7.0-2
United States               Administration And
Environmental Protection         Resources Management              April 1994
Agency                  (3303F)
 £
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                   EPA'SFY1993
              ANNUAL FINANCIAL
                   STATEMENTS
                     EPA Headquarters library .
                                             Recycled/Rocyctebte
                                             Prtnted on paper thatconua™

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                 TABLE OF CONTENTS
MESSAGE FROM THE ADMINISTRATOR
SECTION  A
     Overview of EPA
     Overview of Trust Funds, Revolving
      Funds and Commercial Activities"
         Superfund
         Leaking Underground Storage Tank (LUST) Program
         Oil Pollution Prevention Program
         Asbestos Loan and Grant Program
         Pesticides Reregistration and Expedited
          Processing Fund (FIFRA Fund)
         Revolving Fund for Certification and
          Other Services (Tolerance Fund)
SECTION  B
  1
  4

  7
 18
 21
 24
 27

 30
     Message from the Chief Financial Officer
     Principal Financial Statements
SECTION C
 33
 35
    Office of the Inspector General Reports
 73
EPA's FY 1993 Annual Financial Statements
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EPA's FY 1993 Annual Financial Statements

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              MESSAGE FROM THE ADMINISTRATOR

          I am pleased to present the Fiscal Year 1993 Annual Financial Statements for the U.S.
    Environmental Protection Agency.  These statements were prepared by the Agency's Chief
    Financial Officer (CFO) and present a snapshot of the financial condition of EPA's trust
    funds, revolving funds and commercial activities.  Since the financial statements help to
    evaluate the effectiveness of the Agency's systems and operational weaknesses, I consider
    them to be an integral part of my strategy for increasing accountability and strengthening
    management practices throughout the Agency.

          This year we made considerable progress in preparing our financial statements. We
    reduced the timeframe for producing the statements by three months.  In addition, as a direct
    result of improvements we made, EPA received more favorable opinions from the auditors
    on several of its funds, including an unqualified opinion on its newest fund, the Oil Spill
    Trust Fund.                                  .

          The overall results of the audits attest to the continuing improvements  in the Agency's
    internal controls,  financial management and accounting practices.   The audit results also
    measure our performance against the baseline we established last year.  Finally, the
    partnership formed between our finance and program offices in preparing these financial
    statements has strengthened financial management and improved program performance
    throughout the Agency.

          The requirement to produce annual financial statements provides the Agency with an
    opportunity not only to examine its financial systems and operations, but also  to begin linking
    financial data with program performance information.  We plan to use  the financial
    statements as the foundation for achieving our long-term vision of results-oriented
    management and increased accountability.  The statements play a  key role in our ultimate
    goal of developing and implementing  an  integrated approach to Agency-wide strategic
    planning, budgeting, financial management and program evaluation.  This approach will
    guide the Agency's program and investment decisions.

          To implement this vision consistently across the Agency, we plan to integrate and
    coordinate key management initiatives including the CFO Act, new guidelines for the Federal
    Managers' Financial Integrity Act, provisions of the Government  Performance and Results
    Act (GPRA) and the recommendations of the National Performance Review (NPR).  In
    addition, we must ensure the availability  of timely, reliable, accurate and useful financial and
    program information.  At EPA, we recognize the value of this information and are putting in
    place the necessary infrastructure to improve our ability to measure program performance,
    track program costs and evaluate financial management practices.   .
EPA's FY 1993 Annual Financial Statements
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          As Administrator, I personally am dedicated to developing the most effective and
   responsive organization possible in order to meet the immense challenges set forth by  our
   environmental mandate.  Our goal is an integrated management system that supports effective
   environmental decision making.  The production of these audited financial statements is an
   important step, among many, that will move us toward this goal.

          In the last year, we took our first steps toward a new way of doing business, to
   management that focuses our resources most effectively on producing a cleaner, healthier
   environment.  While I am extremely pleased with the progress we have made, what appeals
   to me even more is the promise of the coming years.
                                                               Carol M. Browner
          5 1
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EPA's FY 1993 Annual Financial Statements

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                                                                                                    1
OVERVIEW OF EPA

  ission. Stated broadly, the job of the U.S.
Environmental Protection Agency (EPA) is to
improve and preserve the quality of the
environment, both national and global.  EPA
works to protect human health and the natural
resources on which all human activity depends.
America's continuing growth and prosperity
depend  on its ability to find  effective, creative
solutions to environmental problems.

A Complex Growing Agency. When it was
formed  in  1970, EPA employed 5,400 people. It
had a budget of approximately $1 billion and
was responsible for a handful of major
environmental laws. Today  more than 17,000
highly skilled, culturally diverse people work for
EPA; and the Agency has a  budget of
approximately $6 billion parceled out among
programs implementing 16 major laws that
Congress has passed to protect the environment:
                                                     The Clean Air Act
                                                     The Clean Water Act
                                                     The Safe Drinking Water Act
                                                     The Comprehensive Environmental
                                                     Response, Compensation and Liability
                                                     Act (CERCLA, or  "Superfund")
                                                     The Emergency Planning and Community
                                                     Right-To-Know Act
                                                     The Resource Conservation and Recovery
                                                     Act
                                                     The Federal Insecticide, Fungicide, and
                                                     Rodenticide Act
                                                     The Toxic Substances Control Act
                                                              «
                                                     The Marine Protection, Research, and
                                                     Sanctuaries Act
                                                     The Uranium Mill  Tailings Radiation
                                                     Control Act
                                                     The Indoor Radon  Abatement Act
                                                     The Ocean Dumping Ban Act
                                                     The Coastal Zone  Management Act
                                                     The Pollution Prevention Act
                                                     The Federal Facilities Compliance Act
                                                     The Oil Pollution Act.
                                       EPA Workyears
                          20.000
                          18,000 i
                          12.000
                          1.000
                          4,000
                                     1MB   1WO   1M1
                                                      t«K   1883
EPA's FY 1993 Annual Financial Staiemems
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                               9,000
                              4.000
                               3.000
                              2JXO
                               1.000
              EPA Budgets
           BtdiKtH Construction Grants
      Problems and New Solutions.  Many of
 EPA's responsibilities originated in response to a
 new generation of environmental problems which
 surfaced in the  1980s.  Most notable is the
 whole range of global environmental concerns:
 climate change, stratospheric ozone depletion,
 rainforest destruction, and  acid rain. Also
 important are such domestic issues as pollution
 prevention, radon contamination of homes, food
 safety, and  pollution carried by run-off from
' lawns, farms, and highways. In many ways,
 these new problems are both more widespread
1 and more complex than those of the past.

 EPA has responded to emerging environmental
 problems in bold and creative ways. In addition
 to its traditional regulatory approaches, the
 Agency is addressing environmental concerns by
 creating market incentives  and encouraging
 voluntary actions.  The Agency's goal is to
 anticipate the environmental needs of the next
 century and develop new policies and programs
 that will meet those needs.

 In the last four years, EPA experienced an
 unprecedented amount of change.  There has
 been increased emphasis on risk to human health
 and the ecology as one of the factors in
 environmental protection decisions.  Both
 budget and workforce resources for the Agency's
 environmental programs have experienced
                   growth.  This expansion primarily has been
                   accomplished in the air, water, hazardous waste,
                   pesticides, enforcement and multimedia
                   programs.

                   Effective Resource Management. One of the
                   most significant areas of change in recent years
                   has been in the management of the Agency's
                   resources. Managers throughout  the Agency
                   directed their attention and support toward
                   strengthening resources management.
                   Improvements resulting from this concerted
                   effort include:

                   •      Strengthening accountability for resource
                         management functions  by  designating
                         Senior Resource Officers in each
                         Headquarters and Regional office, who
                         are responsible  not only for procurement
                         but other aspects of financial  resource
                         management as well;

                   •      Continuing to diversify the Agency's
                         workforce to ensure the greatest possible
                         range of talent managing our  resources;

                   •      Providing additional funds in  FY  1993 to
                         strengthen our Integrated Financial
                         Management System (EFMS)  and
                         allocating funds to correct the weaknesses
                      .   identified in our FMFIA reporting.
 Page 2
EPA's FY 1993 Annual Financial Statements

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       Reorganizing the Office of
       Administration and Resources
       Management (OARM) to increase •
       accountability and control;

       Increasing emphasis on effective contracts
       management including substantially
       elevating the level of resources devoted
       to that effort;

       Proceeding with plans to correct our
       material weaknesses in financial
       management as well as nonconformances
       in our accounting system;

       Improving audit follow up and
       implementation by issuing, in conjunction
       with the General Accounting Office and
       the Inspector General, an early warning
       report of high priority audits requiring
       EPA action.

To the extent possible, EPA has implemented
 hese changes in recent years in conjunction with
establishing the structure and accountability
measures required under the Chief Financial
                                                Officers (CFO) Act. The Agency CFO program
                                                accomplishments include the following:

                                                »      Issuing a comprehensive Financial
                                                      Management Five-Year Plan which
                                                      provides a blueprint for improving
                                                      financial management throughout  the
                                                      Agency, complete with specific activities
                                                      and milestones;

                                                •      Developing  financial management
                                                      performance measures for an FY  1994
                                                      pilot program in six offices for traditional
                                                      financial management functions, including
                                                      accounting operations, budget execution
                                                      and management controls;

                                                •      Working with program office staff to
                                                      continue the development of the program
                                                      performance measures which are
                                                      discussed  in this report; and

                                                •      Preparing the CFO's Annual Report
                                                      which highlights the financial status of
                                                      the Agency  and identifies existing and
                                                      potential areas of concern.
EPA's FY 1993 Annual Financial Statements
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OVERVIEW  OF TRUST FUNDS, REVOLVING  FUNDS,
AND  COMMERCIAL  ACTIVITIES
The CFO Act of 1990 placed new emphasis on
financial management in major federal agencies.
One of the major requirements of the Act is the
preparation of annual financial statements for
each of the Agency's revolving and trust funds,
and commercial operations.

EPA's financial statements for FY  1993 include
the following trust funds, revolving funds, and
commercial activities:

•      the Oil Pollution Prevention Program;
•      Superfund;
•      Leaking Underground Storage Tank
       (LUST) Program;
•      the Loan Portion of the Asbestos Loan
       and Grant Program;
•      the Pesticide Reregistration  and Expedited
       Processing Revolving Fund  (FIFRA
       Fund); and
•      the Revolving Fund for Certification and
       Other Services (Tolerance Fund).

Of these, Superfund is by far the largest, as
measured by monies spent (obligations) and EPA
workyears used by the funds. The  Oil Pollution
Prevention Program will  be included in the
financial statements for the first time this year.

EPA Financial Statements.  Under the CFO
Act, financial statements are required to reflect
the overall financial position of the funds, as
well as the results of  the operations of the funds
and their activities or operations. Detailed
financial information  on EPA's trust funds,
revolving funds and commercial activities is
contained in the Principal Statements section of
this report

The first part of the financial statements is this
overview prepared in  accordance with OMB
guidance. It contains a separate section on  each
                  of the six revolving fund, trust fund, and
                  commercial activity programs reported on,
                  including:

                  •      a description of each program,
                  •      a financial perspective of each program,
                        and
                  •      a discussion of program performance.

                  EPA's programs and activities not currently
                  covered by the CFO Act are not included in the
                  FY 1993 financial statements.  The Agency plans
                  to expand annual financial statements in future
                  years to include  additional EPA programs.  The
                  Agency currently is investigating options for
                  tracking and reporting additional program
                  performance and financial information in a
                  manner that would be  useful to those interested
                  in knowing more about the results of EPA's
                  programs.

                  The following paragraphs provide an overview
                  of the organization, management, and authorizing
                  legislation for each of the six programs.

                  Trust Funds. A trust  fund is a fund established
                  to account for receipts which are held in trust for
                  use in carrying out specific purposes and
                  programs  in accordance with an agreement or
                  statute.  Three of the EPA programs covered by
                  the CFO Act  are trust  funds arid are housed
                  primarily in the Office of Solid Waste and
                  Emergency Response.  These programs, which
                  use trust fund revenues to finance the cost of
                  cleaning up contaminated sites, are:
                        the Superfund,
                        the Oil Pollution Prevention Program and
                        the Leaking Underground Storage Tank
                        (LUST) Program.
Page 4
EPA's FY 1993 Annual Financial Statements

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     K(
m
The Office of Solid Waste and Emergency
Response (OSWER) is headed by an EPA
  ssistant Administrator who is responsible for
:he Agency's waste management programs.  The
offices within OSWER are: Emergency and
Remedial Response (with responsibility for
Superfund and Oil Pollution Prevention),
Underground Storage Tanks (with responsibility
for LUST), Solid Waste (with responsibility for
the solid and hazardous waste programs under
the Resource Conservation and Recovery Act),
and Waste Programs Enforcement (with
responsibility for enforcement for all of
OSWER's programs).

EPA has ten Regional offices which manage the
day-to-day operations  of these three programs.
Over three quarters of the staff responsible for
carrying out the  Superfund, Oil Pollution
Prevention and LUST programs reside in the
Regions. The three programs are located in the
Regional Waste  Management Divisions (except
in Regions 4 and 10 where the LUST program  is
in the Water Division  and in Regions 1, 6 and 7
  here the  Oil Pollution Program is located in the
 nvironmental Services Division).

While OSWER and the Regional Waste
Management, Water and Environmental Services
Divisions have lead responsibility for the
Superfund, Oil Pollution Prevention and LUST
programs, these programs are supported by staff
in other Headquarters  and Regional offices.
These offices charge administrative and
extramural expenses to the three programs, but
primarily to Superfund.

In Headquarters, these support functions are
carried out primarily by the Offices of
Administration and Resources Management,
Enforcement, Inspector General and Research
and Development. In  the Regions, support is
provided by staff from the Office of Planning
and Management and the Environmental Services
Division, as well as in other Federal Agencies in
the case of Superfund.  Funding for these efforts
is supported through an allocation of trust fund
resources.

Revolving Funds.  A revolving fund is a fund
authorized by specific provisions of law to
finance a continuing cycle of operations with
receipts derived from such operations available
in their entirety for use by the fund. Two EPA
programs covered by the CFO Act  are revolving
funds and both of these are housed primarily in
the  Office of Prevention, Pesticides and Toxic
Substances (OPPTS).  These programs are:

•     the Pesticides Reregistration and
      Expedited Processing Fund (FIFRA
      Fund), and  •
•     the Revolving Fund for Certification and
      Other Services (Tolerance Fund)

EPA is charged by Congress with the job of
regulating the use of pesticides and balancing the
risks and benefits posed by pesticide use.  The
Agency regulates the use  of pesticides through.
its Office of Pesticide Programs (OPP), within
OPPTS.  OPP consists of seven divisions  and a
staff office.  Both appropriated and revolving
funds are utilized by OPP in accomplishing its
mission.  The two revolving funds which
supplement appropriated resources for OPP are:
The Pesticides Reregistration and Expedited
Processing Fund (FIFRA Fund) and The
Revolving Fund for Certification and Other
Services (Tolerance Fund).

The mission of EPA's pesticide program is to
serve the nation by safeguarding public health
and the environment-from risks posed by
pesticides.  The regulation of pesticides comes
under the authority of two laws - the Federal
Insecticide, Fungicide, and Rodenticide Act
(FIFRA) and the Federal Food, Drug and
Cosmetic Act (FFDCA).  FIFRA gives EPA the
authority and responsibility for registering
pesticides for "Specified uses and the
reregistration of existing pesticides  that were
registered prior to.November 1,  1984.  Pesticide
     EPA's FY 1993 Annual Financial Statements
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regulatory decisions are based primarily on
EPA's evaluation of the test data provided by
applicants. Tolerance residue setting activities
are authorized by FFDCA.  EPA's pesticide
regulations cover:
       20,000 pesticide products
       2,200 registrants
       3,300 formulators
       29,000 distributors and other
       establishments
       40,000 commercial pest control firms
       1 million farms
       90 million households
Commercial Activities,  The CFO Act requires
reporting on programs performing substantial
commercial functions and specifically identifies
the making of loans as such an activity.  EPA is
reporting on one commercial activity which is
administered under the Office of Pollution
                  Prevention and Toxics (OPPT) within the Office
                  of  Prevention, Pesticides and Toxic Substances:

                  •      the Asbestos Loan and Grant Program.

                  This overview covers the entire Asbestos Loan
                  and Grant Program.  However, the loan portion
                  of the program is the  only part that is a
                  commercial activity and is the only part of the
                  program covered by the audited financial
                  statements.  The Asbestos School Hazard
                  Abatement Act (ASHAA) of 1984 directed EPA.
                  to create a loan and grant program to financially
                  assist Local Education Agencies (LEAs) or
                  school districts with asbestos abatement projects
                  in public and nonprofit elementary and
                  secondary schools.  The Act was subsequently
                  reauthorized in 1990 for an additional five years.
                  The ASHAA loan and grant program is
                  administered in the Chemical Management
                  Division, Field Programs Branch of OPPTS.
                .'A
                '!*
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EPA's FY 1993 Annual Financial Statements

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Superfund
  e Superfund program is administered under
the Comprehensive Environmental Response,
Compensation and Liability Act of 1980
(CERCLA) as amended by the Superfund
Amendments and Reauthorization Act, 1986
(SARA) and the Omnibus Reconciliation Act of
1991.  The program is primarily managed by the
Office of Solid  Waste and Emergency Response.

Program Description

CERCLA (Superfund) was enacted on December
11,  1980 to address public health and
environmental threats from spills of hazardous
materials and from sites contaminated with
hazardous substances.  The Superfund law
established a comprehensive program to identify
and clean up these spills and sites. EPA was
authorized to use a trust fund (the Hazardous
Substance Superfund) to pay for this work and to
 iursue recovery of expenditures from parties
  sponsible for the contamination.

The .law directs EPA to handle releases  of
hazardous substances by either compelling
potentially responsible parties to respond or
conducting a removal or Remedial Action using
the Superfund.  Removal  actions are  short-term
responses to an immediate threat posed by the
uncontrolled release of a hazardous substance,
such as from a transportation accident or a fire.
Remedial Actions are long-term, more permanent
remedies taken  at those sites where the risk to
human health and the environment warrants
placing the site  on the National Priorities List
(NPL).

Cleaning up a Superfund  site is a multi-stage and
multi-year process. In fact, the average site takes
seven to ten years from discovery to  start of
cleanup.  Prior to being placed on the NPL,  EPA
conducts a preliminary assessment of the site.
                                               Where warranted, this is followed by a site
                                               investigation.  While EPA continues to seek
                                               ways to speed site cleanups, the work on
                                               complex sites can stretch into decades especially
                                               when ground water must be treated.  EPA also
                                               conducts removal actions at non-NPL sites.
                                               Since 1980, approximately 3,400 short-term
                                               removal actions have been started (270 in FY
                                               1993 alone), with the majority at non-NPL sites.

                                               Once a site is listed on the NPL, EPA works
                                               with the community around the site to plan the
                                               long-term cleanup with a detailed study of the
                                               site and an evaluation of cleanup options. The
                                               planning process can take up to four years with
                                               an average cost of $1.35 million per site.

                                               The  actual cleanup (construction) work itself
                                               averages $22 million per site. Because of the
                                               high cost and limited Superfund resources,
                                               EPA's enforcement program emphasizes
                                               compelling responsible parties to conduct the
                                               cleanup actions.  Responsible parties currently
                                               fund approximately 72 percent of NPL sites.

                                               While the Superfund responsibilities cannot be
                                               delegated, at some sites the State, local
                                               government or Indian Tribe takes the lead in
                                               managing the site cleanup.  At other sites, the
                                               State or local agency cooperates with EPA on
                                               handling a site cleanup.
                                               Financial Perspective

                                               In 1980, the Congress established in the
                                               Department of the Treasury a trust fund entitled
                                               the "Hazardous Substance Response Trust Fund",
                                               which is known now as the Hazardous Substance
                                               Superfund. Congress also appropriated funding
                                               for five years totalling  $1.6 billion. As the
                                               long-term nature and expense of site cleanup
EPA's FY 1993 Annual Financial Statements
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 became more evident, Congress reauthorized the
 program in 1986 and the taxing authority for an
 additional five years of EPA funding totalling
 $8.5 billion.  In 1990, Congress extended taxing
 authority for an additional three years adding
 $5.1 billion to EPA's funding.

 The Department of Treasury's Hazardous
 Substance Superfund Trust Fund is the source  of
 funding for EPA's Superfund account. Through
 annual and supplemental appropriations,
 Congress establishes the amount of the fund that
 EPA may use.  EPA withdraws monies from the
 trust fund as needed to cover disbursements.  At
 the end of FY 1993, the trust fund reflected an
 unappropriated balance of $2.1 billion. Congress
 could make these funds available to EPA in
 future appropriations.

 The Superfund trust  fund is supported primarily
 by taxes on crude and petroleum, on the sale or
 use of certain chemicals,
 and an environmental tax
 on corporations.  Other
 sources of funding for
1 Superfund include
 cleanup costs recovered
 from responsible parties,
 interest,: fines and
 penalties paid by
 individuals and entities
 who violate the terms of
 the CERCLA provisions,
 and by general revenues.
                           Superfund Staff by Location - FY 93
                                     Total FTEs-3,509
                                       Regions (75%)
                                                 HQ-A1I Others (16%)

                                        HQ-OSWER (10%)

                                              mqr m •«•) 100 pmn.
  ril
2.000
1.800
1,200
 100
Superfund response program expenditures
through FY  1993 total $8.7 billion.  In EPA's
most recent  report to Congress, the Office of
Solid Waste and Emergency Response estimated
the remaining costs of cleaning up the 1,177
                          sites currently on the
                          NPL to be $14.3
                          billion for FY 1994
                          and beyond.  This
                          estimate does not
                          include the
                          responsible party
                          contribution.
        Superfund Financial Trends
                                 OMgMton*
                                  KOuUyt
                                     FYCO
 Parties, responsible for
 contaminating Superfund
 NPL sites are
 increasingly paying the
 cost of cleanup, saving the fund for those sites
 where parties are unable to contribute.
 Responsible party commitments to site cleanup
 have exceeded $1 billion in each of the past
 three years.  In FY  1993, EPA  achieved
 settlements for response actions at NPL sites
 valued at $910.3  million.
                                              FY»1
                                                      FY82
                                                               FY43
                          Superfund
                          appropriations,
                          obligations and
                          outlays have
                          remained fairly
                         'constant from 1990
                          through 1993 as can
                          be seen on the
                          financial trends chart.
                   In FY 1993, the Superfund program was staffed
                   by a total of 3,509 FTEs, and total Superfund
                   obligations were approximately $1.6 billion. .
                   Further analysis of these numbers is provided in
                   the following sections.
 Page 8
EPA's FY 1993 Annual Financial Statements

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Superfund by Activity.  The Agency has
identified four major components of the
  uperfund program: Remedial Activities,
  emoval Activities, Enforcement Activities, and
Other Activities. These activities were identified
based upon the "Superfund Activity Code",
which is the  accounting process the Agency uses
to identify Superfund activities with accounting
transactions.   Each of these components has
various activities which are identified below.

Remedial activities represent the long-term
response at a Superfund site and include the
Preliminary Analysis/Site Investigation (PA/SI),
Remedial Investigation/ Feasibility Study
(RI/FS), Remedial Design (RD), Remedial
Action (RA), associated oversight and laboratory
analysis activities, and remedial support and
management.
Removal activities represent the short-term
response and stabilization of hazardous
substances and include the removal actions,
associated oversight and laboratory analysis
 .ctivities, expedited response  actions, Technical
Assistance Team activities, and removal support
and management.
Enforcement activities represent the actions the
Agency takes in the recovery of Superfund
expenditures, settlement negotiations with
responsible parties, and associated oversight.

Other activities represent activities of the
Agency in supporting the Superfund program as
a whole.  These "Other" activities cross the
remedial, removal, and enforcement program
lines  and are associated with remedial,  removal
and enforcement.  "Other" activities include
Research and Development, contract award and
management, financial management, personnel
activities, and rent and utility costs.

These charts provide a look at Agency  spending
patterns for the current  fiscal year and the past
three-year period.  The  spending patterns are
identified for both obligations and disbursements.
An obligation represents a commitment to
procure and pay, and is funding for an activity.
Obligations are not the same as actual cash
disbursements. Disbursements (outlays)
represent cash payments for products or services
rendered.  In general, for any given fiscal year,
obligations are an indication  of current and
future activities and disbursements  are indicative
of completed activities.
      Superfund Obligations by Activity - FY 93
                Total obligations $1.6 Billion
                     Remedial (42%)
                _                 Enforcement (12%)
        Other ,

                         Removal (18%)

         On ID ran*e. tm mm a f» tmnarroqm m*f ra tqutl 100 garon
Superfund Obligations by Activity.  Remedial
activities account for more than 40 percent of the
      Superfund Obligations by Activity • Trends
   tlnMWOf*
    2.000
    1.200
          FYM      FY«1      FYM      FYM

EPA's FY 1993 Annual Financial Statements
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 Superfund budget. Remedial Actions are taken
 at large sites requiring complex cleanups.  Over
 60 percent of the sites on the NPL have had
 design or construction for cleanup initiated, and
 most contract dollars (more than 60 percent in
 FY 1993) go for cleanup.

 The "Other" category represents all infrastructure
 support costs, including rent and utilities, to both
 cleanup and enforcement as well as funds  for
 other offices within EPA, such as Research and
 Development, and for other Federal agencies
 which support the Superfund program.

 The Superfund program conducts a large number
 of short-term removal actions each year to
 control immediate threats, with over 2,500 of
 these completed by the end of FY 1993.
 Removals account for approximately 18 percent
 of the FY 1993 Superfund cleanup costs.

 While enforcement represents the smallest part
 of the Superfund budget, the resources invested
 there have a large payoff.  See Measures 6-9 and
 the summary discussion which follows.    •  .

 The four-year trend chart of Superfund
 obligations indicates an increase in support
Bother) spending  in FY 1993.  Total funding has'
 remained relatively constant.

 Superfund Disbursements by Activity.
 Disbursements represent the actual payment for
  Superfund Disbursements by Activity - PY 93
           Tenl Obtamtmtnta -11.3 BUkm
                 Remedial (37%)
     Other (30%)
                             Enforcement (14H)


                     Removal (18*)
                                                      Superfund Disbursements by Activity - Trends
                                                           FV90      PTtt    '  FYK      FYM
                                                 services;  The type of expense (activity) will
                                                 have an impact on how quickly  an obligation is
                                                 actually disbursed. For example, payroll costs
                                                 are obligated and  disbursed at one time. The"
                                                 same holds for travel. Contract activities are
                                                 obligated at one time. However, the service may
                                                 be performed over a period of time.  The mix of
                                                 payroll, travel, contracts, etc., will determine
                                                 how closely obligations and disbursements
                                                 match.

                                                 Superfund by Location. Superfund activity can
                                                 be further broken  down by location.  Obligations
                                                 and disbursements are displayed by Region,
                                                 Headquarters (HQ) - Office of Solid Waste and
                                                 Emergency Response (OSWER), and HQ - All
                                                 Others. Much of  the operational responsibility
                                                 resides  in the EPA regions.  HQ - OSWER
ns Superfund Staff by Office - FY 93
xooo
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tea

1
1
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OA OARU 000 OAR OW COC OPPE OSWER OE FtagkXM
Page 10
                               EPA's FY 1993 Annual Financial Statements

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represents the Office of Emergency and
Remedial Response  and Office of Waste
   •grams Enforcement here at headquarters.  HQ
- All Others represents all other offices such as
the Office of Enforcement, Office of Research
and Development, and other offices which
provide support to the Superfund program.

Superfund Staff by Location.  Since most
operational activity occurs in the regions, the
largest numbers of staff positions  are located in
the regions.
      Superfund Obligations by Location - FY 93
               Total Obligation* - $1.6 Billion
                     Regions (70%)
                                HQ-AII Others (10%)
                     HQ-OSWER (20%)
Superfund Obligations by Location. EPA
headquarters is further broken down between
Headquarters OSWER (Immediate Office -
OSWER, Office of Emergency and Remedial
                                                   Response, and Office of Waste Programs
                                                  Enforcement) and all other remaining non-
                                                  OSWER offices.

                                                  The bulk of the obligations occur in the regions.
                                                  Agency strategy, in the past few years, has been
                                                  to place more of the operational responsibility in
                                                  the regions.  As a result, most obligations occur
                                                  in the regions.

                                                  Superfund Disbursements by Location.  Current .
                                                       Superfund Disbursements by Location • FY 93
                                                                 Total OiafautMRMnt* • (1.3 Billion
                                                                       Regions (65%)
                                                                                  HQ-AII Ottiars (12%)


                                                                       HO-OSWEH (22%)

                                                                  , «• ram a M pworaeM m«» fat (qua! MS sunn.
                                                  year disbursements follow the same pattern as
                                                  current year obligations: Regional disbursements
                                                  are the largest; HQ - OSWER disbursements are
                                                  second; and HQ - All Others are last.
     Superfund Obligations by Location - Trends
  thMIOora
   2.0001
   veoo
   1.200
    400
         FY«0
                           FY«      FVM
                                                      Superfund Disbursements by Location - Trends
                                                     fin Maura
                                                      8.0001
                                                      1.600
                                                       too
                                                       400
                                                            pvao
                                                                                            MQ.CBW
EPA's FY 1993 Annual Financial Statements
                                                                                        Page 11

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  Disbursements closely mirror obligations by
  location except for the Regions.

  Disbursements indicate completed activity while
  obligations represent future activity.  Since a
  large portion of Superfund Remedial activity is
  long-term and is conducted in the Regions, all
  current year obligations will not be disbursed in
  the same fiscal year.

  Program Results

  The direct beneficiaries of the Superfund are
  those people living in the vicinity of the sites
  this cleanup program addresses.  Indirect
  beneficiaries include those living further from
  the sites who might suffer degradation of their
  groundwater, drinking water, or air if these
  programs did not alleviate the risk of
  contamination  before it became more
  widespread.  Early action to contain impacted
  areas also lessens the potential liability of parties
  responsible for the contamination.

 . The net result  of Superfund cleanup work at sites
1  on the NPL has been to reduce risk from
,  exposure to hazardous waste for approximately
  25 million people who live within a four mile
  radius of these sites. For one million of these
  people, the program has eliminated threats posed
  by direct contact with hazardous substances.

  The Superfund cleanup program to date has
  made significant strides in reducing risk from
  exposure to hazardous waste. Over 340 million
  gallons of liquid waste and 330 million gallons
  of surface water have been treated by the
  Superfund program.  Seventy-five billion gallons
  of groundwater also have been treated in cleanup
  work.  In addition, 23 million cubic yards of
  solid waste, 12 million cubic  yards of soil and
  200,000 cubic yards of sediment have been
  treated in conjunction with the thousands of
  persons that have been relocated from the
  vicinity of hazardous waste sites and supplied
  with alternative water.
                   Superfund program performance measures
                   reported in the Agency's FY 1992 CFO Report
                   included accomplishments attributable to the
                   Federal facilities program.  For FY 1993,
                   accomplishments claimed by that program have
                   been removed, and Federal facility sites are not
                   included in the NPL universe.  Since the purpose
                   of the CFO Report is to relate program
                   performance to the trust fund and the funds used
                   to cleanup these sites do. not come from the trust
                   fund, this data has not been included in the .
                   report.

                   EPA's performance measures for the Superfund
                   program for  FY 1993 fall into two categories:
                   site cleanup  (Measures  1-5) and enforcement/cost
                   recovery (Measures 6-9).

                   Cleanup.  For site cleanup we measure not only
                   the completion stage but also the critical steps in
                   the cleanup process.  Because the cleanup
                   process can take a number of years, it is
                   important to look at the "pipeline" of activities to
                   get an accurate sense of progress .

                   Measure 1:  Number of sites on the National
                   Priorities  List (NPL) where cleanup has
                   started/total number of sites on the NPL.
                                                            ,   )
                   Activities which count under this measure  are
                   short-term removal actions and the remedial
                   investigation/feasibility study which assesses the
                   nature and extent  of contamination at the site
                   and analyzes cleanup alternatives so that a
                   remedy can be selected.

                   Results: In FY 1993, cleanup, was started at 21
                   sites.  Cumulative performance to date is 1,124
                   cleanups begun/1,177 sites on the NPL.

                   The number  of cleanups started declined in FY
                   1991 through 1993 relative to earlier years as the
                   Superfund program's emphasis has shifted to the
                   later stages of the cleanup effort needed  to
                   complete work at  a site.  Also, cleanup  has now
                   begun at nearly all sites on the NPL. The 53
  Page 12
EPA's FY 1993 Annual Financial Statements

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remaining sites have been evaluated for
    icdiate threat, even though cleanup action has
 lot yet begun.
Measure 2: The number of non-NPL sites
with hazardous releases where EPA has begun
a cleanup action.

Sites with confirmed hazardous releases, which
do not score high enough to be included on the
NPL or where an emergency exists, are eligible
for a short-term Superfund removal action if they
meet certain regulatory criteria.  This measure
counts the number of sites where a removal
action has started.

Results:  In FY 1993, cleanup actions were
begun at 198 non-NPL sites, bringing the total
number of sites addressed through such actions
since program inception to 2,227.
  [easure 3: The number of sites on the NPL
  here a decision has been made about how to
proceed with the cleanup of at least a
significant portion of the site/the total number
of sites on the NPL.

Activities which count under this measure
include the documentation of how to proceed
with the remedial action - the signing of a
Record of Decision (ROD) - or the
documentation of the selection and authorization
of a removal - an Action Memorandum.  The
ROD identifies the remedy that has been chosen
for remediating the site (or portion thereof) and
summarizes the site problems, the alternative
remedies considered, and the public's
involvement in the decision.  The Action
Memorandum substantiates the need for action,
identifies the proposed action, and explains the
rationale for the particular type of removal action
selected. Action Memoranda were not included
as measures in the FY 1992 financial statements;
however, they are significant measures in the
documentation of removal action progress and
are included in this report for increased data
accuracy.

Results:  Cleanup decisions were made for 59
sites in FY 1993, resulting in a total to date of
891 sites of the 1,177 sites on the NPL.
Measure 4: Number of sites on the NPL
where Remedial Action has been completed
for at least a significant portion of the site/the
total number of sites on the NPL.

This measure counts those  NPL sites (or portions
thereof) which have progressed through the
Remedial Action phase.  At this stage the
construction work'to implement the remedy is
complete, and EPA has conducted a final
inspection to determine that the remedy is
functioning properly and performing as designed.

As indicated above, a  site may have more than
one Remedial Action.

Results: In FY 1993,  73 sites (or significant
portions thereof)  progressed through the
Remedial Action cleanup phase. This brings the
total number of such sites to 301 of the 1,177
sites on the NPL  [In  the FY 1992 financial
statements,  seven  of the sites that were reported
as reaching remedial action were Federal
facilities. This year's  report excludes Federal
facilities.

Measure 5: The number of sites on the NPL
where cleanup construction is completed/the
total number of sites  on the NPL.

This measure counts the sites for which EPA has
declared cleanup construction complete. Sites
qualify for construction completion when:

1)  any necessary physical  construction is
    complete whether or not final cleanup levels
/   or other requirements have been achieved;
EPA's FY 1993 Annual Financial Statements
                                    Page 13

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   200


   180


   120


   10
      NPL Sites with Construction Complete
              Cumulative Sites to Dal*
            M  IS  M  17
                                91  02  KI
 2)  EPA determines that the response action does
    not involve construction; or

 3)  the site qualifies for deletion from the NPL.

 Additional clarification on the definition of site
 cleanup is described in the Federal Register,
 March 2, 1993.

 Results: During FY 1993. cleanup was
 completed at 68 sites.  The substantial increases
 in completions reflect management's increasing
focus on completions, the maturing of sites
 already in the pipeline, and the streamlining of
 documentation requirements.  Cumulative results
-•for the program to date are 216 sites with
 cleanup construction completed of the 1,177 sites
 on the NPL.  {In the FY 1992 financial
 statements, one site cleanup was attributable to
 a Federal facility.  Federal facilities are
 excluded from this year's report.]

 Enforcement

 EPA's enforcement program seeks to involve
 those responsible for contaminating the
 Superfund site in its cleanup and pursues cost
 recovery of monies EPA expends  from the trust
 fund.

 Measure 6:  The number of enforcement
 actions EPA has taken at sites on the NPL
                   against the Potentially Responsible Parties
                   (PRPs) for contaminating the site/the total
                   number of sites on the NPL.

                   This measure counts the number of legal actions
                   EPA has taken to involve responsible parties in
                   site study and cleanup.  These actions include
                   administrative and judicial settlements, injunctive
                   referrals and administrative orders for removal,
                   site study, and Remedial Design and Remedial
                   Action (RD/RA).  It includes both those
                   situations where parties voluntarily entered into a
                   settlement with EPA and those where EPA uses
                   its enforcement authority to- compel responsible
                   parties to conduct  work. .

                   Results:  During FY 1993, 127 enforcement
                   actions for site study and cleanup were taken at
                   115 sites of the 1,177 sites on the NPL.  Seventy-
                   eight of these actions were settlements for
                   RD/RA (36 consent decrees and 42 unilateral
                   administrative orders).

                   Since  the inception of the Superfund program,
                   EPA has achieved responsible party (RP)
                   commitments to site response at 748 sites (64
                   percent)  of the 1,177 non-Federal  facility sites
                   on the NPL with an estimated cumulative value
                   of over $7.9 billion. In FY 1993, EPA achieved
                   RP commitments to response work at 115 (10
                     thiMtom
                       300
                              Cost Recoveries - By Year
                          •1  *2 «  M  is. W
 Page 14
EPA's FY 1993 Annual Financial Statements

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percent) of the 1,177 NPL sites.  The estimated
yalue of the FY 1993 RP NPL cleanup
 omrnitment is $841.6 million.
Measure 7:  Past costs achieved in settlement.

