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350 ieo^ UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Łą \ OFFICE OF INSPECTOR GENERAL
5 CENTRAL AUDIT DIVISION
? 726 MINNESOTA AVENUE BRANCH OFFICES:
KANSASCITY KANSAS66101 1445 ROSS AVENUE, SUITE 1200
913-551-7878 DALLAS, TEXAS 75202-2733
FAY- Q11*
No. L006515-05 Awarded to the Texas Natural $>
Resource Conservation Commission p
Audit Report No. E3LLL7-06-0031-8100040 rf C-:
FROM: Bennie S. Salem /U*^^^^-^-w^_. & <~ & ?
s .
Divisional Inspector General ./Ł. /?'
TO: Jerry M. Clifford ^^ § $
Acting Regional Administrator
Region 6
Attached is our audit report concerning the Leaking Underground Storage Tank (LUST)
Cooperative Agreement Nos. L006515-91, L006515-04, and L006515-05 awarded to the Texas
Natural Resource Conservation Commission (TNRCC). The primary objectives of this audit were
to determine whether TNRCC adequately accounted for the LUST Trust Fund monies and complied
with the LUST cooperative agreement special conditions. This report contains findings and
recommendations that are important to both the Environmental Protection Agency (EPA) and
TNRCC.
This audit report contains findings that describe problems the Office of Inspector General
(OIG) has identified and corrective actions OIG recommends. The report represents the opinion of
OIG, and the findings contained in this report do not necessarily represent the final EPA position.
Final determinations on matters in this report will be made by EPA managers in accordance with
established audit resolution procedures.
Action Required
In accordance with EPA Order 2750, you, as the action official, are required to provide us
within 90 days, a report on the actions you plan or have taken as a result of our
RECYCLED
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recommendations. Your response and the TNRCC response to the draft report were sufficient to
satisfy this requirement. Consequently, we are closing this report upon issuance.
If you wish to discuss this report, please contact me at (913) 551 -7831 or Dave Boyce, Audit
Manager in our Dallas office, at (214) 665-6620. Please refer to the report number on all related
correspondence.
Attachment
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Audit of LUST Cooperative Agreements Awarded to the
Texas Natural Resource Conservation Commission
EXECUTIVE SUMMARY
PURPOSE
The primary objectives of our audit were to determine
whether:
costs claimed were allowable, allocable, and
reasonable under the cooperative agreements; and
TNRCC complied with federal laws, regulations,
and cooperative agreement special conditions.
BACKGROUND
The Superfund Amendments and Reauthorization Act (SARA)
of 1986, Section 205, amended the Solid Waste Disposal Act
and established the Leaking Underground Storage Tank
(LUST) Trust Fund to finance the cleanup of petroleum
releases from underground storage tanks.
SARA authorized EPA to provide LUST trust funds to the
states for the cleanup of leaking underground storage tanks
through cooperative agreements. The agreements identify the
amount of funds allocated to each state and establish LUST
program performance requirements. States may use the trust
fund to finance:
the cost of site corrective action;
enforcement action taken to compel owners and
operators (responsible parties) to take corrective
action;
oversight of responsible party lead cleanups;
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cost recovery efforts of trust fund expenditures from
responsible parties; and
reasonable and necessary administrative expenses
directly related to the above activities.
RESULTS IN BRIEF
In our opinion, the $19.8 million of costs claimed were
allowable, allocable, and reasonable under the cooperative
agreements.
In general, TNRCC complied with applicable federal laws,
regulations, and cooperative agreement special conditions.
However, TNRCC has not recovered any of the $32 million
of federal funds spent on approximately 1139 sites since 1987.
Funds were not recovered by TNRCC primarily because the
funds were used at sites that resulted in minimal recovery
potential; i.e., sites with multiple responsible parties,
financially incapable responsible parties, or unknown
responsible parties. Secondly, TNRCC had not established an
effective cost recovery program. We identified several
deficiencies hindering the effectiveness of TNRCC's cost
recovery program, including the lack of adequate procedures
for:
accounting for complete site-specific cost;
issuance, tracking, and followup of demand letters;
and
documenting decisions regarding cost recovery
actions.
