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fEPAX
1611
OCX*
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON, D.C. 20460
August 25, 1994
OFFICE OF
THE INSPECTOR GENERAL
(V
MEMORANDUM
-
SUBJECT
FROM:
TO:
Consolidating Risk Reduction Engineering Laboratory -
Releases Control Branch (Edison, New Jersey) to
Cincinnati, Ohio
Special Review Report No. E1SKF4-02-0059-4400100
Elissa R. Karpf
Associate Assistant Inspector General
for Acquisition and Assistance Audits
Gary J. Foley
Acting Assistant Administrator
for Research and Development
We have conducted a special review to determine the feasibility
of restructuring the Office of Research and Development's Risk
Reduction Engineering Laboratory - Releases Control Branch (RREL-
RCB) from Edison, New Jersey to Cincinnati, Ohio. This review
was conducted as part of the Office of Inspector General's early
warning system program in accordance with OIG Manual chapter 150.
Action Required
In accordance with EPA Order 2750, you, as the action official
are required to provide this office with a written response to
the audit report within 90 days of the final report date. For
corrective actions planned but not completed by your response
date, reference to specific milestone dates will assist this
office in deciding whether to close this report.
We have no objections to the further release of this report to
the public. This report contains matters that describe the issues
the Office of Inspector General (OIG) has identified and
corrective action the OIG recommends. This report represents the
opinion of the OIG. Final determination on matters in this
report will be made by EPA managers in accordance with
established EPA audit resolution procedures.
Should you have any questions please contact Paul D. McKechnie at
(617) 565-3160, or Herbert Maletz at (212) 264-5730.
Recycled/Recyclable
Printed with Soy/CaneHa Ink on paper that
contain* at least 50% recycled fiber
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EXECUTIVE SUMMARY
Office of Research and Development's (ORD's) Risk Reduction
Engineering Laboratory-Releases Control Branch (RREL-RCB)
personnel could better serve the Agency by relocating and
consolidating the Releases Control Branch (RGB) located in
Edison, New Jersey, into the Cincinnati Risk Reduction
Engineering Laboratory (RREL). Currently RGB scientists are not
allowed to conduct any hands-on research activities at Edison
laboratories. Their present activities are limited to writing
and publishing technical papers, and making presentations at
meetings and conferences throughout the country. Also, RGB's
functions do not involve extensive site visits to hazardous waste
sites. In essence, the RGB scientist and engineer activities are
mostly confined to an office environment, rather than a
laboratory.
BACKGROUND
ORD personnel perform many functions including assisting other
agencies, universities, or industries in designing and conducting
environmental research; serve as consultants and provide
technical assistance in their field of expertise. RREL's primary
mission is to perform research to develop and demonstrate
engineered approaches and technologies for prevention, treatment,
and control of hazardous wastes, contamination in drinking water,
and pollution in surface waters and on the land. Over the years,
RGB staff had performed basic small scale research operations in
certain Edison buildings containing an analytical lab and a
facility for producing small quantities of synthetic soils. In
fiscal years 1987 and 1988, Congress approved funding for
building a research facility at Edison (Environmental Technology
and Engineering Center or E-TEC) to develop and evaluate
commercial-scale innovative technologies. However, in 1991 and
1992 local government and private citizens objections resulted in
Congress ordering RGB to stop the project. Subsequently, RGB's
principal research facility (building 245) was closed due to a
lack of funds to make health and safety improvements.
WE FOUND THAT
RGB is a field office for RREL-Cineinnati. Since 1970,
environmental technology research and development have been
conducted at the facility. RGB consists of the Branch Chief's
office and three sections (Technology Evaluation, Soil and
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Material Engineering, and Releases Technology) with total
staffing of 17 full-time employees (FTEs) and three permanent
part-time individuals. Each section is managed by a section
chief, and has four or five engineers and scientists.
We believe that the RGB function could be consolidated into RREL,
Cincinnati to improve overall operations and result in cost
savings to EPA. A significant amount of time and money was spent
for RGB trips to Cincinnati and RREL trips to Edison for
conferences or meetings whereas limited travel was related to
site visits. Currently most personnel perform extramural project
management functions acting as Project Officers or Work
Assignment Managers for about 13 cooperative agreements and 3
contracts. In essence, in recent years RGB personnel have
assumed a technical/professional administrator role. While they
still may perform "research", it is of a consultatory nature,
providing oral or written guidance or expertise or conducting
computer analysis. Their research is conducted in an office not
a laboratory environment. Two other RREL groups in Edison are
performing similar extramural project management functions and
technical desk-type "paper-oriented research".
WE RECOMMENDED THAT
The Acting Assistant Administrator for Research and Development:
Formulate and implement a plan to relocate RGB and two other
RREL functions from Edison, New Jersey to RREL Cincinnati.
Any relocation/consolidation should be initiated in phases
and coordinated with recommendations made by the MITRE
Corporation's Study of EPA Laboratories and Facilities. At
a minimum such plan should take into consideration the
following:
a. Gradual phasing out of Edison functions instead of
relocating the entire office at one time.
b. Some individuals might have to temporarily remain at
Edison to complete a specific project.
The Agency concurred with the findings and recommendations of the
report.