This measures provides the amount of cost
recovery that has been achieved to date. A
number of factors limit Superfund's ability to
recover its past costs, including bankruptcy of
PRPs, other litigation concerns, involvement  of
other Federal agencies as PRPs, the inability  to
identify financially viable PRPs, and the
exclusion of certain indirect costs from cost
recovery. Of the $8.7 billion in past costs, $4.8
billion are considered recoverable.
          Cost Recoveries - Cumulative
Results:  Through FY 1993, Superfund has
achieved settlement for $1.033 billion and is
seeking another $944 million in ongoing cost
recovery actions.  Also, through FY 1993,
Superfund has incurred approximately $4.8
billion in past costs which are considered
recoverable.

Future cost recovery actions will seek additional
portions of the $4.8 billion in  recoverable past
costs.  Cost recovery actions for individual sites
are generally initiated in the year prior to ilie
expiration of the statute of limitations.

Measure 8:  The amount of money EPA has
collected from parties responsible for
contaminating sites on the NPL/the total
amount achieved in settlements and judicial
actions.

This measure totals the value of cost recoveries,
penalties and damages collected during the fiscal.
year compared  to the amount of cost recoveries
actually achieved (assessed) in settlements and
judicial actions.

There is frequently  a delay between the date the
settlement is reached (the day cost recovery  is
considered to be achieved) and the date the
funds are collected.  Because of the time
required to file the necessary documents with the
courts, delays of three months and longer  are not
uncommon. As a result, settlements reached in
the second half of one fiscal year are  frequently
collected in the following year.

Results: In FY 1993, the Agency collected over
$185 million in cost recoveries and reached
settlements for the recovery of $221.7 million.
Since the inception  of the program, the Agency
has collected over $731.7 million in cost
recoveries.  This represents 71 percent of the
total value of cost recovery settlements reached
by the program to date.  .
           PRP Response Settlements
                                       TOM
                                       ROM
   2.000
                                                        tO II  12 13 *t IS M  §7 H » W »1  02  83
EPA's FY 1993 Annual Financial Statements
                                     Page 15

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   Measure 9:  The estimated amount of money
   parties responsible for contaminating
   Superfund sites legally have committed to
   spend on site cleanup/the total amount of
   money spent by the Superfund on site
   cleanup.

   This measure estimates the dollar value of
   cleanups responsible parties have agreed to
   perform at NPL and non-NPL sites. The
   estimate is derived from the Remedial Design or,
   where this is not available, from the Record of
   Decision. This estimate is then compared  to the
   amount of funds expended from the trust fund to
   provide an order-of-magnitude contrast between
   EPA expenditures for site response versus
   private party expenditures for site response,
   recognizing that the actual outlay of funds takes
   place over several years.   The resulting ratio is a
   measure of cost avoidance to  the fund.

   Results:  In FY 1993, the Agency reached  199
   settlements (NPL and non-NPL) for responsible
  party response worth an estimated $910.3
   million. Response settlements may be broken out
.'  as follows:

   •    Remedial Design/Remedial Action
     '  settlements- $811.0 million
*.         -  Consent decrees referred to the      -.
            Department of Justice - $366.3     's
            million.
            unilateral administrative orders  -
            $420.6 million
            Administrative  Orders on Consent -
            $24.1 million
   •   Settlements for removal and site evaluation -
      $99.3 million.

   When the value of FY 1993 response settlements
   is added to the cost recovery settlements
   achieved of $221.7 million, the  total ($1.13
   billion) represents the amounts for which private
   parties committed to pay for site response.  FY
   1993 Superfund obligations totaled $1.6 billion.
   Compared to Superfund enforcement
                   expenditures in FY 1993 ($189 million), these
                   results represent a ratio of $6.00 in settlements
                  for each dollar spent on  enforcement.

                   Summary.  The Superfund program exceeded
                   most of the internal goals the Agency  set for
                   itself in FY 1993.  The Agency exceeded its goal
                   of 200 total sites by  the end of FY  1993 by
                   achieving 216 construction  completions and
                   expects to achieve a total of 650 by the year
                   2000.              .  .

                   The Superfund enforcement program also
                   compiled an enviable record in FY  1993.
                   Responsible parties contributions now  account
                   for a majority of the Superfund cleanup work.
                   The value of responsible party settlements has
                   risen dramatically in the  past few years due to
                   EPA's enhanced enforcement authorities and an
                   "enforcement first" policy and now  comprise 79
                   percent of the remedial actions initiated in FY
                   1993.

                   Building on the momentum of the Superfund
                   revitalization program, in FY 1993 the Agency
                   initiated  a series of nine  initiatives to improve
                   the Superfund program without changing the
                   current statute. These initiatives address
                   enforcement fairness, streamlining response
                   actions, enhancing environmental justice,
                   community  involvement, and enhancing the roles
                   of the States in the Superfund program.

                   In addition, the program  wilt  continue its
                   emphasis in accelerating  cleanups through the
                   Superfund Accelerated Cleanup Model,
                   completing construction at NPL sites, pursuing
                   cleanups done by PRPs and improving contract
                   management.

                   Next Steps.  One critical area we will continue
                   to focus  on  is contracts management.  Since  the
                   Superfund program is highly contract leveraged,
                   an efficient  and effectively  managed contracts
                   program is integral to Superfund's success. The
                   Agency is implementing  a long-term contracting
  Page 16
EPA's FY 1993 Annual Financial Statements

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^0CO1
strategy that projects Superfund's needs over the
next decade and redesigns our portfolio of
  ntracts to meet these.  We are phasing in new
 'ontracts, most of which will be managed by the
Regional offices. This strategy is now under
Agency review.
*
EPA's Alternative Remedial Contracting Strategy
(ARCS) Task Force recommended improving
cost control in the ARCS contracts to reduce
administrative expenditures. The ARCS Task
Force recommended a target ratio be set at 20
percent for program management costs against
total contract expenditures. This target was
subsequently lowered by Congress in the VA-
HUD appropriations bill language to 15 percent
for FY 1992, 12 percent for FY  1993  and 11
percent for FY 1994.  EPA's  actions to control
costs resulted in EPA achieving  the program
management Congressional targets for FY 1992
(with an actual ratio of 13.9 percent) and again
in FY  1993 (with an actual ratio of 11.5
percent).  The national target  continues to
decrease each year, encouraging contractors
 leaning up sites to manage administrative costs
  isely.
     EPA also must continue to address weaknesses
     in our contracts program.  Although the Agency
     has contracted substantially for policy and
     regulatory development support, this has been
     done out of necessity rather than choice. The
     Agency would prefer to have this work done by
     government employees. Due both to limits in
staff resources and to the availability of contract
funds, the Agency has contracted out these
activities.

EPA also enhanced enforcement fairness via
approximately 43 de minimis settlements in FY
1993 and by pursuing several other efforts such
as the use of alternative dispute resolution  to
assist in cost allocation issues at approximately
35 sites.  EPA also plans to issue guidance on
soil screening levels for approximately 90
chemicals commonly found at Superfund sues
and issue a policy regarding future land use of
Superfund sites.  The first 30 soil screening
guidances are in draft and being piloted in the
regions; the remaining 60 are in development.
Additional guidance will also be issued for
certain types of sites for presumptive/
standardized remedies which should speed the
selection of remedies.  In addition, 14 sites, 2
areas and 5 region-wide areas have been
identified as pilots for special environmental
justice emphasis.

EPA's efforts to convert base extramural
resources to Agency FTE to perform these types
of functions have been unsuccessful thus far.  In
lieu of substituting Agency staff for contractors
to perform sensitive work, we are instituting
more stringent Agency contracting procedures.
However, as long as we continue to use
contractors to handle such a large portion of the
Superfund work, we remain vulnerable to
potential problems.
     EPA's FY 1993 Annual Financial Statements
                                                                                      Page 17

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Leaking Underground Storage Tank (LUST) Program
The Leaking Underground Storage Tank (LUST)
program was authorized by the Resource •
Conservation and Recovery Act.  The Office of
Solid Waste.and Emergency Response is
responsible for implementation of the LUST
program.

Program Description

The Resource Conservation and Recovery Act
was amended in 1984 to give EPA the authority
to regulate underground tanks storing petroleum
products. In 1986, Congress set up a S500
million Leaking Underground Storage Tank
(LUST) Trust Fund which is financed by a 1/10
of a cent tax on the sale of motor fuels.  The
trust fund was reauthorized for five years in
1990 with no cap on funds collected. The fund
is used to oversee cleanups by responsible
parties or to clean up LUSTs where the
owner/operator cannot or will not do so, or
where no owner/operator can be found.

The.U.S. has 5-7 million underground tanks
storing petroleum products. Approximately  1.3
million of these are regulated by  EPA; the rest -
mainly on farms and at other locations that
contain heating oil for on-site consumption - are
exempt by law.

Underground storage tanks (USTs) are found at
gas and service  stations, convenience stores and
non-marketer locations such as bus depots and
government facilities. An estimated 15-25
percent of regulated tanks may be leaking.
Leaks from USTs can cause fires or explosions,
and some leaks  contaminate groundwater.

Due to the large size and diverse nature of the
regulated universe, EPA has set up a
decentralized UST program.  The Agency relies
primarily on States and localities to carry out the
underground storage tank program. EPA has
                  formal agreements with all States to operate the
                  UST program as EPA's agent (including
                  inspections and enforcement). At the end of FY
                  1993, EPA had delegated program authority to
                  13 States, granting them formal approval to
                  regulate USTs in lieu of EPA.
                  Financial Perspective

                  Since 1986, the Treasury managed LUST Trust
                  Fund has collected $1.1  billion.  This fund is the
                  source of funding for EPA's LUST account.'
                  Through annual and  supplemental appropriations,
                  Congress establishes the amount of the fund that
                  EPA may use.  Congress has. appropriated a total
                  of $410 million to EPA  through the end of FY
                  1993. EPA withdraws monies from the trust
                  fund as needed to cover disbursements.  At the
                               LUST Projects - FY 93
                                Total EPA Funding $83 Million
                                   State Managed (97%)
                                                EPA Managed (3%)
                  end of FY 1993, the trust fund had an
                  unappropriated balance of $675 million.
                  Congress could make these funds available to
                  EPA in future appropriations.

                  Due to the decentralized nature of the LUST
                  program, EPA has awarded 86 percent of  its
Page 18
EPA's FY 1993 Annual Financial Statements

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           LUST Financial Trends
  100
   to
   20
       PC 90
                         FYK     FYM
appropriated funds to the States, since the
program's inception.

In FY 1993, EPA utilized 82.7 FTE and $83
million to implement the LUST program.
OSWER supported the LUST program with  67
FTE and $73 million, while approximately 16
     and $10 million were used by non-OSWER
offices in Headquarters and the Regions.
Responsible parties conducted 97 percent of the
cleanups with State oversight.

The appropriated funds increased by $10  million
in FY 1992 compared to FY 1991. The FY
1993 Appropriations Act kept funding at  the
same level as FY 1992, but a Midwest Flood
Supplemental Appropriation provided an
additional $8 million.   Obligations decreased by
almost $1 million in FY 1993 after an $8.6
million increase in FY 1992.  However, net
outlays continued to increase from FY  1990
through FY 1993.  Since the LUST program is
funded by no-year appropriations, obligations
and outlays are funded by current-year
appropriations as well as prior-year unobligated
and unexpended balances respectively.
 Program Results

 The LUST program has initiated corrective
 actions at over 171,000 sites as of the end of
 FY 1993.  These cleanup actions are protecting
 hundreds of thousands of people from the effects
 of leaking petroleum storage tanks.

 For the LUST program, the FY '1993
 performance  measures count the number of sites
 with confirmed releases of petroleum products,  .
 the number of these where cleanup has  been
 initiated and  the number where it  has been
 completed.

 Measure 1:  The number of sites nationwide
 where EPA and the States have found a
 petroleum leak from an underground storage
 tank.

 This measure counts those sites where a release
 has been identified  and confirmed by EPA or the
, designated State agency.  It represents the
 potential universe of sites for cleanup by the
 LUST program.  This measure does not count
 tanks on farms and at other locations exempted
 by law from  the LUST program.

 Results: During FY 1993, 53,000 USTs were
 added to the  list of sites with  confirmed releases.
 At the end of the fiscal year, a total of 237,000
 sites were on this list.

 Measure 2:  The number of sites with
 petroleum leaks from an underground storage
 tank where cleanup has been initiated/the
 total number of known sites with leaking
 tanks.

 This measure counts those LUST  sites where
 action has been  initiated to remediate or clean up
 the contamination, and compares that number to
 the universe of sites with known releases.
 Cleanups may be initiated by  a State (with or
 without LUST trust fund money) or by  the
 responsible party.
EPA's FY 1993 Annual Financial Statements
                                     Page 19

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 Results: In FY1993, the program initiated
 actions at 42,000 sites.  Cumulative program to
 date: 171,000 cleanups initiated/a total universe
 at the end ofFY 1993 of 237,000 sites with
 confirmed releases.

 Measure 3:  The number of sites with
 petroleum leaks from an underground storage
 tank that have been cleaned up/the total
 number of known sites with leaking tanks.

.This measure counts those sites where  the State
 has determined that no further cleanup is
 necessary, and compares this number to the
 universe of sites with known releases.  The
 cleanup can be led by the State or the
 responsible party and State cleanups  may or may
 not have used trust fund money.
      LUST National Corrective Action Activity
    -340
    200
         FY«0      FY»<      FYM     FYS3
                   Results: During FY 1993, cleanup was
                   completed at 32,000 LUST sites.  Total to date
                   completions is 87,000/a total universe at the end
                   ofFY 1993 0/237,000 sites with confirmed
                   releases.

                   The FY 1993 LUST data indicates a continuing
                   increase in the number of confirmed releases
                   from underground tanks.  This is not surprising
                   as many tanks which were installed 20 to 30
                   years ago  are now corroding and leaking. We
                   anticipate  that the rate of confirmed releases will
                   continue at a  rate of about 50,000  per year for
                   the next several years.

                   The numbers  of cleanups initiated  and completed
                   are also on the upswing, due to the growth of
                   State programs and EPA's efforts  to speed up
                   site assessments and get the cleanups underway
                   quickly. EPA also has worked with States to
                   quicken the pace of cleanups and make them as
                   least costly as possible.

                   Over the next several years, the  LUST program
                   will focus  on preventing as well as remediating
                   releases. By  December  1993, all owners must
                   utilize an accepted method of leak detection on
                   all existing systems.  In addition, the program
                   will expand its efforts to ensure  that new tanks
                   are properly installed and that old  ones are
                   properly close.  Proper tank installation and
                   closure and careful monitoring of tanks in use
                   will minimize future problems with leaking
                   underground storage tanks.
Page 20
EPA's FY 1993 Annual Financial Statements

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Oil  Pollution  Prevention Program (Oil Spill Trust Fund)
 PA's Oil Pollution Prevention program is-
housed in the Office of Solid Waste and
Emergency Response (OSWER) and uses the Oil
Spill Trust Fund to finance the cost of cleaning
up spills. The Emergency Response Division
(ERD) within OSWER's Office of Emergency
and Remedial Response (OERR) provides
assistance to Regional On-Scene Coordinators
during oil spill incidents.  Support for
enforcement activities is provided by OSWER's
Office of Waste  Programs Enforcement (OWPE).

Program Description
The Oil Pollution Act (OPA) of 1990 was passed
in response to increasing frequency and severity
of accidental oil discharges into the environment,
such as the Exxon-Valdez spill The goal of the
Oil Pollution Prevention Program is to protect
public health, welfare and the environment from
hazards associated with a discharge, or a threat
 f a discharge, of oil and other petroleum
 iroducts or hazardous substances into navigable
waters.
Under the OPA, EPA is responsible for oil spill
prevention, preparedness, response, and
enforcement activities associated with non-
transportation-related facilities.  These facilities,
which range from hospitals and apartment
complexes to large tank farms, include any
storage facility with aboveground storage
capacity greater than 1,320 gallons, a single
aboveground storage tank larger than 660
gallons, or underground storage greater than
40,000 gallons.

The OPA requires area committees (comprised
of state, local and federal officials) to develop
Area Contingency Plans which: detail the
responsibilities of those involved in planning the
response process; describe unique geographical
features of the area covered; and identify
available response equipment.  EPA must review
and approve facility response plans which:
ensure consistency with the National
Contingency Plan; identify and ensure the
availability of resources to respond to a worst
case discharge; establish communications;
identify an individual with authority to
implement removal/actions; and describe training
and testing drills at the facility.

The most resource-intensive and time critical ,
requirements are those related to facility
response plan reviews and approvals. Of the
4,074 facility response plans submitted to the
Agency, 2,300 facilities pose a significant or
substantial threat to the environment and will
require Agency approval by February 1995, or
the requesting facility must cease operations.

EPA is establishing the regulatory framework
under which it will proceed with its OPA-
mandated responsibilities.  This framework
includes the Oil and Hazardous Substances
National Contingency Plan (NCP 40 CFR Part
300) and the Oil Pollution Prevention regulation
(40 CFR Part 112).  The NCP is the nation's
blueprint for responding to releases of oil and
hazardous substances.  The Oil Pollution
Prevention program establishes requirements to
prevent and prepare to respond to  spills at oil
storage facilities  subject to the  regulation.

Headquarters  develops policy and. program
guidance to: 1) prevent harmful releases of oil
and other petroleum products; 2) improve
nationwide capability to respond to threats of
discharge of oil or other petroleum products; 3)
improve  nationwide capability for  containment
and removal of releases that occur in navigable
waters; 4) coordinate with other federal agencies
on facility response plan requirements and
review and approval; 5) minimize  the resulting
environmental damage from releases; and
EPA's FY 1993 Annual Financial Statements
                                    Page 21

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 6) fully utilize enforcement authority to compel
 responsible parties to clean up spills and to
 provide a strong economic incentive to invest in
 preventive measures and comply with
 regulations.

 In addition, Headquarters supports field
 operations through operational guidance,
 technical bulletins, and demonstrations of new
 technologies. Headquarters also supports the
 OPA-mandated facility response plan process,
 chiefly through the development of approval
 criteria for the response plans.

 The Regions conduct oil storage facility
 inspections to ensure compliance with EPA's oil
 pollution prevention regulation, also known as
 the Spill Control and Countermeasures regulation
 (SPCC).  A major component of the Regions'
 work is the monitoring, directing, or performance
 of removal actions during oil spills.  They also
 conduct periodic equipment inspections and
 unannounced area drills. The Regions take
 administrative actions against facility operators
 for failure to comply with SPCC plans and new
. OPA requirements, and refer a limited number of
 actions for judicial action. Administrative and
I judicial actions  also are brought as a result of oil
• and hazardous substance spills. Regions also
 assist the Federal Emergency Management
 Agency at major disasters and participate in
 response training of State and local staff.

 The: beneficiaries  of the Oil Pollution Prevention
 program are those people living in the vicinity of
 confirmed spills when cleanup actions are  taken
 either by. EPA or the responsible party. People
 living near regulated facilities benefit from the
 increased safety measures incorporated into the
 facilities' response plans.

 Financial Perspective

 Since the beginning of the Oil Spill Trust Fund's
 existence through FY  1993, Congress  has
 appropriated a total of $39 million to the
                   Agency.  In FY 1993, EPA used 75.5 FTE and
                   had budget authority of $20.7 million to
                   implement the Oil Pollution Prevention program.
                   The $20.7 million sum includes $700,000
                   received as a result of a Midwest Flood
                   Supplemental Appropriation.  The Agency
                   obligated $18.2 million  for oil spill response
                   activities in FY  1993 and processed $6.2 million
                   in net outlays.

                   Program Results

                   Measure l(a)  Oil Facility Response Plans
                   Received and (b) Extensions Granted

                   This measure counts (a) the number of oil
                   facility response plans received and (b) the
                   number of extensions granted to facilities for
                   submitting response plans. Under the Oil
                   Pollution Act (OPA), facilities which store oil
                   and have the potential to cause "substantial
                   harm" to the environment must prepare a
                   response plan for the worst case discharge.

                   Results:  To date,  4,074 facility response plans
                   have been received and 2,378 extensions have
                   been  granted.
                   Measure 2(a)  Oil Spill Cleanups and (b) On-
                   Scene Monitoring of Potentially Responsible
                   Party (PRP) Lead Cleanups

                   This measure counts (a) the number of oil spills
                   cleaned up by EPA using OPA funds and (b) the
                   number of times EPA monitors a PRP's cleanup
                   actions.  EPA monitors a cleanup when a
                   Potentially Responsible Party responds to the
                   spill to ensure adequate cleanup takes place.

                   Results:  Twenty-five oil spills were cleaned up
                   in FY 1993 using OPA funds. _ EPA monitored
                   170 responsible party oil spill cleanups in FY
                   1993.
 Page 22
EPA's FY 1993 Annual Financial Statements

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  [easure 3(a) Administrative Actions for spill
 iolations and prevention regulation violations
and (b) Judicial Penalty Enforcement Actions
for spill violations and prevention regulation
violations.

This measure counts (a) the number of
administrative and (b) judicial enforcement
actions resulting from prohibited spills and
violations of the regulations of the Clean Water
Act as amended by the Oil Pollution Act. These
                                                 two actions reflect a significant portion of the
                                                 resources used in the oil program and indicate
                                                 significant achievements in compliance.  An
                                                 administrative complaint is counted on the date it
                                                 is issued to the  respondent.  A judicial case is
                                                 counted on the date of the referral letter/cover
                                                 memo to the Department of Justice.

                                                 Results: Eleven administrative cases were filed,
                                                 and four judicial enforcement actions were
                                                 referred to the Department of Justice in  FY
                                                 1993.

EPA's FY 199? Annual Financial Statements
                                                                                      Page 23

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  Asbestos Loan and  Grant Program
  The Asbestos Loan and Grant Program is
  administered under the Asbestos School Hazard
  Abatement Act (ASHAA) primarily by the
  Office of Prevention, Pesticides and Toxic
  Substances (OPPTS).  This overview covers the
  entire Asbestos Loan and Grant program.
  However, the loan portion of the program is the
  only part that is a commercial activity  and is the
  only part of the program covered by the  audited
  financial statements.

  Program Description

  The purpose  of the ASHAA program is to
  reduce risk to school children and employees
  posed by asbestos. Since its inception,  the
  program has  provided more than  $420  million in
  financial assistance to financially needy  Local
  Education Agencies (LEAs) with the most
  hazardous asbestos  abatement projects.  During
  this period, a significant amount of exposure to
,  asbestos fiber has been eliminated. Although the
.  statute was reauthorized through  1995, EPA has
  not included  funding in any of its recent budget
  requests to Congress.  Each year, new  funding
  has been dependent on Congress  adding
.  resources, in varying amounts, to the Agency's
  budget request.  The 1994 Appropriations Bill
  did not contain any funding for ASHAA loans
  and grants.  The State designee and educational
•  organizations have been notified of this reduction
,  in the ASHAA program.

  The Act envisions a three-step process. First,
  EPA is to make applications available  to public
  and non-profit schools for completion and
  submission to their State Governors (or the
  Governor's Designee). Second, Governors (or
  Designees) are  responsible for collecting,
  reviewing, and  submitting applications to EPA.
  Third, EPA receives and reviews all applications
  and makes offers of financial assistance available
  on the basis of the applicant's asbestos hazard
                  and demonstrated financial need.  The
                  reauthorized statute mandates that awards of
                  financial assistance must be made by April 30 of
                  each year for which Congress appropriates
                  funding for the loan and grant program.

                  In making its award decisions, the ASHAA
                  legislation instructs EPA to generate its own
                  national priority list from applications received.
                  A ranking method is then employed to sort all
                  proposed abatement projects into categories
                  depending on certain characteristics of the  .
                  asbestos containing building materials (ACBM).
                  Only projects with  friable ACBM and some
                  degree of damage are considered for financial
                  assistance.  If the project has damaged friable
                  material, the ranking method next establishes
                  four categories based on the degree of damage to
                  the ACBM, and whether the material is exposed
                  or located in an air plenum. The four categories
                  are:

                  Priority One - Significantly damaged friable
                  surfacing material which is exposed and/or
                  located in an air plenum.

                  Priority Two - Friable asbestos containing
                  materials which are exposed or in an air plenum
                  and are defined by  an  AHERA accredited person
                  as one of the following:

                  •   Damaged or significantly damaged thermal
                      system insulation.

                  •   Damaged surfacing material.

                  •   Damaged or significantly damaged
                      miscellaneous material  which has been
                      isolated to protect human health and the
                      environment.  "

                  Priority Three - Damaged or significantly
                  damaged friable miscellaneous material which
  Page 24
EPA's FY 1993 Annual Financial Statements

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does not necessitate isolation but is exposed
 ,nd/or located in an air plenum.

Priority Four - Any damaged or significantly
damaged friable material which is not exposed or
located in an air plenum.
Since the inception of the program, only projects
within hazard categories one and two were
within reach for funding before funds were
expended.
While the condition of the asbestos-containing
materials determines the priority for
consideration of a project, financial need controls
whether an award is offered, the award amount,
and the loan/grant composition of the award.  In
accordance with the statute,  monies are not made
available to any applicant which has  sufficient
resources available to support  an asbestos
abatement program.  Financial indicators used to
determine eligibility for both private  and public
schools include Budget per Pupil and the burden
 :f abatement costs on an LEA's operating
 udget.
Assistance may take the form of either a grant or
an interest-free loan, or some combination of
both. Loans may include  up to 100 percent of
abatement project costs and grants may cover up
       Asbestos Fund Awards - FY 93
            Total Award* - $54.5 Million

               Loans (93%)
                              Grants (7%)
 to 50 percent of costs.  ASHAA does not require
 that EPA provide recipients the total funding
 necessary to complete an abatement project.

 Financial Perspective

 Since  1985, the ASHAA Loan and Grant
 program has awarded $422.3 million for asbestos
 abatement projects.  Approximately $310.7
 million of these awards were for twenty-year
 loans.
   »«».   Asbestos Fund Financial Trends
     100,
     BO
                                       luni
       I
     20-
                                    -— Qrtna
                                                          FY90
                                                                                    FYW
 Implementation of the Federal Credit Reform
 Act of 1990 changed the way the Agency uses
 appropriated funds for asbestos loans.  Prior to
 the Act,  the total amount of the loan was funded
 by the appropriation. As of FY  1992, only the
 subsidy portion of the loan (actual cost to the
 government) is funded by the appropriation. The
 balance is funded with money borrowed from the
 Treasury and repaid  as EPA collects loan
 repayments.

 In FY 1993, grant^and loan awards totalled to
 $76.2 million, an increase of $21.7 million over
 FY  1992 awards. Of the 1993 awards, 93
 percent were loans and 7 percent were  grants.
 This is a 20 percent  decrease in the ratio of
 program grants versus loans compared to the FY
.1992 ratio.  By decreasing grants relative to
EPA's FY 1993 Annual Financial Statements
                                     Page 25

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loans, EPA lowers the Federal government's
costs for reducing asbestos exposure hours. Both
loan obligations and loan repayment collections
continued to increase from FY 1990 through FY
1993.

During FY 1993, the Agency collected $10.4
million in loan repayments.  Based on loan
disbursement and collection history, the Agency
projects collecting $10.5 million in loan
repayments in FY 1994.
                   Program Results

                   EPA's performance measures for the ASH A A
                   program include two measures:

                   Meaasure 1: Number of AS HA A awarded
                   projects.

                   Results: In FY 1993-, the ASHAA program
                   funded 305 projects in 156 LEAs across the
                   country,

                   Measure 2:  Elimination of Exposure Hours.

                   Results: When the-projects currently funded are
                   completed, EPA estimates that 3.2 million
                   exposure hours will be eliminated per week.
   Asbestos Exposure Hours Eliminated per Week
       IMS  1M* 1M7  1tM  1M* 1MO  1991  1992 1903
                                                    900
                                                    «00
                                                    200
                             ASHAA Projects Awarded
                               (Two rounds of awards in FY 87)
                                                       IMS 19H  1M7 ISM  t999  IMO 1991  1992 1993
Page 26
EPA's FY 1993 Annual Financial Statements

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JPesticides Registration and  Expedited Processing  Fund
"FIFRA  Fund)
The Pesticides Reregistration and Expedited
Processing Fund (FEFRA Fund) is administered
under the Federal Insecticide, Fungicide, and
Rodenticide Act (FIFRA) primarily by the Office
of Prevention, Pesticides and Toxic Substances

Program Description
As part of its authority to regulate pesticides,
EPA is responsible for reregistering existing
pesticides. The FIFRA legislation, requiring the
registration of pesticide products, was originally
passed in 1947. Since then, health and
environmental standards have become more
stringent and scientific analysis techniques are
much more precise and sophisticated. In the
1988 amendments to FIFRA (FIFRA '88),
Congress mandated the accelerated reregistration
of all products  registered prior to November 1,
 984.  The amendments established a statutory
 ;oal of completing reregistration eligibility
decisions by 1997.  The legislation allows for
various time extensions which can extend this
deadline by three years or more.  Additional
resources, however, will be needed to meet these
goals/deadlines.

Congress authorized the collection of two kinds
of fees until 1997 to supplement appropriated
funds for the program - an annual Maintenance
Fee and a one-time Reregistration Fee.
Maintenance fees are  assessed on registrants of
pesticide products and are structured to collect
approximately $14 million per year.
Reregistration fees are assessed on the
manufacturers of the active ingredients in
pesticide products and are based on the
manufacturer's share of the market for the active
ingredient. In fiscal years 1992,  1993, and  1994,
approximately  14 percent of Maintenance Fees
collected, up to $2 million each year, are to be
used for the expedited processing of old
chemical and amended registration applications,
Fees are deposited to the FIFRA Revolving
Fund.  By statute, excess monies in the FIFRA
Fund may be invested. Waivers and/or refunds
are granted for minor  use pesticides,
antimicrobial pesticides, and small businesses.

The reregistration process is being conducted
through reviews of groupings of similar active
ingredients called cases.  There are five (5)
major phases of reregistration:

•   Phase  1 - Listing of Active Ingredients. EPA
    publishes lists of active ingredients and asks
    registrants whether they intend to seek
    reregistration. Completed in FY 1989.

•   Phase 2 - Declaration of Intent and
    Identification of Studies.  Registrants notify
    EPA if they intend to reregister and identify
    missing studies. Completed in FY 1990.

•   Phase 3 - Summarization of Studies.
    Registrants submit required existing studies.
    Completed in FY  1991.

•   Phase 4 - EPA Review and Data Call-Ins
    (DCIs).  EPA reviews the studies, identifies
    and "calls-in" missing studies by issuing a
    DCI.  A "DCI" is  a request to a pesticide
    registrant for scientific data to. assist the
    Agency in determining the pesticide's
    eligibility for reregistration.

•   Phase 5 - Reregistration Decisions.  EPA
    reviews all studies and issues a Reregistration
    Eligibility Document (RED) for the active
    ingredient(s).  A "RED"  is a determination
    by  the Agency whether products containing a
    pesticide active .ingredient are eligible for
    reregistration. The registrant complies with
    the RED by submitting product specific data
EPA's FY 1993 Annual Financial Statements
                                     Page 27

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    and new labels. EPA reregisters or cancels
    the product.  Pesticide products are
    reregistered,  based on a RED eligibility
    determination, when it meets all label
    requirements.  This normally takes 14 to 20
    months after issuance of the RED.

Financial Perspective

During FY 1993, the  Agency's obligations
charged against the FIFRA Fund for the cost of
the reregistration and  expedited processing
programs were 192 FTEs and $15.6 million.  Of
these amounts, the Office of Pesticide Programs
funded the 192 FTEs  and obligated $12.3
million of this cost.
IM_ FIFRA Financial Trends
«o
30
i
• 2D-
> to


FMHfcotpB
""M*- >^ __~^
•x~- 	 ~^--

t
FV90 FT91 FY92 FYM
Appropriated funds are used in addition to
FIFRA revolving funds.  In FY 1993,
approximately $25.3 million in appropriated
funds were obligated for reregistration and
expedited processing program activities. The
unobligated balance in the fund at the end of FY
1993 was $9.92 million.  This is an increase of
$0.94 million compared to the FY 1992 year-end
balance of $8.98 million.

The fund has two types  of receipts:  fee
collections and interest earned on investments.
Of the $16.3 million in FY 1993 receipts,
approximately 97 percent was fee collections.
                   During the past two years, the fund balance and
                   corresponding investment earnings have
                   decreased because program expenses
                   (disbursements) exceeded collections.  The fee
                   collections decreased by almost S0.4 million in
                   FY 1993 compared to FY 1992. The obligations
                   decreased in FY 1993 because the Office of the
                   General Counsel and other Agency offices no
                   longer make direct charges to the fund.
                             FIFRA Fund Receipts - FY 93
                                 Total Receipts - $18.3 Million


                                    Fees (97%)

                                                                            : Investment Earnings (3%)
                   Program Results

                   The following measures support the program's
                   strategic goals of Food Safety and Safer
                   Pesticides as contained in the Pesticide Program
                   Strategy, 1994-1997. The product reregistration
                   measure is different from the measure reported
                   in FY 1992,  It has been changed to remain
                   consistent with the definition of the performance
                   indicators being tracked by the Strategic
                   Targeted Activities for  Results System (STARS).
                   In FY 1992, STARS measured only the number
                   of reregistrations, while in 1993, it counted the
                   number of products reregistered, canceled and
                   amended.  This figure more  accurately reflects
                   program effort based on a RED eligibility
                   determination.
Page 28
EPA's FY 1993 Annual Financial Statements

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Measure 1: Number of Reregistration           Measure 2: Number of products reregistered,
  ligibility Documents (REDs) completed.         canceled, or amended.

'Results:  The number of Reregistration Eligibility   Results:  In FY 1993, 219 products were
Documents (REDs) completed was 19 (versus a     reregistered, 434 cancelled (111 of which for
target of 20), an increase of 4 over FY 1992       nonpayment of fees) and 12 amended.  The
when 15 were completed.  There are •             combined 665 actions were achieved versus a
approximately 405 REDS of which 47 have been    target of 1122. In addition, 423 products  were
completed.                                     forwarded to the EPA Office of Compliance
                                               Monitoring for suspension.
 EPA's FY 1993 Annual Financial Statements                                                    Page 29

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  Revolving Fund for Certification and  Other Services
  (Tolerance  Fund)
  The Revolving Fund for Certification and Other
  Services (Tolerance Fund) is administered under
  the Federal Food, Drug and Cosmetic Act
  (FFDCA) primarily by the Office of Prevention,
  Pesticides and Toxic Substances (OPPTS).

  Program Description

  As part of its authority to regulate pesticides,
  EPA is responsible for setting "tolerances".  If
  the pesticide is being considered for use on a
  food or feed crop or as a food or feed additive,
  the applicant must petition EPA for
  establishment of a tolerance (or exemption from
  a tolerance) under authority of FFDCA. A
  tolerance is the maximum legal limit of a
  pesticide residue on food commodities and
  animal feed. Tolerances are set at levels that
  ensure that the public is  protected from
  unreasonable health risks posed by eating foods
 , that have been treated with pesticides in     ;
.-. accordance with  label directions.   The tolerance
  program is a major part of the Agency's Food
 -Safety goals.

     . In 1954, Congress authorized the collection
  of fees for the establishment of tolerances for
  raw agricultural commodities (section 408 of
  FFDCA).  Congress, however, did not authorize
  the collection of fees for food additive
  tolerances  (section 409 of FFDCA).  EPA,
  therefore, does not collect fees for food additive
  tolerances.  The Agency  also does not collect
  fees for Agency-initiated actions such as the
  revocation of tolerances for previously canceled
  pesticides. Fees  collected for tolerances for raw
  agricultural commodities were deposited to the
  U.S. Treasury General Fund until 1963 when
  Congress established the Tolerance Fund.
  Specific fees are contained in 40 CFR 180.33
  and range from $3,200 to $56,175, depending
  on the type of tolerance action requested.
                  Waivers and/or refunds are granted for minor use
                  pesticides submitted under the Inter-Regional
                  Research Project Number 4 (IR-4 Program),
                  public interest, such as reduced-risk pesticides,
                  and economic hardship.  The fees are updated
                  annually based on the cost-of-living adjustment
                  in Federal General Scale wage rates.  Fees were .
                  increased 3.7 percent "in FY -1993.   By statute,  .
                  monies in the Tolerance Fund may  not be
                  invested.

                  Financial Perspective

                  During FY 1993, the Agency charges to the
                  Tolerance Fund for the cost of the tolerance
                  setting functions were $0.9 million.
                  Appropriated funds are used in addition to
                  revolving funds. In FY  1993, approximately
                  $4.5 million in appropriated funds were
                  obligated. The unobligated balance in the
                  revolving fund at the end of FY 1993 was $4.25
                  million.  This is an increase of $0.5 million
                  compared to the FY 1992 year-end balance of
                  $3.75 million.
                         Tolerance Fund Financial Trends
                          FYW
                                  F₯»l
                                          FYM
                                                  FVM
  Page 30
EPA's FY 1993 Annual Financial Statements

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                                                                                                        1
The fund balance remained about the same in
FY 1991 and FY"1992 then increased by almost
 0.5 million in FY 1993.  This fund balance
 ncrease mainly resulted from fee collections
which rose by $0.4 million in FY  1993
compared to FY 1992. Earnings (obligations)
decreased from FY 1992 to FY 1993 primarily
as a result of the decrease in the number of
permanent tolerance petition completions.
Program Results

Tolerance fees collected in FY 1993 were
approximately $1.5 million and "earnings" in FY
1993 were approximately $0.9 million.  Earnings
represent the value of petitions that are  80
percent or more completed.  In 1993, EPA could
not use the tolerance fees in  the revolving fund
until the work on a petition was at least 80
percent completed.
Measure 1:  Number of permanent tolerance
petitions completed.