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RECOMMENDATION We recommend that the Acting Regional Administrator work
with TNRCC to develop and implement an effective cost
recovery program that a minimum includes procedures that
ensure:
site-specific accounting for all identifiable
costs;
issuance, tracking, and followup of demand
letters; and
formal documentation of cost recovery
decisions.
AUDITEE'S COMMENTS TNRCC generally agreed with our findings and
recommendations and provided that a task force had been
created on its own initiative, during the summer of 1997. The
task force recommended an entire process for cost recovery,
for which TNRCC is currently adopting formal cost recovery
procedures and is developing the baseline data that will be
used to measure future cost recovery efforts.
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Audit of LUST Cooperative Agreements Awarded to the
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TABLE OF CONTENTS
Page
EXECUTIVE SUMMARY i
ABBREVIATIONS v
INTRODUCTION 1
OBJECTIVES 2
RESULTS OF AUDIT 2
OPINION 2
REPORT ON COMPLIANCE AND INTERNAL CONTROLS 3
CONCLUSION 6
RECOMMENDATION 6
AUDITEE COMMENTS 7
OIG EVALUATION 8
BACKGROUND 8
SCOPE AND METHODOLOGY 9
APPENDICES
APPENDIX I - TNRCC COMMENTS 11
APPENDIX H - DISTRIBUTION 13
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Audit of LUST Cooperative Agreements Awarded to the
Texas Natural Resource Conservation Commission
EPA
FSR
LUST
OIG
OSWER
SARA
TNRCC
Abbreviations
Environmental Protection Agency
Financial Status Report
Leaking Underground Storage Tank
Office of Inspector General
Office of Solid Waste and Emergency Response
Superfund Amendments and Reauthorization Act
Texas Natural Resource Conservation Commission
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Audit of LUST Cooperative Agreements Awarded to the
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INTRODUCTION
The Superfund Amendments and Reauthorization Act
(SARA) of 1986, Section 205, amended the Solid Waste
Disposal Act and established the Leaking Underground
Storage Tank (LUST) Trust Fund to finance the cleanup of
petroleum releases from underground storage tanks.
SARA authorized the Environmental Protection Agency
(EPA) to provide LUST trust funds to the states for the
cleanup of leaking underground storage tanks through
cooperative agreements. The agreements identify the
amount of funds allocated to each state and establish LUST
program performance requirements. States may use the
trust fund to finance:
the cost of site corrective action,
enforcement action taken to compel
owners and operators (responsible
parties) to take corrective action,
oversight of responsible party lead
cleanups,
* cost recovery efforts of trust fund
expenditures from responsible
parties, and
reasonable and necessary
administrative expenses directly
related to the above activities.
Based on the results of our survey of LUST cooperative
agreements awarded by Region 6, we initiated a financial
and compliance audit of the Texas Natural Resource
Conservation Commission (TNRCC) LUST cooperative
agreement nos. L006515-91, L006515-04, and L006515-
05. These cooperative agreements were selected because
they had not been subject to prior review.
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Audit of LUST Cooperative Agreements Awarded to the
Texas Natural Resource Conservation Commission
OBJECTIVES
The primary objectives of our audit were to determine
whether:
costs claimed were allowable,
allocable, and reasonable under the
cooperative agreements; and
TNRCC complied with federal laws,
regulations, and cooperative
agreement special conditions.
RESULTS OF AUDIT
OPINION
In our opinion, the costs claimed were allowable, allocable,
and reasonable under the cooperative agreements. The
results of our analysis are summarized below.
Cooperative
Agreement No.
L006515-91
L006515-04
L006515-05
Total
Costs Claimed
and Accepted
(Note 1)
$12,907,780
3,877,975
3.022.755
SI 9.808.510
EPA Payments as of
October 24, 1996
Allowable EPA Share
Balance Due
$19,808,510
19.808.510
$ 0
Note 1. This column represents costs TNRCC claimed on
its final Financial Status Reports (FSR), dated November
22, 1994, for cooperative agreement no. L006515-91 and
December 3, 1996, for cooperative agreement no.
L006515-04. The amount shown for cooperative
agreement no. L006515-05 represents costs claimed on
TNRCC's interim FSR, dated October 24, 1996.
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Audit of LUST Cooperative Agreements Awarded to the
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REPORT ON
COMPLIANCE AND
INTERNAL CONTROLS
TNRCC Needed an
Effective Cost Recovery
Program
Accounting for
Site-Specific Costs
In general, TNRCC complied with applicable federal laws,
regulations, and cooperative agreement special conditions.