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TABLE OF CONTENTS
Page
EXECUTIVE SUMMARY i
PURPOSE, SCOPE AND METHODOLOGY 1
BACKGROUND 2
RESULTS OF REVIEW
The Releases Control Branch field office
located in Edison, New Jersey should be
relocated and consolidated into the
Cincinnati, Ohio Risk Reduction Engineering
Laboratory 5
A. BENEFITS OF CONSOLIDATING THE RGB
FIELD OFFICE - 7
B. ADVANTAGES AND DISADVANTAGES OF EDISON... 15
CONCLUSION 18
RECOMMENDATIONS 19
AGENCY RESPONSE 20
EXHIBITS
EXHIBIT A - RREL ORGANIZATION CHART 21
EXHIBIT B - RGB ORGANIZATION CHART 22
EXHIBIT C - RGB TRAVEL EXPENDITURES 23
APPENDICES
APPENDIX 1 - AGENCY RESPONSE 25
APPENDIX 2 - DISTRIBUTION 27
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PURPOSE. SCOPE AND METHODOLOGY
Pursuant to our survey covering activities at the Edison, New
Jersey facility, we commenced an audit of the Office of Research
and Development's Risk Reduction Engineering Laboratory (RREL)
Releases Control Branch (RGB) located at Edison, New Jersey.
During this audit, this special review was performed to determine
if RGB could better serve the Agency by being relocated to the
Cincinnati, Ohio RREL. The objective of this review was to
evaluate the work performed by the Edison RGB personnel and
determine the feasibility of relocating all or part of the staff
to the RREL Cincinnati, in fulfilling the Agency's mission.
To accomplish the review objective, we interviewed various RGB
management and non-management personnel to determine their
functions. We examined RGB and RREL travel authorizations and
vouchers from October 1992 through February 1994 to determine the
extent and purpose of travel performed. Special attention was
given to travel between RGB (Edison) and RREL (Cincinnati). In
addition, we reviewed vehicle utilization logs for RGB's two
Government vehicles.
We also received assistance from our Northern Audit Division's
Cincinnati office. They interviewed RREL personnel concerning
available space should the RGB function be relocated, and if any
relocation offers were made.
We performed this review from March 1 to April 30, 1994. The
review, scheduled to be covered in our overall audit, was
expedited to assist EPA's Office of Research and Development
(ORD) in the nationwide review of laboratory functions and
locations.
Due to its limited scope, this review does not represent an audit
in accordance with Government Auditing Standards (1988 Revision)
as required by the Comptroller General of the United States.
Accordingly, we did not review or evaluate the internal control
structure. We performed our review in accordance with the
procedures set forth in the Office of Inspector General Manual,
Chapter 150 "Special Reviews."
The conclusions, we reached in this special review are intended
to assist Agency personnel in their overall evaluation of the
Laboratory structure.
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BACKGROUND
EPA's ORD maintains 12 research laboratories, employing
approximately 1,300 people throughout the country. Each
laboratory director reports to an office director who reports to
the Assistant Administrator. Personnel at these laboratories
perform many functions including assisting other agencies,
universities, or industries in designing and conducting
environmental related research. ORD employees also serve as
consultants and provide technical assistance in their field of
expertise. RREL is one laboratory located in Cincinnati, Ohio.
RREL performs research to develop and demonstrate engineered
approaches and technologies for the prevention, treatment, and
control of hazardous wastes, contamination in drinking water, and
pollution in surface waters and on the land. RREL-Cincinnati has
four divisions:
o Drinking Water Research
o Superfund Technology Demonstration
o Water and Hazardous Waste Treatment Research
o Water Minimization, Destruction and Disposal Research
Within each division there are a minimum of three branches (see
Exhibit A for a detailed breakdown). RCB-Edison, New Jersey is a
field office of the Superfund Technology Demonstration Division
(STDD). RGB comprises the Branch Chief's office and three
sections:
o Technology Evaluation - examines new technologies as they
apply to Superfund hazardous-waste treatment.
o Soil and Material Engineering - performs research and
development involving soil. Specifically, examines .various
separation and extraction methods.
o Releases Technology - provides technical assistance in
numerous areas to EPA, other Federal agencies, State/local
governments, and other organizations.
Each section chief oversees a staff of four to six people. Total
staffing consists of 17 full-time employees (FTEs) and three
permanent part-time individuals (see Exhibit B). This averages
out to a worker/supervisor ratio of 4 to 1, well below the
National Performance Review's mandated 11 to l ratio. If part-
timers are excluded the ratio decreases to 3 to l which is
significantly below the Agency's current ratio of 5.5 to 1.
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RGB's function is to help develop and demonstrate innovative
treatment methods and equipment for cleaning and treating
hazardous waste. This function has entailed publishing reports
and technical papers, and making presentations at meetings and
conferences throughout the country. RGB staff had previously
performed basic small scale research operations in certain Edison
buildings containing an analytical lab and a small facility for
producing small quantities of synthetic soils.
In fiscal years 1987 and 1988, Congress approved funding for the
Environmental Technology and Engineering Center (E-TEC). This
project was intended to be a flexible research facility located
in Edison for developing and evaluating commercial-scale
innovative technologies for the treatment and destruction of
hazardous waste materials. However, in 1991 and 1992 local
government and private citizen objections prompted Congress to
cancel the project. We found that RGB currently does not perform
any "hands on" research involving soil testing or other small-
scale research at its facility. Instead, most personnel perform
extramural project management functions for approximately 13
cooperative agreements and 3 contracts.
In addition to RGB, three other RREL groups are located at Edison
(see Exhibit A). The Technical Assistance Section (TAS), part of
the Cincinnati Technical Support Branch, falls under the same
division as RGB (STDD). TAS' branch chief and four FTEs provide
technical assistance and support to Regions 1, 2, 3, 7, and 10
and the RGB sections. The Storm and Combined Sewer Program is
the second RREL group at Edison. The program involves, research
for the prevention and control of pollution from non-sewered
urban run-off and combined sewer overflow. This group, part of
the Water and Hazardous Waste Treatment Research Division-
Physical/Chemical Systems Branch, consists of two individuals who
perform research related to storm water and sewer overflows. The
third RREL group at Edison is the Quality Assurance Management
Staff (QAMS), Office of Modeling, Monitoring Systems and Quality
Assurance. This group consists of one chief and two former RGB ,
employees.
