4 5 Total
182 231 413
15 16 31
0
15
12 12
2 17
The Annual Report states that the Agency met the January 1,
1988, CERCLA target for completing PAs for all sites in CBRCLIS as
of October 1986. However, the reader should note that the FY87
Annual Report acknowledged that the Agency may not meet a similar
goal for Sis. Part of the reason for this may be a reduction in
SI completion volume in FY88. According to Exhibit 1.0-4, the
number of FY88 SI completions was the lowest in the last five
years, decreasing from FY87 levels by seven percent. This reduc-
tion in volume must have been anticipated, because the Agency
established an FY88 target 16 percent lower than the FY87 accom-
plishment. Although the Agency apparently exceeded its own FY88
target for SI completions, this target would not have been
sufficient to induce Agency components to meet the CERCLA deadline.
Annual Report Chaptere 3.0 and 4.0 -
Additional Comments
According to OSWER officials, CERCLIS was expanded and
improved during FY88. However, as previously discussed, our review
identified concerns with the accuracy of some data in the system.
Further examples of system problems include the following:
In December 1988, we requested that Headquarters OSWER
officials provide us CERCLIS printouts from which to
select our samples for Regions 4 and 5. We were initi-
ally advised that printouts could not be provided due
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to "data discrepancies." During January 1989, these
officials apparently believed the discrepancies were
sufficiently resolved, and we received our printouts.
During our field work, Region 5 officials advised the
auditors that they considered the system to contain
inaccuracies.
From our discussions and observations in the two regions,
we believe that inadequate input controls continue to hamper the
accuracy and reliability of CERCLIS. OSWER officials advised us
that a work group has been formed to review these input controls
and make recommendations for improvements. In addition, they
stated they are conducting monthly data quality audits.
In addition to our concern about the accuracy of the data,
CERCLIS accomplishments for FY88 differed depending on the date of
the printout. For example, we obtained three different figures for
Removal Starts in Region 4. A Headquarters CERCLIS report dated
October 19, 1988, listed 62; the draft Annual Report dated February
23, 1989, listed 67; and a Region 4 CERCLIS printout dated March
14, 1989, listed 65.
OSWER Directive 9200.3-1A established a cut-off date of
October 17, 1988, for producing final quarter accomplishments
reports. However, the regions did not adhere to the cut-off date
and continued to input information into CERCLIS months after the
end of the fiscal year. OSWER officials stated that for purposes
of completeness, the Agency wants to get all accomplishments into
CERCLIS, regardless of lateness. Nevertheless, since the CERCLIS
runs used for the Annual Report were generated shortly after the
cut-off date, and since the regions continued to enter accomplish-
ments into the system, the Annual Report may be understating some
Agency accomplishments.
The reader should understand that in some instances, activi-
ties conducted at a site are claimed in multiple categories, i.e.
both as Removals and Remedial Actions. These same activities are
apparently considered to meet more than one Agency definition.
For example, at the Region 4 Newport Dump site, the documentation
in the files stated that "the remedial action was initiated on
July 2, 1987 and completed on October 31, 1987." Yet the CERCLIS
printouts we received indicated that not one, but three actions
occurred on October 30, 1987: a Removal Completion; a first RA
Completion; and a final RA Completion. Some Agency officials have
devised the term "removials" to apply to these cases; OIG auditors
in Region 4 have initiated an audit of this practice.
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Following up on our FY87 review, we found that the four PA
Completions and one RI/FS Start which Region 5 counted in FY87,
but should have recorded in FY88, were not counted again in this
year's statistics. However, based on the previously discussed
Removal Start' which Region 5 counted in both years, the potential
exists that other accomplishments may also be double counted.
Annual Report Chapter 5.0 -
The National Priorities List Of Sites
The Annual Report listed five sites deleted from the NPL
nationwide in FY88 . We obtained documentation from Headquarters
which verified that the Agency deleted these five sites from the
NPL. Two of the sites deleted were in Region 4, while Region 5
did not have any sites deleted. We did not do any further work in
Region 4 validating the completion dates for the two sites deleted.
Annual Report Chapter 6.0 -
Enforcement Program Activities
We reviewed four categories of enforcement activities dis-
cussed in the Annual Report: Administrative Orders (AOs); RI/FS
Settlements; RD/RA Settlements; and Referrals. In most cases, the
nationwide CERCLIS totals provided to us agreed with the totals
shown in the Annual Report . The only instance in which the nation-
wide totals did not agree was in the AO category. The CERCLIS
printouts showed 202 Unilateral/Administrative Orders, while the
Annual Report contained 207 .
For our samples of cases selected in each activity category,
we were able to locate all appropriate source documents and verify
that the actions occurred during FY88, as claimed. Figure 5 out-
lines the number of sample cases reviewed.
FIGURE 5
CASES REVIEWED
Number of Actions Sample
Enforcement Category in Regions 4 and 5 Size
Administrative Orders 60 7
RI/FS Settlements 26 13
RD/RA Settlements 12 12
Referrals 31 6
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The reader should note that for these settlements, not all
parties to the settlement have to be in agreement, nor all monies
collected, to meet the EPA definition of an accomplishment. For
example, at the time of our review the Consent Decree for the
Laskin/Poplar'site had been filed in court, but not yet signed by
the affected parties, and penalty monies had not actually been
collected. There is, therefore, some degree of uncertainty
regarding the final resolution of this case.