However, TNRCC had not recovered any of the $32 million
of federal funds spent on approximately 1139 sites since
1987. Funds were not recovered by TNRCC for two
primary reasons. First, funds were used at sites with
minimal recovery potential; i.e., sites with unknown
responsible parties, financially incapable responsible parties,
or multiple responsible parties for whom responsibility
could not be clearly determined. Second, TNRCC had not
established an effective cost recovery program.
Our review disclosed several deficiencies hindering the
effectiveness of TNRCC's cost recovery program, including
the lack of adequate procedures for:
accounting for complete site-specific cost;
issuance, tracking, and foilowup of demand
letters; and
documenting decisions regarding cost
recovery actions.
Office of Solid Waste and Emergency Response (OSWER)
Directive 9610.10A, as referenced in the cooperative
agreements, require states to maintain site-specific
accounting for all costs of corrective and enforcement
actions and to contact responsible parties about their
liability and demand payment. Further, EPA guidance
requires states to fully document all decisions regarding cost
recovery.
TNRCC had not established adequate procedures to
account for all site-specific costs paid with LUST trust
funds. Site-specific records primarily documented the costs
of cleanup activities performed by contractors, but in
general, did not include TNRCC's salary costs for program
activities, such as administration, corrective action,
inspection, enforcement, and responsible party remediation.
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By not accounting for all site-specific costs, TNRCC
reduced the total recoverable costs.
The cooperative agreements specifically required and
provided funds for the organization and maintenance of site-
specific information on activities and costs funded by the
LUST trust fund. Additionally, OSWER Directive No.
9610.10A, dated May 24, 1994, requires site-specific
accounting for:
...all costs of corrective action and enforcement,
including interest, indirect and "management and
support" costs associated with these activities that
are paid for by the Trust Fund...
We found that, although a majority of the work performed
by program staff represented corrective action and
enforcement activities, only two employees charged their
time as site-specific. All other employee time charges were
to more general project cost allocations.
We were informed by TNRCC management at the
conclusion of our fieldwork that new timekeeping
procedures requiring the use of site-specific project cost
allocations by all petroleum storage tank staff were being
implemented.
Issuance, Tracking, and TNRCC had not established adequate procedures for the
Followup of Demand issuance, tracking, and subsequent followup of demand
Letters letters issued to responsible parties for payment of costs
incurred for corrective action and enforcement activities.
As a result, demand letters were rarely issued.
Cost recovery efforts mainly consisted of initial notification
letters to potentially responsible parties to advise them that
their facility might be a source of contamination and they
might be liable for cleanup costs incurred. Even though $32
million had been spent on approximately 1139 sites, we
learned from program staff that fewer than 10 demand
letters had been issued since the program inception in 1987.
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OSWER Directive 9610.10A provides that in each case
states should make reasonable efforts to contact owners and
operators who are liable for releases, notify them of their
liability for enforcement and corrective action costs, and
demand payment.
On November 8, 1994, EPA issued a memorandum
providing clarification of OSWER Directive 9610.10A. The
memorandum provided that demand letters should be issued
if a responsible party is located. If a responsible party is
, determined to be financially unable and a formal
determination of insolvency is made, the determination may
be used to document that a demand letter is not necessary.
At the conclusion of our audit fieldwork, we learned that
new procedures requiring the issuance, tracking, and
followup of demand letters are under consideration by
TNRCC. In the case of multiple responsible parties, the
procedures would require demand letters be issued to all
parties, requesting the individuals work out their respective
liability. Alternately, TNRCC would retain the authority to
request the Attorney General take action to determine
liability in instances where the parties could not come to
some agreement.
Documenting Cost TNRCC had not established procedures for adequately
Recovery Actions documenting cost recovery actions. Therefore, project
records did not always reflect decisions made on cost
recovery actions. While the project records sometimes
indicated the reasons for not pursuing cost recovery, no
formal documentation of cost recovery decisions was
included.
In its November 8, 1994 memorandum discussing the LUST
cost recovery policy, EPA acknowledged that certain
situations would warrant a state not issuing a demand letter.