In 1982 and 1985, EPA conducted a study which evaluated the cost
and program implications of various laboratory consolidations
with the primary goal to reduce costs. However, most of the
findings and recommendations were not implemented. Also, the
Science Advisory Board's Fiscal Year 1992 report raised major
concerns including EPA's excessive reliance of on-site
contractors for research, attrition of Federal career scientists,
and obsolescence of equipment and facilities. These observations
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are also relevant at the present time.
The EPA Administrator recently prepared a Congressional budget
request to fund an external study of the ORD laboratories. The
Office of Research Program Management contracted the MITRE
Corporation to assess options to enhance the quality,
effectiveness and efficiency of EPA laboratory operations and to
provide flexibility to respond to current and future roles and
missions. The Study will examine such options as consolidation
of laboratories, laboratory/program realignment, improved
management practices, and shifts in resources. The Final Study
was due to the Agency on May 30, 1994.
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RESULTS OF REVIEW
The Releases Control Branch field office located in Edison, New
Jersey should be relocated and consolidated into the Cincinnati,
Ohio Risk Reduction Engineering Laboratory
Pursuant to the President's National Performance Review (NPR)
recommendations, EPA's streamlining plan, and the Office of
Research and Development's (ORD) February 7, 1994, plan for
"Redesigning Research at EPA," we believe the Agency can bring
about fundamental improvements by relocating and consolidating
the Releases Control Branch (RGB) located in Edison, New Jersey
into the Cincinnati Risk Reduction Engineering Laboratory (RREL).
Also, current RGB project management and other responsibilities
can be more effectively performed centrally in Cincinnati where
other RREL technical and administrative functions are located.
In addition, RGB staff expressed frustration over their increased
administrative responsibilities of managing extramural resources
and the lack of "hands on" laboratory research. Moreover, cost
savings in such areas as payroll, travel, equipment and supplies
could be achieved.
The NPR recommended that agencies streamline their operations and
reduce the ratio of managers/supervisors to other personnel. On
November 1, 1993, EPA submitted a Streamlining Plan to the Office
of Management and Budget {Improving Environmental Protection
through Empowered Employees). Each EPA office was also required
to prepare a plan for their organization. One aspect of EPA's
guidance to its program offices for reducing supervisory ratios
and making operations more efficient was to "consolidate small
divisions, branches and sections".' On February 7, 1994, ORD
prepared a report to the EPA Administrator: "Redesigning Research
at EPA" to meet the goals laid out by the President and the
Administrator regarding senior level positions, reducing
administrative burdens, increasing delegation and
decentralization, increasing the empowerment of ORD staff and
enhancing diversity, and improving opportunities for greater
productivity at all levels of the organization.
RGB is a field office for RREL-Cincinnati. Since 1970,
environmental technology research and development have been
conducted at the facility. RGB consists of the Branch Chief's
office and three sections {Technology Evaluation, Soil and
Material Engineering, and Releases Technology) with total
staffing of 17 full-time employees (FTEs) and three permanent
part-time individuals. Each section is managed by a section
chief, and has four or five engineers and scientists. Two other
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REEL groups are also located at Edison. First, the Technical
Assistance Section (TAS) is part of the Cincinnati Technical
Support Branch. Both RGB and this branch fall under the Superfund
Technology Demonstration Division (STDD) (Exhibit A).
TAS consists of a section chief and four FTEs. According to the
RGB chief, two staff members are considering transfers to the
Quality Assurance Management Staff (QAMS) (another Edison ORD
group). TAS project officers (POs) and work assignment managers
(WANs) provide technical support to Regions 1, 2, 3, 7, and 10,
and monitor cooperative agreements (CAs) and contracts. 'Second,
the Storm & Combined Sewer Program located at Edison consists of
a section chief who reports to Cincinnati, and one non-EPA
employee employed by the Oak Ridge Institute of Scientific
Education. The primary function of this group is to develop,
write and publish research papers and perform project management
functions.
Over the last 25 years, RGB personnel have made important
contributions towards the development of environmental technology
research and activities. Such research included development of
mobile technologies for cleaning of hazardous waste sites,
evaluation of technologies to contain and treat oil spills,
methods for preventing water pollution from urban stormwater
discharges and combined sewer overflows, and methods for
detecting and remediating leaking underground storage tanks.
Specific technologies developed at Edison include the Mobile Soil
Washer System, Mobile Incineration System, and Containment and
Cleaning of Mobile Oil Spills.
In 1987, EPA received congressional funding ($5.6 million) to
design and construct the Environmental Technology and Engineering
Facility (E-TEC) at Edison. However, in 1991 Congress,
responding to local public objections, eliminated E-TEC from
EPA's 1992 budget. As a result, RGB's previous "basic small
scale research operations" were eliminated due to lack of funds
to make health and safety improvements to Building 245 (RGB's
research facility).
RGB scientists and engineers can no longer work in any on-site
laboratories. In view of this situation, at a March 14, 1992,
meeting the Director, RREL offered RGB technical staff the
opportunity to transfer to Cincinnati to conduct research. RGB
is currently transferring some laboratory equipment to Cincinnati
and other Edison facilities, while discarding other items.
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A. BENEFITS OF CONSOLIDATING THE RGB FIELD OFFICE
1. IMPROVED MANAGEMENT STRUCTURE
The geographic locations of the Edison and Cincinnati facilities
makes laboratory management more complex. Relocating and
consolidating RGB with RREL-Cincinnati can provide a leaner
management structure, where the laboratory director could have
greater direct knowledge and control of daily operations,
planning, and administrative matters. Such direct, centralized
control can result in greater productivity and flexibility to
adapt to changes in research priorities with minimal disruption.