It is important for the reader to understand that the dollar
figures cited in the Annual Report for AOs, RI/FS Settlements, and
RD/RA Settlements are estimates made by the regional officials.
In most cases these are not actual monies collected for the
Superfund, but rather are estimates of the amount of money saved
the Federal Government by having the responsible parties perform
the cleanups. Regional officials stated that the estimates are
based on normal costs to clean up sites similar to those in ques-
tion, unless more specific information is available to be used.
We requested source documents to validate the amounts of these
estimates in Regions 4 and 5, but regional officials were unable
to provide any documentation.
The Annual Report presents enforcement accomplishments in a
number of different categories, based on official Agency defini-
tions and statistics tracking. It is important for the reader to
understand that the same Superfund site may appear in more than
one category. For example in Region 5, the American Anodco, Inc.,
site was counted in both the Administrative Order and RI/FS Settle-
ment categories. Thus, the reader should not add together the
numbers of accomplishments in the different categories to form a
picture of the overall enforcement accomplishments at Superfund
sites during FY88.
Annual Report Chapter 11.0 -
Technology-Related Research And Development
We reviewed the information presented in the Annual Report on
the SITE Program. Concurrent with our review of the Annual Report,
the DIG was conducting a survey of the SITE Program. To determine
if the information presented on the SITE Program was reasonable and
accurate, we asked the auditors working on the SITE Program survey
to analyze this chapter. Based on their review, we believe that
the information presented on the SITE Program is generally reason-
able and accurate.
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Annual Report Chapter 14.0 - Executive Branch Estimate Of
Resources Heeded To Complete Superfund Implementation
We did not perform in-depth audit work on the information
in this chapter. Much of it consists of FY88 obligations/ the
resource estimates from the FY89 Operating Plan, and the Agency's
budget request for FY90, all of which is readily available
information. Further, Section 14.3, on the Agency's estimate of
post-FY90 costs to clean up the existing NPL, was added to the
draft report after we completed our field work. Consequently, we
did not have sufficient time to perform an in-depth review of this
information prior to the Agency's scheduled issuance of the final
report. However, we do wish to emphasize that the projected dollar
figure of approximately $18.6 billion does not address sites which
are not presently proposed for listing or actually on the NPL.
Annual Report Preparation Process
As with last year's Annual Report, the process used to prepare
this year's was not fully effective. Although this Annual Report
was due to Congress January 1, 1989, it was not submitted to OMB
for review until September 1989, one month later than last year's
report. While the Agency improved the overall timeliness of issu-
ing the report, it was still not completed until December 1989.
Many of the reasons for the Annual Report's lateness are the same
as last year. These issues need to be addressed if future Annual
Reports are to be submitted timely to Congress.
Part of the reason that the Annual Report encountered such
difficulties is that the coordinator's resources were limited, thus
inhibiting the completion of the prior year's Annual Report. In
fact, while we were performing our review of the FY88 Annual Report
the coordinator was still devoting much of his time to the FY87
Annual Report. We finished almost all of our field work for the
FY88 review prior to the Agency's transmittal of the FY87 Annual
Report to Congress.
Another factor contributing to the Annual Report's delay was
the fact that the coordinator was unable to secure selected accom-
plishment figures in a timely manner from Agency offices respon-
sible for compiling them. For example, as previously discussed,
we were initially unable to secure CERCLIS printouts from OSWER
two months after the end of the fiscal year, due to "data discre-
pancies ."
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Accurate and complete monitoring information is not available
to the signatory officials. The Director, Office of Emergency and
Remedial Response, has a tracking system to monitor the status and
progress of the Annual Report. However, the tracking system avail-
able for ther Administrator and the Assistant Administrator for
OSWER is incomplete and inaccurate. In June 1989, we secured a
printout from the "Statutory Deadlines Tracking System", which con-
tained no record of the FY88 Annual Report. Furthermore, the
printout showed that the FY87 Annual Report was completed on
February 26, 1988, when, in fact, it was not signed by the Admini-
strator until over a year later. Without accurate and complete
monitoring information, officials responsible for signing the
Annual Report cannot ensure it is completed on time.
Finally, we are concerned that delays in the FY88 Annual
Report will delay future Annual Reports past the January due date
to Congress. Preparation of the FY89 Annual Report did not begin
until past the point in time necessary to meet the CERCLA deadline.
CERCLA states that the authorizing committees in Congress
will hold oversight hearings after receiving the Annual Report, to
ensure that the statute is being implemented according to the pur-
poses of the law and congressional intent. The delay in issuing
the FY88 Annual Report will not only delay that oversight process,
but also did not afford Congress the opportunity to consider any
needed action during the FY90 appropriations cycle.
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EXHIBIT
REVIEW OF REGIONAL RECORDS
71
LEGEND
HC-MQCDUL MOKWAL KQCDW.
PROGRAMS
MMJD FVK ACTONS
SOURCE MOMENTS N0T LOCOED
VWJD FYtt
15
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