In those cases, however, the states should ensure that the
bases for any compromise or termination of trust fund
claims were adequately supported in the records of the state
and reflected the efficient use of trust fund resources. The
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Audit of LUST Cooperative Agreements Awarded to the
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memorandum further provided that regardless of the action
taken by the state in exercising its discretion in cost
recovery cases, the state is required to fully document its
decision and to formally close out all cases.
CONCLUSION
An effective cost recovery system is important to ensure
that funds are available to pay for future LUST cleanup
activities. Specific procedures such as site-specific
accounting; the issuance, tracking, and followup of demand
letters; and the documentation of cost recovery actions are
vital elements to the development of an effective cost
recovery program and to maximizing the amount of funds
that can be recovered.
Recognizing the need to establish an effective cost recovery
system, TNRCC has begun instituting procedures to address
weaknesses in its cost recovery program.
RECOMMENDATION
We recommend that the Acting Regional Administrator,
Region 6, work with TNRCC to develop and implement an
effective cost recovery program that at a minimum includes
procedures that ensure:
accounting for all identifiable site-specific
costs;
issuance, tracking, and followup of demand
letters; and
formal documentation of cost recovery
decisions.
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Audit of LUST Cooperative Agreements Awarded to the
Texas Natural Resource Conservation Commission
AUDITEE COMMENTS TNRCC generally agreed with our findings and
recommendations and provided that a task force had been
created during the summer of 1997. The task force
recommended a process for cost recovery. TNRCC is
currently adopting formal cost recovery procedures and is
developing the baseline data that will be used to measure
future cost recovery efforts.
TNRCC's specific comments to the individual findings
and recommendations are summarized as follows.
Accounting for Site Specific Costs. TNRCC responded that
detailed site information was kept for the direct costs of site
investigations and emergency actions. Additionally,
TNRCC stated that it is in the process of creating specific
program cost account numbers for capturing indirect costs.
Program cost account numbers had only been used in a
limited number of cases until recently. TNRCC anticipates
that the indirect costs will represent only a fraction of total
site costs.
Issuance, Tracking and Followup of Demand Letters.
TNRCC acknowledged that only a limited number of
demand letters had been mailed to responsible parties. The
process for the issuance and followup of demand letters was
considered as part of the task force recommendations and
subsequent procedures.
Documenting Cost Recovery Actions. TNRCC
acknowledged that a formal memorandum documenting
cost recovery actions had not been prepared for each site.
However, it emphasized that there was no statute of
limitations to complete this process and that TNRCC had
plans to pursue this action further and to fully document the
cost recovery position for each site where federal grant
dollars were used. In addition, TNRCC has been
prioritizing its sites for cost recovery. This prioritization
will be used as a basis for TNRCC's decision for cost
recovery actions.
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Audit of LUST Cooperative Agreements Awarded to the
Texas Natural Resource Conservation Commission
OIG EVALUATION
We acknowledge TNRCC's comments and commend their
planned actions. However, we wish to clarify TNRCC's use
of the terms direct and indirect cost in the section on
Accounting for Site-Specific Costs. Through discussions
with TNRCC subsequent to receipt of their response, we .
determined that their use of the term direct cost refers to
contractor costs, while the term indirect cost refers to
TNRCC salary costs. The finding, as presented in this
report, addresses contractor and TNRCC salary costs,
rather than direct and indirect costs.
BACKGROUND
In 1984 and 1986, Congress passed Underground Storage
Tank legislation under Subtitle I of the Resource
Conservation and Recovery Act. SARA, Section 205
authorized EPA to. provide LUST trust funds through
cooperative agreements with the states to clean up leaking
underground storage tanks.
These agreements provide the basis for EPA's oversight and
management of the LUST trust fund. The agreements
identify the amount of funds that have been allocated to
each state and establish LUST program performance
requirements. In Texas, the LUST program is administered
by TNRCC located in Austin, Texas.
Region 6 awarded LUST cooperative agreement no.
L006515-91 to TNRCC on September 14, 1990. The
objective of the agreement was to provide funding to
implement cleanup actions at sites contaminated by
regulated substances stored in underground storage tanks.
The agreement, with six amendments, totaled $14,341,979
and covered the period September 1, 1990, through
August 31, 1994. TNRCC submitted a final FSR on
November 22, 1994.