The combined personnel can be assigned to projects where they can
be more effectively utilized (i.e. matching assignment with .
individual's background). Also, some scientists can be released
from administrative work burdens and allowed to actively
participate in research projects.
ORD's February 7, 1994, plan of Redesigning Research at EPA {page
2-6} stated that individuals whose job is to do research must be
empowered to do so, without the current administrative and
project management encumbrances. It also indicated that in-house
scientists and extramural project managers could work together on
teams to design and conduct research. ORD believes, and we
agree, there are many advantages of using complementary groups of
centrally located project managers and bench scientists.
Collaboration and cooperation between these groups and
interaction with their commercial and academic peers will
"increase the effectiveness of both groups, significantly
increase the number of people actually doing research, and
enhance the way in which contracts and projects are managed."
Consolidation can reduce emphasis on departmental boundaries, a
primary goal for redesigning ORD's organizational structure.
Hence, the traditional division, branch-section structure,
prevalent in RREL-RCB's organization will be eliminated.
According to "Redesigning Research at EPA" ORD's new structure
would create a "flatter or more horizontally configured
organization" which is also "lean, delayered and more responsive"
and would promote more reliance on the "self-managing team as the
basic functional unit". It would also lead to significant
administrative streamlining since "There is widespread agreement
that ORD must simplify its policies, processes and procedures".
Under the current system "ORD technical staff feel increasingly
hamstrung by excessive administrative requirements - with a
general sense that there has been a resulting decrease in the
quality and quantity of scientific and engineering research and
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development" (pg. ES-5). We agree RGB scientists and engineers
should devote their talents by utilizing technical skills with
actual hands-on research. However, performing extensive project
monitoring and administrative functions prevent personnel from
such research activities.
Consolidation can also reduce layers of managers (i.e. branch or
section chiefs), which in turn reduces administrative burdens,
improves communication, and facilitates team spirit. For
example, if consolidated, TAS {RREL group at Edison), would have
direct interaction with Cincinnati branch members and a
management layer would be eliminated. Similarly, the two Storm &
Combined Sewer Program individuals are responsible for monitoring
the University of Alabama CA, and writing papers. This office
reports to the Chief, Water and Hazardous Waste Treatment
Research Division, Physical/Chemical Systems Branch, both in
Cincinnati. Relocating this office to Cincinnati will improve
branch and program office communication and create greater
research opportunities as the Edison staff could exchange ideas
and perform laboratory research with RREL scientists.
Consolidating RGB will also enable RREL to redesign and eliminate
traditional boundaries, reconfigure and simplify the
organizational structure, and establish a flatter organization
that can effectively utilize cross-disciplinary and cross-
laboratory teams.
Cincinnati is an ideal location with convenient air service to
attract employees. Its location next to the University of
Cincinnati (largest environmental engineering department in the
United States) enhances the use of cooperative agreements (CAs).
RRSL has ties with local universities including the University of
Dayton, Xavier, Wright State, and Ohio State. Also, the many
unique Federally owned facilities are convenient, collocation
with other Headquarters laboratories is beneficial to RREL's
program, and location of test facilities in industrial areas
enhances their operation. In addition, the incineration test
facility's remote location facilitates operation because of the
lack of public opposition.
2. RGB" RESEARCH ACTIVITIES
For almost 25 years, RGB scientists have performed a variety of
"research" activities. These activities have encompassed a wide
range of disciplines and functions to provide high quality,
timely, scientific and technical information, products and
assistance in support of Agency programs..
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Initially, the preponderance of their work was directed towards
actual in-house laboratory research dedicated to specific aspects
of environmental protection. However, more recently their hands-
on research has virtually ceased. Instead, their efforts were
changed from "beaker stirring" to monitoring the scientific and
technological performance of those outside the Agency. This has
occurred because of RGB's increased emphasis on extramural
research and rapidly diminishing internal assignments.
RCB scientists are generally senior level POs and WAMs (GS-13 and
above) who have assumed a technical/professional administrator
role. While they still may perform "research", it is of a
consultatory nature, providing oral or written guidance or
expertise or conducting computer analysis. Their "research" is
conducted in an office environment and not in a laboratory. In
addition, a significant portion of their time involves overseeing
project activities, not the performing of them. . This monitoring
of extramural contractors and CA recipients includes providing
technical assistance; reviewing project status, reports and
billings; preparing work assignments and modifications; attending
meetings and conferences; and discussing and resolving problems.
POs are primary technical representatives of EPA's contracting
officers responsible for initiating procurement actions,
evaluating proposals, assisting in Statement of Work preparation,
and reviewing progress reports. WAMs prepare and monitor work
assignments, and review technical and financial reports among
other items. RCB research effort are directed towards providing
contractors or CA recipients with technical direction/support.
Technical direction, defined by EPA Acquisition Regulations,
includes providing "direction to the contractor which assists him
in accomplishing the Statement of Work" and providing "comments
on and approval of reports or other deliverables." In effect,.
RCB "research" is limited to an office environment {reviewing
manuals, technical papers, etc.) as opposed to conducting tests
and experiments. As such, we believe POs and WAMs can be located
at Headquarters, regional offices or laboratories.
a. Opportunities For In-House Research
Consolidating RCB can strengthen ORD's in-house and extramural
research activities. RCB activities are primarily technical .
support oriented. To handle these activities efficiently, RCB
scientists and engineers need to constantly sharpen their
technical skill and knowledge by conducting research. The plan
of "Redesigning Research at EPA" outlined five research
components including Strategic and Program Support Research.