Results: The number of pertnanent tolerance
petitions completed for section 408 raw
agricultural commodities and section 409 food
additives was 39 compared to a target of 50.
This represents final determinations by the
Agency concerning permanent tolerance petition
requests for allowable levels of pesticide
residues on  raw agricultural commodities and in
food additives.  This is a decrease of 23
completions compared to the 62 in FY 1992.
The number of permanent tolerance petition
reviews ("cycles") completed was 385 compared
to a target of 413.   This measure supports the
strategic goals of Food Safety and Safer
Pesticides as contained in the Pesticide Program
Strategy, 1994-1997.
                                    Tolerance Completions
                          60
                                FY90
                                          FY91
                                                    FY92
                                                              FY93
EPA's FY 1993 Annual Financial Statements
                                    Page 31

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Page 32
EPA's FY 1993 Annual Financial Statements

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  MESSAGE FROM THE CHIEF FINANCIAL OFFICER

       As the Chief Financial Officer of the U.S. Environmental Protection Agency (EPA), I
am proud to present EPA's Fiscal Year 1993 Annual Financial Statements. These statements
provide our Agency managers with an assessment of the financial condition of our trust
funds, revolving funds and commercial activities. They are submitted in accordance with
requirements of the Chief Financial Officers (CFO) Act of 1990 and Office of Management
and Budget guidance.

       EPA's financial statements present the financial position and results of operation of
the following six funds: Superfund Trust Fund; Leaking Underground Storage Tanks (LUST)
Trust Fund; Oil Spill Trust Fund; Loan Portion of the Asbestos Loan and Grant Program;
Pesticides Reregistration and  Expedited Processing Fund (FIFRA Fund); and Revolving Fund
for Certification and Other Services (Tolerance Fund).  The preparation of financial
statements and participation in the audit process provide useful information about our
programs and accounting systems and help us identify areas where improved information
systems, management controls and accountability are needed.

       EPA accelerated the submission of its annual financial statements by 90 days this
year.  In addition to the abbreviated timeframe, we  were able to make significant
improvements in a number of areas. These include:

•     completing the reconciliation of long-standing conversion errors resulting from the
       installation of our integrated financial management system (IFMS) in 1989;

•     receiving a more favorable opinion on the FIFRA fund. This year the auditors
       expressed a qualified opinion as opposed to the disclaimer we received in FY 1992;
       and

•     receiving an unqualified opinion on the Oil Spill Trust Fund, which was added to our
       financial statements for the first time this year.

I am encouraged by the progress we have made as well as by the auditors' overall
recognition of management's commitment to identify and resolve EPA's financial
management problems.

       While I am pleased with these improvements, much work still needs to be done, since
a number of the auditors' findings from last year's statements remain.  While we will not be
able to resolve all of these issues immediately, among my top priorities are to:  improve the
management of our accounts receivable; establish a property tracking system; and resolve
financial management systems documentation, interface and reporting problems. In many
cases, corrective actions are well underway, and I anticipate that our progress will be
reflected in next year's financial statements.
EPA's FY 1993 Annual Financial Statements                                                Page 33

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       EPA's Financial Management Five-Year Plan outlines our strategy for strengthening
accountability and financial management practices throughout the Agency.  The plan
establishes benchmarks, goals and specific milestones by which our progress can be
measured in future years.  By following our plan, consistent with available resources, I
believe we will meet our critical resource management needs and position the Agency to
achieve its environmental mission.

       I  am confident that we at EPA are on the right track for restoring public trust in the
Federal government as responsible financial stewards. I strongly believe the recent financial
reform efforts, which the federal government has undertaken via the National Performance
Review and various legislative efforts, will go  a long way toward resolving common
problems faced by the Federal financial community.

       On a personal note, I want to acknowledge the hard work of the employees
throughout the Agency who contributed to the  production of these financial statements.  I am
especially indebted to the excellent support provided by EPA's Office of Solid Waste and
Emergency Response; Office of Prevention, Pesticides and Toxic Substances; Office of
Policy, Planning and Evaluation; Office of the Inspector General; and my own dedicated
staff.
                          /,
                         F
                                                      onathan Z Cannon
Page 34
EPA's FY 1993 Annual Financial Statements

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Principal Financial Statements
                 Contents
                 Financial Statements
                    Statements of Financial Position
                    Statements of Operations and Changes in Net Position
                    Statements of Cash Flows
                    Statements of Budget and Actual Expenses
                 Notes to Financial Statements
                    Note 1.   Summary of Significant Accounting Policies
                    Note 2.   Fund Balances with Treasury
                    Note 3.   Investments - Federal
                    Note 4.   Loans Receivable, Net Non-Federal
                    Note 5.   Property, Plant and Equipment - Net
                    Note 6.   Debt - Federal
                    Note 7.   Other Funded Liabilities - Federal
                    Note 8.   Total Net Position
                    Note 9.   Program or Operating Expenses
                    Note 10.  Other Expenses
                    Note 11.  Prior Period Adjustments
                    Note 12.  Non-Operating Changes
                    Note 13.  Contingencies
                    Note 14.  Restatement of Prior Year Financial
                              Statements
EPA's FY 1993 Annual Financial Statements                                          Page 35

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EPA Trust Funds, Revolving  Funds and Commercial Activities
Statements of Financial Position  - Restated (Note 14)
As of September 30, 1993 and  1992 (Dollars in Thousands)
 Assets
 Financial Resources:
 Fund Balances With Treasury (Note 2)
 Investments - Federal (Note 3)
 Marketable Equity Securities (Note 1)
 Accounts Receivable, Federal, Net (Note 1)
 Accounts Receivable, Non-Federal, Net (Note 1)
 Loans Receivable, Non-Federal, Net (Note 4)
 Appropriated Amounts Held by Treasury (Note  1)

 Non-Financial Resources:
 Advances and Prepayments, Non-Federal
 Property, Plant and Equipment, Net (Note 5)

    Total Assets

 Liabilities and Net Position

 Liabilities

 Accounts Payable, Non-Federal
 Accounts Payable, Federal
 •Accrued Payroll and Benefits
 Deferred Revenue, Non-Federal (Note 1}
 Deferred Revenue - Federal (Note 1)      ^
 Debt - Federal (Note 6)
 Other Funded Liabilities - Federal (Note, 7)
 Accrued Leave - Unfunded

    Total Liabilities

 Net Position

 Trust Fund Balances
 Commercial Activities
 Revolving Fund Balances
 Less Future Funding Requirements

    Total Net Position (Note  8)
    Total Liabilities  and Net Position
                                1993

                              $  11,485

                                  4,699
                                  7,955
                               193,938

                              3,173,380
                                    133
                                 14.030

                              $3.405.620
                                     Superfund
                                      Trust Fund
                             $  112,057
                                105,541
                                  7,698
                                183,430
                                  4,511
                                 11.556

                                424,793
                             2,992,383
                                (11.556)

                              2.980.827
                             $3.405.620
  1992

$  65,200
    8,958
  122,315

2,967,460
   .   678
   16.094

$3.180.705
$ 102,212
  126,733
    6,464
  248,561
   14,929
   10.723

   509,622
2,681,806
   (10.723)

 2.671.083
$3.180.705
   Page 36
EPA's FY 1993 Annual Financial Statements

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           LUST
         Trust Fund
  1993               1992
    1,638
    6,471
            Oil Spill
           Trust Fund
  1993                1992

 $  14,478            $
       14
       33

   89,021
       51

   80,722
    3,654
       61
$  94.421
      247
       84
$  87.575
$   14.478
    1,749
      157
    1,503
        5
      144
$    1,334
        91
       157
    1,906
    1,652
     1,582
   92,515
   85,923
    12,896
   92.515
   94.421
   85.923
$  87.575
    12.896
$   14.478
                                                                      (Continued)
EPA's FY 1993 Annual Financial Statements
                                                   Page 37

-------
EPA Trust Funds, Revolving Funds and Commercial Activities
Statements of Financial Position - Restated (Note 14}, Continued
As of September 30, 1993 and 1992 (Dollars in Thousands)
 Assets
 Financial Resources:
 Fund Balances With Treasury (Note 2)
 Investments - Federal (Note 3)
 Marketable Equity Securities (Note 1)
 Accounts Receivable, Federal, Net (Note 1)
 Accounts Receivable, Non-Federal, Net (Note 1)
 Loans Receivable, Non-Federal, Net (Note 4)
 Appropriated Amounts Held by Treasury (Note 1)

 Non-Financial Resources:
 Advances and Prepayments, Non-Federal
 Property, Plant and Equipment, Net (Note 5)

    Total Assets

 Liabilities and Net Position

 Liabilities

 Accounts Payable, Non-Federal
 Accounts Payable, Federal
 Accrued Payroll and Benefits
 Peferred Revenue, Non-Federal
 Deferred Revenue - Federal
 Debt'- Federal (Note 6)
 Other Funded Liabilities - Federal (Note 7)
 Accrued Leave • Unfunded

    Total Liabilities

 Net Position

 Trust Fund Balances
 Commercial Activities
 Revolving Fund Balances
 Less Future Funding Requirements

    Total Net Position (Note 8)
    Total Liabilities and Net Position
                                      Asbestos
                                  Commercial Activity
                                1993          1992
                              $   63,073
                                      4
                                130,011
                               $193,088
                                     66
                                 12,172
                                117,634
                                129,872
                                 63,216
                                 63.216
                               $193.088
$  29,877
   19,400
       12
  124,515
  $173.804
       53
    1,318
  123,209
   124,580
   49,224
    49.224
  $173.804
 The accompanying notes are an integral part of these statements.
   Page 38
EPA's FY 1993 Annual Financial Statements

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            FIFRA
         Revolving Fund
  1993                 1992
          Tolerance
         Revolving Fund
1993                   1992
$




950
10,209
2
4
533
$ 11.698
$





$=
357
73
260
5,755
6,445
5,253
5.253
11.698
$ 65 $ 4,246 $ 3,757
15,243
28
15 - -
574
$ 15925 $ 4.246 $ 3.757

$ 1,428 $ 89 $ 153
209 466
457
8,917 3,691 3,604
11.011 4,246 3,757
4,914
4.914
$ 15,925 $ 4.246 $ 3.757
. -
EPA's FY 1993 Annual Financial Statement?
                            Page 39

-------
 EPA Trust Funds, Revolving Funds and Commercial Activities
 Statements of Operations and Changes in Net Position
 Restated (Note 14)
 For the Years Ended September 30, 1993 and 1992
 (Dollars in Thousands)
                                                      Superfund
                                                      Trust Fund
 Revenues and Financing Sources

 Appropriations Expensed
 Revenues from Services to the Public
 Interest and Penalties, Non-Federal
 Interest Income, Federal
 Income From Overhead Allocation
 Fines, Penalties and Other Revenues
 Less: Receipts Returned to Treasury

 Total Revenues and Financing Sources

'Expenses

 Program or Operating Expenses (Note 9)
 Depreciation and Amortization
 Bad Debts and Writeoffs
 Overhead Expenses from Allocation
 Other ExpensesHNote 10)

 Total Expenses.         :
 Excess of Revenues and Financing Sources
 Prior Period Adjustments (Note 11)

 Excess of Revenues and Financing Sources
 Over Total Expenses
 Plus: Unfunded Expenses
 Excess of Revenues and Financing Sources
 Over Funded Expenses

 Changes in Net Position

 Net Position, Beginning Balance
 Excess of Revenues and Financing Sources
 Non-Operating Changes  (Note 12)

 Net Position, Ending Balance
                                                  1993
                                   1992
                   $1,343,528   $1,40.8,040
                       18,941
                     •  32,695        4,514
                       22,257
                     420,242
                     (185.359)
  17,586
 200,596
(184.639)
                    1.652.304   1.446.097
1,340,418
5,016
161,463
22,257
1
1.529.155
123,149
17.361
140,510
833
i 141.343
1,408,582
520
5,455
17,586
2
1.432.145
13,952
3.574
17,526
1,092
$ 18.618
                   $2,671,083   $2,146,393
                     141,343       18,618
                     168.401      506.072

                   $2.980.827   $2.671.083
   Page 40
EPA's FY 1993 Annual Financial Statements

-------
            LUST
          Trust Fund
    1993
  1992
                             Oil Spill
                            Trust Fund
 1993
. .1992
  $   75,137
$  69,153
$   7,804
        827
      238
      755






75.964
75,107
29
1
827
75.964
69.391 8.559
69,117 7,804
19
17
238 755
69.391 8,559
(22) - - -
(22)
$
$


$
(22)
85,923
(22)
6.614
92.515

$ $ * ' •
$ 80,077 $ - , $ -
• -
5.846 12.896
$ 85.923 $ 12.896 ._ - $ • ' -
(Cont
EPA's FY 1993 Annual Financial Statements
                                                         Page 41

-------
 EPA Trust Funds, Revolving Funds and Commercial Activities
 Statements of Operations  and Changes in Net Position
 Restated (Note 14), Continued
 For the  Years Ended September 30, 1993 and 1992
 (Dollars in  Thousands)
 Revenues and Financing Sources

 Appropriations Expensed
 Revenues from Services to the Public
 Interest and Penalties, Non-Federal
 Interest Income, Federal
 Income From Overhead Allocation
 Fines, Penalties and Other Revenues
 Less: Receipts Returned to Treasury

 Total Revenues and Financing Sources

'Expenses

 Program or Operating Expenses (Note 9)
 Depreciation and Amortization
 Bad Debts and Writeoffs
 Overhead Expenses from Allocation
 Other Expenses (Note 10)

 Total Expenses
 Excess of Revenues and Financing Sources
 Prior Period Adjustments (Note 11)

 Excess of Revenues and Financing Sources
 Over Total Expenses
 Plus:  Unfunded Expenses
 Excess of Revenues and Financing Sources
 Over Funded  Expenses

 Changes  in Net Position

 Net Position, Beginning Balance
 Excess of Revenues and Financing Sources
 Non-Operating Changes (Note 12)

 Net Position, Ending Balance
                                                       Asbestos
                                                    Commercial Activity
                                                   1993
                           16
                          310
                          895
                       11.939
                       10,718

                            7
                          895
                          310

                       11.930
                    $  49,224

                       13.992

                     $  63.216
The accompanying notes are an integral part of these statements.
                                    1992
                    $  10,718    $   3,395
    13
     7
  902
 4.317
 3,395
  902
	7

 4.304
    13
                                        13
   Page 42
EPA's FY 1993 Annual Financial Statements

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             FIFRA
         Revolving Fund
                                                  Tolerance
                                                 Revolving Fund
    1993
1992
1993
1992


I



$
$
$

18,156
432
25,303
43.891
18,928
200
25,303
44.431
(540)
971
431
431
4,862
431
(40)
5.253

24,690 926
783
22,811 4,474
48.284 5.400
24,517 926
172
22,811 4,474
47.500 5.400
784
3.699
4,483
$ 4.483 $
$ 627 $
4,483
(196)
$ 4.914 $

1,200
3,532
4.732
1,200
3,532
4.732
*
-
$
$ -
$ 	 -
EPA's FY 1993 Annual Financial Statements
                                                          Page 43

-------
  EPA Trust Funds,  Revolving Funds and Commercial Activities
  Statements of Cash Flows by Fund Activity
  Restated (Note 14)
  For the Years Ended September 30,  1993 and 1992
  (Dollars in Thousands)
  Cash Flows from Operating Activities:

  Excess - Revenues and Financing Sources
   Over Total Expenses
  Adjustments Affecting Cash Flow:
  Appropriations Expensed
  Decrease (Increase) in Marketable Equity Securities
  Decrease (Increase) in Accounts Receivable
  Decrease (Increase) in Loans Receivable
  Decrease (Increase) in Other Assets
  Increase (Decrease) in Accounts Payable
  Increase (Decrease) in Other Liabilities
  Depreciation and Amortization
  Bad Debt Expense
  Other Unfunded Expenses
  Other Adjustments
  Total Adjustments
  Net Cash Provided (Used) by Operating Activities

" Cash Flows from Investing Activities:

  Proceeds from 'Sales of Investments
 ; Purchase of Equipment
 t
  .Net Cash Provided (Used) by Non-Operating Activities

 ' Cash Flows from Financing Activities:

  Appropriations (Current Warrants)
  Transfers of Cash from Others
  Deduct:
   Withdrawals
   Transfers of Cash to Others

  Net Appropriations
  Borrowing  from the Treasury
  Net Cash Provided (Used) by Financing Activities

  Net Cash Provided (Used) - Total
  Fund Balances with Treasury, Beginning
  Fund Balances with Treasury, Ending
                                                           Superfund
                                                            Trust Fund
                                                      1993
                         $ 140,510

                        (1,343,528)
                            (4,699)
                           (70,620)

                               545
                           (10,113)
                           (75,549)
                             5,016
                             4,053
                               833
                            16.715
                        (1,477,347)
                        (1,336,837)
                            (2.954)

                            (2,954)
                         1,355,215


                            69.139

                         1,286,076

                         1,286,076

                           (53,715)
                            65.200
                        S   11.485
                                          1992
$   17,526;

(1,408,040)

 .  (45,595)

   (13,605)
    39,546
   175,395
       520

     1,092
    (1.719)
(1,252,406)
(1,234,880)
     1.316
     1,316
 1,295,639
    49.720

 1,245,919

 1,245,919

    12,355
    52.845
$   65.200
 Page 44
EPA's FY 1993 Annual Financial Statements

-------
                  LUST
                 Trust Fund
         1993
1992
                            Oil Spill
                           Trust Fund
  1993
1992
               (22)
           (75,137)
                 4
            (3,407)
               254
                29
  (69,153)
     (290)
     (223)
    2,279
     (153)
       19
$         -      ••  $
     (7,804)
     1,425
       157
            (1.248)
           (79,505)
           (79.527)
       17
  (67,504)
  (67,504)
     (6,222)
     (6,222)
                16)
                 (6)
      (47)
      (47)
            74,700
  80,500
    20,700


$
74,700
74,700
(4,833)
6,471
1.638
80,500
80,500
12,949
(6.478)
$ 6.471
20,700
20.700
14,478
$ 14,478
.
-
$
(Continued)
1
EPA's FY 1993 Annual Financial Statements
                                           Page 45

-------
 EPA Trust Funds, Revolving Funds and Commercial Activities
 Statements of Cash Flows by Fund Activity
 Restated (Note 14), Continued
 For the Years Ended September 30, 1993 and 1992
 (Dollars in Thousands)
 Cash Flows from Operating Activities:

 Excess - Revenues and Financing Sources
  Over Total  Expenses
 Adjustments Affecting Cash Flow:
 Appropriations Expensed
 Decrease (Increase) in Marketable Equity Securities
 Decrease (Increase) in Accounts Receivable
 Decrease (Increase) in Loans Receivable
 Decrease (Increase) in Other Assets
 Increase (Decrease) in Accounts Payable
 Increase (Decrease) in Other Liabilities
 Depreciation and Amortization
 Bad Debt Expense
 Other Unfunded Expenses
 Other Adjustments
 Total Adjustments
 Net Cash Provided (Used) by Operating Activities

 Cash Flows from Investing Activities:

 Proceeds from Sales of Investments   \
 Purchase pf Equipment

 Net Cash Provided (Used) by Non-Operating Activities

 Cash Flows from Financing Activities:

 Appropriations (Current Warrants)
 Transfers of Cash from Others
 Deduct:
  Withdrawals
  Transfers of Cash to Others
 Net Appropriations

 Borrowing from the Treasury
 Net Cash Provided (Used) by Financing Activities

 Net Cash Provided (Used) - Total
 Fund Balances with Treasury, Beginning
 Fund Balances with Treasury, Ending

 The accompanying notes are an integral part of these statements.
                                                            Asbestos
                                                        Commercial Activity
                              1993



                            $      9

                            (10,718)

                             19,408
                              (5,496)

                                 13
                              5,279

                                  7

                              (6.531)
                              1,962
                              1,971
                             31,225
                             31,225

                             31,225

                             33,196
                             29,877
                         $   63.073
    1992



  $     13

    (3,395)

   (19,406)
   (13,379)

        53

    13,412


      (734)
   (23,449)
   (23,436)
    53,313
    53,313

    53,313

    29,877

$   29.877
Page 46
EPA's FY 1993 Annual Financial Statements

-------
                 FIFRA
               Revolving Fund
        1993
  1992
                           Tolerance
                          Revolving Fund
1993
1992
          $    431
$    4,483
               (26)

                12
              (485)
            (4,121)
               200
       (27)

   (16,799)
       183
   (17,584)
       172
     (41)
      89
    441
       (6)
            (4,420)
            (3,989)
             5,033
              (1591

             4,874
                                 (162)
   (34,217)
   (29,734)
     6,638
      (119)

     6,519
    489
    489
       (6)
       (6)
               885
                65
               950
                                  196
                                 (196)
      (196)

   (23,411)
    23.476
        65
    489
   3.757
   4,246
       (6)
   3.763
    3.757
EPA's FY 1993 Annual Financial Statements
                                            Page 47

-------
 EPA Trust Funds, Revolving Funds and Commercial Activities
 Statement of Budget and Actual Expenses
 For the Year Ended September 30, 1993
 (Dollars In Thousands)


Budaet

Actual
Obliaations
Resources
$





$
1,875,354
85,468
20,700
111,657
25,491
5.683
2.124.353
Direct
1,587,754
74,451
18,225
90,906
(754>
.
$ 1.770.582
Reimbursed
$ 21,047
-
-
• • -
16,328
1.526
$ 38.901
Expenses
$ 1,529,155
75,964
8,559
11,930
44,431
5.400
$ 1,675,439
  Program Name

  Superfund
  LUST
  Oil Spill
  Asbestos Loan Program
  FIFRA
  Tolerance Fund

  Total

Budget Reconciliation:
  Total Expenses

  Add:
    Capital Acquisitions
    Other Expended Budget Authority

  Less:
    Depreciation and Amortization
    Unfunded Annual Leave Expense
    Interest Expense
•:  '  Bad  Debt Expense
  AccFued'Expenditures

  Less Reimbursements

  Accrued Expenditures, Direct
     Financial Statement Adjustment, not on SF-133
     Overhead Expenses from Allocation, not on SF-133
     Unreconciled Difference
  Accrued Expenditures, Direct - per SF-133
                                     $1,675,439


                                         3,119
                                         5,245
                                          833
                                          310
                                       161.471
                                     1,510,699

                                        38.901

                                     1,471,798
                                      (486,061)
                                       (54,511)
                                       (32.8131
                                     $ 898.413
  The accompanying notes are an integral part of this statement.
Page 48
EPA's FY 1993 Annual Financial Statements

-------
EPA Trust Funds,  Revolving Funds and Commercial Activities
Statement of Budget and Actual Expenses—Restated (Note 14)
For the Year Ended September 30,  1992
'Dollars in Thousands)

Budaet

Actual
Obliaations
Resources
$1,944,698
76,966
109,509
30,873
4.820
Direct
$1,729,094
75,403
100,071
4,821
Reimbursed
$ 10,156 .
17,071
1.104
Expenses
$l',432,145
69,391
4,304
47,500
4.732
   Program Name

   Superfund
   LUST
   Oil Spill
   Asbestos Loan Program
   FIFRA
   Tolerance Fund
   Totals                  $2.166.866     $1.909.389

Budget Reconciliation:
   Total Expenses

   Add:
      Capital Acquisitions
      Other Expended Budget Authority

   Less:
      Depreciation and Amortization
      Unfunded Annual Leave Expense
      Interest Expense
      Bad Debt Expense
   .Accrued Expenditures

   Less Reimbursements

   Accrued Expenditures, Direct
      Financial Statement Adjustment, not on SF-133
      Overhead Expenses from Allocation, not on SF-133
      Unreconciled Difference
   Accrued Expenditures, Direct - per SF-133
                                                              $1.558.072
                                                              $1,558,072
                                                                  1,150
                                                                123,707
                                                                   711
                                                                  1,092
                                                                     7
                                                                  5.472
                                                               1,675,647

                                                                 28.331

                                                               1,647,316
                                                                 (12,816)
                                                                 (45,069)
                                                                 13.554
                                                              $1.602.985
The accompanying notes are an integral part of this statement.
EPA's FY 1993 Annual Financial Statements
                                                                      Page 49

-------
 EPA Trust Funds, Revolving Funds and Commercial Activities
 Notes to Financial  Statements
 (Dollars in Thousands)


 Note  1.  Summary of Significant Accounting Policies:
 A. Basis of Presentation

 These financial statements have been prepared to report the financial position and results
 of operations of the Environmental Protection Agency (EPA) for the  Hazardous Substance
 Superfund (Superfund) Trust Fund, Leaking Underground Storage Tank (LUST) Trust Fund,
 Oil Spill Response Trust Fund, Asbestos Loan Program (a commercial activity), Reregistration
 and  Expedited Processing (FIFRA) Revolving Fund and the Revolving Fund for Certification
 and Other Services (Tolerance), as required by the Chief Financial Officers Act of 1990.  The
 reports have been prepared from the books and records of EPA in accordance with "Form
 and Content for Agency  Financial Statements," specified by the' Office of Management and
 Budget (OMB)  in Bulletin 93-02 and applicable provisions of Bulletin 94-01  and EPA's
 accounting policies which are summarized in this note.   These statements are therefore
 different from the financial reports also prepared by EPA pursuant to OMB directives that are
 used to monitor and control EPA's use of budgetary resources.

 B. Reporting Entities

 EPA was created in 1970 by executive reorganization from various components of other
 Federal agencies in order to better marshal and coordinate federal pollution control efforts.
 The  Agency is generally organized around the media  and substances it  regulates — air,
 water, land,, hazardous waste, pesticides and toxic substances.

 The  Hazardous Substance Superfund Trust Fund was authorized by the Comprehensive
 Environmental Response, Compensation and Liability Act (CERCLA) to respond to hazardous
:substance  situations or  sites which threaten human  health and the environment.  The
 Superfund  Amendments and Reauthorization Act (SARA) increased funding and gave the
•program new  responsibilities and authorities. There are three basic components to the
 Superfund  program: site assessment and cleanup activities; enforcement; and  support.
 Support includes facilities and management, research and development and other non-direct
 site  work.   These components are integrated and coordinated to ensure the most cost
 effective use of Superfund monies in order to achieve the greatest possible cleanup.  The
 program is funded from monies appropriated from general furrd tax collections, interest on
 investments, fines and cost recoveries. As authorized by Congress, Superfund Trust Fund
 appropriations include certain amounts that are transferred to other Federal agencies for
 authorized activities in support of the Superfund program.   The uses of  these transfer
 appropriations are not reported in the Superfund Trust Fund financial statements.  Rather,
 they are reported by the  specific agencies that receive the transfer amount. The Superfund
 Trust Fund is accounted for under Treasury symbol number 8145.

 The  LUST Trust Fund was authorized by the amendment of the Resource Conservation and
 Recovery Act  (RCRA) in 1986 to implement a comprehensive regulatory program for
 underground storage tanks and to provide funds for responding to releases from leaking
 underground petroleum tanks. EPA oversees cleanup and enforcement programs which are
 implemented by the  States.   Funds  are  allocated to  the  States  through  cooperative
 Page 50                     EPA's FY 1993 Annual Financial Statements

-------
 greements  to  clean  up those sites posing the greatest threat to human health  and
environment.  The program is financed by a  0.1 cent a gallon tax on motor fuels, and is
accounted for under Treasury symbol number 8153.

The Oil Spill Response Trust Fund was authorized by the Oil Pollution Act of 1990.  In FY
1992, monies were included in the Agency's Salary and Expense appropriation in the amount
of $4,951, Abatement, Control and Compliance appropriation in the amount of $ 10,982, and
Research and Development appropriation in the amount of $2,500, for carrying out oil  spill
response activity. The Oil Spill Response Trust Fund was established in fiscal year 1993 and
monies were appropriated to the Oil Spill Response Trust Fund.   EPA.is responsible for
directing, monitoring and providing technical  assistance for major inland oil spill response
activities.  Funding of oil spill  cleanup actions is  provided through the Department of
Transportation under the Oil Spill Liability Trust Fund. FY 1993 is the first year for audit of
the Oil Spill Response Trust Fund and, accordingly, no comparative data is available for FY
1992.  The Oil Spill Response Trust Fund is accounted for under Treasury symbol number
8221.

The Asbestos Loan Program was authorized by the Asbestos School Hazard Abatement Act
of 1986 to manage asbestos building materials in schools, is reported in accordance with the
Federal Credit Reform Act of 1990.  For FY 1992 and 1993  obligations, the program is
funded by a subsidy appropriated from the General Fund for the actual cost of financing the
loans, and  by borrowings from Treasury for the unsubsidized portion of the loan.   The
Program fund receives the subsidy and administrative appropriations, disburses the subsidy
   the Financing fund, and disburses administrative expenses to the providers.  The Financing
 und receives the subsidy payment, borrows from Treasury and disburses and collects the
asbestos loans.  Loans obligated before 1992 are maintained in a Liquidating fund and are
disbursed from the Liquidating fund. The loans receivable and collections on those loans are
recorded in a General Fund receipt account. Under provisions of the Federal Credit Reform
Act, the balance of any monies collected on loan repayments must be returned to the general
revenue fund at Treasury. Accounting activity for the Asbestos Loan Program is accounted
for under the 0118, 4321, 4322 and 2917 Treasury symbols.

The  FIFRA  Revolving  Fund was authorized in  1988 by  amendments to the Federal
Insecticide,  Fungicide  and  Rodenticide  Act.   The  1988 amendments  mandated  the
accelerated reregistration of  all products registered prior to November 1, 1984. Congress
authorized the collection of fees to supplement appropriated funds for reregistration and to
fund expedited processing of certain pesticides. FIFRA also  includes provisions for the
registration of new pesticides, monitoring the distribution and use of pesticides, issuing  civil
or criminal penalties for violations, establishing cooperative agreements with the states, and
certifying training programs for users of restricted chemicals.  Appropriated funds, however,
pay for these activities. The  FIFRA Revolving  Fund is accounted for under Treasury symbol
number 4310.

The Tolerance Revolving Fund was authorized in  1963 for the deposit of tolerance fees.  A
tolerance is the maximum legal limit of a pesticide residue or}, food commodities and animal
feed.  Tolerances are established by EPA to prevent consumer exposure to unsafe levels of
pesticide residues. In 1954,  Congress authorized the collection of fees for raw agricultural
commodities. Fees were deposited to the Treasury general fund until 1963 when Congress
EPA's FY 1993 Annual Financial Statements                                               Page 51

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 established the Revolving Fund for Certification and Other Services (Tolerance Revolving
 Fund). The Department of Agriculture and the Food and Drug Administration are responsible
 for enforcing adherence to these tolerance levels. Funding is provided by fee collections and
 by appropriated funds for federal services in establishing tolerances for residues of pesticide
 chemicals in or on raw agricultural commodities. The Tolerance Revolving Fund is accounted
 for under Treasury symbol number 4311.

 The accompanying financial statements include the accounts of all funds described in this
 note.  Each of the funds included in the financial statements charge some administrative
 costs  directly to  the fund and  charge the remainder of the administrative  costs  to
 Agency wide appropriations. The following is a list of all the programs and the corresponding
 administrative costs funded by Agency wide appropriations (unaudited):
  Superfund

  LUST

  Oil Spill

  Asbestos

  FIFRA

  Tolerance
    1993

$ 22,257

     827

     755

     895

  25,303

   4,474
.    1992

$ 17,586

     238


     902

  22,811

   3,532
.These amounts are included in the Income from Overhead  Allocation and the Overhead
 Expenses from Allocation line items as shown in the financial statements.

/The Superfund and LUST Trust Funds are allocated general support services costs (such as
 .rent, communications, utilities, mail operations, etc.) that  were initially charged to the
•Agency's Program and Research Operations (PRO) and Abatement, Control and Compliance
 (AC&C) appropriations.  During the year, these costs are allocated from the PRO and AC&C
 appropriations to the Superfund and LUST Trust Funds based on a ratio of direct labor hours,
 using budgeted or actual full-time  equivalent personnel charged to these appropriations, to
 the  total of all direct  labor hours. Agency general support services cost charges to the
 Superfund and LUST Trust Funds may not exceed the ceilings established in the Superfund
 and LUST Trust Fund appropriations. The related general support services costs charged to
 the  Superfund  and LUST Trust Funds were $25,146 and $216 for FY 93.

 C.  Budgets and Budgetary Accounting

 Congress adopts an annual appropriation amount to  be available until expended for the'
 Superfund Trust Fund, for the LUST Trust Fund, and for the Oil Spill Response Trust Fund.
 Transfer accounts for the Superfund and LUST Trust Funds have been established for the
 purpose of carrying out the  program activities. A Trust Fund account has been established
 at Treasury for the purpose  of carrying out the oil spill response program activities. As EPA
 disburses obligated amounts from  the transfer accounts, EPA draws down  monies from the
 Superfund and LUST Trust  Funds at Treasury to cover the amounts  being disbursed. EPA
 Page 52               .      EPA's FY 1993 Annual Financial Statements

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draws down all the appropriated monies from the Treasury's Oil Spill Liability Trust Fund to
the Oil Spill Response Trust Fund when Congress adopts the annual appropriation amount.

The Asbestos Loan Program is a commercial activity financed by a combination from two
sources: one for the long term cost of the loan and another for the remaining non-subsidized
portion  of the loan.  Congress  annually adopts a one  year appropriation, available for
obligation in the fiscal year for which it is appropriated, to cover the estimated long term
cost of the Asbestos loans. The long term costs are defined as the net present value of the
estimated cash flows associated with the loans. The portion of each loan disbursement that
does  not represent long term cost is financed under a permanent indefinite borrowing
authority established with the Treasury.  The annual appropriation bill limits the amount of
obligations that can be made for direct  loans.  A permanent indefinite appropriation is
available to finance the costs of subsidy re estimates that occur after the year in which the
loan is disbursed.                                        .    .
Funding of the FIFRA and the Tolerance Revolving Funds is provided by fees collected from
industry  to offset costs incurred by EPA  in carrying out  these  programs.  Each year EPA
submits an apportionment request to OMB based on the anticipated collections of industry
fees.

D.  Basis of Accounting

Transactions are recorded on an accrual accounting basis and a budgetary basis.  Under the
accrual method, revenues are recognized  when earned and expenses are recognized when
a liability is incurred, without regard to receipt or payment of cash.  Budgetary accounting
facilitates compliance with legal constraints and controls over the use of Federal funds. All
interfund balances and transactions  have  been  eliminated.

E.  Revenues and Other Financing Sources

The Superfund, LUST, and Oil Spill  Response Trust Funds receive the majority of funding
needed to support the program through appropriations that may be used, within statutory
limits, for operating and capital expenditures (primarily equipment). Additional financing for
the Superfund Trust Fund is obtained through reimbursements from potentially responsible
parties.

Under Credit Reform provisions, the Asbestos Loan Program receives funding to support the
subsidy cost of loans through appropriations which may be used.within statutory limits. The
Asbestos Direct Loan Financing fund, an off-budget fund, receives funding to support the
loan disbursements through collections from the Program fund for the subsidized portion of
the loan and through borrowing from Treasury for the non-subsidized portion. The Asbestos
Direct Loan Liquidating fund received funding to support the pre-Credit Reform loans through
appropriations.

The FIFRA and the Tolerance Revolving Funds receive funding through fees collected for
services  provided.  The FIFRA Revolving Fund also receives interest on invested funds.

Appropriations are recognized as revenues at the time they are  used to pay program or
administrative expenses.   Appropriations expended for  property, and  equipment  are
EPA's FY 1993 Annual Financial Statements                                               Page 53

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recognized as expenses when the asset is consumed in operations.  Other revenues are
recognized when earned, i.e., when services have been rendered.

F. Funds with the Treasury

EPA does not maintain cash in commercial bank accounts. Cash receipts and disbursements
are handled by Treasury.  The funds maintained with Treasury are Appropriated Funds,
Revolving Funds and Trust Funds.  These funds have balances available to pay current
liabilities and finance authorized purchase commitments.

G.  Investments in U. S. Government Securities

Investments in U. S. Government securities are maintained by Treasury and are reported at
amortized cost net of unamortized discounts.  Discounts are amortized over the term of the
investments  and  reported as interest  income.   The  FIFRA  Revolving  Fund holds the
investments to maturity, unless they are needed to finance operations of the fund. No
provision is made for unrealized gains or losses on these securities because, in the majority
of cases, they are held to maturity.

H. Marketable Equity Securities

During fiscal year 1993, the Agency received marketable equity securities, valued at $4,699
as of September  30,  1993, from a company in settlement of Superfund cost  recovery
actions. The Agency does not intend to exercise ownership rights related to these securities,
held by Treasury, but instead will convert these securities to cash as soon as  practicable.
in prior similar transactions, this has been accomplished in less than one year.

I.  Accounts Receivable

Both the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA)
and the Superfund Amendments and Reauthorization Act (SARA) provide for cost recovery
of costs from potentially responsible parties (PRPs).  However,  cost recovery expenditures
are expensed when  incurred  because  there is  no assurance that these funds will  be
recovered.