Cooperative agreement no. L006515-04 was awarded on
September 21, 1994. The purpose of the agreement was to
provide continued funding for administration of the LUST
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Audit of LUST Cooperative Agreements Awarded to the
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program. The agreement, with four amendments, totaled
$4,452,836 and covered the period September 1, 1994,
through August 31, 1996. TNRCC submitted a final FSR
on December 3, 1996.
Cooperative agreement no. L006515-05 was awarded on
August 30, 1995. The purpose of the agreement was to
provide continued funding for administration of the LUST
program. The agreement, with two amendments, totaled
$3,428,888 and covered the period September 26, 1995,
through August 31, 1997. A final FSR is due upon
completion.
SCOPE AND
METHODOLOGY
We conducted a financial and compliance audit of LUST
cooperative agreement nos. L006515-91, L006515-04,
and L006515-05 to determine if the costs incurred and
claimed were allowable, allocable, and reasonable under the
cooperative agreement terms and conditions and in
accordance with laws and regulations. The audit
represented a final audit of costs claimed under cooperative
agreement nos. L006515-91 and L006515-04 and an interim
audit of cooperative agreement no. L006515-05. The audit
included review of costs incurred during the period
September 14, 1990, through September 30, 1996. We
performed our fieldwork from May 1997 to September
1997 at EPA Region 6 and TNRCC offices in Austin,
Texas.
We conducted the audit in accordance with the Government
Auditing Standards (1994 Revision) issued by the
Comptroller General of the United States. Accordingly, the
review included tests of the accounting records and other
auditing procedures as we considered necessary. Other than
the issues discussed in this report, no other significant issues
came to our attention that warranted expanding the scope of
our audit.
The audit did not include a complete review of the grantee's
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Audit of LUST Cooperative Agreements Awarded to the
Texas Natural Resource Conservation Commission
system of internal controls; rather we focused our attention
on the key systems in place to control and manage the
cooperative agreement. Additionally, we relied on the
Statewide Single Audit Report of the State of Texas for the
fiscal year ended August 31, 1994, to the extent possible.
We reviewed the original agreement justifications and
language to determine the purpose of the agreement and
requirements. We looked at FSRs and cash drawdowns and
compared them to original authorizations, amendments,
certifications, and obligations. Grant expenditure
worksheets were used to confirm what payments of
authorized levels were actually made.
In evaluating the adequacy of these systems, we focused our
attention on assuming that procedures were adequate to
comply with the legal and regulatory criteria set forth in
EPA, federal, and state guidance cited in the Office of
Inspector General audit guide.
Because of the inherent limitations in any system of internal
accounting control, errors or irregularities may occur and
not be detected. Except for the deficiencies discussed in the
section of this report entitled Report on Compliance and
Internal Controls, nothing came to our attention which
would cause us to believe that TNRCC's procedures were
not adequate for our purposes.
In addition to the audit of accounting transactions, we
selected and tested transactions to determine TNRCC's
compliance with federal laws, regulations, and cooperative
agreement special conditions. We reviewed TNRCC's
compliance with the cooperative agreements program and
financial reporting requirements and interviewed TNRCC
administrative and program staff to determine whether
policies and procedures were appropriately implemented.
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Barry R. McBee. Chairman
R. 8. "Ralph" Marquez. Commissioner
John M Baker. Commissioner
Dan Pearson, Executive Director
APPENDIX I
Page 1 of 2
TEXAS NATURAL RESOURCE CONSERVATION COMMISSION
Protecting Texas by Reducing and Preventing Pollution
December 09, 1997
Bennie S. Salem
Divisional Inspector General
Office of Inspector General
U.S. Environmental Protection Agency
726 Minnesota Avenue
Kansas City. Kansas 66101
RE: Draft Leaking Underground Storage Tank Report
Cooperative Agreement Nos. L006515-91. L006515-04 and L006515-05
Audit Report No. #3LLL7-06-0031-XXXXXX
Dear Mr. Salem:
We appreciate this opportunity of receiving and commenting on the draft audit report of the Texas
Natural Resource Conservation Commission's (TNRCC) underground storage tank program. We
hope the comments from the TNRCC can be incorporated into the final audit report.