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Strategic research provides fundamental information about the
environment to be utilized by EPA or non-Federal customers. It
could include in-house or extramural research. In-house research
would focus on a few selected scientific aspects of environmental
problems, while extramural research would be conducted at
external institutions. Program support research, on the other
hand, provides support to EPA program offices, regions, States
and local agencies, and the private sector. Such research
includes both in-house and extramural research. Extramural
program support research is usually handled through contracts or
CAs with academic institutions or private organizations.
RGB personnel stated that their current functions were mainly
focused towards monitoring extramural activities rather than
actual laboratory hands-on research. RGB personnel are not being
used at their full potential since current research consists of
addressing environmental issues through publishing reports or
technical papers, making presentations, or attending symposiums.
Personnel commented they no longer perform hands-on research, and
are not allowed to "touch a test tube or shake the beaker."
RGB scientists no longer conduct research, the laboratory is
vacated, equipment is being shipped to other facilities, and
items are being excessed. We believe that after everything is
removed the laboratory will cease to exist. RGB scientists and
engineers, including the branch chief, expressed frustration at
the .lack of opportunity to carry on hands-on laboratory research.
Such frustration is detrimental to employee morale and adversely
affects productivity. • Through consolidation, ORD can better
utilize the talents of these scientists and fulfill its mission
of maintaining a high quality research program. Since innovation
and creativity is the basis of research, it should not be
confined within the office walls. A consolidated RREL can boost
employee morale, and create a unified organization with a diverse
scientific background under one roof.
RGB employees indicated a lack of research opportunities and at
times the need to set aside their technical "desk-type paper-
oriented research" for other priorities. For example, one
employee indicated she would like to devote more time to in-house
long-term research, but could not while providing administrative
and technical support. Another individual stated he frequently
had to set aside research and devote time to administrative or
clerical priorities. We believe consolidation can reduce such
interruptions as RREL will have more flexibility to select
individuals from a larger group of Cincinnati and Edison
.personnel for assigning administrative work. The RGB chief and
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other personnel indicated over the years many employees departed
and the Branch is short-handed.
Consolidation can significantly improve research by providing RGB
personnel the opportunity to conduct hands on research at the
RREL laboratory and broaden the exchange of ideas among fellow
scientists and additional outside academic institutions.
Moreover, personnel can now have daily interactions, and joint
projects with RREL scientists, which would" promote creativity and
enhance the quality of their research activities.
An RGB individual correctly described research as an
"intellectual business" of which exchange of ideas constituted a
vital part. Personnel can also enhance their present research
(primarily reading, writing and publishing reports). The
flexibility to switch between hands-on and desk-type research
will significantly increase the quality of these papers and
reports and enhance scientific skills in different areas.
b.. Improved Monitoring Of CA's And Contracts
The lack of funding for FTEs has resulted in an increasing
dependence on a contractor and CA recipient workforce (extramural
activities) to perform technical and research functions. As a
result, increased demands have been placed, on RGB to provide
oversight, thus reducing available time to perform research and
technical support functions. We believe such extramural research
activities can be performed effectively from Cincinnati.
RGB personnel currently monitor 13 CAs which represent 13 percent
of the total awarded by Headquarters to RREL from July 1991 to. '
September 30, 1993 (about 99). Approximately 68 percent of these
CAs are located within Regions 4 to 10 and 32 percent within
Regions 1, 2, or 3. On the other hand, RREL personnel monitor 27
CAs located in Regions 1, 2, or 3. It is evident that with "
improved telecommunication systems, effective monitoring is no
longer adversely affected by the distance of the recipient.
Recently three CAs were transferred from Edison to Cincinnati.
For example, the individual monitoring the Pulse Sciences CA
transferred to QAMS. Since RGB did not have a person available,
RREL had to take over the project. Similarly, the University of
Michigan, and Center for Hazardous Materials Research Center CAs,
previously monitored by RGB are now handled by RREL. The Branch
Chief stated that monitoring of CAs/contracts and/or other
functions that RGB personnel perform, could be efficiently
monitored from Cincinnati, or any other place.
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We believe that through consolidation CA monitoring can be
improved in addition to in house research .activities. RREL could
have more flexibility to assign CAs to individuals based on the
location, their specialization, or other pertinent factors. This
would reduce travel expenses as explained in subsequent
paragraphs. Similar arguments would be valid for RGB contracts.
Consolidation could also improve other extramural project
management activities involving making informed decisions based
on reviewing reports or researching data. With improved
telecommunications, problem resolution and overall extramural
project management could be handled effectively from Cincinnati
through Local Area Network (LAN), faxes and teleconferences.
3. IMPROVED HANDLING OF ADMINISTRATIVE MATTERS
Consolidation can improve general administrative matters such as
maintaining employees', time and attendance records; resolving
payroll issues; preparing, approving, and processing travel
documents; ordering supplies; ordering and repairing equipment;
etc. Currently RGB has one permanent Federal employee (Executive
Secretary) handling these functions and utilizes a contractor for
.administrative support functions such as preparing travel
vouchers, typing letters, telefaxing, photocopying, filing,
handling overnight mail, E-mail, etc.
When' using contractor personnel, RGB employees prepare a time
consuming Work Request Sheet. Consolidation can alleviate this
.problem, as there can be a cadre of experienced administrative
personnel available to perform these functions. The five-year
contract (approximately $250,000 per year) will expire on
September 30, 1994, and RGB is planning to use the American
Association of Retired Personnel (AARP) to perform this function
at Edison. In addition, expenses related to sending memoranda,
packages, etc. to and from Cincinnati can be reduced.
Consolidation -can provide RREL the opportunity to redesign its
administrative work force and improve efficiency.