It is EPA's policy to record accounts receivable from PRPs for Superfund site cleanup costs,
incurred by EPA, when a consent decree, judgment, or other binding agreement is reached.
These agreements are generally obtained after site cleanup costs are incurred.  It is EPA's
position that until a consent decree is obtained, the amount  recoverable should not be
recorded.  The allowance for uncollectible PRP accounts receivable is determined on a
specific identification basis as a result of a case-by-case review of receivables at the regional
level, and a general reserve for those not specifically identified.

EPA also records accounts receivable from states for a portion of Superfund site cleanup
actions within those states.  Cost sharing arrangements vary according to whether a site
was privately or publicly operated at the time of hazardous substance disposal and whether
the EPA response action was removal or remedial. State cost share agreements are usually
10% to 50% of site cleanup cost. States may pay the full amount of state cost shares in
Page 54
EPA's FY 1993 Annual Financial Statements

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 dvance, or in incremental amounts throughout the cleanup project.  No allowances for
uncollectible state  cost share receivables have  been recorded, because EPA has not had
collection problems on these  agreements.
Other receivables for Asbestos and FIFRA represents interest receivable.
A summary of non-federal accounts receivable as of a September 30, 1993 and September
30, 1992 is as follows:
                   Fiscal Year 1993 Non-Federal Accounts Receivable.
                                 Superfund       LUST      Asbestos
PRP receivables (including interest)     $ 336,638       $
                                                          $
                                                               10
State cost share receivables            20,156         33
Other receivables                         55
Allowance for uncollectible receivables   (162,911)       	-
                                 $ 193.938       $ 33

                   Fiscal Year 1992 Non-Federal Accounts Receivable
PRP receivables (including interest)
State cost share receivables
Other receivables
Allowance for uncollectible receivables
                                    (5.926I
                                 $ 122.315
                                                $ 51
        FIFRA
        $   -
Superfund
$


80,920
47,317
4
LUST
$


-
51
.
Asbestos
$


-
- •
12
FIFRA
$


-

28
12
$  28
EPA's FY 1993 Annual Financial Siatements
                                                                               Page 55

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Accounts Receivable - federal result primarily from interagency agreements for services
performed  and receivables  from EPA funds other than Trust or Revolving Funds  or
Commercial Activities.
Interagency agreements

Intraagency receivables

Other
                           Accounts Receivable - Federal
    Superfund
  1993   1992
 $7,955  $2,695
   LUST
1993  1992
$  5  $   -
   Asbestos
1993    199;
$   -  $
                                             $  14   $
J. Loans Receivable

Loans are accounted for as receivables after funds have been disbursed. The amount of
Asbestos Loan Program loans obligated but not  disbursed are  disclosed.in  Note 4.  No
allowance for uncollectible amounts has been established for loans obligated prior to October
1, 1991 because there has never been a default and a review of outstanding amounts does
not indicate a potential default.  Loans receivable resulting from loans obligated on or after
October 1, 1991 are reduced by an allowance equal to the present value of the subsidy
costs associated with these loans.  The subsidy cost is calculated based on the interest rate
differential  between the loans and Treasury borrowings, the estimated delinquencies and
defaults net of recoveries offset by fees collected and other estimated cash flows associated
with these  loans.

K. < Appropriated "Amounts Held by Treasury

For the Superfund  and LUST Trust Funds, cash available to  EPA that is not needed
immediately for current disbursements remains in the respective Trust Funds managed by
Treasury.   At the end  of fiscal years 1993 and  1992, approximately $3,173,380 and
$2,967,460,  respectively, remained in the Treasury-managed Superfund Trust Fund and
approximately $89,021 and  $80,722, respectively, remained in the LUST Trust Fund to
meet EPA's disbursement needs.

L. Advances and Prepayments

EPA records the differences resulting from disbursements recorded by Treasury but not
recorded by EPA and the disbursements recorded by EPA but npt by treasury as advances
and prepayments. As a result of the correction of a data conversion error, the LUST Trust
Fund has recorded a prepayment of $3,540 which related to prior years and will reverse
during fiscal year 1994.
Page 56
EPA's FY 1993 Annual Financial Statements

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M.  Property, Plant and Equipment

The land and buildings which EPA uses are provided by the General Services Administration,
which charges a Standard Level Users Charge (SLUG) that approximates the commercial
rental rates for similar properties.  Equipment purchases are capitalized at cost if the initial
acquisition cost is at least five thousand dollars.  Equipment with an acquisition cost of less
than five thousand dollars is expensed when purchased. Equipment is depreciated using a
modified straight line method over a period of six years depreciating 10% the first and last
year and 20% in years 2 through 5.

N.  Liabilities

Liabilities represent the amount of monies or other resources that are likely to be paid by EPA
as the result of a transaction or event that has already occurred.  However, no liability can
be paid by EPA without an appropriation or other collection of revenue for services provided.
Liabilities  for which an appropriation has not been  enacted are classified  as unfunded
liabilities and there is no certainty that the appropriations will be enacted.  Liabilities of EPA,
arising from other  than contracts, can be abrogated  by the Government acting in  its
sovereign capacity.

0.  Accounts Payable - Federal

The Superfund Trust Fund  contracts for a wide range of goods  and services through
interagency  agreements with other federal agencies. As of September 30, 1993 and 1992,
the balance of Accounts Payable - Federal of $105,541 and  $126,733,  respectively,
represents interagency agreements payable. The balance of Accounts Receivable - Federal
as of September 30, 1993 and 1992 includes $7,955  and  $2,695, respectively, relating to
interagency  agreements.  Accounts Payable - Federal includes $20,704 which is due to the
Abatement,  Control and Compliance appropriation and $84,837 which is payable to other
federal agencies.

Accounts Payable -  Federal for the Tolerance Revolving Fund  includes $466 of application
fees for Tolerance  Petitions.  Agency policy is to record fees as earned after specific
processing milestones, and then use the earnings to reimburse appropriated funds used to
pay expenses. EPA earned the fees in  prior years,  but did  not record the earnings  or
reimburse the  appropriated funds.
                                                        **
P.  Deferred Revenue

Superfund deferred  revenue represents amounts paid to EPA by states, for state cost share
arrangements, or by other entities, for site cleanup costs or other services, in advance of
EPA's performing the services.  Such amounts may  have been paid  voluntarily or under
protest. Deferred revenue is reduced and is recognized as £he  related services are incurred.
However, amounts paid in protest are  not recorded as income  until the protest is  resolved.
EPA's FY 1993 Annual Financial Statements                                               Page 57

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FIFRA Revolving Fund deferred  revenue represents fees collected in advance of services
being performed for the reregistration of existing pesticides and for the registration of new
pesticides. Tolerance Revolving  Fund deferred revenue represents fees collected in advance
of services being performed for the establishment of tolerances for residues of pesticide
chemicals in or on raw agricultural commodities.

Components of deferred revenue as of September 30, 1993 and 1992 are as follows:
Non-Federal:
  State cost share
   arrangements
  Site cleanup costs
  Other
Federal:
  Interagency
   agreements
                           Fiscal Year 1993 Deferred Revenue

                                          Superfund        FIFRA
135,011
                                              'Tolerance
$ 48,419

$183.430
$ 4.511
$
5.755
$5.755
$ 	 -
$
3.691
$3.691
$ 	 ;
Non-Federal:
  State cost share
   arrangements
  Site cleanup costs
  Other
Federal:
  Interagency
   agreements
                           Fiscal Year 1992 Deferred Revenue

                                          Superfund        FIFRA
133,142
$115,419       $

 	:        8.917

               $8.917


$ 14.929       $	-
Tolerance


  $

   3.604

  $3.604
Page 58
      EPA's FY 1993 Annual Financial Statements

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Q.  Borrowings Payable to the Treasury

Borrowings payable to Treasury result from loans from Treasury to fund the Asbestos direct
loans described in  part B of this note.  Periodic principal payments are made to Treasury
based on the collections of loans receivable.

R.  Interest Payable to Treasury

The Asbestos Loan Program makes periodic interest payments to Treasury based on its debt
to Treasury.  At the end of fiscal year  1993 and 1992, there was no outstanding  interest
payable to Treasury because payment was made on September 30.

S.  Annual, Sick and Other Leave

Annual leave is accrued as it is earned and the liability is reduced as leave is taken. Each
year, the balance in the accrued annual leave account is adjusted to reflect current pay rates.
To  the extent current, or  prior year appropriations are not available to fund annual leave
earned but not taken, funding will be obtained from future financing  sources. Annual leave
expense for the Superfund Trust Fund was $833 in FY 1993 and $1,092 in FY 1992. Sick
leave and  other types of nonvested leave are.expensed  were taken.

T.  Retirement Plan

The majority of EPA's employees participate in the Civil Service Retirement System {CSRS},
to which EPA makes matching contributions equal to 7% of pay.

On January  1, 1987,  the  Federal Employees Retirement System (FERS)  went into effect
pursuant to  Public Law 99-335.  Most employees  hired after December 31, 1983, are
automatically covered by FERS and Social Security.  Employees hired prior to January  1.
1984 were allowed to either join FERS and Social Security or remain in CSRS. A  primary
feature  of FERS is that it offers a savings  plan  to EPA employees which automatically
contributes 1 percent of pay and matches any employee contribution up to an additional 4
percent of pay. For most employees hired after December 31, 1983, EPA also contributes
the employer's matching share for Social Security.

EPA does not report CSRS or FERS assets, accumulated plan benefits, or unfunded liabilities,
if any, applicable to its employees.  Reporting  such amounts -is  the responsibility of the
Office of Personnel Management. Such data is not allocated to individual departments and
agencies.
EPA's FY 1993 Annual Financial Statements                                              Page 59

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Note 2.  Fund Balances with Treasury:
The Treasury maintains EPA's fund  accounts  and processes all of EPA's receipts and
disbursements. The available balances are for payment of EPA's obligations under its various
programs.   The  restricted balances  pertain to expired appropriated  authority  and  are
unavailable for future obligations.
Fiscal Year 1993:
       Trust Funds:
             Superfund
             LUST
             Oil Spill

       Commercial Activities:
             Asbestos Loan
                Program

       Revolving Funds:
             FIFRA
             Tolerance
Fiscal Year 1992:

     -.  Trust Funds:
             Superfund
             LUST
             Oil Spill

       Commercial Activities:
             Asbestos Loan
                Program

       Revolving Funds:
             FIFRA
             Tolerance
        Total

     $  11,485
        1,638
       14,478
     $ 63,073
     $    950
       4,246
        Total

     $ 65,200
       6,471
     $ 29,877
     $    65
       3,757
Available

$ 11,485
   1,638
  14,478
$ 44,835
 $  950
   4,246
Available

$ 65,200
   6,471
$ 20,439
$    65
   3,757
Restricted

 $
 $ 18,238
Restricted

  $
 $ 9,438


  $
Page 60
EPA's FY 1993 Annual Financial Statements

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Note 3.  Investments - Federal:
The FIFRA Revolving Fund invests monies in Federal securities that can be bought and sold
on the open market.  The cost of the investments is recorded at face value less interest to
be earned over the term of the investment (unamortized discount).  Invested amounts are
disinvested and become available for payment of EPA's obligations as needed.

Investments in Federal marketable securities were as follows:

                                  Face      Unamortized      Investments,
                                 Value        Discount          Net
September 30, 1993              $10,220            $11         $10,209
September 30, 1992              $15,285            $42    "     $15,243
Note 4.  Loans Receivable,  Net - Non-Federal:
Asbestos Loan Program loans disbursed from obligations made prior to FY 1992 would be
reported net of an allowance  for estimated  uncollectible loans,  if an  allowance  was
considered necessary. Loans disbursed from  obligations made after FY 1991 are governed
by the Federal Credit Reform Act. The Act mandates that the present value of the subsidy
costs (i.e., interest rate differentials, interest subsidies, anticipated delinquencies, and
defaults) associated with direct loans be recognized as an expense in the year the loan is
made. The net present value of loans is the amount of the gross loan receivable less the
present value of the subsidy.

An analysis of loans receivable and the nature and amounts of the subsidy and administrative
expenses associated entirely with Asbestos Loan Program loans is provided in
the following sections.
EPA's FY 1993 Annual Financial Statements              .                                 Page 61

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Pre-Credit Reform Loans:
                           Loans Receivable,
                                Gross
                      Allowance for
                        Estimated       Loans Receivable,
                    Uncollectible Loans        Net
September 30, 1993
September 30, 1992

Post Credit Reform Loans:
        $ 117,631
        $ 123,197
                     $ 117,631
                     $ 123,197
September 30, 1993
September 30, 1992

Total 1993:
Total 1992:
   Loans Receivable,
        Gross
         $ 21,129
         $  2.323
Allowance for
Subsidy Cost
(present value)
    $  (8,749)
    $  (1.005)
Loans Receivable,
     •Net
       $12,380


      $130.011
      $124,515
Subsidy Expenses for Post Credit Reform Loans:

Current Year's Loans:
Fiscal Year 1993:
FiscalYear 1992:
Total Direct Loan Subsidy Expense:
Fiscal Year 1993
Fiscal Year 1992
$ 8,054
$ 1,012
Administrative Expenses for Pre and Post Credit Reform Loans:
                                             1993        1992
Charged Directly to the Asbestos Loan Program     $2,664       $ 2,383
Additional Administrative Support Expenses
Charged to Other Appropriations
Total
                      895
                   $3.559

Total
$8,054
$1.012
Interest
Differential
$8.054
$1.012
Expected
Defaults
$ -
$ -
Fee
Offsets
$ -
$~
Fiscal Year 1.993 Other Information:  $13,000  for obligations established prior to  Credit
Reform and $108,600 for obligations established after Credit Reform remain unpaid.  No
expenses were incurred in FY 1993 for subsidy reestimates.
Page 62
    EPA's FY 1993 Annual Financial Statements

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Note 5.  Property,  Plant, and Equipment - A/ef:
Real Property (land and buildings) used as office space for EPA employees in the course of
mission related activities and facility related services are provided by the General Services
Administration (GSA). GSA charges a Standard Level Users Charge that approximates the
commercial rental rates for similar properties.

A  small  percentage  of  real property,  such as  laboratories,.is  acquired by  EPA using
appropriated funds.

Equipment purchases are capitalized if the equipment is valued at five thousand dollars or
more and has an estimated  useful life of at least 2 years.   The Agency depreciates all
capitalized equipment on a modified straight-line basis over a period of 6 years, depreciating
10% the first and last years and 20% in years 2 through 5.  The Trust and Revolving Funds
normally do not  reflect purchases of property other than equipment.

Schedule of Property, Plant, and Equipment by  Fund:
Fiscal Year 1993:
Acquisition Value
Accumulated Depreciation
Net Book Value

Fiscal Year 1992:

Acquisition Value
Accumulated Depreciation
Net Book Value
Superfund
 $56,310
  42.280
 $14.030
Suoerfund
 $53,357
  37.263
 $16.094
LUST
$134
  73
$ 61
EPA's FY 1993 Annual Financial Statements
                               Page 63

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Note 6. Debt - Federal:
Under the provisions of the Federal Credit Reform Act, borrowings from Treasury represent
the portion of loan disbursements not subsidized by appropriated funds.

FY 93 and 92 borrowings from Treasury are:
Intragovernmental
Debt:   .

Fiscal Year 1993
Borrowing from
Treasury

Fiscal Year 1992
Borrowing from
Treasury
                  Beginning       New
                   Balance      Borrowings   Repayments Ending Balance Refinancing
$1.318      $10.854
            $  1.318      $-
           $-
$ 1.318    $-
Note 7.  Other Funded Liabilities - Federal:

Resources payable to Treasury consist of all the  precredit reform debt.  This amount
represents the remaining principle not collected and paid back to Treasury.
Resources Payable to Treasury are:
                                  1992

                                $123.209
Note 8.  Total Net Position:

The total net position of EPA's  Trust and Revolving  Funds and commercial activities
represents the financial position of these funds after consideration of the net effects of
operations  in  the  current  year  and  the  cumulative  effects of  all  prior   years.
Appropriated/Subsidy Capital represents the funding authority provided by Congress, net of
Page 64
     EPA's FY 1993 Annual Financial Statements

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interagency transfers.  Invested Capital represents the book value, net of depreciation, of
EPA resources  invested  in equipment.   Cumulative Results of  Operations  represents  the
cumulative deficit or surplus from the funds' operations.
Fiscal Year 1993:
Appropriated/Subsidy
Capital

Invested Capital

Cumulative Results of
Operations

Future funding
requirements - non-
actuarial

Total Net
Position
 Suoerfund       LUST      Oil Spill     Asbestos       FIFRA

$2,767,175    $95,972    $12,896     $63,216      $•"   -

    14,030
  (11.556)
61
  211,178     (3,518)
                               533
                              4,720
             $92.515   .  $12,896     $63,216
                             $5.253
Fiscal Year 1992:
Appropriated/Subsidy
Capital

Invested Capital

Cumulative Results of
Operations

Future funding
requirements -
non-actuarial

Total Net
Position
 Superfund       LUST


$2,154,509    $34,551

    16,094         84


  511,203     51,288



  110.723)	-
       Oil Spill    Asbestos      FIFRA


        $    -    $49,224     $

                               574


                              4,340
$2.671.083    $8
                 $49.224     $4.914
EPA's FY 1993 Annual Financial Statements
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Note.9.  Program or Operating Expenses:
Fiscal Year 1993 Operating Expenses
by Object Classification:

 (1) Personnel Services and Benefits
 (2) Travel and Transportation
 (3) Rental, Communication and Utilities
 {4} Printing  and Reproduction
 (5) Contractual Services
 (6) Supplies and Materials
 (7) Equipment not Capitalized
 (8) Land and Structures
 {9J Investments and Loans
{10} Grants, Subsidies and Contributions
{11) Insurance Claims and Indemnities
(12) Accrued Expenses*

    Total Expenses by Object Class
                  Superfund
                   $211,842
                      10,841
                      30,165
                         934
                   1,051,499
                       4,097
                       8,404
                          47

                     173,306
                           (3)
                    (150.714)

                  $1.340.418
  LUST
$ 4,849
    502
    393
     17
  1,997
     69
    173
 68,741

  11.634)

$75.107
"Accrued expenses for FY 1992 were not reversed by object class due to the volume of data entry required.
Accrued expenses for FY 1993 are recorded by object class.
Fiscal Year 1992 Operating Expenses
by Object Classification:

 (1) Personnel Services and Benefits
 (2) Travel and Transportation
 (3) Rental, Communication and Utilities
 {4) Printing and Reproduction
 (5) Contractual Services
 (6) Supplies, and Materials
 (7) Equipment not Capitalized
 (8) Grants, Subsidies and Contributions
 (9) Insurance Claims and Indemnities
(10) Accrued Expenses"

    Total Expenses by Object Class
                   Superfund
                  $  201,285
                      10,064
                      26,831
                        1,436
                     955,390
                        3,610
                      11,489
                     158,794
                          15
                      39.668

                  $1.408.582
  LUST
$ 4,558
    536
    554
     49.
  2,253
     53
    227
 60,832

 	55

$69.117
 Accrued expenses are not recorded by object class in the accounting system due to the volume of data entry
required. Accrued expenses are the net of the reversal of FY 1991 accruals and FY 1992 accruals.
Page 66
EPA's FY 1993 Annual Financial Statements

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                 Oil Spill
Asbestos
FIFRA
Tolerance
$4,488 $
133
443
22
2,669 2,657
37
8 7
4 8,054
$7.804 $10.718
Oil Spill Asbestos
$ - $ 53
1
2,329
1,012
$ 	 ; $3.395
$11,756
62
2,291
160
4,661
49
688
827
(1.5661
$18.928
FIFRA
$14,261
198
2,049
68
6,108
193
505
1,378
(24.3)
$24.517
$926
$926
Tolerance
$1,200
$1.200
EPA's FY 1993 Annual Financial Statements
                                                  Page 67

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   Note 10.  Other Expenses:

   As a matter of policy, EPA expenses discounts lost during the fiscal year as interest expense.
   EPA pays Treasury interest on the Asbestos Loan borrowings.
                                    Suoerfund    Asbestos
   Fiscal Year 1993:
   Discounts Lost
   Interest Paid to Treasury
   Total
               $ 1

               $JL
310
   Fiscal Year 1992:

   Discounts Lost
   Interest Paid to Treasury
   Total
                                    Superfund   Asbestos'
               $ 2

               $ 2
 $  -
  7
 $ 7
   Note 11,  Prior Period Adjustments:

   Fiscal Year 1993:

   Effective September 30, 1993 unreconciled and unidentified general ledger balances, in
   addition to those identified in the 1992 audit, and resulting from  the  1989 financial
   accounting system conversion, were removed from the general ledger as adjustments to prior
   period. Unreconciled cash differences for FY's 1989 through 1991 were also removed from
   the general ledger  as  adjustments to prior period  effective September 30,  1993.  The
   amounts removed were as follows:
   Superfund Trust Fund
   LUST Trust Fund
   FIFRA
           $17,361
               (22)
               971
Page 68
EPA's FY 1993 Annual Financial Statements

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   Fiscal Year 1992:

   Prior to FY  1992, interest earnings on investments for FIFRA were included as part of
   unearned  advances.   Effective  October 1, 1991,  these earnings were  reclassified to
   Cumulative Results of Operations.
   Reclassification of Interest Earnings - FIFRA Revolving Fund
                                         $  3,699
   In addition, unrecognized prior year earnings for reimbursable work, were recorded as an
   adjustment effective October 1, 1991.
   Earnings on Reimbursable Activity - Superfund Trust Fund
                                            3,574
   Effective October 1, 1991, the Superfund and LUST Trust Funds removed unreconciled and
   unidentified general ledger balances resulting from the 1989 financial accounting system
   conversion by recording adjustments to equity accounts.
   Correction, system conversion errors - Superfund Trust Fund      26,044
   Correction, system conversion errors - LUST Trust Fund           4,704
   Note 12.  Non-Operating Changes:

   The Non-Operating  Changes  resulted from  funds transferred-in  from Treasury, funds
   collected and returned to Treasury, statement of financial position reclassifications, and other
   non-operating increases and decreases.
   Fiscal Year 1993:

   Increases:
   Transfers-in
   Other Increases
   Total Increases

   Total Decreases
Superfund

$1,573,528

 1,573,528

 1.405.127
   Net Non-Operating
   Changes            $  168.401
  LUST

$74,700

 74,700

 68.086


$ 6.614
Oil Spill

$20,700

 20,700

  7.804


$12.896
Asbestos

  $31,225
   31,225

  • 17.233


  $13.992
FIFRA

   $ -




  -40


  $(40)
EPA's FY 1993 Annual Financial Statements
                                                     Page 69

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   Fiscal Year 1992:

   Increases:
   Transfers-in
   Other Increases
   Total Increases

   Total Decreases

   Net Non-Operating
   Changes
Superfund

  $512,852
     7.128
   519,980

    13.908


  $506.072
 75,000

 69.154



$ 5.846
Oil Spill   Asbestos

  $    -      $19,400
  	:       53.163
       -  .     72,563

  	-      134.481
                                     FIFRA
•196
                            $(196)
   Note 13.  Contingencies

   EPA is a party in various administrative proceedings, legal actions, and claims brought by or
   against it. These include:

                Various personnel actions, suits, or claims brought against the Agency by
                employees and others.

                Various contract and assistance program claims brought against the Agenc
                by vendors, grantees and others.

                The legal recovery of Superfund  costs  incurred for pollution cleanup of
                specific sites, to include the collection of fines and penalties from responsible
                parties.

                Claims against recipients for improperly spent assistance funds which may be
                settled by a reduction of future EPA funding to the grantee or the provision
                of additional grantee matching funds.

   These matters,  affecting the Superfund Trust Fund, range individually up to several million
   dollars. If such  claims are successfully asserted against EPA, they could have a material
   impact on the Superfund Trust  Fund financial statements. Total losses at the end of FY
   1993 on these administrative claims and litigation could amount to approximately $ 35,400
   and $ 4,800, respectively.   Total losses at the end of FY 1992 on these administrative
   claims and litigations could amount to approximately $ 18,700 and $ 5,000, respectively.
   The ultimate outcome of these claims  and litigations cannot presently be determined.
   Accordingly, no provision for any liability that may result in adjudication has been recognized
   in the accompanying financial statements.
Page 70
    EPA's FY 1993 Annual Financial Statements

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   In the opinion of EPA's management and General Counsel, the ultimate resolution of any
   legal actions still pending will not materially affect EPA's operations or financial position.

   At the end of FY 1993, the Superfund Trust Fund had $ 3.5 million in contract obligations
   that were cancelled.  These Obligations were entered  into in FY  1986.  Although these
   obligations were cancelled under the requirements of Public Law 101-510  "M" Account
   Legislation, since these obligations related to valid contracts, there is a potential that these
   obligations will become a liability that will require funding from a future appropriation. -No
   obligations were cancelled at the end of FY 1992.          '• •     '


   Note 14.  Restatement of Prior Year Financial Statements

   Due to a change in defining the reporting entity, the Superfund Trust Fund and the LUST
   Trust Fund Statements of Financial Position have been restated. As of September 30, 1992,
   EPA included amounts held by the  U.S. Treasury not yet appropriated as  an asset and
   offsetting the liability on the Statements of Financial Position. EPA has no control over these
   balances, which may be appropriated to EPA or to other Federal agencies in the future. As
   a result, EPA has determined that this balance should not be included on the Superfund Trust
   Fund or LUST Trust Fund financial statements.  The Statements of Financial  Position, as of
   September 30, 1992, have been restated for consistency.

   Additionally, due to an error in the Superfund Trust Fund Appropriations Expensed balance
   on the September 30,  1992, Statement of Cash Flows, this amount has been restated.

   Finally, EPA has  changed its method of accounting for pre-credit reform loan balances, to
   comply with the Credit Reform Act of 1990.  As a result, loan activity as of and for the year
   ending September 30, 1992, has been restated in all financial statements of the Asbestos
   Loan Program.
EPA's FY 1993 Annual Financial Statements                                               Page 71

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Page 72
EPA's F\: 1993 Annual Financial Statements

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             UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

                        WASHINGTON, D.C. 20460
                            MAR 30 1994
                                                          OFFICE Of
                                                       THE INSPECTOR GENERAL
MEMORANDUM
SUBJECT
Auditors' Report on  the Fiscal 1993 Financial
Statements for the Superfund Trust Fund,  Leaking
Underground Storage  Tank Trust Fund and the
Asbestos Loan Program
Audit Report. PlSFL3-20-a003-4ttX>231
FROM:
TO:
Kenneth A. Konz
Assistant Inspe,
Jonathan  Z. Cannon
Chief Financial  Officer (3101)
                                           Audit (2421)
     Attached  is our Independent Public Accounting firm's report
 ummarizing  the results of the engagement to audit the fiscal
1993 financial statements for the Superfund Trust Fund, Leaking
Underground  Storage Tank (LUST)  Trust Fund and Asbestos Loan
Program.  The  firm's objectives were to determine if the
financial statements were fairly presented, adequate internal
controls were  in place, and the Agency complied with relevant
laws and regulations.

Results of Financial Statement Audit

     The firm  qualified its opinion on the Statements of
Financial Position for the LUST Trust Fund and the Asbestos Loan
program; and disclaimed an opinion on the other financial
statements for the LUST Trust Fund and the Asbestos .Loan Program.
In  addition, the firm disclaimed an opinion on all of the
Superfund financial statements.   The qualified opinions and the
disclaimers  of opinion were due in part to weaknesses in the  .
following areas:
                                                r
      • recording and reconciling of Superfund accounts
        receivable,

      • recording of accounts payable and accrued liabilities,

      • reporting of net position components, and

      • the  lack of an integrated property system.
  EPA's FY 1993 Annual Financial Statements
                                                     Page 73

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The results of the compliance tests for each fund indicated that,
for the items tested, EPA management had complied with applicable
laws and regulations that, might have a material effect on the
financial statements.

Action Required

     In accordance with EPA Order 2750, as the action official
you are required to provide this office a written response to the
audit report within 90 days of the final audit report date.  For
corrective actions planned but not completed by your response
date, reference to specific milestone dates will assist us in
closing the report.  We will work with your staff during our
upcoming audit of the fiscal 1994 financial statements to assist
them in implementing corrective actions to improve the accuracy
and timeliness of EPA's financial information.

     This audit report contains findings that describe problems
the Office of Inspector General (OIG) identified and corrective
actions the OIG recommends.  This report represents the opinion
of the OIG.  Final determinations on matters in this report will
be made by EPA managers in accordance with established. EPA audit
resolution procedures.  Accordingly, the findings described in
this report do not necessarily represent the final EPA position.
We have no objection to the further release of this report to the
public.

Audit of Superfund Performance Measures

     In addition to the financial statement audit work performed
by our independent public accounting firm, our office audited the
Superfund performance measures contained in the financial state-
ments.  The overall objective of this work, performed in Regions
1, 5, 6 and 7, was to determine whether data reported by the
regions was reliable.  In addition, since most of the information
on which the measures are based comes from the Comprehensive
Environmental Response, Compensation and Liability Information
System (CERCLIS), we assessed the adequacy of the internal
controls over CERCLIS data entry and quality in these regions.

     In summary, we determined the risk that material errors in
the CERCLIS data would occur, and not be promptly detected,
varied from low to moderate in the regions where audit work was
performed.  A low score in the risk assessment process indicated
good controls and a low risk of material misstatement.  A
moderate score indicated weaker controls and a moderate risk of
material misstatement.
Page 74
EPA's FY 1993 Annual Financial Statements

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     We were able to verify  91 percent  of  the  recorded
accomplishments and settlement actions  which we reviewed  in  the
regions.  These accomplishments  and  settlement actions
represented the following performance measures included in the
overview section of the  financial statements.

     o Measure 1 - Number of sites on the  National Priority  List
                   where cleanup has started

     o Measure 2 - Number of non-National  Priority List sites
              with hazardous releases where ~PA has begun a
              cleanup action                      .

     o Measure 3 - Number of sites on the  National Priority  List
                   where a decision  has been made about how  to
                   proceed with  the  cleanup of at least a
                   significant portion  of  the  site

     o Measure 4 - Number of sites on the  National Priority  List
                   where remedial action has been completed  for
              at least a significant portion of the site

     o Measure 5 - Number of sites on the  National Priority  List
                   where cleanup construction  is complete

     o Measure 6 - Number of enforcement actions EPA has taken  at
                   sites on  the  National Priority List against
                   the parties potentially responsible for
              contaminating  the  site

     o Measure 7 - Past  costs achieved  in  settlement

     o Measure 9 - Estimated amount  of  money parties responsible
                   for contaminating Superfund sites have
                   committed to  spend on site  cleanup

We also confirmed that the amount reported for Performance
Measure 8, amount of money EPA has collected from parties
responsible for contaminating sites  on  the National Priority
List, was the amount reported by the Department of the Treasury.

     Concerning Performance  Measures 7  and 9,  we found that  the
estimated settlement amounts recorded were not always
sufficiently documented  and  the  source  of  the  documented
estimates varied significantly.  Therefore, we were unable to
assess the reasonableness of the estimated settlement amounts
that were reported.  Guidance has not been issued to the regions
on preparing estimated response  settlement amounts and requiring
that the basis for the estimated settlement.amounts be
documented.  Officials in the Office of Waste  Programs
Enforcement agree that guidance  on preparing and documenting
settlement amounts is necessary  and  as  a result, have taken
action to develop such guidance.
EPA's FY 1993 Annual Financial Statements                                      Page 75

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     The results of  our  audit  work related to the Superfund
performance measures are further discussed in a separate audit
report entitled — "Reliability of CERCLIS Data:   Superfund
Performance Measures for Fiscal 1993"  (Audit Report E1SFF3-11-
0029-4100229).  Should you or  your staff have questions about
that report,  please  contact Edward Gekosky, Divisional Inspector
General for Audit, Headquarters Audit  Division, or Frances Tafer
of his staff, on  (703) 308-8222.  Should you or your staff have
any questions concerning the attached  report, please contact
Melissa Heist, Divisional Inspector General, Financial Audit
Division on 260-1479, or Drusilla Yorke of her staff on 260-9628,

Attachment

cc:  See Attached Report Distribution  List
Page 76
EPA's FY 1993 Annual Financial Statements

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                     Report Distribution List

Assistant  Administrator for Solid Waste and Emergency
  Response (5101)
Assistant  Administrator for Prevention, Pesticides and Toxic
  Substances (7101)
Assistant  Administrator for Enforcement (2211)
General Counsel,  Office of General Counsel (2310)
Regional Administrators, Regions 1 through 10
Director,  Office of Waste Programs Enforcement (5501)
Director,  Office of Emergency and Remedial Response (5201)
Director,  Office of Underground Storage Tanks '(5401W)
Director,  Office of Pollution Prevention and Toxics (7401)
Comptroller (3301)
Director,  Office of Grants and Debarment (3901F)
Director,  Office of Acquisition Management (3801F)
Director,  Office of Information Resources Management (3401)
Director,  Office of Administration and Resources Management,
  RTP,  NC  (MD-20)
Director,  Office of Administration and Resources Management,
  Cincinnati,  OH
Director,  Financial Management Division (3303F)
Director,  Budget Division (3302)
Director,  Facilities Management and Services
  Division (3204)
Director,  National  Data Processing Division,  RTP,  NC (MD-34)
Director,  Contracts Management Division,  RTP,  NC (MD-33)
Director,  Superfund Enforcement Division (2243)
Financial  Management Officers, Regions 1 through 10,
  Research Triangle Park, Cincinnati and Las Vegas
Chief,  Fiscal  Policies and Procedures Branch (3303F)
Chief,  Superfund Accounting Branch (3303F)
Chief,  Headquarters Accounting Operations Branch (3303)
Chief,  Financial Systems Branch (3303F)
Chief,  Financial Reports and Analysis Branch (3303F)
Chief,  Financial Compliance and Quality Assurance Staff (3303F)
Chief,  Security and Property Management Branch (3204)
Agency Followup Official (3304)
Carolyn Levine, Audit Liaison for the Office of Administration
  and Resources Management (3102)
Charlene Dunn, Audit Liaison for the Office of 'Solid Waste
  and Emergency Response (5103)
•Joyce Hay, Audit Liaison for the Office of Prevention, Pesticides
  and Toxic Substances (7104)
EPA's FY 1993 Annual Financial Statements
Page 77

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                  This Page  Left  Blank  intentionally
Page 78
EPA's FY 1993 Annual Financial Statements

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 The United States
 Environmental Protection Agency
 Independent Auditors' Reports
      on the
 Annual Financial Statements of EPA's
      Superfund Trust Fund
      Leaking Underground Storage Tank Trust Fund
      Asbestos Loan Program
 For the years ended September 30, 1993 and 1992

 Audit Assignment Number P1SFL3-20-S003
 Contract Number 6&-W2-0020
Leonard G. Birnbaum and Company
Alexandria, Virginia

January 28, 1994
 EPA's FY 1993 Annual Financial Statement!
                                                        Page 79

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                              This page is intentionally left blank.
Page 80
EPA's FY 1993 Annual Financial Statements

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                          LEONARD   G.  BIRNBAUM  AND COMPANY
                                   CEflTIFMED PUBLIC ACCOUNTANTS
                                          WASHINGTON OFFICE
                                         S2BS FBANCONIA 30AO
                                         ALEXANDRIA. VA. 22310
                                            (701) 922-7822

                                          FAX: (703) 922-ma
LEONARD a  31RN3AUM
LESUS A. LglPEfl
OAVtO SAKOFS
CAROL A. SCHNEIDER


MEMBERS OP THE
AMERICAN INSTITUTE
    OF C?A'S
  WASHINGTON. 3.C.
 SUUUIT. NEW  .£?S£Y
'.os ALTOS. CALJFOSNIA
SAN OIEGO. CALIFORNIA
           Independent Auditors' Report on Financial Statements - Superfund Trust Fund
      The Inspector General
      U.S. Enviionmentai Protection Agency:
      1.      We were engaged to audit the accompanying statements of financial position of the
      Superfund Trust Fund of the U.S. Environmental Protection Agency (EPA) as of September
      30, 1993 and 1992, and the related statements of operations and changes in net position, cash
      flows, and  budget and actual expenses for the years then ended.  These financial statements
      are the responsibility  of EPA's management,

      Basis of Accounting

      2.     As described in Note 1 to  the financial statements, these financial statements were
      prepared in conformity with the applicable accounting practices prescribed  or permitted by
      OMB Bulletin 93-02 and applicable provisions of OMB Bulletin 94-01, Form and Content of
      Agency Financial Statements, which is a comprehensive basis of accounting other than
      generally- accepted accounting  principles.

      Planned Exclusions

      3.   .  We  did not audit the 1993  or  1992 financial statement amounts discussed in
      paragraphs  4  and 5 of this report.  It was impracticable to extend our procedures sufficiently
      to determine the extent to which the financial statements as of and for the years ended
      September 30, 1993 and  1992  may have been affected  by these amounts.
     EPA's FY 1993 Annual Fuunciil Statement!
                                                                                       Page 31

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 4.     Administrative costs of 522,257,000 and 517,586,000, for the years ended September
 30, 1993 and 1992, respectively, we're funded from other EPA appropriations and were
 recorded as income from overhead allocation and offsetting overhead expenses from
 allocation for financial statement purposes.  Administrative costs funded from other EPA
' appropriations do not affect net position.  We were unable to audit the administrative costs
 funded, from other EPA appropriations because the audit of these appropriations for
 ailowability and alienability of such costs  was not within the scope  of these audits.
 Adjustments, if any, to administrative costs funded by other EPA appropriations would affect
 the statements of operations and changes in net position.