The stated objectives of the audit were to evaluate grant costs claimed by the TNRCC and
compliance with federal laws, regulations, and cooperative agreement conditions. While the
TNRCC was found in compliance with these objectives, the only deficiencies noted were related
to cost recovery.
The draft audit states the "TNRCC had not established adequate procedures to account for all site-
specific costs paid with LUST trust funds". In response, the TNRCC keeps detailed information on
the direct costs associated wich each site where site investigations and emergency actions are funded
by federal grant dollars. The TNRCC also has a process of creating specific program cost account
(PCA) numbers for capturing indirect costs for sites where federal grant dollars were used: however.
this practice was only used in a limited number of cases until recently. The TNRCC has already
implemented steps to improve record keeping for indirect costs at these sites even though they are
expected to be only a fraction of the costs associated with each site.
The audit report mentions a deficiency in issuing and subsequent follow up of cost recovery demand
letters. The TNRCC acknowledges that only a limited number of demand letters were mailed prior
to this audit. In fact, the TNRCC created a task force on its own initiative, during the summer of
11
P.O. Sox 130ST Austin. Tixas 73711-3087 512/239-1000 " Internet address: www.tnrcc.state.tx.us
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APPENDIX ?I
Page 2 of 2
Mr. Bennie S. Salem
Re: Draft Leaking Underground Storage Tank Report
Page 2
1997, which recommended an entire process for cost recovery. A procedure for issuing initial
demand letters and follow up letters was also considered. This cost recovery process is defined in
a report dated July 7, 1997, and a copy is enclosed for your review. The TNRCC is currently
adopting forma] cost recovery procedures and is developing the baseline data that will be used to
measure future cost recovery efforts.
Finally, the audit determined that the TNRCC was not documenting its decisions made on cost
recovery actions and that formal closure for cost recovery was required at all sites. The TNRCC
shared with the auditors copies of sample memorandums used to document the agency's decision
not to pursue cost recovery at a site. While it is recognized that such a memorandum has not been
prepared for each site; there is no statue of limitations for this action. The TNRCC has plans on
pursuing this action further and will fully document its cost recovery position for each site where
federal grant dollars were used. Furthermore, within the last twelve months, the TNRCC has made
progress in prioritizing its sites for cost recovery which will be the basis for the TNRCC 's decision
on seeking cost recovery or not.
The auditors' recommendation that the Regional Administrator work with the TNRCC on a cost
recovery program is well appreciated. In fact, the TNRCC has already opened discussions with the .
region staff and has shared with them the direction the TNRCC is planning on cost recovery. These
discussions were fruitful and well received by EPA's regional staff. We will make a conscientious
effort to continue these discussions to further improve our cost recovery program.
Thank you again for this opportunity to comment on the audit findings. I assure you that efforts are
underway to address the three areas where some deficiencies were found. If elaboration on any of
these comments are needed, please feel free to contact me or Ms. Jacqueline Hardee, Manager of
the Petroleum Storage Tank Division's State Lead Remediation Section at (512) 239-2120.
Sincerely,
Joe D. Woodard, Director
Petroleum Storage Tank Division
Texas Natural Resource Conservation Commission
Enclosure: 1 report
cc: Ron Pedde, Office of Waste Management, MC 122 (ref: ED #10267)
Dan Pearson, Executive Director, MC 1 02
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Audit of LUST Cooperative Agreements Awarded to the
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APPENDIX 0
DISTRIBUTION
Office of Inspector General
Inspector General (2410)
Deputy Assistant Inspector General for External Audits (2421)
EPA Headquarters
Agency Audit Followup Coordinator (2724)
Agency Audit Followup Official (3101)
Associate Administrator for Congressional and Legislative Affairs (1301)
Associate Administrator for Communication, Education, and Public Affairs (1701)
Associate Administrator for Regional Operations & State/Local Relations (1501)
Director, Grants Administration Division (3903F)
EPA Library (3404)
EPA Region 6
Regional Administrator (6RA)
Director, Multimedia Planning and Permitting Division (6PD)
Chief, Grants and Authorization Section (6PD-G)
Chief, UST/Solid Waste Section (6PD-U)
Director, Office of External Affairs (6XA)
Audit Resolution Coordinator (6MD-R)
Regional Library (6MD-0)
State Offices
Executive Director, Texas Natural Resource Conservation Commission
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