4. REDUCTION IN TRAVEL EXPENDITURES
Consolidation can result in reduced expenditures especially
.traveling between Edison and Cincinnati for meetings, training,
and administrative matters. Our analysis of RGB travel from
October 1, 1992 to February 28, 1994, (16 months) disclosed 17
employees traveled (148 trips) at a cost of $98,193 throughout
the United States and Canada. We concentrated on 127 trips
($87,049) as the remaining trips were for training, or no
explanation was noted on the travel authorization.
12 Audit Report: E1SKF4-02-0059-4400100
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RGB personnel travelled to other regions and/or Headquarters
(RREL-Cincinnati and Washington DC) for 118 of these 127 trips
(see Exhibit C). Further analysis indicated that 96 trips
($63,288) were for meetings or conferences and 21 trips for site
visits or technical support. However, only one trip was to a
Region 1, 2, or 3 site. RGB's branch and section chiefs traveled
to RREL on 17 trips ($9,703) to attend meetings. These four
managers.often traveled together for these meetings. For
example, all four traveled between October 31, and November 2,
1993 to RREL "for a meeting ($2/031). Also, RREL paid an
additional $650 for costs of this trip. Other individuals also
traveled from RGB together. For example, from July 21 to July
23, 1993, six RGB individuals traveled to RREL for meetings
($3,818). Consolidation would eliminate such trips.
We also reviewed 27 RGB local travel vouchers totalling $573 for
the same period. Twelve vouchers were for reimbursement of tolls
for Government vehicles. By eliminating training expenses we
concentrated on 18 trips ($357). We found that 12 trips were for
meetings or conferences and only three trips were to a Region 2
site. Additionally, we examined local travel for RGB's two
Government cars from December 1992 to March 1994. These vehicles
were used on 76 occasions, accumulating 4,366 and 4,739 miles.
Most trips were within New Jersey with a few to New York and
Pennsylvania, for site visits and meetings, it should be noted
that General Services Administration (GSA) regulations (41 CFR
101-39.3) requires leased vehicles to be driven at least 1,000
miles per month (12,000 per year). As both vehicles travelled
about 4,000 miles for the 15 month period, they were
significantly underutilized and should have been returned to GSA.
Conversely, we reviewed RREL Cincinnati travel to Edison, New.
York City or the surrounding area for the same 16 month period.
During this period, 43 employees made 73 trips at a cost "of
$50,312. Our review concentrated on 53 trips ($34,719) as the
remaining ones were for training or reasons not explained. We
found 21 of these trips were for site .visits or technical support
and 32 trips were for meetings or conferences. Analysis of
travel by RREL's director and division chiefs with Edison
sections or branches disclosed three individuals traveled 12
times to Edison ($6,713). Most of these trips involved meetings
to discuss RREL or branch activities. For example, the Technical
Support Branch Chief in Cincinnati made five trips to Edison to
meet with the TAS Chief, resulting in expenditures of $2,831.
Several RGB officials advised that travel was more extensive when
actual "hands on" research was performed. However, with the
discontinuance of such research, travel has been reduced. A vast
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majority of their expenditures during the review period were for
meetings or conferences (local and non-local travel of $63,500).
Furthermore, there were 22 Edison trips to RREL alone ($13,400)
for meetings or conferences.
While we recognize trips to Superfund sites were necessary, our
review indicated such travel was infrequent. The majority of
travel was for meetings or conferences. Accordingly, we believe
through relocating RGB staff to Cincinnati, and utilizing
teleconferencing, LAN networks, and facsimile machines, EPA could
have realized a potential savings of at least $32,300 (for the 16
month review period) in scarce travel funds. This represents
$24,000 for Cincinnati and Edison conferences or meetings and
$8,300 by consolidating RGB and RREL training.
Furthermore, significant time could, have been saved in preparing,
approving and processing the numerous travel authorizations and
vouchers. Such administrative time could have been utilized more
effectively on program related operations. Additionally, related
travel time saved could result in higher productivity. For
example, time travelling to the airport, awaiting departure,
flying time (at least two hours), renting a vehicle, driving to
the meeting, etc. can waste at least five hours on a trip. The
same time loss would-occur on the return trip.
Another benefit of consolidation could be reduced payroll
expenses because of a lower locality pay adjustment than
currently offered in the New York area. We compared current
salaries of Edison employees and what they would be if relocated
to RREL Cincinnati. Currently, the 24 Edison employee's annual
compensation totals $1,464,289 (salaries for one secretary and
one clerical position were not considered). If all employees
relocated to Cincinnati, compensation would be reduced to
$1,411,337, (annual decrease of $52,952). Additional savings
would also occur due to reductions in the Government's
contributions to the Thrift Savings Plan contributions for
employees under the FERS retirement system.
We realize all employees may not wish to relocate and additional
savings may be realized by retirements or individuals leaving the
Agency. Specifically, 18 of the 24 RREL individuals at Edison
are GS-13 or above, 10 have more than 20 years of Government
service, and three will attain 20 years in early 1995. Also,
three individuals below GS-13 have more than 20 years of service.
As Congress has permitted agencies to offer an employee early-out
'option, several individuals may accept the offer. The
possibility that some personnel will leave the Agency will permit
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individuals to be hired at lower grades. Such actions will
further reduce Agency payroll and help achieve the mandated
personnel reductions.
B. ADVANTAGES AMP DISADVANTAGES OF EDISON
While there are reasons for moving Edison functions to
Cincinnati, there are also advantages for remaining. The RGB
chief presented these benefits.
o Edison personnel are close to problems they are called
upon to solve; and near clients, including their peers
in private industry.
o Edison is close to important projects and researchers
in universities, colleges, and the Northeast Hazardous
Substance Research Center.
o Edison provides excellent, low cost travel.
o RCB has an established base of important, successful
programs and experienced personnel with a strong track
record of high quality scientific work.
o Edison has existing fixed facilities owned by EPA and
ample space to support new activities.