 5.     Prior to October 1, 1991, EPA was not required to prepare  financial statements for
 the Superfund Trust Fund in conformance with OMB Bulletin 93-02, Form and Content of
 Agency Financial Statements, nor was EPA required to have such statements audited..
 Accordingly, the statement of financial position as of September 30, 1991, has not been
 audited.  Statement of financial position amounts as of September 30, 1991, enter into the
 determination of results of operations and changes in net position, cash flows, and budget
 and actual expenses for the year ended September 30, 1992. Similarly,  our disclaimer of
 opinion on the September 30, 1992 statement of financial position affected our ability to
 report on the fiscal year 1993 results of operations and changes in  net position, cash flows,
 and budget and actual expenses.

 6.     In our report on the fiscal year 1992 financial statements, dated  April 7,  1993, we
 reported that we were unable to audit the balance of amounts held  by the U.S. Treasury for
 future appropriations because that balance is maintained and controlled  by the U.S. Treasury
 and the audit of such amounts was not included in the scope of our engagement.  As
-described in Note 14 to the financial statements, EPA changed its method of reporting
 amounts held by the U.S. Treasury for future appropriations and no longer reports these
 amounts in its financial statements. Accordingly, the  1992  financial statements have been
 restated and our present planned exclusions on the 1992 financial statements, as presented
 herein, differ from those in our previous report.

 Limitations

 7.     We were unable to satisfy ourselves regarding  the 1993 and 1992 financial statement
 amounts discussed in paragraphs 3 through  16 of this report.  It was impracticable to extend
 our procedures sufficiently to determine the extent to which the financial statements as of and
 for the years ended September 30, 1993 and 1992, may have been  affected by these
 conditions.

 8.  '  We were unable to determine if accounts receivable  - non-federal, net, stated at
 5193,938,000 and 5122,315,000 as of September 30, 1993 and 1992, respectively, have been
 Page 82
EPA's FY 1993 Annual Financial Statement*

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recorded for all cost recovery actions, because EPA personnel did not fully comply with
policies and procedures for recording accounts receivable;  adequately document
reconciliations of accounts receivable; and perform such reconciliations timely.  Adjustments,
if any, to the balance of accounts receivable would affect all of the financial statements for
the years ended September 30, 1993 and 1992.

9.     We were unable to audit the property, plant and equipment, net, stated at
314,030,000 and 316,094,000 as of September 30, 1993 and 1992, .respectively, because
EPA did not have adequate detailed schedules to support the financial statement amounts.
EPA's supporting property records did not identify all the  property' and equipment acquired.
Property and equipment acquired by contractors and through interagency agreements had not
been recorded.  Certain property and equipment disposed of had not been removed from the
accounting records.  Adjustments, if any, to the property,  plant and .equipment, net,  balance
would affect all of the financial statements for the years ended September 30,  1993 and
1992.

10.    We were unable to audit accounts payable, non-federal, stated at 3112,057,000 and
5102,212,000 as of September 30, 1993 and 1992, respectively, because accruals for grant
expenses of grant recipients that used the ACH payment system were not made. We were
unable to determine the amounts that should have been recorded for these liabilities.
Adjustment, if any, for accrued liabilities to grant recipients would affect ail of the financial
statements for the years ended September 30, 1993 and 1992.

11.    We were unable to audit the retainages payable to contractors.  EPA did not  maintain
sufficient accounting records for such amounts and, therefore, did not record these liabilities
in the financial statements.  Adjustment, if any, for retainages payable to contractors would
affect all of the financial statements for the years ended September 30,  1993 and 1992.

12.    We were unable to audit deferred revenue, non-federal, stated at 3183,430,000 and
3248,561,000 as of September 30, 1993 and 1992, respectively, because EPA did  not have
policies and procedures in place to adjust deferred revenue from state cost share contracts as
revenues were earned and to maintain adequate accounting records to properly support the
financial statement amounts.  Adjustments to deferred revenue from state cost share  contracts
would affect all of the financial statements for the years ended September 30,  1993 and
1992.

13.    We were unable to audit net position, stated at 32,980,827,000 and 32,671,083,000,
as of September 30,  1993 and 1992, respectively, and the  changes in net position for the
years then ended, because (a) EPA contracting officers or  responsible officials were  unable to
confirm unliquidated obligation balances, a component of net position, and we were  unable to
perform alternative procedures, and (b) EPA did not  maintain sufficient accounting records to
EPA'* FY 1993 Annual Financial Statement*
Page 83

-------
 provide the net position disclosures in conformance with OMB Bulletin 93-02, Form and
 Consent of Agency Financial Statements.  Adjustments, if any, to the components of net
 position would affect all of the financial statements for the yean ended September 30, 1993
 and 1992.

 14.    We were unable to audit expenses for grants because grant drawdown requests from
 certain recipients did not identify the appropriation or account information to which the
 expenses related.  Adjustments, if any, to grant expenses would affect all of the financial
 statements for the yean ended September 30,  1993 and  1992.

 15.    We were unable to audit general support service costs allocated from other EPA
 appropriations, because for our fiscal year 1993 engagement, EPA could not provide the
 details of supporting accounting transactions in a timely manner. We were unable to audit •
 these costs for fiscal year  1992 because the audits  of these costs were not included within the
 scope of our audit. Adjustments, if any, to the amount  of expenses  allocated from other
 appropriations would affect all of the financial statements for the years ended September 30,
 1993 and  1992.

 16.    We were unable to audit capital and operating  leases because EPA did not identify,
 and the notes to the financial statements do not disclose, capital or operating lease
 commitments as of September 30, 1993 and 1992, in accordance with OMB Bulletin 93-02,
 Form and Content of Agency Financial Statements. The bulletin requires disclosure of the
 capital and.operating lease arrangements including the basis for contingent rentals, terms of
 renewal or purchase options, escalation clauses, and restrictions imposed.

 Disclaimer of Opinion

 17.    Because of the matten discussed in paragraphs 3 through 16  of this  report, the scope
 of our work was not sufficient to enable us to express, and we do not express, an opinion on
 the financial statements of the Superfund Trust Fund for the years ended September  30, 1993
and 1992.

Emphasis Matters

 18.    The Comprehensive Environmental Response Compensation and Liability Act of 1980
 (CERCLA) and its amendments authorized EPA to respond to releases of hazardous
substances  which threaten human health and the environment  EPA  is responsible for
identifying and prioritizing waste sites and ensuring that the nation's most hazardous sites are
cleaned up. Those sites posing the most serious threat are placed  on the National Priorities
List (NPL).  EPA is authorized to recover, from responsible parties, cleanup costs paid from
the Superrund Trust Fund.  Since the inception of  Superfund, Congress has authorized S15.2 •
Page 84
EPA's FY 1993 Annual Financial Statements

-------
billion to be made available to EPA in appropriations through fiscal year 1994.  In the
Overview section of the accompanying financial statements, EPA has reported that 58.7
billion has been spent for Superfund response program expenses through fiscal year  1993.
The current authorization expires September 30, 1994.  Congressional hearings concerning
the reauthorization of Superfund are scheduled throughout fiscal year 1994 and beyond.

19.    la the Overview section, EPA indicated 1,177 non-federal sites on the NPL as of
September 30,  1993.  EPA estimates that the remaining costs of cleaning up these 1,177 sites
will be S14.3 billion for fiscal year 1994 and beyond, not including the responsible parties'
contributions.   However, in a U.S. General Accounting Office (GAO) report titled Superftuid
Program Management, dated December  1992, EPA estimated the remaining costs to clean up
the 1,275 federal and non-federal sites remaining on the NPL as of September 30, 1992,
would be S40 billion.  The financial statements do not include an accrual for any estimated
cleanup costs, because no costs have been incurred for these future cleanup actions.  To
accomplish the cleanup of all remaining  sites on the NPL, future -funding and rime,  beyond
that currently authorized, will be needed.

Supplementary Information

20.    The financial information presented in Management's Overview of EPA and Overview
of Trust  Funds, Revolving Funds and Commercial Activities is not a required part of the
financial statements but is supplementary information required by OMB Bulletin 93-02, Form
and Content of Agency Financial Statements. We have read this information and considered .
whether  it is materially inconsistent with the financial statements.  Such information has not
been subjected  to auditing procedures and, accordingly, we express no opinion on it.

Distribution

21.    This report is intended for the information of Congress, OMB, and EPA.  This
restriction is not intended to limit the distribution of this report, which is a matter of public
record.
LEONARD G. BIRNBAUM & COMPANY
Alexandria, Virginia
January 28, 1994
 EPA's FY 1993 Annual Financial Statement*
Page 3S

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                              This page is intentionally left blank.
Page 86
EPA'i FY 1993 Annual Financial Statements

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                          LEONARD  G.  BIRNBAUM AND COMPANY
                                             PUBLIC  ACCOUNTANTS
                                          WASHINGTON OFFICE
                                          3265 rRANCONIA flOAO
                                          ALEXANDRIA. 7*. J2310
                                             1703) 92

                                            AX: (7031 922-325*
LEONARD a  3IRN9AUM
'.£SU£ A. VSI1»E«
OAVID SAKQFS
CAROL A. SCHNEIDER


MEMBERS OP THE
AMERICAN INSTITUTE
          N. D.C.
 SUMMIT. M6W ,£3S£Y
'.OS iLTOS. CACFCRNIA
SAN DIEGC. CAUlfORNIA
    OP C?*'S
              Independent Auditors* Report on Internal Control - Saaerfund Trust Fund
           The inspector General
           U.S. Environmental Protection Agency:
           1.     We were engaged to audit the financial statements of the Superfund Trust
           Fund, of the U.S. Environmental Protection Agency (EPA), as of and for the year
           ended September 30, 1993. We have issued our report thereon dated January 28,
           1994, in which we disclaimed an opinion on the financial statements.

           2.     In planning and performing our engagement for the year ended September 30,
           1993, we considered EPA's internal control structure in order to determine our audit
           procedures and to determine whether the internal control structure meets the
           objectives identified in the fourth paragraph.  This consideration included obtaining
           an understanding of the internal control policies and procedures and assessing the
           level of control risk relevant to all significant cycles, classes of transactions,  or
           account balances.

           3.     Performance measures  present the financial and program accomplishments of
           the reporting entity's activities. We did  not review the data, that support reported
           performance measures or the internal control structure, policies and procedures
           designed to ensure the existence and completeness  of such information, as required
           by OMB Bulletin 93-06, Audit Requirements for Federal Financial Statements,   .
           because this work was performed and reported on  by EPA's OIG.

           4.    . The  management of EPA is responsible for establishing and maintaining an
           internal control structure.  In fulfilling this responsibility, estimates and judgments
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      by management are required to assess the expected benefits and related costs of
      internal control structure policies and procedures. The objectives of an internal
      control structure are to provide management with reasonable, but not absolute,
      assurance that transactions, including obligations and costs, are executed in
      compliance with laws and regulations that could have a direct and material effect on
      the financial statements, and any other laws and regulations that OMB, EPA
      management, or EPA's OIG have identified as being significant and for which
      compliance can be objectively  measured and evaluated.  The objectives of an internal
      control structure are also to provide management with reasonable, but- not absolute,
      assurance that funds, property, and other assets are safeguarded against loss  from
      unauthorized use or disposition; and transactions  applicable to EPA operations are
      properly recorded and accounted for to permit the preparation of reliable financial
      statements and to maintain accountability over assets, in accordance with, the
      accounting principles described in Note  1 to the financial statements.  Because of
      inherent limitations in any internal control structure, errors or irregularities may
      nevertheless occur  and not be detected.  Also, projection of any evaluation of the
      structure to future periods is subject to the risk that procedures may become
      inadequate because of changes in conditions or that the effectiveness of the design
     and operation of policies and procedures may deteriorate.

     5.     For the purpose of this report, we have classified the significant internal
     control structure policies and procedures in  the following categories:

    -.•   General accounting and financial reporting
     '-••   Receivables and collections
     •  Property
      •   Accounts payable and accrued liabilities
      •   Fund balance
      •  Obligations
    ,..•  Disbursements and operating expenses

     6.     For all of the internal control structure categories listed above, we obtained
     an understanding of the design of relevant policies and procedures, determined
     whether they have been placed in operation,  assessed control risk, and performed
     tests of the control  procedures.

    "7.     We noted certain matters involving the internal control structure and  its
     operation that we consider to be material weaknesses and reportable conditions under
    . standards established by  the American Institute of Certified Public Accountants and
     OMB Bulletin 93-06.
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     8.      A material weakness is a rqportable condition in which the design or
     operation of the specific internal control structure elements does not reduce to a
     relatively low level the risk that errors or irregularities in amounts that would be
     material in relation to the financial statements being audited may occur and not be
     detected within a timely period by employees in the normal course of performing
     their assigned functions.  Reportable conditions involve matters coming to our
     attention relating to significant deficiencies in the design or operation of the internal
     control structure that, in our judgment, could adversely affect EPA's ability to
     ensure that obligations and costs are in compliance with applicable laws; funds,
     property, and other assets are safeguarded against unauthorized use or disposition;
    'and transactions applicable to  EPA operations are properly recorded, to .permit the
     preparation of reliable financial statements in accordance with accounting principles
     described in Note 1 to the financial statements.
                                                              •      t
     9.      Our consideration of the internal control structure would not necessarily
     disclose all matters in the internal control structure that might be reportable
     conditions and, accordingly, would not necessarily disclose all reportable conditions
     that are also considered to be  material weaknesses.  Those conditions that we
     consider to be material weaknesses are included in Attachment 1 of this report. The
     conditions that we consider to be reportable conditions are included in Attachment 2
     of this report.  Attachment 3 presents the status of known but uncorrected prior year
     audit findings.

     10.     We also rioted other less significant matters involving the internal control
     structure and its operation that we will report to the management of EPA in a
     separate management letter.

     11.  '   This report is intended for the information  of Congress, OMB, and EPA.
     This restriction is not intended to limit the distribution of this report, which is a
     matter of public record.
LEONARD G. BERNBAUM & COMPANY
Alexandria, Virginia
January 28, 1994
                                                             •
                                                     <*
EPA'i FY 1993 Annual Financial Submenu
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                                 Superfund Trust Fund

                          Attachment 1 - Material Weaknesses

    1.  Improvements In Financial and Budgetary Accounting and Reporting Are
    .Needed

    EPA needs to make  improvements in its financial and budgetary accounting and
    reporting systems and procedures.  We noted that interagency activity is not fully
    accounted for in the  budgetary accounts. We also found that the proprietary
    accounts for  the components of net position are not properly maintained and do not
    disclose  the correct amounts. Further, we  noted that the financial system does not
    maintain beginning account balances at the  regional finance office  level.

    EPA management reported in its 1993  FMFIA report that systems-related  problems
   : of the Integrated Financial Management System (IFMS) impair EPA's ability to
    provide complete, reliable, and timely  data for decision making and control of assets.
    These problems include:  (a) incomplete users manual and  systems documentation;
    (b) inadequate automated project cost accounting capability; (c) incomplete interfaces
    with programmatic and administrative systems;  and (d) inadequate financial
    management  reports.  The IFMS reporting-system weaknesses also impose significant
    constraints on EPA's ability to perform its  financial reporting duties in an effective,
    efficient, and timely  manner. EPA financial management personnel spend  a
    significant amount of resources reconciling and correcting information for reporting
    purposes.

    Certain Budgetary Accounts Were Not  Utilized

    EPA has not established the required budgetary Standard General  Ledger (SGL)
    accounts to record reimbursable authority received by EPA as a result of interagency
    agreements.  The SGL accounts that have not been utilized to record interagency
    agreement activities include Reimbursable Orders Accepted, Unfilled Customer
    Orders-Unobligated,  Unfitted Customer Orders-Obligated,  and Reimbursements and
    Income Earned. These accounts are needed and should be used in the preparation of
    OMB standard forms.

    EPA  is currently preparing che required OMB standard forms using proprietary
    accounts that provide lower levels of detail. This process is inefficient and results in
    a lack of budgetary control over reimbursable work,  a budgetary resource. This has
    occurred because not all of the required budgetary entries to account for interagency
    reimbursements have been consistently made.  Like an appropriation, reimbursable
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     work is subject to fund control and can be apportioned, allotted, committed,
     obligated, and expended.

     We noted that EPA's current process causes an out of balance condition in  the
     interagency budgetary accounts of 353,255,615 as of September 30,  1993.  This
     error is offset in the non-interagency budgetary accounts as evidenced by the fact
     that the budgetary accounts are in balance.  EPA needs to establish the proper
     budgetary accounts  to account for and exert budgetary control over the reimbursable
     agreements.

     Understatement of Accrued Expenditures on SF-133

     We noted that the SF-133, Report on Budget Execution, for the year ended
     September 30, 1993 contained an understatement of 5486,061,000 in accrued
     expenditures.  The accrued expenditures reported on the SF-133 were 5818,444,909
     and should have been $1,304,505,909. The understatement was caused by  an
     adjustment, to accounts payable as of September 30, 1992 that was recorded for
     financial statement purposes but was not reflected in EPA's preparation of
     subsequent SF-133s.

     EPA personnel did  not adjust the SF-133 for adjustments made after year end in
     1992, which resulted in inaccurate reports being submitted  to OMB during  fiscal
     year 1993.

     Proprietary Accounts Do Not Correaty Disclose Net Position

     EPA's proprietary SGL accounts do not correctly disclose the components of net
     position because the automated year end closing process in the IFMS is incorrect.
     This is evidenced by the fact that certain account balances that should equal other
     accounts do not.  For example, net property in the  proprietary accounts does not
     equal invested capital, cumulative results does not equal the balance of accounts
     related to receipts to be returned to  U.S. Treasury plus the net effect of reimbursable
     interagency agreements.  Also, beginning net position plus  current appropriations
     less appropriations expensed and the net change in  invested capital and unfunded
     activities do not equal ending net position. As a result, EPA financial management
     personnel spent significant time and resources to develop net position financial
     information for footnote disclosure.  Manual adjustments were recorded for financial
     statement purposes.   However, the components of net position as required by OMB
     Bulletin 93-02 still could not be properly disclosed.
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     Regional Account Balances Were Not Maintained

     We noted that the JFMS general ledger does not maintain beginning account balances
     at the regional finance office level.  EPA's automated closing procedures close all
     assets and liabilities recorded by the regions to a combined amount by account at the
     headquarters level.  As a result, regional account balances for die subsequent year
    - begin with a zero balance and the account balance at headquarters represents all
    ~ finance offices.  This procedure makes it difficult to determine "and reconcile the
     actual asset and  liability account balances with detail records at die regional level.
     Although a  supplemental reporting system, the Management Accounting and
     Reporting System (MARS), contains historical information by regional office,  MARS
     does not include all entries recorded in IFMS.  Therefore, manual reconciliation
     procedures are necessary to obtain account balances at die regional level. EPA is
     planning to  change  the automated  closing procedures in the IFMS in fiscal year 1994'
     so that regional  balances will be maintained.

     EPA. Actions

     In our fiscal year 1992 report,  we recommended that EPA's CFO:  (1) continue
     efforts to change the automated closing procedures to retain regional account
     balances; (2) establish SGL budgetary accounts and implement transaction codes to
     properly account for reimbursable authority using these accounts; and (3) review and
    .correct the automated closing procedures.   The CFO agreed with our
    ^.recommendations and provided  EPA's plans for corrective actions that would  be
    ataken during fiscal  years 1993 through 1995. Since these EPA corrective action
    •/plans are;still in process, we are not making any new recommendations  in these
     areas.

     In its 1993 FMFIA report, EPA management reported its financial systems,
     specifically  IFMS,  as an OMB High Risk Area.  EPA also reported accounting
     system-related financial management problems as a material weakness.   EPA's
     corrective action plans include:  1) implementing a new version  of IFMS including
     user manuals and system documentation; 2) completing enhancements to produce
     complete and accurate OMB and Treasury  reports and financial statements;  3)
     conducting training; and 4) issuing guidance on reporting enhancements.  These
    .corrective actions are scheduled to be  completed during fiscal year 1994. EPA
     management believes  that diese  actions will resolve many of these weaknesses.
     Therefore, we are making no additional recommendations  in diese areas at this time.
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     2.  Improvements An Needed in Recording Accounts Receivable

     EPA has several types of Superfund receivables, the most significant resulting from
     cost recovery actions from individuals and businesses that EPA has determined were
     responsible for causing hazardous waste sites.  EPA identifies these potentially
     responsible parties during site-specific enforcement procedures.  It is EPA's policy to
     record accounts receivable from  these responsible parties when'consent decrees,
     judgments, or other binding  agreements are reached, that authorize EPA to recover
     site cleanup costs incurred by EPA.  The amounts collectible as a result of consent
     decrees, judgments or agreements, include the site-specific cleanup costs and general
     and administrative costs incurred by EPA related to the site cleanup.  EPA also has
     agreements with states to share in the costs of site cleanups.  These agreements are
     known as Superfund State Contracts (SSCs) and provide for EPA to-collect a portion
     of cleanup costs from the states.

     We tested a statistical sample of  accounts receivable balances from EPA's records as
     of September 30, 1993; a nonstatistical sample of accounts receivable transactions
     recorded during fiscal year 1993; and a nonstatistical sample of EPA cost recovery
     cases tracked by the Department of Justice (DOJ).  The results of our tests indicated
     that there were significant delays in recording accounts  receivable. As a result,  we
     found material amounts of unrecorded receivables.  We also found that EPA bad
     recorded receivables for Superfund State Contracts  which  were conditional upon
     future events. Further, we found that EPA had not recorded marketable securities
     received in payment of accounts  receivable.  Finally, we noted that EPA had not
     established an adequate allowance for uncollectible  accounts.

     Material Amounts of Accounts Receivable Were Not Recorded

     We tested the completeness of accounts receivable from potentially responsible
     parties by reviewing EPA's reconciliations of accounts receivable per IFMS with the
     EPA Outstanding Balances for Debts Owed U.S. FY 89 - Present per the Department
     of Justice (DOJ). We obtained supporting documentation from DOJ, provided this
     information to EPA regional financial management  offices  (FMOs), and requested
     explanations  of significant differences.

     We found that S57,005,700 of accounts receivable had not been recorded in IFMS as
     of September 30, 1993. These unrecorded receivables resulted primarily from
     EPA's Offices of Regional Counsel (ORCs) not forwarding documentation to the
     finance offices timely or when ORCs believed that collectibility was hampered,
     because an appeal had been filed or the responsible parry was in bankruptcy.  We
     noted' that some of the receivables were recorded in fiscal vear 1994 because the
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r.

it
  FMOs did not receive the documentation from ORCs until after September 30,  1993.
  EPA recorded adjustments in .the financial statements based upon our :est work.
  However, our test work only encompassed a non-statistical sample and die results
  indicate that there may be other unrecorded accounts receivable.

  EPA policy states that the FMO should establish accounts  receivable  for judgments
  and should maintain these receivables while under appeal until the case is resolved or
  the status has changed. The FMOs stated that the ORCs had, in some cases, advised
  the FMOs not to record certain receivables because  of the  uncertainty of collecting
 .;the amounts.  ORCs should forward documents to finance  offices timely and provide
  assessments regarding the coilectibility of these accounts.  EPA finance offices
  should record receivables, in accordance with EPA policy, assess che status, and
 .provide for an adequate allowance for uncollectibility based upon the status of these
.receivables.

• .Accounts Receivable Were Not Recorded Timely

'  Our tests of receivables disclosed that 26 accounts receivable, totaling $15,366,734,
 ."from our nonstatistical sample of 52 receivables, totaling $208,098,207, were not
'recorded timely. Nine of these receivables, totaling $5,665,387, should have been
  recorded as of September 30,  1993,  but were not recorded until fiscal year 1994.
.  For the 26 receivables tested,  an average of 51 days elapsed from execution of the
  consent decree or other judgment creating the debts, to recording the receivables in
  IFMS.  Also, we found that two accounts receivable amounting to $903,750 had not
  been recorded in the IFMS  until after the collections were received.  Because of
  delays such as these,  there may have been additional accounts receivable as of
  September 30, 1993,  that were not recorded.  This likelihood is further  supported by
  our tests of completeness, discussed  above, where we found additional receivables
  that were not recorded  until fiscal year 1994 thai should have been recorded as of
.. September 30, 1993.

  EPA policy states that Regional Superfund Branch Chiefs  should ensure that any
  demand  letter, consent decree, EPA  order, or other notice requiring payment is
  forwarded to the Regional FMO within one work day of final signature.  We found
  that receivables were not recorded timely because ORCs often did not forward
  settlement documents and orders to the FMOs within one day of final signature, as
  required by this policy.  Also, ORCs did not  promptly  receive or forward judicial
  orders from the DOJ.

 -The failure to record  receivables timely causes inaccurate external reports  and
  financial statements, as well as internal EPA reports used  for monitoring and
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     managing accounts receivable.  This could also result in die loss of interest and
     penalties and contribute to the uncoilectibiiiry of receivables.

     Marketable Equity Securities Received In Payment Of Receivables Were Not
     Recorded

     We identified 34,698,756 in marketable equity securities collected from parries in
     bankruptcy, for payment of an accounts receivable of approximately 319,000,000.
     These securities had been received by EPA and were held at the U.S. Treasury as of
     September 30, 1993, but had not been recorded in EPA's general ledger.  Instead,
     the entire accounts receivable remained in EPA's general ledger receivable balance,
     even  though securities had been received in payment.

     OMB Bulletin 93-02 requires disclosure of marketable securities at acquisition cost
     or market value. We believe that marketable equity securities received by EPA in
     settlement of accounts receivable should be recorded  at fair market value when
     received.  The accounts receivable balance should be adjusted when the securities are
     received and recorded.  EPA agreed to record the marketable securities noted above
     in the financial statements at our request.

     Certain State Cost Share Contracts Were Inappropriately Recorded as Receivables

     During  our review of the Superfund State Contracts (SSCs) at Regions 2, 4, 5  and 9,
     we noted the SSCs have varying terms regarding  payment.  Some of these contracts
     require  partial payments of the states'  share only  after specific events occur. These
     partial payments per the SSCs are not billable or  collectible until the occurrence of
     future events.  We noted that Regions 2 and 4 had recorded accounts receivable for
     the total amount of these SSCs when the contracts were signed regardless of payment
     terms, based  on EPA's policy.  We did not note these types of SSCs at Regions 5 or
     9.
     Accounts receivable should not be recorded until such amounts are billabie or events
     occur that entitle EPA to receive cash or other assets. EPA's current treatment of
     these SSCs resulted in an overstatement of accounts receivable of 337,322,273 as of
     .September 30,  1993, at Regions 2 and 4.  Based upon our test'work, EPA recorded
     an adjustment to accounts receivable  for this amount.  However, these types of SSCs
     may exist at other regional offices where we did not perform these tests.
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     Adequate Allowance For Uncolkaible Accounts Was Not Recorded

     We identified accounts receivable from parties in bankruptcy for which no allowance
     for uncollectible accounts had been established.  An allowance should be established
   •vto provide  for the potential uncollectibility of these accounts. Our analyses also
     indicated that coilectibility is impaired on a portion of the older accounts receivable.

     We calculated an allowance based on (1) specific identification of debtors in
     bankruptcy in Regions 2, 5 and 9; (2) identification of debtors in bankruptcy who are
     transferring marketable securities to EPA as settlement for accounts receivable; (3)
    ' accounts receivable which were established prior to 1990; and (4) a reserve upon the
     remaining population of accounts not specifically identified.  We believe an 8%
     general reserve is necessary, in addition to specific identification allowances, based
     on our detailed analysis of collection activity and receivable turnover.  EPA
     increased its allowance by 5153,364,836 as of September 30, 1993, based on our test
     work.

     EPA Actions  .

     Weaknesses in EPA's management of accounts receivable have existed and have been
     •reported by the OIG since 1987. EPA  management recognizes that improvements
     :are still needed in managing and recording accounts receivable.  In the 1993 FMFIA
     report, EPA reported a material weakness in the accounts receivable area including
    • deficiencies such  as technical shortfalls in the accounts receivable module, non-
     current policies and procedures, inaccurate and incomplete reports, and insufficiently
   £ trained personnel. EPA management also reported as a material nonconformance,
   .a thai there, have been several instances of unrecorded accounts receivable as a result
   ^of untimely notification of finance offices by program officials.  In addition, EPA
    ' reported that the EFMS accounts receivable module includes erroneous calculation of
     interest and penalties and is unable to automatically process  installment receivables.

     EPA's corrective action strategy for fiscal  year 1994 includes: 1) implementing a
     new version of the IFMS core  software to  provide new accounts receivable
     functionalities, system documentation and user manuals; 2) completing enhancements
     to produce  needed accounts receivable reports; 3) conducting jaining classes on
     accounting  for and managing accounts receivable; and 4) issuing and updating policy
     guidance on systems enhancement to produce complete and accurate reports.  We
     recognize management's efforts to take corrective action for these accounts
     receivable issues.
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     Draft Report Recommendations

     We recommended in our draft report that the CFO, in conjunction with the Assistant
     Administrator for Solid Waste and Emergency Response,  supplement existing
     policies and procedures to improve the coordination between Offices of Regional
     Counsel and Financial Management Offices for:

     (1)    timely forwarding of documents;
     (2)    recording and reconciliation of accounts receivable for cost recovery actions;
            and
     (3)    identification of uncollectible accounts and recording an adequate allowance
            for these accounts.
                                                            •     ,
     We also recommended that the CFO establish or modify policies and procedures to:

     (1)    account for and record receipts and sales of marketable securities received in
            exchange for accounts receivable; and
     (2)    account for receivables arising from Superfund State Contracts when the
            events occur that entitle EPA to bill and collect amounts due.

     EPA's Response to Draft Report Recommendations and Our Evaluation

     The CFO stated in his response to our draft report that, since 1990,  his staff has
     worked with the Assistant  Administrators for Solid Waste and Emergency Response
     (OSWER) and Office of Enforcement (OE) to improve the coordination between the
     Offices of Regional Counsel (ORCs) and the Financial Management  Offices (FMOs)
     in the area of recording  and accounting for accounts receivable. While substantial
     improvements have been made, the CFO agreed that additional improvements are
     warranted.  The CFO stated that the FMOs should do  a better job of documenting
     the reconciliations of accounts receivable with ORCs and  program offices.  Further,
     the CFO indicated that corrective actions have previously been taken, in the form of
     memorandums and on-site reviews, to emphasize the importance of timely flow of
     documents for recording receivables and to provide a monitoring strategy to ensure
     coordination between offices in this area.

     The CFO also agreed with our recommendation to establish or modify, policies and
     procedures for accounting  for and recording marketable securities  received in
     exchange  for accounts receivable and receivables arising from Superfund State
     Contracts (SSCs).  The CFO  indicated that EPA has already started  working to
     resolve these issues.
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     The CFO provided a corrective action plan to strengthen incernal controls by
     updating Superfund accounts receivable policies  and procedures and providing
     training to regional finance office personnel.  The C?0 also indicated a corrective
     plan to develop a new strategy with OE, OSWER, the Office of the Comptroller,
     and Department of Justice to address the timely  recording of receivables.  These
     corrective actions are scheduled to be implemented during nscai year 199.4 and be
     completed by September 30, 1994.

     The CFO's proposed corrective actions are generally responsive to our
     recommendations.  However, we  would like  to point out that'we recommended in
     our fiscal year 1991 Superfund  financial audit report that EPA ensure tha: financial
     policies and procedures  for accounts receivable and collections were updated. EPA-'s
     corrective action plan to issue a revised RMD 2550D was originally scheduled to be
     completed by December 31, 1993.

     We noted that, in the CFO's response and corrective action' plan,  this target date has
     been changed to July 31, 1994 for a revised draft RMD 2550D or draft Comptroller
     Policy Announcement.  This plan provides for a Green Border review of RMD
     2550D  or Comptroller Policy Announcement to  be issued by September 30, 1994.
     Our review of FMD's Followup Tracking System during  1993 indicated that the date
     for issuance of RMD 2550D had been revised to November 30, 1994.  We urge the
     CFO to monitor the progress of these corrective actions to ensure that these revised
     target dates for completion are met.

     We also noted that the corrective  actions did  not specifically address marketable
    •"securities and SSCs. We believe  that these issues should be included in the revised
    'RMD 2550D and Comptroller  Policy Announcements to be issued in conjunction
     with the policies and procedures addressing accounting and reconciliation issues.

     Recommendation

     We recommend that the CFO ensure that policies and procedures  for recording
     marketable  securities received in payment of accounts receivable and accounting for
     Superfund State Contracts are included in the revised RMDS.

     J.  Property and Equipment Records Need  to Be Integrated, with  the General
     Ledger

     EPA does not have an integrated property system chat records and accounts for
   '  capitalized property and equipment at the  time of acquisition.  EPA uses  two systems
     to account for and control property:  1) the Personal Property Accountability System
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     (PPAS) and 2) spreadsheets prepared from manual adjusting entries which capitalize
     property in EFMS.  However, neither of the systems contains complete historical cost
     data and information to support and identify all capitalized property.

     EPA maintains spreadsheets to summarize the'property and equipment items
     capitalized in the general ledger.  These spreadsheets identify the type of assets
     acquired, dates of acquisition, and original cost, but do not include property
     identification numbers that could be used to identify the assets.' Each month, FMOs
     prepare listings of property and equipment that meet EPA's capitalization criteria
     based on detailed reviews of disbursements for property and equipment originally
     recorded as operating expenses.  The FMOs  then prepare manual general ledger
     journal entries to capitalize these amounts.

     EPA uses the listings to update the detailed property spreadsheets that are used as the
     basis for calculating and- recording depreciation.  However, contractor-acquired EPA
     property and EPA property purchased under interagency agreements was not
     capitalized or recorded in the property spreadsheets or in EPA's general ledger.
     Additionally, EPA generally did not remove property items disposed of from the
     general ledger.

     EPA maintains a separate system,  PPAS, to control property.  Annual physical
     inventories are required to be taken and be reconciled to the PPAS.  However, the
     PPAS was not designed to support the capitalized amount of property and equipment
     in EPA's accounting records.  For example,  the PPAS does not identify the original
     cost of property owned.  Instead, property is valued in the PPAS at the purchase
     requisition or obligated amount.  Such amounts do not reflect actual cost,  including
     the effect of discounts,  installation charges, and trade-in values.  Additionally,  the
     PPAS does not currently have the capability  to calculate depreciation  expense or
     maintain accumulated depreciation amounts.  The PPAS does identify
     contractor-acquired property, based on information provided from  contractors.
     However, PPAS does not record or identify EPA property purchased under
     interagency agreements.

     An integrated property system should provide both accountability for  and control
     over property recorded in EPA's general ledger.   The system should provide
     information such as type of asset, date of acquisition, original, cost, estimated useful
     life, depreciation, physical location, and identity of custodial officers. The system
     should eliminate duplication of effort in  recording and accounting  for property, as
     well as identify all EPA property,  including that held by contractors and other
     agencies.
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     As a result of the system differences, EPA could not reconcile the spreadsheets
     supporting the general ledger balance of property and equipment to the PPAS or to
     the physical inventories. Further, the general ledger balance does  not contain
     property held by contractors and other agencies  that should have been capitalized.
     Because the detailed accounting records supporting  the financial statement balance of
     property and equipment were inadequate and incomplete, we were unable to audit
   '.  this account balance in  the statement of financial position.

     EPA Actions

     EPA's accounting system problems for property are not new.  The OIG and contract
   •  auditors have reported these issues since 1981.  In.its initial FMFIA report, covering
     fiscal year 1983, EPA identified the need for an accounting  system enhancement to
   . integrate its  accounting and property management systems.  In fiscal year 1993, this •
    . need for an integrated property system still existed, and is reported as a part of the
    -.material weakness under accounting system-related  financial management problems.
     We also noted that EPA reported, as a material conformance, problems with the
     manual reconciliation of information in the IFMS, which is supported by
     spreadsheets, and property data in PPAS.

     We recognize management's initiative in forming a Quality Action Team (QAT) in
   •  March 1993 to take corrective action for property issues.  EPA is  considering
     implementing an IFMS  property module, however it is waiting until another
   '-'' .government  agency completes the testing of the  module before EPA decides to
     implement it. EPA believes that implementation could not begin until fiscal year
     .4995. Because of the ongoing effort, we are not making "further recommendations in
     this report.

     4. Accounts Payable, Accrued Liabilities And  OPAC Payments Should Be Properly
   • Recorded

     We identified a potential material understatement of accounts payable and accrued
     liabilities as  of September 30,  1993, which resulted from a lack of effective controls
     to identify and record these liabilities.  EPA did not properly estimate and record
     unpaid and unbilled grant expenses as accrued liabilities.  EPA does not have
     procedures to specifically identify accounts payable related to contractor retainages.
     In addition, EPA recorded  payments made to other federal agencies through the U.S.
   ^.Treasury's On-line Payment and Collection (OPAC) System  as prepaid adjustments in
     the Abatement Control and Compliance Appropriation (AC&C),  although the
     payments applied to other appropriations. Adjustments  to properly distribute these
     payments to  the correct appropriation were act made at year end.
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     Error In Accounts Payable and Accrued Liabilities

     We identified a $20,802,824 understatement of accounts payable at September 30.
     1993 at the Research Triangle Park - Financial Management Center (FMC-RTP).
     This error resulted from the omission of contract payments  made from October I
     through October  15, 1993 from a detailed report used to record accounts payable at
     the FMC-RTP.  These contract payments related to services provided prior to year
     end, and should have been recorded as accounts payable. We'also found that FMC-
     RTP misclassified certain accounts payables amounting  to 37,328,394 as accrued
     liabilities.  EPA made an adjustment to record these payables as of September 30,
     1993 at our request.

     Contractor Retainages Were Not Recorded As Payables
                          ,                                   *
     We 'found  that EPA had not recorded accounts payable for contractor retainages.
     Retainages have occurred in previous fiscal years when contractors submitted
     invoices for payments related to services performed and EPA withheld portions of
     the amount due.   Retainages may be held until EPA is,satisfied that the contractor
     has met all contractual requirements pertaining to a contract. The policy of holding
     retainages  was changed in fiscal year 1992 so that retainages were no longer
     withheld from contractor invoices. However, all previously withheld retainages were
     not returned to contractors at that time.

     Contract payments for EPA were made primarily by FMC-RT? officials through the
     Contract Payment System (CPS).  EPA did not determine the amount of outstanding
     contract retainages as of September 30,  1993 and 1992.  FMC-RTP officials believe
     that they have accounted for an estimated amount of retainages in  calculating accrued
     liabilities as of September 30, 1993 and 1992.  Accrued liabilities were calculated as
     one-twelfth of the total contract disbursements  for fiscal years 1993 and 1992.  This
     calculation provides an accrual for anticipated contractor expenses for services
     performed before year end that were not billed until the following fiscal year.
     Because the amounts included in this calculation included any disbursements made in
     fiscal years 1993 and 1992 for retainages, the accrual would include some provision
     for retainages.

     Although we agree that this calculation of accrued liabilities may include some
     provision for contract retainages, because of the lack of detailed information on
     retainages paid during these years or owed at each year end, we were unable to
     determine if the accruals were sufficient to account for retainages withheld by EPA
     as of September 30, 1993 and 1992.  Because  EPA has contracts extending as long-
     as five to ten years, retainages may be withheld for considerable periods before they
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    are paid.  Further, we believe that these retainages should be identified and classified
    as accounts payable instead of accrued liabilities.  Under accrual accounting,
    payables and expenses should be recorded for the entire amount for the services
    rendered, prior to deducting any retainages. The unpaid balances  of retainages
    should have been recognized by EPA as accounts payable as of September 30, 1993
    and 1992.

    As a result of our 1992  report recommendation,  FMC-RTP officials initiated a
    review of contract closeouts in fiscal  1993 to attempt to determine the amounts of
    .contract retainages paid  during the year.  Based on the results of this-review, which
    was not completed during our fieidwork, EPA expects  to use this data to estimate the
    materiality of retainages payable.  Because of this ongoing review, we are making no
    further recommendations at this time.

    Accrued Liabilities For  Grant Expenses Were Not Recorded

    EPA awards grants to state and local governmental units and other entities, primarily
    nonprofit organizations, for research and other support activities that benefit ail EPA
    programs.  The grantees perform the work and request reimbursements  from EPA
    through the Automated Clearing House (ACE) Payment System or by using other
    payment request documents. EPA's Fiscal Year 1993  Year-end Closing Procedures
    require each  regional office to record accrued liabilities for the estimated  amount of
    grant expenses through  September 30, 1993, where the grantee has performed the
    work but not yet submitted the grant payment requests to EPA. The procedures state
    mat these accrued liabilities should be based on historical data and past experience.
    We performed testwork at Regions 2,  5 and 9 and Las Vegas - Financial
    Management Center (FMC-LV) to determine if these liabilities had been recorded.

    At Region 2, we found  that accrued liabilities were not recorded at year end for
    grant expenses that were being reimbursed through the ACH payment system.  We
    found one  ACH request received at Region 2 on October 22,  1993, totaling
    57,283,994.  Based on our discussion with Region 2 officials, we concluded that the
    payment related to services performed and costs incurred prior to  September 30,
    1993.  We noted that Region 2's average monthly ACH payments during 1993
    amounted to $1,190,977.  These payments are typically made  for  expenses incurred
    in previous months.   However,  due to significant fluctuations in the timing and
    amount of various grantees' drawdowns, we could not determine the costs incurred
    for which an accrual  should have been recorded.  Because no accrual was made, we
    believe that accrued liabilities were significantly understated.   No  adjustment was
    proposed because we were unable to  determine the amounts that should have been
    recorded.
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    At Region 5, we also noted that no accrued liabilities were recorded at year end for
    grant expenses that were incurred but not yet reimbursed through che ACH payment
    system.  We noted chat Region 5's average monthly ACH payments during nscai
    year 1993 were 32,407,328. These payments are typically made for expenses
    incurred in previous months. We concluded that an accrual should have been
    recorded  for the estimated costs incurred before year end.  Because no accrual was
    made, we believe that accrued liabilities were significantly understated.  No
    adjustment was proposed because we were unable to determine the amounts that
    should have been  recorded.

    At Region 9, we found that accrued liabilities for grant expenses (except ACH
    payments) were recorded for one-twelfth of the unliquidated obligation balance as of
    September 30,  1993.  This resulted in an estimated accrual of 52,299,829.  This
    methodology is improper because it does not represent a reasonable estimate of
    expenses  incurred at year end.  Such expenses are not necessarily incurred
    proportionately over a given period of time and may have no direct relationship with
    the amounts of outstanding obligations.  However, we were unable to determine the
    actual amount  that should have been accrued by Region 9 for  non-ACH grants.

    We also found that no accrued  liabilities were recorded at Region 9 for grant
    expenses  that were being reimbursed under the ACH payment system.  We noted
    that the average monthly payments made to recipients during 1993 were 3674,485.
    These payments are typically made for expenses  incurred in previous months. We
    concluded that an accrual should have been recorded for the estimated costs incurred
    before year end.  Because no accrual was made, we believe that accrued liabilities
    were significantly understated.  No adjustment was proposed because we were unable
    to determine the amounts that should have been recorded.

    At FMC-LV, we  also noted that no accrued liabilities were recorded for grant
    recipients being reimbursed through the ACH payment  system.  According  to Las
    Vegas officials, the year end closing procedures  stated that no accrued liability
    should be established where there was no evidence that goods or services were
    delivered or performed. We noted that Las Vegas' average monthly ACH payments
    were 32,746,513. These payments are typically made for expenses incurred in
    previous  months.  We concluded that an accrual  shbuid have been recorded for the
    estimated costs incurred before year end.  Because no accrual was made, we believe
    that accrued liabilities were significantly understated.   No adjustment was proposed
    because we were  unable to determine the amounts that should have been recorded.

    None of EPA's finance offices  where we reviewed accrued liabilities had recorded
    proper accruals for grant expenses incurred by recipients prior to year end.  Because
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    these expenses occur on a continuing basis and there are normally delays in
    requesting reimbursement, we believe based upon our analysis of average monthly
    payments, that the amounts of unrecorded liabilities at all EPA finance offices are
    likely to be material to the financial statements.

    OPAC Payments Were Not Charged To The Correct Appropriations At Year End

   :EPA reimburses other Federal Agencies for work performed on behalf of EPA via
    the U.S. Treasury's OPAC system.  These payments relate  to.work performed under
    various EPA appropriations.  In order  for EPA's disbursements to balance to
    Treasury, EPA records these OPAC payments in EFMS as prepaid adjustments under
!   ;the AC&C appropriation.  Upon confirmation that another Federal Agency  has
« -charged EPA via OPAC, Cincinnati Financial Management  Center (CFMC) forwards
''<••  a form to the project officer for approval of the payment. This completed form,
   '•when returned, identifies the interagency agreement and appropriation accounts to be
    charged.  However, we noted that these project officer approval forms may be
   .outstanding as long as 6 months before they are returned  to CFMC,

  :  We found at September 30, 1993, that  approximately S20 million of the S26 million
tji. of OPAC payments recorded as prepayments in the AC&C  appropriation related to
I  Superfund work. However, we also noted that when calculating year end accrued
.«.. liabilities, CFMC did not take into effect these OPAC payments in estimating costs
 -- .incurred but not billed on  the related interagency agreements.  As a result,  the
•
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     (4)    establish procedures to account for OPAC payments in a timely manner under
            the appropriations to which the payments apply.

     EPA's Response to Draft Report Recommendations ard Our Evaluation

     The CFO agreed  with our recommendation for requiring  supervisory review of
     supporting data and reports used to identify and record accounts payable and accrued
     liabilities. The CFO stated that FMD's year end  closing  instructions to the finance
     offices will include this requirement as well as more specific guidance for accounting
     for accounts payable and accrued liabilities.  The CFO's  corrective action plan for
     developing year end closing procedures and revising year end closing instructions to
     incorporate supervisory review requirements  indicated target dates of June  30  and
     July 31,  1994.

     The CFO also agreed with our recommendation to issue specific guidance for
     calculating and recording accounts payable and accrued liabilities for grant expenses.
     The CFO stated mat specific guidance is already included in year end closing
     instructions.  However, he indicated that this guidance will be expanded to' include
     more  detailed procedures to accurately calculate and record payables and liabilities.
     The guidance will also include supervisory review and approval requirements.  The
     CFO provided corrective action plans to contact FMOs regarding suggestions  for
     accounting for these payables and  accruals and to expand the year end instructions to
     include more specific guidance. The target dates for these corrective actions are
     June 30 and July  31, 1994.

     The CFO agreed  with our recommendation to ensure consistent application of year
     end closing instructions among finance offices for recording accounts payable  and
     accrued liabilities. The CFO stated that his staff  will conduct frequent follow-up
     communications with all finance offices to ensure consistency.  The CFO provided a
     corrective action plan  to reemphasize to ail finance offices to follow the  written year
     end instructions.  The target date for this action is September 30, 1994.

     The CFO agreed  with our recommendation to establish procedures  to account  for
     OPAC payments in a timely manner under the appropriation's to which the payments
     apply. The CFO stated that his staff will be  reviewing the use of the prepaid
     account for recording  OPAC payments at year end.   The CFO provided  a corrective
     action plan to determine if charges need  to be made using the prepaid account for.
     OPAC payments, and to expand year end instructions to provide specific guidance on
     accounting for OPAC payments.  The  target dates for these corrective actions  are
     May 30 and July  31, 1994.
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     The CFO's proposed corrective actions are generally responsive to our
     recommendations. However, we noted that the  policies and procedures for
     calculating, documenting, reviewing, approving, and recording accounts payable,
     accrued liabilities and OPAC payments are proposed to be included in the year end
     closing instructions.  We believe that the Office of Comptroller's Resources
     Management Directives System (RMDS) is the appropriate and more effective
     method to establish Agency financial policies and procedures. RMDS was designed
     to provide all such guidance in one unified system, through which comprehensive
    •.and current financial guidance would be provided to all Agency offices.

     Recommendation                                                    .

     We recommend that the CFO instruct the Comptroller to develop and establish
    •'Agency policies and procedures in RMDS for accounting for and recording accounts
    , payable, accrued liabilities and OPAC payments, including specific guidance to
     address, each  of the various types of these transactions.

   >5.  State Cost  Share Revenue Should Be Properly Recognized

     State cost share contracts are agreements between EPA and states to share in the
     costs of Superfund site cleanups at specified ratios of costs incurred.  We noted
   Xduring our test  work that EPA recorded receivables on  state cost share contracts and
     corresponding deferred revenue when these contracts were signed.  We also found
     that the deferred revenue was not reduced and recognized as earned revenue  as site
     cleanup work occurred, which entitled EPA to earn a portion of the states' cost
    .Region' 2 -began a pilot program in fiscal year  1993 to develop procedures to adjust
     the deferred revenue account and record earned revenue by cost share contract and to
     determine the amount of deferred state cost share revenue that should have been
     recognized to date.  Region 2 had determined  the site project costs incurred to date
     and percentages of project completion for each related cleanup, action. Using this
     information at Region 2 and based on the terms of the cost share contracts, we
     calculated the amount of deferred 'revenue for  each state cost share contract that
    \shouid have been recognized as earned as of September 30, 1993.  We also obtained
    -'this information at Regions 5 and 9, and performed similar calculations.

    sWe found that S35 million of deferred revenue should have been recorded as earned
     at Regions 2, 5 and 9 as of September 30, 1993, of which S8 million related to fiscal
     year 1993 and S27 million related to prior years.  EPA recorded adjustments based
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     on our test work.  However, we did not determine the amount of adjustments chat
     should be recorded at other regional finance offices.

     EPA. Actions

     EPA agreed with the recommendation in our 1992 report to develop procedures for
     calculating state cost shares to properly recognize earned revenue as cleanup services
     are performed.  The corrective action target date for reconciling and adjusting the
     deferred revenue account is April  1,  1994.  The proposed corrective actions are
    • responsive to our recommendations.  EPA management has made progress in this
     area during fiscal year 1993 through  the efforts at Region 2. Therefore, we are
     making no further recommendations at this time.  .

     6.  Grant Payment Requests Should Provide Appropriation And Account
     Information

     Grant recipients did not identify the appropriations to which grant payments under
     the U.S. Treasury's Automated  Clearing House (ACH) Payment System should be
     charged, unless the payment requests were specifically related to Superfund site
     cleanups.  EPA's Las Vegas Financial Management Center (FMC-LV) applied these
     ACH payment requests for grant expenses funded by  more than one appropriation
     using a first-in first-out (FIFO)  method,  by charging the oldest available unliquidated
     obligations; This method  may cause a misscatement of expenses during the fiscal
     year among the appropriations that provide funding under the same grant agreement.
     Further, payments on grants that were solely funded from Superfund were not
     always charged to the correct Superfund account numbers.

     We'found that the operating expenses included grant disbursements that resulted
     from charging  payments to Superfund, even though the expense or a portion thereof
     may have been for non-Superfund purposes.  Also, certain grant expenses actually
     incurred to benefit Superfund may have been excluded from the expenses because
     they were charged to another appropriation.  In addition, the grant expenses for
     Superfund  charged to incorrect account numbers could affect indirect cost rates and
     future cost recovery actions.  Although.EPA officials at FMC-LV generally agreed
     with this issue, they did not believe that the methodology being used resulted in
     material misstatements of grant expenses.

     We selected a statistical sample of Superfund disbursements that included 5
     transactions, totaling 5499,464, on multi-funded grants paid at FMC-LV.  Based on
     our analysis of the  funding percentages at the time the payments were made, we
     found that  the method used by FMC-LV resulted in 382,115, or 17.1%, of
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 •   potentially mischarged costs because the grantees did not identify the appropriations
    to which the expenses pertain. FMC-LV used a method of charging these expenses
    which may have resulted in improper charges because the method did not consider
    the work performed or the funding levels by appropriation in place at the time the
 •   payments were made.  We also found that, using the funding percentages in place as
 .  of September 30, 1993 for these same 5 multi-funded agreements, would have
 .*, resulted in $279,334, or 5.095, of potential mischarges to the Superfund
 \.: appropriation for all payments made on these grants during the fiscal year.  In
    addition, we also noted that S532,491  of grant payments were not identified to the
 {  Superfund account number charged because the ACH payment.requests did not
 "•^'.provide the account numbers for these expenses,
 *,*
 •   EPA Actions

    We recommended in our 1992 report that the Director of the Grants Administration
    'Division require grant recipients to provide grant accounting information on all ACH
    ,.pavment requests.  EPA agreed in principle with our 1992 report recommendation,
 - .-however, they stated that requiring detailed information from grantees was
 '  unnecessary and unreasonable.  As part of EPA's corrective action, the Grants
 \  Administration Division has established a Quality Action Team to explore these
  .  issues and develop options to the existing process.  The QAT has not yet established
 .  a corrective action plan or a target date for implementation. 'Because corrective
 ',•. action is still underway, we are making no further recommendations at this time.
 »
  *  	
    EPA's Response to  Draft Report and Our Evaluation
  >
 '  The CFO disagreed with  our position on the charging of multi-funded grant
    payments processed at FMC-LV. The disagreement  stems from our use  of a
  ,  !proration method to determine the potential mischarged costs to- the Superfund
  .  •appropriation for multi-funded grants in  which the grant recipients do not identify the
  !  iappropriation or account number to be charged.  EPA officials stated that a proration
    method based on the percentages of funding from each source would be no more
    accurate and  would be highly questionable as to  validity due to the frequency of
  ;  tagreement amendments.  We believe that, although the percentages may change
  1  frequently, the proration method provides a more reasonable basis for charging these
    •grant payments based upon the levels of funding provided by various EPA  sources,
    rather than the FIFO method used by FMC-LV,  which charges payments to the
    oldest available funding.

    We concur with the CFO's opinion that there is  no absolute correct or incorrect
    method of recording recipient pa-> -nents, except  requiring the recipient to identify
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     each payment at the appropriation and account number level.  However, EPA
     officials stated that requiring the recipient :o identify each payment by account
     number would be unnecessary and unreasonable.  We do not agree with this
     assessment.   We believe that requiring the recipient to identify the account numbers
     would be the best solution.  This method would require the recipient to identify the
     work performed under the grant and relate the requests for payment to the proper
     appropriation and account number.

     We also noted that in the OIG's Report of Final Audit of the Hazardous Substance
     Response Trust Fund at Las Vegas  for Fiscal Year 1982, the OIG recommended
     eliminating the FIFO method used for recording grant Letter of Credit (LOG)
     drawdowns at FMC-LV.  (The LOG system has since been replaced by the ACH
     payment system.) In response, EPA officials stated that grants with multiple account
     numbers were amended to require that account numbers be identified on all LOG
     drawdowns.  Based  on EPA's acknowledgement and response to this issue from
     1982, we believe that requiring the  recipient to identify the account numbers was
     not considered unreasonable and should have been implemented.

     The CFO also did not concur with our statement that grant expenses  for Superfund
     charged to incorrect account numbers could affect indirect cost rates and future costs
     recovery actions. EPA officials stated that the FIFO method is only  used for
     Superfund agreements that are non site-specific.  Recipients are required to identify
     account numbers for payments to site-specific projects.  EPA officials further stated
     that since site-specific Superfund payments are properly recorded, indirect cost rates
     and future cost recovery would not  be affected.

     We agree that Superfund  site-specific charges do not affect the indirect cost rates
     because these charges are direct costs. However, indirect costs, such as the non site-
     specific payments being charged using the FIFO method reported in this finding, do
     affect the indirect cost rates calculated for Superfund cost recovery.

     As we stated in the draft report, we are not making any further recommendations in
     this area since the QAT has not yet established a corrective action plan or a target
     date for implementation.  We have also agreed to mast witri EPA officials to attempt
     to resolve this issue.
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                              Superfund Trust Fund

                       Attachment 2 - Reoortable Conditions

  1.  Certain EDP Systems and Controls Need To Be Strengthened

  Some of the weaknesses that limit the effectiveness of EPA's financial management
  are related to the Integrated Financial Management System (IFMS) and its continued
  dependence on EPA's predecessor Financial Management System (FMS). EPA
  management has reported material weaknesses in its 1993 FMFIA report relating to
 . financial systems.  In addition to these material weaknesses, which are included  in
 ' the material weaknesses reported in Attachment 1, we noted the following additional.
  reportabie conditions.

  Changes to Accounts Receivable System Did Not Solve All Outstanding Problems

  During fiscal year  1993, EPA reported that corrections were made to the accounts
  receivable module  of IFMS.  Some of the changes concerned the generation and
  computation of compound interest  and the processing of installment payments.
  During our review, we noted that the solutions to both of these areas involve manual
  procedures which work around limitations of the automated system instead of
 . correcting them. EPA management explained that this was an interim measure until
 '.the-.new version of IFMS is implemented in 1994.

 ,In addition, two other deficiencies in the accounts receivable module were noted.
' The first concerns  who may override the  system interest  rate tables/data field.
  During our testing, we noted that data entry employees have the ability to override
  the stated interest rate without supervisory review and approval.  The second
  deficiency related to a similar issue regarding the accrued interest field.  The system
  correctly calculated the accrued interest.  However, once calculated, it was subject to
  manual override at the data entry level without supervisory review and approval.  In
  order to maintain effective controls, documented supervisory review and approval
  should be required prior to the override of key financial  data fields.

  Account Number Limitation

 'EPA continues to be dependent on its predecessor financial management system, '
  FMS, to interface between IFMS and several key subsystems.  This dependency will
v. continue, even after the implementation of the new IFMS upgrade, until these
  subsystems are improved or functionally replaced by additional enhancements to
  IFMS.  Because of this dependency, the current 41 character account number
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                         EPA's FY 1993 Annual Financial Statements

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     capability of IFMS, although much needed for site-specific cost accounting, cannot
     be fully utilized because FMS only has a 10-character account number capability.

     As a result of the limitation, manual work-arounds involving the project/site codes
     are needed so that the EPA has sufficient account numbers for all of its sites.  The
     10-character account number limitation of FMS is expected to cause additional
     problems for Regions 4 and 5 during fiscal year 1994.  There will not be enough
     characters in the current account numbers to relate direct and indirect costs to sites
     and projects in these regions in an automated fashion.  EPA's ability to account for
     costs at Superfund sites and projects may be adversely  impacted and could result in
     the failure to identify and recover these costs in cost recovery actions.

     EPA Actions

     EPA management has- reported in its 1993 FMFIA report that a new version of
     IFMS will provide new accounts receivable functionalities. EPA also is developing
     project cost accounting capability requirements in fiscal year 1994 and plans to
     eliminate the FMS by September 1995.

     Draft Report Recommendations

     We recommended in our draft  report that EPA's CFO:

     (1)     establish controls requiring supervisory review and approval of manual
            overrides of interest rates and accrued interest; and
     (2)     ensure that project/site codes being used because of present system limitations
            can provide project cost accounting for all regions and can be effectively
            modified to the expanded  account number in the future.

     EPA's Response to Draft Report Recommendations and Our Evaluation

     The CFO agreed with the intent of our draft report  recommendations.  The CFO
     agreed to review existing policies and procedures and the feasibility  of establishing
     controls in IFMS to prevent the use of inappropriate interest rates. The CFO
     proposed corrective action plans to conduct a review and analysis, develop
     recommendations, and select and implement recommendations for this issue.  The
     target dates for these actions are from March 31, 1995 to June 30, 1995.

     The CFO also stated that FMD has developed a procedure to continue recording
     Superfund site codes pending implementation of the IFMS account structure
     throughout IFMS systems. The CFO also indicated that ongoing projects have .
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     objectives to ensure the ability to convert to the EFMS format or access Superrund
     site numbers from the FMS format  However, the CFO stated that the capatiry for
     using the CFMS 41 character account structure would be very limited until reliance
    . on FMS is eliminated in fiscal year  1995.  The CFO provided corrective action plans
     to install capacity to use the EFMS format in all systems except FMS by October 1,
     1994.  The CFO also indicated a corrective action plan  for an IFMS  enhancement to
     provide an edit function for Superfund site/project codes by March 30, 1995.
    .Finally, the CFO provided a revised target date of October 30, 1995  for eliminating
    "EPA's dependence on the FMS.

    ;''The CFO's proposed corrective actions are responsive to our recommendations.
    , Therefore,  we are making no further recommendations at this time.  However, we
     are concerned  that the Agency's reliance on the predecessor financial system,  FMS,
     will continue into fiscal year 1996.

     2. Leases Should Be Recorded And Reported
    •i
     We identified capital and operating leases during our test work which were  not
     capitalized or disclosed in the financial statements.

     A lease is  a capital lease if it meets any one of the following classification criteria:

    •a.      The lease transfers ownership of the property to  the lessee by the end of the
          . lease term.
     b.     .The lease contains an option to purchase the leased property at a bargain
            price,
     c.      The lease term is equal to or greater than 75 percent of the estimated
            economic useful life of the leased property.
     d.      The present value of rental and other minimum lease payments equals or
            exceeds 90 percent of the fair value of the leased property.

     the amount to be recorded as an asset and a capital lease liability is  the lesser of the
     present value of the minimum lease payments or the fair value of the leased
     property.
                                                     "" ~
     When a lease does not satisfy any one of the four capitalization criteria above, the
     agreement is considered an operating lease.  An operating lease does not require that
     the minimum lease payments be capitalized. However,  future lease payments on
     operating leases, if the lease term exceeds one year, should be disclosed in  the notes
     ta the financial statements.
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     EPA's Financial Management Division has not issued guidance to financial
     management offices regarding the accounting treatment for capital versus operating
     leases.  Furthermore, EPA does not have a system in place to capture and evaluate
     all leases to support the required financial statement disclosures for both capital and
     operating leases.  We believe that EPA may have entered into odier leases, in
     addition to those identified during our tesrwork, that should be accounted for as
     capital leases.

     OMB Bulletin 93-02 requires disclosures for both operating and capital leases.
     Because of the lack of guidance and a tracking system for leases, the value of
     equipment acquired through capital leases has not been determined or reported in the
     financial statements. In addition, the required capital and operating lease disclosures
     are not presented in the financial statements.
                                                              *
     We did not perform procedures to determine if the capital or operating leases entered
     into by EPA were material.

     EPA Actions

     We recognize management's initiative in forming a QAT in March 1993 to take
     corrective action for property issues, including the recording and reporting of leases.
     Because of the ongoing QAT effort, we are noc making further recommendations in
     this report
EPA's FY 1993 Annual Financial Statement!
Page 113

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 '..




  I'',

             -
This page is  intentionally  left  blank,
Page 114                   EPA's FY 1993 Annual Financial Statements

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                          ATTACHMENT 3 - SCHEDULE OF OPEN AUDIT REPORTS
                                            AS OF SEPTEMBER 30, 1993
      Report Findings
Fiscal Year 1992 - Report
On Financial Audit •
Superfuod, LUST
and Asbestos Loan Program
         Recommendation
                                                                     Corrective Action
                               Target Date
                                                                                      Status
Financial reporting system
improvements are needed.
Redesign classification structure
elements so that IFMS will
automatically provide trial balances at
the highest level of aggregation
required for financial reporting
purposes.
Develop format of
MARS/SPUR report to
aggregate the general ledger
account balances and
enhance balances.
August 31, 1994
Ongoing
                             Continue Efforts to change (he
                             automated closing procedures to
                             retain regional account balances
                                    Submit programs to obtain
                                    beginning General Ledger
                                    account balances and convert
                                    1993 balances by SFO.
                            December 31, 1993
                            (original)
                            June 30, 1994
                            (revised)
                      Ongoing
                             Implement budgetary accounts and
                             transaction
                             codes to properly account for
                             reimbursable
                             authority.
                                    Research SGL requirements
                                    for reimbursable authority
                                    and existing EPA policy and
                                    procedures. As necessary,
                                    issue revised procedures and
                                    instructions.
                            October 15, 1994
                      Ongoing
                             Review and correct the automated
                             closing procedures.
                                    Refer to Federal Financial
                                    System User Group for
                                    action.
                            March 30, 1994
                      Ongoing
                             Evaluate the timely closing of its
                             year-end accounting records prior to
                             the US Treasury's implementation of
                             the automated Standard General
                             Ledger trial balance.
                                    Evaluate year-end closing
                                    process.
                            April 30, 1994
                      Ongoing
Properly and equipment
records needs to be
integrated with the
general ledger.
Assign transaction codes in the IFMS.
for capital property and equipment
asset purchases and issue policies and
procedures for recording these
transactions.
Develop implementation
strategy for
recommendations presented
by Quality Action Team
(QAT).
FY 1995
Ongoing
       EPA's FY 1993 Annual Financial Statements
                                                                               Page 115

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      Report Findings
Accounts payable/accrued
liabilities are not properly
recorded.
         ti *v
                           ATTACHMENT 3 - SCHEDULE OF OPEN AUDIT REPORTS
                                             AS OF SEPTEMBER 30,  1993
         Recommendation
                                                                     Corrective Action
                               Target Date
Determine the approximate amount of   Conduct review of sample of   March 31, 1994
contractor retainages being withheld     contracts.
and develop and implement
procedures to ensure the amount can
be fairly presented in the financial
statements.
                                                  Ongoing
Accounting for grant
drawdowns does not provide
required account information.
Require inclusion of grant account
information from grant recipients for
all ACH payment requests.
Determine if additional procedures
need to be developed to account for
grant drawdowns.
Establish QAT to review the
procedures, establish-
milestones, report to process
owners, and implement
changes.
To be determined
by QAT
                                                                                                                    Ongoing
Genera] EDP controls need
to be strengthened.
' Capital leases have not been
 recorded.
i          -•;.        .'•;
Implement current, comprehensive
information system policies.
standards, and procedures on
a centralized basis.
Implement Version S.Ie of
IFMS and complete
enhancements to produce
complete and accurate
reports for accounts
receivable.
                                                                                             June 1994
                      Ongoing
                             Issue policies and procedures to
                             FMOs regarding properly recording
                             and accounting for leases.
                             Require FMOS to review all current
                             leases and evaluate whether leased
                             equipment should be capitalized.
                                    Property QAT will review
                                    current policies and
                                    procedures along with
                                    the other property issues and
                                    implement procedures to
                                    record and report leases.
                            To be determined
                            by QAT
                       Ongoing
Repairs and improvements
were charged to Superfund
and LUST.
Obtain Office of General Counsel
(OGC) opinion on whether EPA had
authority during fiscal
year 1992 to use Superfund and
LUST funds for repairs and
alterations.
Fiscal Year 1991 - Report On
Financial Audit - Hazardous
Substance'Superfund
Obtain an opinion from
OGC.
October 29, 1993
(original)
April 12, 1994
(revised)
                                                                                                                    Ongoing
Accounts receivable were not
recorded in a timely manner
or in the correct fiscal year.
Ensure that financial policies and
procedures for Superfund accounts
receivable and collections are
up-to-date.
Issue revised RMDS
2550-D.
December 31,1993
(original)
Nov. 30, 1994
(revised)
                                                                                                                    Ongoing
       Page 116
             EPA's FY 1993 Annual Financial Statements

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     Report Findings
Collections were not
recorded in a
timely manner.
                         ATTACHMENT 3 - SCHEDULE OF OPEN AUDIT REPORTS
                                          AS OF SEPTEMBER 30, 1993
        Recommendation
Ensure that financial policies and
procedures for Superfund accounts
receivable and collections are
up-to-date.
                                                                 Corrective Action
Issue revised RMDS
2550-D.
                             Target Date         Status
December 31, 1993     Ongoing
(original)
November 30, 1994
(revised)
Fiscal Year 1991 - Report On
Financial Audit - Hazardous
Substance Superfund
Procedures have not been
updated since the
implementation of the
IFMS.
Ensure that the RMDS is fully
implemented and includes procedures
and requirements for recording and
supporting transactions in the
IFMS.
Issue RMDS 2530.
September 1992
(original)
December 1994
(revised)
Ongoing
       EPA's FY 1993 Annual Financial Statements
                                                                          Page 117

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                         LEONARD  G.  BIRNBAUM AND  COMPANY

                                  CERTIFIED  ?UBUC  ACCOUNTANTS

                                        WASMIMOTON OMICt

                                        tltt FftANCONIA HOAO
                                                 VA. 1»10
                                           (703) I22-TIZ2
                                         FAX: (T9J|
LEONARO & 'aiHNCAUM                                                                WASHINGTON. O.C.
ustii A. uinn                 •                                                   SUMMIT. NEW
OAVIO SAKOFS                                                                    t.os AUOS.
CAAOl A. SCHNUDIR                                                     •       .    IAN 3IEGO. CAUF08NIA

       or rut                                  '
                                 s* Report on Cornpnance^with Laws and Regulations +
                                      Suoerfund Trust Fund
          Hie Inspector General
          U.S. Environmental Protection Agency:

         •/I.     We were engaged to audit the financial statements of the Superfund Trust
         - Fund of the U.S. Environmental Protection Agency (EPA),  as of and for the year
         ..ended September 30,  1993. We have issued our report thereon dated January 28, .
         ^ 1994,-in which we disclaimed an opinion on these financial  statements.

         >2.     Compliance  with laws and regulations is the responsibility of EPA's
         ^ managemenL  As part of obtaining reasonable assurance about whether the financial
         -^statements are free of material misstatement, we tested compliance with certain
          provisions of the following laws and regulations, designated by OMB, EPA, and
         •/EPA's Office of Inspector General  (OIG), that may have a direct and material effect
          on  the financial statements:
         #
                 Budget and Accounting Procedures Act of 1950
                 Chief Financial Officers Act of 1990
                 Anti-Deficiency Act
                 Federal Managers' Financial Integrity Act of 1982
                 Prompt Payment Act
                 Debt Collection Act of 1982
                 Civil Service Reform Act
                 Fair Labor Standards Act
                 Civil Service Retirement Act
     EPA'i FY 1993 Annual FtnincuU Suieraena                                                Pige 113

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      •
      *
       Federal Employees' Compensation Act
       Federal Employees' Group Life Insurance Act of 1980
•      Federal Employees' Health Benefits Act of 1959
•      Comprehensive Environmental Response, Compensation, and Liability Act of
       1980
•      Superfund Amendments and Reauthorization Act of 1986
•      Omnibus Budget Reconciliation Act of 1991

3.   Our objective was not to provide an opinion on overall compliance with laws
and regulations. Accordingly, we do not express such an opinion.

4.   As required by OMB Bulletin 93-06, Audit Requirements for Federal rinancial
Statements, we obtained an understanding of EPA's process for identifying and
evaluating weaknesses required to be reported in accordance with the Federal
Managers' Financial Integrity Act (FMFIA). We compared the material weaknesses
reported in EPA's fiscal year 1993 FMFIA  report with the material weaknesses and
other reportable conditions reported in our report on internal control structure.  EPA
reported material weaknesses and nonconformances in the areas of rinancial systems,
contract management, accounting system-related financial management problems,
accounts receivable,  property accounting process, and accounting system interfaces in
its fiscal year 1993 FMFIA report.  The definition of a material weakness for
financial statement purposes differs from  the definition in OMB Circular A-123
(revised) Internal Control Systems, for the purposes of FMFIA.  According to OMB.
Circular A-123, a material weakness is a situation in which the designed procedures
or degree of operations compliance therewith does not provide reasonable assurance
that the objectives of internal control specified in FMFIA are being accomplished.
These objectives are: to provide  management with reasonable assurance that
obligations and costs comply with applicable law, assets are safeguarded against
waste, loss, unauthorized use and misappropriation; revenues and expenditures are
recorded and accounted for properly so that accounts and reliable financial reports
may be prepared and accountability of assets maintained; and programs are
efficiently and effectively carried out in accordance with applicable law and
management policy.  As a result of our engagement, we reported six material
weaknesses in internal controls.  To determine whether to report matters as material
weaknesses,  we used the definition of a material weakness included in OMB Bulletin
93-06.  According to the bulletin, a material weakness in the.intemal control
structure is a reportable condition in which  the design or operation of one or more of
the internal control structure elements does  not reduce to a relatively low level the
risk that errors or irregularities in amounts  that would be material in relation to the
financial statements may occur and not be detected within a timely period by
employees in the normal course of performing  their assigned functions. The
Page 119
                      EPA'i FY 1993 Annual Financial Statement*

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     following material weaknesses were reported by us but not included in EPA's
     FMFIA report

     •    not properly recording accounts payable, accrued liabilities and OP AC
          payments;
     •    not properly recognizing state cost share revenue;
     •    not requiring appropriation and account information to properly record grant
    ';.     payments; and
    ''•    not properly identifying  components of net position.

    fThe above weaknesses that we noted were not reported by EPA in its FMFIA report
     because these weaknesses are  primarily specific financial accounting .and reporting
     issues related to the financial  statements, and the weaknesses reported by EPA under
     FMFIA are broader in scope.

     5.   The results of our tests of compliance indicate that, with respect to the  items
     tested, EPA complied, in all material respects, with the provisions referred to in the
     second paragraph of this report.  With respect to items not tested, nothing came to
     our attention that caused us to believe that EPA had not complied, in all material
     respects, with those provisions.  However, we noted the  following matter which
     should be highlighted.

     Certain AEocable Costs Were Not Allocated

     General support services costs are required by EPA policy to be allocated  to
     Superfund during the  fiscal year from EPA's Abatement  Control and Compliance
     (AC&Q appropriation.  The allocations are made using cost allocation plans
     developed by EPA that are designed to distribute these support costs to the benefiting
     programs.  We found that the allocations of general support service costs reached
     budgetary ceilings during fiscal year 1993 and were discontinued at several
     allowance holders.  We did not determine the estimated amounts that would  have
     been allocated to Superfund if they had been continued.

     The Superfund Accounting Branch also prepared an overhead allocation model to
     determine the agency-wide costs that benefitted Superfund but were not allocated
     against its budgetary resources.  This allocation amounted to $22,257,000, which
     was recorded for financial statement purposes only, as both a revenue and expense of
     Superfund.  EPA management believes that any under-allocation of costs due to
     ceiling limitation would be included in the 522,257,000 amount.
EPA'* FY 1993 Annual Financial Statement!                                                  P*ge 120

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    We have previously recommended that EPA management obtain a written opinion
    from its Office of General Counsel (OGQ on the legal basis for charging Stiperfund
    administrative expenses to Agency-wide appropriations.  If the OGC determines that
    EPA's practice of charging the AC&C appropriation for Superfund administrative
    expenses after the Superfund administrative ceilings were reached was improper, the
    OGC should provide guidance on appropriate corrective  action. EPA requested an
    OGC opinion in fiscal year 1992, but has not yet received a response.  We are
    making no further recommendation at this time.