However, while there may be some merit to these points our
analysis has drawn some different conclusions. Edison scientists
have made a significant contribution over the years. . Since
laboratory research has ceased, consolidation can provide RCB
personnel the opportunity to enrich their past record with
greater-future contributions. Moreover, considering the*
Presidential Executive Order, "Streamlining the Bureaucracy", and
the Study to assess EPA's laboratories and facilities (February
11,. 1994), restructuring is not only feasible but highly - -
desirable. Such action can promote more efficient operations and
result in cost savings. The Study states "how they
(laboratories) came to be located where they are is less
important than whether the present locations contribute to .or
detract from the efficient performance of. EPA science functions
and missions both at the laboratory level and at the agency
(system) level." ORD should reevaluate RGB's current
geographical location and determine whether there is a better
arrangement. We believe the benefits of consolidation outweigh
the concerns for retaining activities at Edison.
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Most RGB concerns refer to the proximity of Edison to the
"subjects" of their research, clients and peers in private
industries, and low cost travel facilities to various places. We
acknowledge that New Jersey has a large percentage of Superfund
sites, a large concentration of petrochemical and pharmaceutical
companies, and its industries produce large quantities of
hazardous and toxic substances. However, we question whether the
location of these sites or institutions significantly contribute
to RGB's "research" activities.
Interviews and document reviews disclosed research activities
were generally conducted by outside organizations (e.g.
universities) under CAs. Most section chiefs and scientists
stated that CAs/contracts require less control, oversight, and .
travel as the recipient performs the research. Personnel
indicated that at the beginning of a project they might accompany
the recipient (or contractor) once to observe sampling
procedures. Afterwards, the recipient performs research at their
laboratories and sent RGB the results for review. RGB office
personnel review reports, perform analyses, and make decisions by
relying on computers, E-mail or memoranda. For example, the RGB
engineer monitoring one contract stated he never visited the
contractor, a statement verified by travel records for 16 months.
He further emphasized that all his work is performed through
computer or conference calls from his office. It is interesting
to note that the contractor's office is at Cincinnati, but the
contract is being monitored from Edison.
Although most RGB personnel stated they only traveled
occasionally, one WAM stated he made "regular" site visits mostly
to Dover, N.J. to monitor a contractor. However, review of his
travel for 16 months disclosed only two trips to Dover. Although
these two trips lasted for 11 days, they were far from "regular"
visits. The same individual also subsequently stated that-he
spent "most of his time at Edison and can do technical, research-
oriented work from his office." Another WAM responsible for the
same contract categorically stated her monitoring
responsibilities did not involve anv travel. Similarly, other
individuals (including former RGB personnel), indicated they
generally did not make site visits. The RGB branch chief also
commented that monitoring CAs did not generally require
substantial direct involvement or frequent visits.
RGB contacts with research institutions were primarily maintained
through telephone or memoranda. While there may be occasions for
visits to a specific institution, these trips were sporadic.
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Therefore, we do not believe it is imperative that RGB personnel
remain in Edison to maintain such contacts. RGB can easily
continue their rapport with institutions and maintain effective
communications from Cincinnati.
Another point raised for continuing the RGB-Edison function was
the recent remediations technology field experiments conducted in
collaboration with the Edison Emergency Response Team (ERT). Two
such projects were executed during 1992-93 in Alabama and Florida
and contractors performed the actual work. We realize that at
the initial stage RGB and ERT communication was essential and
made easier by the joint location, but we do not believe it was
critical for RGB personnel to be physically located at Edison.
If personnel were at Cincinnati, planning could have been
performed with equal effectiveness. Additionally, it was noted
that these joint projects were infrequent, and did not constitute
a major portion of RGB's work.
The Edison area generally offered low cost travel to many major
cities, and use of Amtrak provided savings to Washington D.C.
However, when comparing actual travel time, we found Cincinnati
to be more convenient, allowing personnel to spend less travel
time and more research time. For example, RGB personnel made
five trips to Houston, Texas with cost savings {as compared to
Cincinnati) of about $50 per flight. However, traveling from
Cincinnati would have saved an estimated 1 hour and 30 minutes
per flight. While the dollar savings were minimal, the time
saved could have been substantial. RGB's statement that $300
could be saved by using Amtrak to Washington rather than flying
from Cincinnati may be valid, however, Amtrak was rarely used.
Our review identified only 8 of 31 Amtrak trips to Washington,
D.C. The remaining 23 trips were by air,, and did not provide the
savings claimed. We found the actual savings amounted to only
$71 ($4l2-$34l) per trip.
We recognize the uniqueness of the Edison Underground Storage
Tank (UST) facility and RGB contributions in projects related to
this program. We also realize that major funding was approved
for conducting extramural research in leak detection, leak
prevention and corrective actions. Oversight of these agreements
will constitute collaborative research between the Department of
Energy, Department of Defense, and EPA. Although some UST
functions might temporarily remain at Edison, all Releases
Technology Section personnel might not be directly involved.
For example, one individual stated his contract oversight work
could be performed from his office. Since such activities would
likely involve other agencies, arrangements could be made whereby
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these agencies could be more involved with the research aspect
and EPA with the monitoring. We believe that a gradual phase-out
process could be initiated without jeopardizing UST program
operations.