    6.   This report is intended for the information of Congress, OMB, and EPA.  This
    restriction is not intended to limit (he distribution of diis report, which  is a matter of
    public record.
                                     i \^0-nvj
    LEONARD G. BIRNBAUM & COMPANY
    Alexandria, Virginia
    January 28, 1994
                                            A-a.
P»gel21
EPA'f FY 1993.Annul Financial Statements

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                          LEONARD  G.  BIRNBAUM  AND COMPANY

                                   CERTIFIED  PUBLIC ACCOUNTANTS

                                          WASHINGTON OMICI

                                         tltS MAMCONIA flOAO

                                        • ALEXANDRIA. VA. 21310
                                            (TOD t22-ri22

                                          FAX: (703) I22-I2M
USONAHO a 81KNIAUM
LffSUi A. UIM*
OAVIO SAKQFS  "
CA«ot A,
                                                        WASHINGTON. 3.C.
                                                       SUMMIT. NEW JESSSY
                                                       LOS ALTOS. CAL!*0«NIA
                                                       SAM OiEGO. CALIFORNIA
       OP TMI
AMERICAN INSTITUTI
          «V
         Auditors* Report on Financial Statements -
Leaking Underground Storage Tank Trust Fund
     The .Inspector General
     U.S. Environmental Protection Agency:
      1. '  ^ We bave auoUted the statements of financial position of the Leaking Underground Storage
      Tank1 (LUST) Trust Fund of the U.S. Environmental Protection Agency (EPA) as of September
      30,  1993 and 1992, and the related  statements of operations and changes in net position, cash
      flows, and budget and actual  expenses for the years then ended.  These statements are the
      responsibility of EPA's management.  Our responsibility  is to express  an opinion on these
      statements based on our audits.

      Scope

      2.     Except as discussed in paragraphs 4, 7 and 8 of this report, we conducted our audits in
      accordance with generally accepted auditing standards; Government Auditing Standards, issued
      by the Comptroller General of the United States; and Office of Management and Budget (OMB)
      Bulletin 93-06, Audit Requirements for Federal Financial Statements.  Those standards require
      that we plan and perform the audits  to obtain reasonable assurance about  whether the financial
      statements are free of material misstatement.  An audit includes examining, on a test  basis,
      evidence supporting the amounts and disclosures in the financial statements.   An audit also
     •includes assessing the accounting principles used and significant estimates made by management,
      as well as evaluating the overall financial statement presentation.  We believe that our  audits
      provide a reasonable basis for  our opinion.
      EPA's FY 1993 Annual FtnuieUl Statements
                                                             Page 123

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 Basis of Accounting

 3.     As described in Note I, these financial statements were prepared in conformity with the
 applicable accounting practices prescribed or permitted by OMB Bulletin 93-02 and applicable
 provisions of OMB Bulletin 94-01,  Form and Content of Agency Financial Statements, which
 is a comprehensive basis of accounting other than generally accepted accounting principles.

 Planned Exclusion

 4.     Prior to October 1,  1991, EPA was not required to  prepare financial statements for the
 LUST Trust Fund  in conformance  with OMB Bulletin 93-02, Form and Content of Agency
 financial Statements, nor was EPA required to have such statements audited. Accordingly, the
 statement of financial position as of September 30, 1991, has not been audited.  Statement of
 financial position amounts as of September 30, 1991, enter into the determination of results of
 operations and changes in net position, cash flows, and budget and actual expenses for the year
 ended  September 30, 1992.   Similarly,  our qualified opinion on  the  September 30,  1992
 statement of financial position affected our ability to report on the fiscal year 1993 results of
 operations  and  changes in  net  position, cash  flows,  and  budget and  actual  expenses.
 Adjustments, if any, .to balances reflected in the statements of financial position as of September
 30, 1992 and 1991, would affect the statements of operations  and changes in net position, cash
 flows, and budget and actual expenses for the years ended  September 30, 1993 and 1992.

 5.     In  our report  on the fiscal  year 1992 financial statements,  dated April 7, 1993, we
 reported that we were unable to audit the balance of amounts held  by  the U.S. Treasury for
 future appropriations because that balance is maintained and controlled by the U.S. Treasury and
 the audit of such amounts was not included in the scope of our audit  As described in Note 14
 to the financial  statements, EPA changed  its method of reporting  amounts held by  the U.S.
 Treasury  for  future  appropriations and  no  longer reports  these  amounts  in its  financial
 statements.  Accordingly,  the 1992 financial statements have been restated and our present
 planned exclusions  on the 1992 financial statements, as presented herein, differ from those in
 our previous report

 6.     In  our report  on the fiscal  year 1992 financial statements,  dated April 7, 1993, we
 reported that  we were  unable to  audit the administrative  costs  funded  from  other  EPA
 appropriations because the audit of these appropriations for allowability and allocabiliry of such
, costs was  not within  the scope of that audit  We  have since determined this amount to be
 immaterial.  Accordingly, our present planned exclusions on  the 1992 financial statements, as
 presented herein, differ from those in our previous report
                             EPA's FY 1993 Annual Financial Sutemena

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  Scope Limitations and Qualifications

  7.     We were  unable to  audit accounts  payable,  non-federal,  staled at $1,749,000 and
  $1,503,000 as  of September 30, 1993 and 1992, respectively, because accruals for grant
  expenses of grant recipients who use the ACH payment system were not made. We were unable
  to determine the amounts that should have been recorded for these liabilities. Adjustment, if
  any, for accrued liabilities to grant recipients would affect all of the financial statements for the
  yean ended September 30, 1993 and 1992.

  8. '    We were unable to audit net position,  stated  at 592,515,000 and 585,923,000 as of
  September 30, 1993 and 1992, respectively,  and the changes in net position for the years then
  ended because (a) EPA officials were unable to confirm unliquidated obligation balances, a
  component of net position, and we were unable to perform alternative procedures, and (b) EPA
  did  not maintain  sufficient  accounting records  to provide  the net position disclosures in
  conformance with OMB Bulletin 93-02, Form and Content of Agency Financial Statements.
  Adjustments,  if any,  to the components of net  position  would  affect all of  the financial
  statements for the years ended September 30, 1993 and 1992.
     ;'ti
  Disclaimer of Opinion on Statements of Operations and Changes in Net Position, Cash Flows,
  and Budget and Actual Expenses

  9. >',;   Because of the matters discussed in paragraphs 4, 7 and 8 of this report, the scope of our
A work was not sufficient to enable us to express,  and we do not express, an opinion on  the
 • statements of operations and changes in net position, cash flows, and budget and actual expenses
- for the years, ended September 30, 1993 and 1992.
    -• '••  )   ;'  ••
  Opinion on. Statements of Financial Position

  10.    In our opinion, except for the effects of such adjustments, if any,  that might have been
  determined necessary  had we been able to audit accounts  payable, non-federal and net position
  as described 'in paragraphs 7 and 8 of this  report, the statements  of financial position of the
  LUST Trust Fund present fairly, in all material respects, the financial  position of the U.S.
  Environmental Protection Agency's LUST Trust Fund as of September 30, 1993 and 1992, on
  the basis of accounting described in  Note  1 to the financial statements.

 ' Supplementary Information

  11.    Our audits were made for the purpose of forming an opinion on the financial statements
  referred to in the first paragraph of this report, taken as a whole.  The  financial information
  presented in Management's Overview of EPA and Overview of Trust Funds, Revolving Funds and
  Commercial Activities is not a required pan of the financial statements but is supplementary
  EPA's FY 1993 Annual Financial Suietncau                                                 P*8« I24

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information required by OMB Bulletin 93-02, Form and Content of Agency Financial Statements.
We have considered whether this  information is  materially inconsistent with the financial
statements.  Such information has not been subjected to the auditing procedures applied in the
audits of the financial statements and, accordingly, we express no  opinion on it.

Distribution

12.    This report is intended for the information of Congress, OMB, and EPA. This restriction
is not intended to limit the distribution of this report,  which is a matter of public record.
                 . VjAs^Jr*^^*" Cerrr
LEONARD G. BIRNBAUM & COMPANY
Alexandria, Virginia
January 28, 1994
PtgelH
EPA'i FY 1993 Annual Kntnciil Sutcmenti

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                         LEONARD  G.  BIRNBAUM  AWD COMPANY

                                  CERTIFIED  PUBLIC ACCOUNTANTS

                                         WASHINGTON OWCI

                                        1213 MANCONIA SOAO

                                       * ALEXAMQRIA. VA. 22310



                                           (7031 »«-'•«

                                          FAX: (T03) m-Uit

UOMAKO'i «. iWNBAOM                                                                 WASHINGTON. 0,C.
USUE A,! I.IIMH       "                                                              SUMMIT. N6W
DAVID SAKOFS                                                                     "-OS *l-TOi CALIFORNIA
CAHOfc A. SCMMllOf*                                                     ' .           *** OIEO°- CAUfOBHIA
MCMIfftS Of THf
AMINICAN INSTITUTI
    Of
                        Independent Auditors* Report on Internal Control
                        ^
                          Leaking Underground Storage Tank Trust Fund
     The Inspector General
     U.S. Environmental Protection Agency:
      1.  '   We have audited the financial statements of the Taking Underground Storage Tank
      (LUST) Trust Fund of the U.S. Environmental Protection Agency (EPA), as of and for the year
      ended September 30, 1993.  We have issued our report thereon dated January 28,  1994, in
      which we disclaimed an opinion on the statements of operations and changes in net position, cash
      flows, and budget and actual expenses and qualified our opinion on the statement of financial
      position.

      2.     Except as discussed  in  paragraph 3 below  and in paragraphs 4, 7  and  8 of our
      Independent Auditors' Report on Financial Statements, we conducted our audit in accordance
      with  generally  accepted auditing standards;  Government Auditing Standards,  issued by.  the
      Comptroller General of the United States; and Office of Management  and Budget (OMB)
      Bulletin 93-06, Audit Requirements for Federal Financial Statements.  Those standards require
      that we plan and perform the audits to obtain reasonable assurance about whether the financial
      statements are free of material misstatemenL

      3.     Performance  measures present  the  financial  and program  accomplishments of  the
      reporting entity's activities.  We did not review  the  data that support reported performance
      measures  or the  internal control structure, policies and procedures designed to  ensure  the
      existence and completeness of such information, as required by OMB Bulletin 93-06 because this
      was a planned exclusion from the scope of our work due to decisions made by  the OIG.
      EPA'* FY 1993 Annual FintnciiJ Stauanenu                                                P»*c l26

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4.     In planning and performing  our audit for the year ended September 30, 1993, we
considered EPA's  internal control structure in order to determine our auditing procedures for
the purpose of expressing an opinion on the financial statements; and to  determine whether the
internal  control  structure meets the objectives identified in  the following paragraph.   This
consideration included obtaining an understanding of the internal control policies and procedures
and assessing the level of control risk relevant to all  significant cycles, classes of transactions,
or account balances.

5.     The management of EPA is responsible for establishing and .maintaining an internal
control structure.  In  fulfilling this responsibility, estimates and judgments by management are
required to assess  the expected benefits and related costs of internal control structure policies
and procedures.  The  objectives of an internal control structure are to provide management with
reasonable, but not absolute, assurance that transactions, including obligations and costs, are
executed in compliance with laws and regulations that could have a direct and material effect on
the financial statements,  and any other laws' and regulations that OMB, EPA management, or
EPA's OIG have identified as being significant and for which compliance  can be objectively
measured and evaluated.  The objectives of an internal control structure are  also to provide
management with reasonable, but not absolute, assurance that funds, property, and other assets
are safeguarded  against loss from unauthorized use or disposition; and  transactions applicable
to EPA operations  are properly recorded and accounted for to permit the preparation of reliable
financial statements and to maintain accountability over assets, in accordance with the accounting
principles described in Note 1 to the financial statements.  Because of inherent limitations in any
internal control structure, errors or irregularities may nevertheless occur and  not be detected.
Also, projection of any evaluation of the  structure to future periods is  subject to the risk that
procedures  may  become inadequate because of changes in  conditions or that the effectiveness
of the design and operation of policies and procedures may deteriorate.

6.     For the purpose of this report, we have classified the significant internal control structure
policies and procedures in the following categories:

       General accounting  and financial reporting
       Receivables and receipts
       Accounts payable and accrued liabilities
       Fund balance
       Obligations
       Disbursements and operating expenses
 Age 127
EPA's FY 1993 Annual Fmuiei*! Stitemenu

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 7.     For all  of the internal control structure categories  listed above,  we obtained an
 understanding of the design of relevant policies and procedures, determined whether they have
 been placed in operation, assessed control risk, and performed tests of the control procedures.

 8.     We noted certain matters involving the internal control structure and its operation that
 we consider to be material weaknesses and reportable conditions under standards established by
 the American Institute of Certified Public Accountants and OMB Bulletin 93-06.
       •i
      £
 9.    * A material weakness is a reportable condition in which the design or operation of the
 specific internal control structure elements does not reduce to a relatively low level the risk that
 errors or irregularities in amounts that would be material in relation to the financial statements
 being audited may occur and not be detected within a timely period by employees in the normal
 course of performing their assigned functions. Reportable conditions involve matters coming
 to our attention relating to significant deficiencies in the design or operation of the internal-
 control structure that, in our judgment,  could adversely  affect the entity's ability to ensure that
 obligations and costs are in compliance  with applicable laws;  funds, property, and other assets
 are safeguarded against unauthorized use or disposition;  and transactions applicable to  EPA
 operations are properly recorded to permit the preparation of reliable financial statements in
 accordance with accounting principles described in Note 1 to the financial statements.

 10.  ,• Our consideration of the internal control structure would not necessarily  disclose all
 matters in the internal control structure that might be reportable  conditions and, accordingly,
 would not necessarily disclose all reportable conditions  that are also considered  to be material
 weaknesses.  Those conditions that we  consider to be both reportable conditions and material
 weaknesses are:

, General* Ledger Accounts Do Not Correctly Report Net Position Components

 We found that HPA's general ledger accounts do not correctly disclose the components of net
 position  because the automated year end closing process in the CFMS is incorrect. This is
 evidenced by the fact that certain account balances that should equal other accounts do not For
 example, net property in the proprietary accounts does not equal  invested capital,  cumulative
 results do not equal the balance of accounts  related to receipts  to  be returned to the  U.S.
 Treasury.  Also, beginning net position plus current appropriations less appropriations expensed
 and the net change in invested capital and unfunded activities do not equal ending net position.
 As a result, EPA financial management personnel spent significant time and resources to develop
 financial information for the components of  net position for footnote disclosure. -Manual
 adjustments were recorded for financial statement purposes.  However, the components of net
 position as required by OMB Bulletin 93-02 still could not be properly disclosed. The bulletin
  EPA't FY 1993 Annual Financial Statement*                                                  P»gC 128

-------
requires disclosure of the following components of net position: unexpended appropriations
available, unexpended appropriations unavailable, undelivered orders,  cumulative  results of
operations, and invested capital.

EPA Actions

In our  1992 report, we recommended that EPA review and correct the automated year end
closing procedures.  EPA's corrective action  for this issue is scheduled  to begin in fiscal year
1994.  Because of this ongoing effort, we are making no further recommendations at this time.

EPA management has recognized the IFMS  as a material weakness in  its FMFIA  report  for
1993.   The  weakness resulted from incomplete users manuals and system documentation,
incomplete interfaces, and inadequate financial management reports.  EPA is in the process of
upgrading to a new release of the IFMS,  scheduled for implementation in fiscal year 1994,
which EPA's management believe will resolve many of these deficiencies'.

Accrued Liabilities For Croat Expenses Were Not Recorded

EPA awards grants to state governmental units and other entities for removal of waste associated
with leaking underground storage tanks. The grantees oversee the removal work and request
reimbursement from EPA through the Automated Clearing House (ACS) Payment System or
using other drawdown documents.  EPA's  Fiscal  Year  1993 fear-end  Closing Procedures
require each regional office to record an accrued liability for the estimated amount of grant
drawdowns payable through September 30,1993, where the grantee has performed the work but
not yet submitted the grant drawdown documents to EPA.  The procedures  state that these
accrued liabilities should be based on historical data and past experience.

At Region 2, accrued liabilities were not recorded at year end for grant expenses that were being
reimbursed under the ACH payment system.  We noted that Region 2's  average monthly ACH
payments during  1993 amounted to $922,576. These payments are typically made for expenses
incurred in previous months. However, due to significant fluctuations in  the timing and amount
of various grantees' drawdowns, we could not determine the costs  incurred for which an accrual
should have been recorded.

At Region 5, we also noted that no accrued liabilities were recorded  at  year end for grant
expenses that were being reimbursed under the ACH payment system.  We noted that Region
5's average monthly ACH payments during fiscal year 1993 were 51,164,022. These payments
are typically made for expenses incurred in previous months. However, we could not determine
 Pftgel29
EPA'i FY 1993 Annual Fmtnciil Stitcmenti

-------
 the accrual that should have been recorded for estimated costs incurred before year end.

 At Region 9, accrued liabilities for grant expenses (except ACH grants) were recorded for one-
 twelfth of the unliquidated obligation balance as of September 30, 1993.  This resulted in an
 estimated accrual of 51,066,121. This methodology is improper because it does not represent
 a  reasonable estimate of expenses incurred  at year end.   Such expenses are  not necessarily
 incurred proportionately over a given period of time and may have no direct relationship with
 the amounts of outstanding obligations.   However, we were unable to  determine the actual
 amount that should have been accrued by Region 9 for non-ACH grants.

 We also found  that no accrued liabilities were recorded at Region 9 for grant expenses of
 recipients under the ACH payment system. We noted that the average monthly  payments made
 to recipients during 1993 was 5740,235.  These payments are typically "made for expenses
 incurred in previous months.  However, we could not determine the accrual that should have
 been recorded for estimated costs incurred before year end.

 At Las Vegas Financial Management Center (FMC-LV), no accrued liabilities were recorded
 for Migrant expenses of recipients under the  ACH payment system.   According to FMC-LV
 officials, the year end closing procedures  stated that no liability should be accrued where there
 was-no evidence that goods or services were delivered or performed.  We noted  that FMC-LVs
 average monthly ACH payments were 537,419. These payments are typically made for expenses
 incurred in previous months.  However, we could not determine the accrual that should have
 been recorded for estimated costs incurred before year end.
     concluded that there were inconsistencies and failures among finance offices to record
 accrued liabilities for costs incurred by grantees prior to year end.  These expenses occur on a
 .continuing basis and there are normally delays in requesting reimbursement.  However, we were
••unable to determine the amounts of such adjustments that would be necessary to properly record
 the accrued liabilities as of September 30, 1993.  Based upon our analysis of average monthly
 ACH payments, we believe the unrecorded amounts are likely to be material to the financial
 statements.
             • ~ -^

 Draft Report' Recommendation

 We recommended on our draft report that the CFO establish specific policies and procedures for
 recording accrued liabilities  for grant expenses  for all -grant recipients and ensure that the
 regional offices consistently comply with such procedures.
 EPA'* FY 1993 Annual Financial Statement*
Page 130

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EPA's Response to Draft Repon Recommendation and Our Evaluation

The CFO  agreed with our recommendation to issue  specific  guidance  for calculating  and
recording accrued liabilities for grant expenses.   The CFO  stated  that specific  guidance  is
already included in year end closing instructions. However,  he indicated that this guidance will
be  expanded to include more  detailed procedures to  accurately  calculate  and record these
liabilities.  The CFO provided  corrective action plans  to expand the year end  instructions  to
include more specific guidance and include payables and accruals as an agenda item in weekly
closeout meetings to emphasize to afl finance offices to follow the written year end instructions.
The target dates for  these corrective actions are August 1 and  September 30, 199*.

The CFO's proposed corrective actions are  generally responsive  to  our  recommendation.
However,  we noted that the policies and procedures  for calculating and recording accrued
liabilities are proposed to be included in the year end closing instructions.  We believe that the
Office of Comptroller's Resources Management Directives Systems (RMDS) is the appropriate
and more effective method  to establish Agency financial policies and procedures.  RMDS was
designed to provide all such guidance in one unified system, through which comprehensive and
current financial guidance would be provided to all EPA offices.

Recommendation

We recommend that the CFO instruct the Comptroller to develop and establish  policies and
procedures in RMDS for accounting for and recording accrued  liabilities for grant expenses with
specific guidance to  address calculating and documenting methodologies for these transactions.

11.   We also noted other less significant matters involving the internal control structure and
its  operation that we will report to the management of EPA in a separate management letter.

12.   This report is intended for the information of Congress,  OMB,  and EPA. This restriction
is not intended to limit the  distribution of this report, which is a matter of public  record.
LEONARD G. BIRNBAUM & COMPANY
Alexandria, Virginia
January 28, 1994
P»ge 131
EPA't FY 1993 Annual HnmncUl Statements

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                         LEONARD  G.  BIRiNBAUM  AND COMPANY

                                  CERTIFIED PUBLIC ACCOUNTANTS

                                         WASHINGTON OMICf
                                        91H MANCONIA 10*0
                                        ALlXAHtmiA. VA. 12310
       «                                   (703) 12
       !                                 PAX: (7P3) »»••»•
LIOMAKB a •INNftAUM                 .                                                WASHINGTON. O.C
LESUE A, LglPlfl                                                                     SUMMIT. NEW JERSEY
OAVIO SAKOPS                                                                      W AI-TOS.
CAPOi. A. SCMNflOER                                                                  «" OliSO.

MEMBERS OP THf                                                       .   •
AMERICAN  iMsrrruTf
    OP CM'»

            Independent Auditors* Report on Compliance with Laws and Regulations -

                         Leaking Underground Storage Tank Trust Fund
     The Inspector General
     U.S. Environmental Protection Agency:

     1.     We have audited die financial statements of the Leaking Underground Storage Tank
     (LUST) Trust Fund of the U.S. Environmental Protection Agency (EPA), as of and for the year'
     ended September 30,  1993.  We have issued our report thereon dated January 28, 1994, in
     which we disclaimed an opinion on the statements of operations and changes in net position, cash
     flows, and budget and actual expenses  and qualified our opinion on the statement of financial
     position.

     2.     Except as  discussed in paragraphs 4, 7 and 8 of our Independent Auditors'  Report on
     Financial Statements, we conducted our audit in accordance with  generally accepted auditing
     standards; Government Auditing Standards, issued by the Comptroller General of  the United
     States; and Office of Management and  Budget Bulletin 93-06, Audit Requirements for Federal
     financial Statements.   Those standards require that we plan and perform the audit to obtain
     reasonable assurance about whether the financial statements  are free of material misstatemem.

     3.     Compliance with laws and regulations is the responsibility of EPA's management. As
     part of obtaining reasonable assurance about whether the financial statements are free of material
     misstatements,  we  tested compliance with  certain  provisions of the following laws  and
     regulations, designated by OMB, EPA, and EPA's Office of Inspector General, that may have
     a direct and material effect on the financial statements:
      EPA'i FY1993 Annual Financial Sutemeau                          -         '              iP«ge 132

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or more of the internal control structure elements does not reduce to a relatively low level the
risk that errors or irregularities in amounts that would be material in  relation to the financial
statements may occur and not be detected within a timely period by employees in the normal
course of performing their assigned functions. The following material weaknesses were reported
by us but not included in EPA's FMFIA report:

•      not properly recording accrued liabilities for grant expenses; and
•      not properly identifying components of net position.

The above weaknesses that we noted were not reported by EPA in its FMFIA report because
these weaknesses are primarily specific financial accounting and reporting issues related to the
financial statements, and the weaknesses reported by EPA under FMFIA are broader in scope.

6.      We considered these matters in forming our opinion on whether the LUST Trust Fund's
1993 statement of financial position is presented fairly, in all material respects, in conformity
with the applicable accounting provisions described in Note 1 to the financial statements, and
this  report does not affect our report dated January 28,  1994 on those  statements.

7.     The results of our tests of compliance indicate that, with respect to the items tested, the
EPA complied, in all material respects, with the provisions referred to in the third paragraph
of this report, applicable to the LUST Trust Fund, and with respect to items not tested, nothing
came to our attention to cause us to believe that EPA had not complied, in all material respects,
with those provisions.

8.     This  report is  intended for the information  of Congress, OMB,  and EPA.   This
restriction  is not intended to limit the distribution  of this report, which is a matter of public
record.
LEONARD G. BIRNBAUM & COMPANY
Alexandria, Virginia
January 28, 1994
 EJPA'i FY 1993 Annual Financial Statement!
Pige 134

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         Budget and Accounting Procedures Act of 1950
         Chief Financial Officers Act of 1990
         Anti-Deficiency Act
         Federal Managers' Financial Integrity Act of 1982
         Prompt Payment Act
         Debt Collection Act of 1982
         Civil Service Reform Act
         Fair Labor Standards Act
      I   Civil Service Retirement Act
     • -;   Federal Employees' Compensation Act
         Federal Employees' Group life Insurance Act of 1980
      «.   Federal Employees' Health Benefits Act of 1959
     >    Resource Conservation and Recovery Acts of 1976 and 1984
         Superfund  Amendments and  Reauthoiization Act of 1986

  4.     Our objective was  not to provide an opinion on overall  compliance with laws and
  regulations.  Accordingly, we do not express such an opinion.

  5.     As required by  OMB Bulletin  93-06,  Audit  Requirements for Federal Financial
  Statements, we obtained an understanding of EPA's process for identifying and
  evaluating weaknesses  required to  be reported  in  accordance  with the Federal  Managers'
  Financial Integrity Act (FMFIA).  We compared die material weaknesses reported in EPA's
  fiscal year 1993 FMFIA report with the material weaknesses reported in our report on internal
  control structure.   EPA reported material  weaknesses  and nonconformances in its financial
  systems, accounting system-related  financial management problems, and accounting system
  interfaces in its fiscal year 1993 FMFIA report.  The definition of a material weakness for
.  financial statement purposes differs from  the definition in OMB Circular  A-123  (revised)
•  Internal Control Systems,  for the purposes of FMFIA.  According to OMB Circular A-123, a
  material  weakness is a situation in which  the designed procedures or degree of operations
.  compliance therewith does not  provide reasonable  assurance that the  objectives  of internal
•  control specified  in  FMFIA are being accomplished.   Thase objectives  are:  to provide
  management with  reasonable assurance that obligations and costs comply with applicable law,
  asyfs are safeguarded against waste, loss, unauthorized use and misappropriation; revenues and
''  expenditures are recorded  and accounted for properly so that accounts and reliable financial
  reports may be prepared and accountability of assets maintained; and programs are efficiently
  and effectively carried out in accordance with applicable Jaw and management policy.  As a
 .result  of  our engagement, we reported  two material weaknesses in  internal controls.  To
  determine whether to report marten as material weaknesses, we used the definition of a material
  weakness included in OMB Bulletin 93-06. According to the bulletin,  a material weakness in
  the internal control structure is a reportable condition in which the design or operation of one
   P»gi»133
EPA'* FY 1993 Annual Financial Statements

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                              This page is intentionally left blank".
P*gel35
EPA'* FY 1993 Annul Financial Sutenuaui

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                          LEONARD  G.  BIRNBAUM  AND COMPANY

                                   CERTIFIED  PUBLIC  ACCOUNTANTS
                                         WASHINGTON OMtCC
                                         •3IS FHAMCONIA ROAO
                                         ALCXANQfllA, VA. 22310


           , •;                                (709) m-rm
        •    •    •                          »A«: (70S) f22-«lS6
       &  MMIAUM                                                                   WASHINGTON. 0 C.
     A, USlWft                                                                     SUMMIT. *EW JERSEY
DAVID SAKOFS ' v                                                                     LOS ALTOS. CALIFORNIA
CAROL A, SCWNiibfS                                                                   SAM DIEGO.

MEMBERS OP TMf                                            .               '     ' '
AMERICAN INSTITUTI        fa
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Basis of Accounting

3.     As described in Note 1, these financial statements were prepared in conformity with the
applicable accounting practices prescribed or permitted by OMB Bulletin 93-02 and applicable
provisions of OMB. Bulletin 94-01, Form and Content of Agency Financial Statements, which
is a comprehensive basis of accounting other than generally accepted accounting principles.

Planned Exclusion

4.     Prior to October 1, 1991, EPA was not required to prepare financial statements for the
Asbestos Loan Program in conformance with OMB Bulletin 93-02, Form and Content of Agency
Financial Statements, nor was EPA required to have such statements audited. Accordingly, the
statement of financial position as of September 30, 1991, has not been audited.  Statement of
financial position amounts as of September 30, 1991, enter into the determination of results of
operations and changes in net position, cash flows, and budget and actual expenses for the year
ended  September 30, 1992.   Similarly, our qualified opinion on  the  September 30, 1992
statement of financial position  affected our ability to report on the fiscal year 1993 results of
operations and  changes  in net position, cash  flows,  and  budget and  actual  expenses.
Adjustments, if any, to balances reflected in the statements of financial position as of September
30, 1992 and 1991,  would affect the statements of operations and changes in net position, cash
flows, and budget and actual expenses for the yean ended September 30, 1993 and 1992.

Scope  Limitation and Qualification

5.     We were unable to audit net position, stated at 563,216,000 and 549,224,000, as of
September 30, 1993 and 1992, respectively, and the changes in net position for the years then
ended  because EPA did not maintain sufficient accounting records  to provide  the net position
disclosures in conformance with OMB Bulletin 93-02, Form and Content of Agency Financial
Statements.   Adjustments, if any,  to the components of net position would affect all of the
financial statements  for the years ended September 30, 1993 and  1992.

Disclaimer of Opinion on Statements of Operations and Changes in Net Position, Cash Flows,
and Budget and Actual Expenses

6.     Because of the matters discussed in paragraphs 4 and 5 of this report, the scope of our
work was not sufficient to enable us to express, and we do not express, an opinion on the
statements of operations and changes in net position, cash flows, and budget and actual expenses
for the years ended September 30,  1993 and  1992.
 Page 137
EPA'i FY 1993 Annual Financial Statements

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 Opinion on Statements of Financial Position

 7.     In our opinion, except for the effects of such adjustments, if any, that might have been
 determined necessary had we been able to audit net position, as described in paragraph 5 of this
 report, the statements of financial position of the Asbestos Loan Program as of September 30,
 1993 and  1992, present fairly,- in all material  respects,  the financial position of the U. S.
 Environmental Protection Agency's Asbestos Loan Program as of September 30,1993 and 1992,
 on the basis of accounting described in Note 1 to the financial statements.
  i   \                                                       .                       •
 8.     As discussed  in Note 14 to the financial statements, EPA  has changed its method of
 accounting for pre-Credit Reform loan balances, to comply with the Credit Reform Act of 1990.

 Supplementary Information

 9,     Our audits were made for the purpose of forming an opinion on the financial statements
 referred to in the first paragraph of this report, taken as a whole. The financial  information
presented in Management's Overview of EPA and Overview ofTntst Funds. Revolving Funds and
 Commercial Activities is not a required  part of the financial statements but is supplementary
information required by OMB Bulletin 93-02, Form and Content of Agency Financial Statements.
We have considered whether this information is  materially inconsistent with the financial
 statements.  Such information has not been  subjected to the auditing procedures applied in the
audits of the financial statements and, accordingly, we express no opinion on it.
    >
    _*
Distribution

 10.    This report is intended for the information of Congress, OMB, and EPA. This restriction
is hot intended to limit the distribution of this report, which is a matter of public record.
LEONARD G. BffiNBAUM & COMPANY
Alexandria, Virginia
January 23, 1994
 EPA's FY 1993 Annum] Fuuncjil Submenu
Psge 138


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                             This page is intentionally left blank.
Page 139                        EPA'j FY 1993 Annual Financial Sutemenu

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                          LEONARD  G.  BIRNBAUM AND COMPANY
                                   CERTIFIED  PUBLIC  ACCOUNTANTS
                                         WASHINGTON OFFICE
                                         •ZIS FftANCONIA HOAO
                                         ALEXANDRIA, v*. 22310
                                            (T031 »J
                                          FAI: (7031 9Z2-1Z3I
LEOMAftQ 8.  9WNBAUM                                                                  WASHINGTON. C.C.
L£SUC A. L£JF6f»                                                                  '   SUMMIT. NEW JERSEY
OAVIO SAKOFI                                                          .            LOS ALTOS. CALIFORNIA
CAMOL A, SCKNIIOCR                                                                  SAN OIESO. CALIFORNIA

MEMBERS OF TWf
AMERICAN INSTITUTE
    or WA-S

            Indeoendent Auditors' Reoort on Internal Control • Asbestos Loan Proeram •
     The Inspector General
     U.S. Environmental Protection Agency:
       ,?••:
      l..i'   We have audited the financial statements of the Asbestos Loan Program of the U.S.
      Environmental Protection Agency (EPA), as of and for the year ended September 30, 1993. We
      have issued our report thereon dated January -28, 1994, in which we disclaimed an opinion on
   \  the statements of operations and changes in net position, cash flows, and budget and actual
    * .expenses and qualified our opinion on the statement of financial position.

   '  2.'-   "!. Except as discussed in paragraph 3 below and in paragraphs 4 and 5 of our Independent
      Auditors' Report on Financial Statements, we conducted our audit in accordance with generally
      accepted auditing standards; Government Auditing Standards, issued by the Comptroller General             ^
      of the United States; and Office of Management and Budget (OMB) Bulletin 93-06, Audit
      Requirement for Federal Financial Statements.  Those standards require that we plan and
      perform the audits to obtain reasonable assurance about whether the financial statements are free
      of material misstatement.

      3.     Performance  measures present  the financial  and program accomplishments of  the
      reporting entity's activities.   We did not review the  data that support reported performance
      measures or  the  internal control structure, policies  and  procedures  designed to ensure  the
      existence and completeness of such information, as required by OMB Bulletin 93-06, because
      this was a planned exclusion from the scope of our work due to decisions made by the OIG.
      EPA's FV 1993 Annual Financial Statements                                                  Page 140

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4.     In planning and performing our  audit for the year ended  September 30,  1993, we
considered EPA's  internal control structure in order  to determine our auditing procedures for
the purpose of expressing an opinion on the financial statements; and to determine whether the
internal  control  structure  meets the objectives identified in  the  following  paragraph.   This
conside:-ation included obtaining an understanding of the internal control policies and procedures
and assessing the level of control risk relevant to all significant cycles, classes of transactions,
or account balances.

5.     The management of EPA is responsible for  establishing  arid maintaining  an internal
control structure.  In fulfilling this responsibility, estimates and judgments by management are
required to assess  the expected benefits and related costs of internal control structure policies
and procedures.  The objectives of an internal control structure are to provide management with
reasonable, but not absolute,  assurance that  transactions, including obligations and costs, are
executed in compliance with laws and regulations that could have a direct and material effect on
the financial statements, and any other laws and regulations that OMB,  EPA management, or
EPA's OIG have identified as being significant and  for which compliance can be objectively
measured and evaluated.  The objectives of  an internal control structure are also to provide
management with reasonable, but not absolute, assurance that funds, property, and other assets
are safeguarded  against loss from unauthorized use or disposition; and transactions applicable
to EPA operations  are properly recorded and accounted for to permit the preparation of reliable
financial statements and to maintain accountability over assets, in accordance with the accounting
principles described in Note 1 to the financial statements. Because of inherent limitations in any
internal control structure, errors or irregularities may nevertheless occur and  not be detected.
Also, projection of any evaluation of  the structure to future periods  is subject to the risk that
procedures  may  become inadequate because of changes in conditions or that the effectiveness
of the design  and operation of policies and procedures may deteriorate.

6.     For the purpose of this report, we have classified the significant internal control structure
policies and procedures in the following categories:

       General accounting and financial reporting
       Loans receivable
       Accounts payable and accrued  liabilities
       Fund balance
       Obligations
       Disbursements and operating expenses

7.     For all of  the internal  control  structure  categories listed  above,  we obtained an
understanding of the design of relevant policies and procedures, de;ermined whether they have
 Page HI                      EPA'i FY 1993 Annum! Financial Sutementi

-------
 been placed in operation, assessed control risk, and performed tests of the control procedures.

 8.     We noted one matter involving the internal control structure and its operation that we
 consider to be a material weakness and reponable condition under the Standards established by
 the American Institute of Certified Public Accountants and OMB Bulletin 93-06.

 9.     A material weakness is a reponable condition in which the design or operation of the
 specific internal control structure dements does not reduce to a relatively low level the risk that
 errors or irregularities in amounts that would be material in relation  to the financial statements
 being audited may occur and not be detected within a timely period by employees in the normal
 course of performing their assigned functions. Reponable conditions involve matters coming
 to our attention relating to significant deficiencies in the design or operation of the internal
 control structure thai, in our judgment, could adversely affect the entity's ability to  ensure that
 obligations and costs are in compliance with applicable laws; funds, property, and other assets
 are safeguarded against unauthorized use or disposition;  and  transactions applicable to EPA
 operations are properly  recorded to permit the preparation of reliable financial statements  in
 accordance with accounting principles described in Note 1 to the financial statements.

 10.    Our consideration of the internal control structure would not necessarily disclose all
 matter* in the internal control structure that might be reponable conditions and, accordingly,
 would not necessarily disclose all reponable conditions that are also considered to  be material
 weaknesses.  The condition that we consider to be both  a reponable condition and material
 weakness is:

 General Ledger Accounts Do Not Correctly Report Net Position Components

 We :found  that EPA's general ledger accounts do not correctly disclose the components of net
 position because  the automated year end closing process in the IFMS is incorrect.  This is
 evidenced by the fact that certain account balances that should equal other accounts do not For
 example, beginning net position plus current appropriations less appropriations expensed and the
 net change in invested capital and unfunded activities do  not equal  ending net position. As a
 result, EPA financial management personnel  spent significant time and resources to develop
 financial information for  the components of net position for footnote disclosure.   Manual
 adjustments were recorded  for financial statements purposes.  However, the components of net
 position as required by OMB Bulletin 93-02 still could not be properly disclosed.  The bulletin
 requires disclosure of the  following components of  net  position: unexpended appropriations
'available,  unexpended appropriations unavailable, undelivered  orders, cumulative results of
 operations, and invested capital.
 EPA't FY 1993 Annual Financial Statement!
Pige 142

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EPA Actions •

EPA management has recognized the IFMS as a material weakness in its FMFIA report for
1993.   The weakness  resulted from incomplete users manuals and  system documentation,
incomplete interfaces, aad inadequate financial management reports.  EPA is in the process of
upgrading to a new release of the IFMS, scheduled for implementation in fiscal year 1994,
which EPA's management believe will resolve many of these deficiencies.