The Edison facility is EPA's largest piece of real estate with
extensive space for expansion. However, to make effective use of
this land, EPA would have to repair or construct new buildings or
laboratories. In view of limited funding, local government
objections, and Federal cutbacks, this does not appear to be a
viable option. In fact, prior efforts to repair these buildings
were unsuccessful. Edison buildings are also occupied by Region
2's Environmental Services Division, Emergency and Remedial
Response Division, and the Facilities office,- and Headquarters'
Emergency Response Team, and Quality Assurance Management Staff.
Also, office trailers house EPA groups or contractors. Many of
these buildings are old and deteriorating, in fact, Building 245
(RGB's research facility) has been closed due to a lack of funds
to make health and safety improvements. Through consolidation
the existing RGB space could be effectively used by the remaining
groups.
The RREL Director and Deputy Director and the Deputy Director,
Office of Administration and Resource Management (OARM) stated
they have the space to accommodate 26 RGB personnel. The RGB
branch chief also informed us that he had considered moving the
two-trailer Volume Reduction Unit to the Test and Evaluation
(T&E) facility at Cincinnati, but no space was available. After
discarding old equipment RGB might have about eight other
equipment mounted trailers and one stakebody truck which might be
cost effective to move. The Deputy Director, OARM informed us
that the T&E facility (close to RREL) might not be able
accommodate these trailers. However, they could be stored at
other Cincinnati locations and moved to the site when needed.
OARM could arrange space for storing all these trailers.
CONCLUSION
We believe that restructuring the RREL-RCB function is not only
feasible but highly desirable. Such consolidation is responsive
to the NPR's recommendation to reduce the ratio of managers/
supervisors to other personnel, simplify the internal
organization and administrative processes, improve the quality of
services, raise morale and productivity and realize cost savings.
Our consolidation proposal addresses all these matters, but
emphasizes that the RGB scientists will now be allowed to perform
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scientific research as opposed to extramural project monitoring
and administrative activities. ORD's plan for Redesigning
Research at EPA stated that individuals must be empowered to do
research, without today's administrative and project management
encumbrances. By encouraging excellence in both bench science
and extramural project management, ORD can increase the
effectiveness of both groups, significantly increase the number
of people actually doing research, and enhance the way in which
contracts and projects are managed.
We recognize the achievements of RGB personnel, certain
advantages of the Edison location, the potentiality that some
individuals may retire or leave RREL or the Agency rather than
relocate, and temporary short-term disruptions. However, these
factors should not detract from the many advantages under a
leaner management structure. We believe that an implementation
plan should be prepared for a phased approach to accomplish this
consolidation. Although it may be beneficial for certain
individuals to "temporarily" remain at Edison, the number should
be kept at a minimum. The implementation plan should be prepared
together with the recommendations of the Study to Assess EPA's
Laboratories and Facilities due in May 1994.
RECOMMENDATIONS
We recommend that the Acting Assistant Administrator for Research
and Development:
Formulate a plan to relocate the RGB and two other RREL
functions from Edison, New Jersey to the RREL Cincinnati.
Any relocation/consolidation should be initiated in phases
and coordinated with recommendations made by the MITRE
Corporation's Study of EPA Laboratories and Facilities.
To keep disruptions to a minimum such plan should include a
gradual phasing out of these functions instead of relocating
the entire office at one time. Also, some individuals might
have to temporarily remain at Edison to complete a specific
project.
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AGENCY COMMENTS AND PIG EVALUATION
The Agency concurred with our findings and accepted the report
recommendations. The response noted that an external study of
ORD laboratories was underway and as a result the role, mission,
and functions of RREL-RCB Edison was under active consideration.
We were pleased with ORD's positive response to our report. Once
the results of the external study are also analyzed, we believe
ORD needs to prepare a plan with specific milestones for any
relocation/consolidation contemplated.
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EXHIBIT B
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APPENDIX 1
WASHINGTON, D.C. 204SO
JJL I 2 1994 offcs,s»
RESEARCH ANQ DEVELOPMENT
MEMORANDUM. . . . :. -
SUBJECT: Consolidating Risk Reduction Engineering Laboratory
Releases Control Branch (Edison, New Jersey) to
Cincinnati, Ohio
Sc-ecisl Review Report No. E1SKF4-02-0059
FROM: Gary J. Foley ^ N-
Acting Assistant AJd
for Research and Development (8101)
TO: Slissa R. Karpf
Associate Assistant Inspector General
for Accruiaition and Assistance Audits (2421)
Dhank you for the opportunity to review ana comment on the
mentioned report. " We concur with the findings and accept
Thar
above
the recommendations as stated. However,, as you notad in the
Report, an external study of the ORD laboratories is underway and
as* a result the 'role, mission and functions of the Releases
Control Branch ^Edison) is under active consideration.
Attached for your information -is the response from the
Office of Environmental Engineering and Technology Demonstration.
This attachment is not to be considered as ORD's official
response. • "
Attachment
cc: Clarence S. Mahan
Thomas L. Hadd
Alfred Lindsey
Timothy Oppelt
ORD Audit Follow-up Coordinator
-25-
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APPENDIX 1
26
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APPENDIX 2
REPORT DISTRIBUTION
Office of Inspector General
Inspector General (2410)
Deputy Inspector General (2410)
Chief, Resources Management Unit (2421)
EPA Headquarters
Assistant Administrator for Administration and Resources
Management (3101)
Director, Office of Research Program Management (8102)
Audit Liaison, Office of Research and Development (8102)
Director Office of Environmental Engineering and Technology
Demonstration (8301)
Agency Followup Coordinator (3304)
Attn: Director, Resource Management Division
Agency Follow-up Official (3101)
Laboratory
Chief, Releases Control Branch for the Superfund Technology
Division
Edison, New Jersey
Director, Risk Reduction Engineering Laboratory
Cincinnati, Ohio
External
General Accounting Office
27
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