In our 1992 report, we recommended that EPA review  and correct the  automated year end
dosing  procedures.  EPA's corrective action for this issue is scheduled to begin in fiscal year
1994.  Because of this ongoing effort, we are making no further recommendations at this time.

11.    This report is intended for the information of Congress, OMB, and EPA.  This restriction
is not intended to limit the distribution of this report, which is a matter of public record.
LEONARD G. BIRNBAUM & COMPANY
Alexandria, Virginia
January 28, 1994
 Pt«el43
EPA'i FY 1993 Annual Financial Statement!

-------
                      LEONARD   G.  BIRNBAUM AND COMPANY

                               CERTIFIED  PUBLIC ACCOUNTANTS

                                      WASHINGTON OFFICf

                                     I3IS FHANCONIA "OAO

                                     ALEXANDRIA. VA. 3ZJ10



                                        (7031 923-rm

                                      FA*: troji m<*asi
UOMANO a SlftMSAUM
usue A. LUPIN.
OAVIO SAKOFS  *
CAftOi. A. SCMMCIOC*


MIM8EMS OP TMi
AMERICAN INSTtTUTt
    OP CM'S  ;'
                                                                              WASMtMQTON. Q.C.
                                                                             SUMMIT. N«W  JERSEY
                                                                            vos ALTOS. CALIFORNIA
                                                                            SAN oitsa CAUFOBNIA
                      Auditors' Reort on Compliance yfth
                                  Asbestos Loan Program
  Thetljispector General
  U.S. Environmental Protection Agency:

  1.     We have audited the financial statements of the Asbestos Loan Program of the U.S.
  Environmental Protection Agency (EPA), as of and for the year ended September 30, 1993. We
  have issued our report thereon dated January 28, 1994, in which we disclaimed an opinion on
  the statements of operations and changes in net position, cash flows, and budget and actual
  expenses and qualified our opinion on the statement of financial position.

 . 2. '?  • Except, as discussed in paragraphs 4 and  5  of our Independent Auditors' Report on
-.Financial Statements, we conducted our audit in accordance  with generally accepted auditing
 .standards; Government Auditing Standards, issued by  the Comptroller General of the United
  States; and Office of Management  and Budget Bulletin 93-06, Audit Requirements for Federal
  Financial Statements.  Those standards  require that we plan and perform  the audit to obtain
  reasonable  assurance about whether the financial statements are free of material misstatement.

  3. ,.   Compliance  with laws and regulations is the responsibility of EPA's management.  As
  part of obtaining reasonable assurance about whether the financial statements are free of material
  misstatement,  we  tested compliance  with  certain provisions  of the following  laws and
  regulations, designated by OMB, EPA, and EPA's Office of Inspector General, that may have
  a direct and material effect on the financial statements:

  *      Budget and Accounting Procedures Act of 19SO
  EPA'* FY 1993 Annul Financial Sutonenu
                                                                                      Page 144

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       Chief Financial Officers Act of 1990
       Anti-Deficiency Act
       Federal Managers' Financial Integrity Act of 1982
       Federal Credit Reform Act of 1990
       Prompt Payment Act
       Debt Collection Act of 1982
       Asbestos School Hazard Abatement Act of 1984
       Asbestos School Hazard Abatement Reauthorization Act of 1990

4.     Our objective was not to provide an opinion on overall compliance with laws and
regulations.  Accordingly, we do not express such an opinion.

5.     As  required by  OMB  Bulletin 93-06, Audit  Requirement for Federal Financial
Statemejus, we obtained an understanding of EPA's process for identifying and
evaluating  weaknesses  required to be reported  in  accordance  with the Federal Managers'
Financial Integrity  Act (FMFIA).  We compared  the material weaknesses reported in EPA's
fiscal year 1993 FMFIA report with the material weakness reported in our report on internal
control structure.   EPA reported material weaknesses  and nonconformances in its financial
systems, accounting system-related financial management problems and accounting  system
interfaces in its fiscal  year  1993 FMFIA report.  The definition of a material weakness for
financial statement purposes differs from the definition in  OMB  Circular A-123 (revised)
Internal Control Systems, for the purposes of FMFIA.  According to OMB Circular A-123, a
material weakness  is a situation in which the designed procedures or degree  of. operations
compliance therewith  does  not provide reasonable  assurance that the objectives of internal
control specified in FMFIA are  being  accomplished.   These objectives are: to provide
management with reasonable assurance that obligations and costs comply with applicable law,
assets are safeguarded against waste, loss, unauthorized use and misappropriation; revenues and
expenditures are recorded and accounted for properly so that accounts and reliable financial
reports may be prepared and accountability of assets maintained; and programs  are efficiently
and effectively carried out in accordance with applicable law and management policy. As a
result of our engagement, we reported one material weakness in internal control.  To determine
whether to report matters as material weaknesses, we used the definition of a material weakness
included in OMB Bulletin 93-06. According to the bulletin, a material weakness in the internal
control structure is a reportable condition in which the design or operation of one or more of
the internal control structure elements does not reduce to a relatively low level the risk that
errors  or irregularities  in amounts that would be material* in relation  to the financial statements
may occur and not be detected within a timely period by employees in the normal course of
performing their assigned functions. The material weakness reported by us but not included in
EPA's FMFIA report was not properly identifying components of net position.
Page 145
EPA's FY 1993 Annul Fuuncial Statement!

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The above weakness thai we noted was not reported by EPA in its FMFIA report because this
weakness is a specific financial accounting and reporting issue related  to the financial statements,
and the weaknesses reported by EPA under FMFIA are broader in scope.

6.    ' The results of our tests of compliance indicate that, with respect to  the items tested, the
EPA complied, in all material respects, with the provisions referred to in the third paragraph
of this report,  applicable to the  Asbestos Loan Program, and with respect to items not tested,
nothing came to our attention to cause us to believe that EPA had not complied, in all material
respects, with  those provisions.

7.     This  report is intended  for  the information of Congress,.OMB, .and EPA.    This
restriction is not intended  to limit the distribution of this report, which is a matter of public
LEONARD G. BIRNBAUM & COMPANY
Alexandria, Virginia
January 28, 1994
                                                    — '

                                                 ^
 EPA'i FY 1993 Annual Financial Statement!                                                 **&* 14*

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               UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

                           WASHINGTON, D.C. 20460
                                 MAR 3 I
                                                         THE NSP€C70fl GENEML
   MEMORANDUM
   SUBJECT
   FROM:
   TO:
Fiscal 1993 Financial Statement Audit of the  Pesticides
Revolving Funds and the Oil Spill Trust Fund
Audit Report No. E1AML3-20-7001-4100230
Kenneth A. Konz
Assistant Xnspe
Jonathan Z. cannon
Chief Financial Officer  (3101)
                                             Audit  (2421)
             Lynn R. Goldman, M.D.
             Assistant Administrator for Prevention,
               Pesticides and Toxic Substances  (7101)

             Elliott P. Lavs
             Assistant Administrator for Solid Waste
               and Emergency Response  (5101)

        Attached is our audit report on the fiscal 1993 financial
   statements for three of EPA's trust and revolving funds - the
   Reregistration and Expedited Processing Fund  (FIFRA Fund), the
   Revolving Fund for Certification and Other'Services (Tolerance
   Fund), and .the Oil Spill Trust Fund.  The audit was performed in
   accordance with the requirements of the Chief Financial Officers
   (CFO) Act.  The objectives of the audit wew to determine if the
   financial statements were fairly presented, adequate internal
   controls were in place, and the Agency complied with applicable
   provisions, of lava and regulations.  -

        During this audit, ve identified significant financial
   reporting improvements.  As a result of these improvements and
   additional audit work we performed, we are-issuing a qualified
   opinion on the Statement of Financial Position for the FIFRA Fund
   as of September 30, 1993.  Although we noted  improvements in the
   financial reporting for the FIFRA Fund, as a result of additional
   audit work we performed related to the Tolerance Fund, we
   identified weaknesses in controls in the Office of Pesticide's
   fee tracking system.  These weaknesses resulted in material
   errors in the records used to support the deferred revenue aaount
   shown on the Tolerance Fund Statement of Financial Position.
EPA's FY 1993 Annual Financial Statement*
                                                P»ge 147

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Therefore, we are unable to determine if the statement of
Financial Position for the fund as of September 30, 1993 is
fairly presented.  The statement of Financial Position amounts
for the FIFRA and Tolerance Funds as of September 30, 1992, which
we could not audit last year, enter into the determination of
results for the  Statements of Operations and Changes in Net
Position, Cash Flows, and Budget and Actual Expenses for fiscal
1993.  Therefore, we are continuing to disclaim opinions on these
financial statements.  For the Oil Spill Trust Fund, we are
issuing unqualified opinions on the fiscal 1993 Statements of
Financial Position and Cash Flows.  We are qualifying our
opinions on the  Statements of Operations and Changes in Net
Position and Budget and Actual Expenses for the year, only
because we did not audit the overhead expenses allocated from
other appropriations.

  ;-j  We also identified one noncompliance issue which was also
discussed in our audit report on the fiscal 1992 financial
statements.  The Agency has not complied with the CFO Act
requirement to perform biennial reviews of user fees.  We believe
the Agency needs to place a higher priority on completing these
reviews since such reviews might identify user fees EPA could
increase — thereby providing additional revenues for the
Agency's use in  performing its mission.

     In accordance with EPA Order 2750, you are required to
provide this office a written response to the audit report within
9'0 days of the final audit report date.  Since the
recommendations  are addressed to two offices we are designating
the Chief Financial Officer as the primary action official.  As
such, the primary action official should take the lead in
coordinating the Agency's official response so that the 90 day
timeframe is met.  The Assistant Administrator for Prevention,
Pesticides and Toxic Substances, as the secondary action
official, should coordinate with the primary action official.
For corrective actions planned but not completed by the response
date, reference  to specific milestone dates will assist us in
closing the report.  During our upcoming audit of the fiscal 1994
financial statements, we will work with your staff to assist them
in implementing  corrective actions to improve the accuracy and
timeliness of EPA's financial information.

     This report contains findings that describe problems the
Office of Inspector General (OIG) identified and corrective
actions the OIG  recommends.  This report represents the opinion
of the OIG.  Final determinations on matters in this report will
be made by EPA managers in accordance with established EPA audit
resolution procedures.  Accordingly, the findings described in
this report do not necessarily represent the final EPA position.
We have no objection to the further release of this report to the
public.
Ptge 148                EPA'i FY 1993 Annual FinancUl Statements

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      Should you or your staff have any questions  concerning this
report,  please contact  Melissa Heist, Divisional  Inspector
General, Financial Audit Division at 260-1479 or  Michael Powers
of her staff at 260-1480.

Attachment
EPA'* FY 1993 Annual Financial Statements
Page 149

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Page 150
EPA'* FY 1993 Annual Financial Sutements

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      INSPECTOR GENERAL'S REPORT ON THE FINANCIAL
     iTEMENTS FOR THE FIFRA AND TOLERANCE REV<
            FUNDS AND THE OIL SPILL TRUST FUND
The Administrator
U.S. Environmental Protection Agency:

We have audited the principal financial statements of the
Pesticides Reregistration and Expedited Processing Fund {FIFRA
Fund), the Revolving Fund for Certification and Other Services
(Tolerance Fund), and the Oil Spill Trust Fund as of and for the
year ended September 30,  1993.   Following, are the results of our
audit work that included  assessments of whether (1) the financial
statements are fairly presented,  (2) adequate internal controls
related to these funds were in place, and (3) the Agency complied
with applicable laws and  regulations.


FINANCIAL STATEMENTS FOR THE FIFRA FUND

In our previous report on the FIFRA Fund financial statements,
dated April 7, 1993, we did not  express an opinion on the
Statements of Financial Position, Operations and Changes in Net
Position, Cash Flows, and Budget and Actual Expenses for the Fund
as of and for the year ended September 30, 1992 because:

  •  We were unable to audit the September 30, 1992, property,
     plant and equipment  balance stated at $574,000 because the
     detail maintained in the accounting records was not
     sufficient to support the financial statement amounts.

  •  We did not audit the administrative costs of $22,811,000
     that were funded from other EPA appropriations.  These costs
     are recorded for financial  statement purposes as income from
     overhead allocation  and as  offsetting overhead expenses from
     allocation.  We did  not audit these costs because we were
     initially told by EPA management that these costs would not
     be included in the financial statements, and the decision to
     include them was made too late to allow us to audit them.

  •  We were unable to audit the accounts payable and accrued
     liabilities for the  Fund because adequate documentation was
     not available to support year-end adjusting entries of
     $141,223.  In addition,  we  were unable to audit other
     adjustments made to  the FIFRA Fund totaling $181.3 million
     because adequate supporting, documentation was not available.
EPA'i FY 1993 Annual Financial Statement*
Page 151

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   •  Prior to October 1, 1991, EPA was not required to prepare
      financial statements for the FIFRA Fund.   Accordingly,  the
      account balances for this Fund had not been audited as  of
      September 30, 1991.

 The Statement of Financial Position amounts as of September  30,
 1992, enter into the determination of results  of operations  and
 changes in net position, cash flows, and budget and actual
 expenses for the year ended September 30,  1993.  Because we  were
 unable to examine sufficient evidence to determine the
 reliability of the Statement of Financial Position for the Fund
 as of September 30, 1992, the scope of our audit, work was not
 sufficient to enable us to express ah opinion  on the Statements
 of Operations and Changes in Net Position, Cash Flows, and Budget
 and Actual Expenses for the year ended September 30, 1993.

 In addition, we did not audit the administrative costs of
 $25,303,000 that were allocated from other EPA appropriations to
 the FIFRA Fund for fiscal 1993.  These costs are recorded for
 financial statement purposes as income from overhead allocation
 and as offsetting overhead expenses from allocation.  We did not
 audit these administrative costs funded from other EPA
 appropriations because of the substantial increased audit effort
 that would have been required.  We plan to audit this category of
 costs beginning in fiscal 1995 when the Agency will expand the
 coverage of its financial statements to all of its activities.
 Adjustments, if any, to these account balances would affect  the
 Statements of Operations and Changes in Net Position, and Budget
.'and Actual Expenses for the Fund.

 We were unable to audit the FIFRA Fund property, plant and
^equipment balance of $533,000 as of September  30,.1993, because
; the detailed records on property maintained by the Agency do not
.provide adequate support for the financial statement amounts.
 Adjustments, if any, to the property, plant and equipment balance
 would affect all of the FIFRA Fund Financial Statements for  the
 year ended September 30, 1993.

 In our opinion, except for the effects of any  adjustments that
 might have been necessary had we been able to  audit the property,
 plant and equipment balance, the Statement of  Financial Position
 for the FIFRA Fund as of September 30, .1993, is fairly presented
 on.the basis of accounting described in Note 1 to the financial
 statements.  As required by applicable provisions of Office  of
 Management and Budget (OMB) Bulletins 93-02 and 94-01, both
 entitled "Form and Content of Agency Financial Statements,"  Note
 1 describes the accounting policies followed by the Agency to
 prepare its financial statements, which is a comprehensive basis
 of accounting other than generally accepted accounting
 principles.                                 -
 Page 152
EPA'i FY 1993 Annual Financial Statement*

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Our audit work related to the information presented in
Management's Overview of EPA and Overview of TrustFunds,..
Revolving Funds and Commercial Activities consisted of applying
certain limited procedures to the section of the overview
captioned "Pesticides Reregistration and Expedited Processing
Fund  (FIFRA Fund)."  These procedures consisted primarily of
comparing the information with information contained in EPA's
accounting records and making inquiries of management regarding
the presentation of the overview.  We did not audit the
information contained in the overview, and are; therefore not
expressing an opinion on it.

FINANCIAL STATEMENTS FOR THE TOLERANCE FUND

In our report on financial statements dated April 7,  1993,  we did
not express an opinion on the Statements of Financial Position,
Operations and Changes in Net Position, Cash flows, and Budget
and Actual Expenses for EPA's Tolerance Fund as of and for the
year ended September 30, 1992.  We were unable to express an
opinion or, the Tolerance Fund financial statements for the
following reasons:

  •  We did not audit the administrative costs of $3,532,000 that
     were funded from other EPA appropriations.  These costs are
     recorded for financial statement purposes as income from
     overhead allocation and as offsetting overhead expenses from
     allocation.  We did not audit these costs because we were
     initially told by EPA management that these costs would not
     be included in the financial statements, and the decision to
     include them was made too late to allow us to audit them.

  •  We were unable to audit $21.2 million in adjustments made to
     the Tolerance Fund because adequate supporting documentation
     was not available.

  •  Prior to October 1, 1991, EPA was not required to prepare
     financial statements for the Tolerance Fund.   Accordingly,
     the account balances for this Fund had not been audited as
     of September 30, 1991.

The Statement of Financial Position amounts as of September 30,
1992, enter into the determination of results of operations and
changes in net position, cash flows,  and budget and actual
expenses for the year ended September 30, 1993.  Because we were
unable to examine sufficient evidence to determine the
reliability of the Statement of Financial Position for the Fund
as of September 30, 1992, the scope of our audit work was not
sufficient to enable us to express an opinion on the Statements
of Operations and Changes in Net Position, Cash Flows, and Budget
and Actual Expenses for the year ended September 30,  1993.
EPA'f FY 1993 Annual Financial Statement*
Page 153

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  In addition,  due to weaknesses  in controls in the Office of
  Pesticide Programs' (OPP)  fee tracking system, we were unable to
  audit the deferred revenue .amount of $4,157,000 shown on the
  Statement of  Financial Position for the Tolerance Fund as of
  September 30,  1993.  Further, due to a lack of adequate
  supporting documentation,  we were unable to determine the
  validity of $24.3 million  of adjusting entries made to the
  Tolerance Fund.

  Finally,  we did not audit  the administrative costs of $4.5
  million that  were allocated from other EPA appropriations to the
  Tolerance Fund for fiscal  1993.  These costs are recorded for
  financial statement purposes as income from overhead allocation
  and as offsetting overhead expenses from allocation.  We did not
  audit these administrative costs funded from other EPA
  appropriations because of  the substantial increased audit effort
  that would have been required.   He plan to audit this category of
  costs beginning in fiscal  1995  when the Agency will expand the
  coverage  of its financial,  statements to all of its activities.
  Adjustments,  if any,  to these account balances would affect the
  Statements of  Operations and Changes in Net Position, and Budget
  and ^Actual Expenses for the Fund.

  Because of the matters discussed above, the scope of our work was
  not^sufficient to enable us to  express an opinion on the
  Statements of  Financial Position, Operations and Changes in Net
  Position,  Cash Flows,  and  Budget and Actual Expense for the
  Tolerance Fund as of and for the year ended September 30, 1993.

  Our audit work related to  the information presented in
  Management's Overview of EPA and Overview of Trust Funds.
 /-Revolving Funds and Commercial  Activities consisted of applying
.''certain limited procedures to the. section of the overview
 ;jcaptioned "Revolving Fund  for Certification and Other Services
 "(Tolerance Fund)."  These  procedures consisted primarily of
 ..comparing the  information  with  information contained in EPA's
 'accounting records and making inquiries of management regarding
  the presentation of the overview.  We did not audit the
  information contained in the overview, and are therefore not
  expressing an  opinion on it.
 FINANCIAL STATEMENTS FOR THE OIL SPILL TRUST FUND

 Fiscal 1993 was the first year EPA received a separate
 appropriation to carry out its responsibilities under the Oil
 Pollution Act of 1990.  Accordingly, fiscal 1993 was the first
 year EPA prepared  financial statements covering the Oil Spill
 Trust Fund.
 Page 154
EPA'* FY 1993 Annual Financial Statement*

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 We did not audit the overhead expenses allocated from other
 appropriations to the Oil Spill  Trust Fund because of the
 substantial audit effort that would have been involved.  These
 allocated expenses of $755,000 for the year ended September 30,
 1993,  are shown on the Statement of Operations and Changes in Net
 Position as Income from Overhead Allocation and Overhead Expenses
 from Allocations.  We will audit this category of expenses
 beginning in fiscal 1995 when Agency-wide financial statements
 will be prepared.

 In our opinion, except for the effects of any adjustments that  .
 might  have been necessary to the Statements of Operations and
 Changes in Net Position, and Budget and Actual Expenses had we
 audited these account balances,  the financial statements for the
 Oil Spill Trust Fund fairly present, the Fund's:

   • financial position as of September 30, 1993; and
   • results of operations and changes in net position,
   • cash flows, and
   • budget and actual expenses  for the year then ended; on the
     basis of accounting described in Note 1 to the financial
     statements.

.As required by applicable provisions of OMB Bulletins 93-02 and
 94-01,  both entitled "Form and Content of Agency Financial
 Statements," Note 1 describes the accounting policies followed by
 the Agency to prepare its financial statements, which is a
 comprehensive basis of accounting other than generally accepted
 accounting principles.

 Our audit work related to the information presented in
 Management's Overview of EPA and overview of Trust Funds^
 Revolving Funds and Commercial Activities consisted of applying
 certain limited procedures to the section of the overview
 captioned "Oil Pollution Prevention Program (Oil Spill Trust
 Fund).11  These procedures consisted primarily of comparing the
 information with information contained in EPA's accounting
 records and making inquiries of  management regarding the
 presentation of the overview.  We did not audit the information
 contained in the overview,  and are therefore not expressing an
 opinion on it.


 EVALUATION OF INTERNAL CONTROLS

 As a part of our audit,  we evaluated the Agency's internal
 control structure:  (1)  to determine the audit procedures
 necessary to express an opinion  on the financial statements, and
 (2)  to determine whether the internal controls designed by
 management provide reasonable assurance that the following
 objectives are met:
EPA'i FY 1993 Annual Financial Statement*
Page 155

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     transactions  are  properly recorded and accounted for to
     permit  the preparation  of reliable financial statements and
     to maintain accountability over assets;

     transactions,  including those related to obligations and
     costs,  are executed  in  compliance with applicable laws and
                   and
  •  funds, property,  and other assets are safeguarded against
     loss from unauthorized use or disposition.

The audit methodology  section of this report provides further
details on the scope of our internal control audit work.
                       MATERIAL WEAKNESSES

During our evaluation of  internal controls, we noted the
following material weaknesses involving the Agency's internal
control structure related to the FIFRA and Tolerance Revolving
Funds and the Oil Spill Trust Fund.  Applicable guidance
contained in OMB Bulletin 93-06, "Audit Requirements for Federal
Financial Statements,*1 defines a material weakness as a
report able condition in which the design or operation of specific
internal control procedures does not reduce to a relatively  low
level, the risk that errors or irregularities in amounts that
would be material in relation to the financial statements being
audited may occur and not be detected within a timely period by
employees in the normal course of performing their assigned
functions.

!„: * Weaknesses Exist In System Used To Track Tolerance Fees

Weaknesses in controls in OPP's fee tracking system resulted in
significant errors in the office's tolerance fee records.  For
example, we found fee receipts of $457,700 and earnings of $9,800
that were recorded twice; earnings of $163,800 that were recorded
for fees which had been refunded; and fees totaling $288,100 that
were refunded but not recorded in petition records.  The
Financial Management Division relied on OPP's detailed records on
fees to support summary information on deferred revenue that was
entered into the Agency's Integrated Financial Management System
for the Tolerance Fund.   As a result, we could not determine if
the amount of deferred revenue in the Tolerance Fund Statement of
Financial Position as of  September 30, 1993 was accurate.  Since
deferred revenue represents 87 percent of the reported
liabilities for the Fund, we are unable to express an opinion on
the statement.
Page 156
EPA's FY 1993 Annual Financial Statement*

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 2.   Further Improvements Needed In Documentation For Adjusting
 Entries

 During this year's audit of EPA's financial statements,  we found
 financial management personnel improved their documentation for
 adjusting entries.  We did find, however,  that some material
 adjustments were not adequately described  and lacked supporting
 documentation.   Adequate documentation should be maintained to
 ensure that only legitimate adjustments are made to the  Agency's
 financial records.  As a result of the lack of adequate
 documentation,  we could not determine the  validity of $150.4
 million of adjusting entries made to the FIFRA Fund,  and $24.3
.million made to the Tolerance Fund.   We found other ways to
 validate year-end account balances for the FIFRA Fund.   However,
 insufficient documentation for Tolerance Fund entries contributed
 to  our disclaimer of an opinion on the Tolerance Fund financial
 statements.

 '•*•   Property Balances Included In The Financial statements Could
  ot Be Audited

 .ne procedures  used to capitalize property purchased with FIFRA
 and other Agency funds do not identify all property which should
 be  capitalized.  In addition,  property that is capitalized in the
 accounting records can not be uniquely identified in the Agency's
 property accountability system.   Consequently,  when items of
 property are transferred, replaced or lost,  those changes can not
 be  reflected in the accounting records.  As a result, the FIFRA
 Fund property,  plant and equipment balance of $533,000 included
 in  the fiscal 1993 Statement of Financial  Position for the Fund
 could not be audited.  This condition was  also reported  during
 our fiscal 1992 financial statement audit.

 4.   Improvements Needed in Estimating AccountsPayable And
 Accrued Liabilities

 The methods the Research Triangle Park (RTP)  Financial Management
 Center used to  compute year-end accounts payable and accrued
 liability adjustments resulted in a net material misstatement of
 $799,775 in the fiscal 1993 FIFRA Fund financial statements,  and
 an  $816,054  misstatement in the fiscal 1993  Oil Spill Trust Fund
 financial statements.  The RTP Financial Management Center
 overstated its  FIFRA Fund accounts payable adjusting entry of
 $106,829 by $22,106,  and they also overstated their accrued
 liability adjustment of $848,177 by $777,669v  In addition,  the
 RTP Financial Management Center understated the Oil Spill Trust
 Fund accounts payable adjusting entry of $415,309 by $271,603 and
 understated the accrued liability adjustment of $91,051  by
 $544,450.   Agency financial management personnel made the
 necessary corrections to the Agency's financial statements,
 however, additional controls are needed to prevent such
 misstatements in the future.
EPA's FY 1993 Annual Financial Statement*
Page IS?

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 In addition to these weaknesses,  the Agency,  in its fiscal 1993
 FHFIA report,  included as a material weakness accounting system-
 related financial management problems that affect the funds we
 audited.  EPA reported that while its Integrated Financial
 Management System (IFMS)  meets the Joint Financial Management
 Improvement Program core accounting system requirements,  specific
 systems-related problems impair EPA's ability to provide
 complete,  reliable and timely data for Agency decision-making and
 control of assets.  The problems which would  impact the funds we
 audited include: (l) incomplete user manuals  and system
 documentation, (2) an inadequate automated project cost
 accounting capability, (3)  incomplete interfaces with
 programmatic and administrative systems, and  (4)  inadequate
 financial  management reports.
                       REPORTABLB CONDITIONS

We also identified the following reportable conditions.   OMB
Bulletin 93-06 defines a reportable condition as a weakness in
the. design or operation of the internal control structure that
could adversely affect EPA's ability to ensure: (1)  obligations
and costs are in compliance with applicable laws; (2)  funds,
property,  and other assets are safeguarded against unauthorized
use or disposition; and (3)  transactions are properly  recorded to
permit the preparation of reliable financial statements.
    >

*•   Unliquidated ObligationBalance For TheFIFRA Fund Contained
Invalid Obligations

The fiscal 1993 year-end FIFRA unliquidated obligation balance in
-the general ledger contained invalid obligations.  This  occurred
because OPP did not conduct a complete  and timely review of some
of its unliquidated obligations.   In addition,  the Headquarters
Procurement Operations Division did not request deobligation of
funds associated with completed delivery orders.  We identified
approximately $471,000 of unliquidated  obligations that  should be
deobligated and made available for other critical FIFRA  program
requirements.  This is especially important since Agency
management has identified the shortage  of funds as one of the
reasons they will not meet the Congressionally imposed deadline
for reregistering pesticides.
2.  Property Accountability Controls Keed To Be  Strengthened

As a result of weaknesses in controls over property, the Agency
is not  able to account for all property purchased with FIFRA
funds.  We  found:  (1)  employees  improperly exchanged equipment
among themselves without  notifying their custodial officers;
(2) a complete fiscal  1993 physical inventory was not  conducted;
and (3) custodial  officers were  accountable for  too many items of
property.   Our 1992  audit report also identified similar problems
PtgelSB
EPA's FY 1993 Annual Financial Statement!

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Annual Registration Maintenance, and Pre-Manufacture Notice fees
all required review in 1993.  The Agency needs to place a higher
priority on completing these reviews since such reviews might
identify user fees EPA could increase — thereby providing
additional revenues for the Agency's use in performing its
mission.  For example, the Agency collected $1.5 million in
Tolerance Petition fees while the Office of Pesticide Programs
estimated that 49 FTEs at a total cost of $3.2 million were used
to process Section 408 tolerance petitions for raw agricultural
products.  Performing reviews of user fees is consistent with the
Vice President's Report of the National Performance Review, which
raises concerns that "given the size of the federal deficit,
government must find better, more efficient, and.more effective
ways to pay for its activities."  To accomplish this, the report
recommends increasing the use of user fees for many activities*
COMPARISON OF EPA'S FMPIA REPORT WITH OUR EVALUATION O7 INTERNAL
CONTROLS

As required by OMB Bulletin 93-06, "Audit Requirements for
Federal Financial Statements," we compared EPA's Federal
Managers' Financial Integrity Act (FMFIA) report to our
evaluation of the internal control systems related to the FIFRA
and Tolerance Revolving Funds and the Oil Spill Trust Fund.  For
fiscal 1993, EPA continued to report IFMS as a high risk area and
a material weakness.  EPA also continued to report as material
nonconformances the need to:  (1) enhance the process for
recording property in order to improve the accuracy of the
Agency's accounting records, and (2) implement interfaces between
IFMS and other administrative systems.  In addition, the Agency
reported that corrective action had been completed on two
previously reported material nonconforroances — (1) the need to
record adjustments to the general ledger due to IFMS
implementation during 1989* and (2) the need to perform
comprehensive reconciliations between Treasury reports and IFMS.

In addition to the weaknesses identified by EPA, we are reporting
three additional weaknesses that affect the funds we audited.  We
found that OPP did not have an adequate system to track tolerance
fees.  We also found, as we had in our fiscal 1992 audit, that
material adjusting entries for the FIFRA and Tolerance Funds were
not adequately supported, and the methods used to estimate
accounts payable and accrued liabilities for the FIFRA and Oil
Spill Funds resulted in material misstatements of the account
balances for these two funds.
Page 160
EPA'i FY 1993 Annual Financial Statement*

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  regarding  controls over property located in OPP.  Based on a
  physical inventory we conducted of statistically selected items,
  we project that  64 FIFRA funded items valued at $220,384 are
  missing, and  26  items valued at $88,154 were improperly
  transferred to other custodial areas.

  We will also  be  reporting other less significant matters
  involving  the internal control structure and its operation in a
  separate management letter.

  Our consideration of the internal control structure would not
  necessarily disclose all matters in the internal control
  structure  that might be reportable conditions * or material
  weaknesses.   In  addition, because of inherent limitations in any
  internal control structure, errors or irregularities may
  nevertheless  occur and not be detected.  Also,  projection of any
  evaluation of the internal control structure to future periods is
  subject to the risk that procedures may become inadequate because
  of changes in conditions, or the effectiveness of the design and
  operation  of policies and procedures may deteriorate.
 TESTS OF COMPLIANCE WITH LAWS AND REGULATIONS

 As a part of obtaining reasonable assurance about whether the
 financial statements for the FIFRA, Tolerance and Oil Spill Funds
 were free of material misstatements, we tested compliance with
 those laws and regulations that either materially affect the
 financial statements, or that OMB or our office considered
 ^significant to the audit.  .

 
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OTHER SIGNIFICANT MAT]

The 1988 amendments to the Federal Insecticide, Fungicide, and
Rodenticide Act, mandate the accelerated reregistration of all
pesticide products registered prior to November 1, 1984.  The
amendments establish a statutory goal of completing
reregistration eligibility decisions by 1997.  In the Agency's
Overview of Trust Funds. Revolving Funds, and Commercial
Activities, the Office of Pesticide Programs discloses that
additional resources will be needed to meet these deadlines.
According to a recent General Accounting Office report, EPA now
estimates that all pesticides may not be reassessed until 2004,
and all products may not be reregistered until 2006.  We have
chosen to report this matter in our report even though it is not
material to the financial statements because of its significance.
EPA'i FY 1993 Annual Financial Statements
                                                             Page 161

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Pigel62
EPA'i FY 1993 Annual Financial Statements

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            RESPONSIBILITIES AND METHODOLOGY
EPA MANAGEMENT AND OIG RESPONSIBILITIES

EPA's management is responsible for:

  •  preparing annual financial statements covering  its trust
     funds, revolving funds and commercial activities  following
     applicable accounting principles;

  •  establishing and maintaining a system of.internal controls;
     and

  •  complying with applicable laws and regulations.

We are responsible for auditing the financial  statements in order
to determine if the statements are free of material  misstatements
and presented fairly in accordance with the basis of accounting
described in Note 1 to the financial statements.  We are also
responsible for evaluating related internal controls and
compliance with applicable provisions of laws  and regulations.


AUDIT METHODOLOGY

Zn order to fulfill our responsibilities,  except as  described in
our opinions or disclaimers of opinion  on the  financial
statements for the FIFRA and Tolerance  Revolving Funds and the
Oil Spill Trust Fund,  we:

  •  examined on a test basis, evidence supporting the amounts
     and disclosures in the financial statements;

  •  assessed the accounting principles used and significant
     estimates made by management; and

  •  evaluated the overall presentation of the financial
     statements.

In addition, we completed the following- audit  work in  order to
evaluate internal controls and test compliance with  laws and
regulations.
EVALUATION OP INTERNAL CONTROLS

We considered EPA's internal control structure  in planning and
performing our audit of the FIFRA and Tolerance Revolving Funds
and the Oil Spill Trust Fund. The purposes  of this consideration
were:  (1) to determine our auditing procedures for the purpose
of attempting to express an opinion on the  financial statements;
and (2) to determine whether the internal control structure meets
EPA't FY 1993 Annual Financial Statement*
P»ge 163

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 the previously described objectives.  We  obtained an
 understanding of  the significant  internal control structure
 policies and procedures and assessed the  level of control risk
 relevant to all significant cycles, classes of transactions, and
 account balances.   For those significant  internal control
 structure policies and procedures that have been properly
 designed and placed in operation, we performed tests to assess
 whether the controls are effective and working as designed.

 We  classified the significant internal control structure policies
 and procedures into the following categories:

  • Receipts
  • Disbursements
  .'•';; Payroll
  •'•*; investments
  '• Property
  • Budget
  •• Financial Reporting

 As  a part of our  audit work,  we also obtained an understanding  of
 management's process for evaluating and reporting on internal
 control and accounting systems as required by FMFIA.  In
 addition,  we compared the material weaknesses reported in the
 Agency's FMFIA report that  relate to the  financial statements
 under audit to the material weaknesses found during the
 evaluation we conducted of  the entity's internal control system.
 Our objective in performing this  work was not to express an
 opinion on overall compliance with FMFIA  provisions.

 The information presented; in Management's Overview of EPA and
 Overview 'of Trust  Funds.  Revolving Funds  and Commercial
 Activitiesvis supplemental  information required by OMB Bulletins
 93-02 and 94-01 both entitled "Form and Content of Agency
 Financial Statements.*1  OMB Bulletin 93-06, "Audit Requirements
 for Federal Financial Statements," contains certain requirements
 with respect to performance measurement information reported in
 the overview section of financial statements.  Auditors are to
'obtain  an understanding of  the internal control structure
 policies and procedures designed  to ensure that data supporting
 the measures are properly recorded and accounted for to permit
 the preparation of reliable and complete  performance information.
 Auditors are also  required  to assess the  risk that the controls
 in  place would not prevent,  detect or correct a material
 misstatement of the information.  Our audit work in the area of
 performance measures was limited  to comparing the financial
 information included in the overview with information contained
 in  EPA's accounting records and providing comments, to management
 regarding the presentation  of the overview.
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EPA'i FY 1993 Annual Financial Statement!

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TE8T8 OF COMPLIANCE WITH LAWS AND REGULATIONS

As a part of obtaining reasonable assurance about whether the
financial statements were free of material misstatements, we
tested compliance with applicable sections of those laws and
regulations that either materially affect the financial
statements, or that OMB or our office considered significant to
the audit.  In addition, we relied on some compliance testing
performed by Leonard G. Birnbaum and Company, Certified Public
Accountants, as part of its engagement to audit EPA's financial
statements for the Superfund and Leaking Underground storage Tank
Trust Funds, and the Asbestos Loan Program as of and for the
years ended September 30, 1993 and 1992.  We reviewed the firm's
audit work and concluded that we could rely on it to augment our
work.  The objective of our audit work and the work performed by
Leonard G. Birnbaum and Company was not to provide an opinion on
overall compliance with laws and regulations.      .
DETAILS OF AUDIT FIELD WORK PERFORMED

We selected statistical and non-statistical samples from EPA's
detailed accounting records supporting various FIFRA, Tolerance
and Oil Spill financial statement accounts.  We tested these
sample transactions to determine if they were adequately
supported by documentation and were recorded in accordance with
internal control policies and procedures and applicable laws and
regulations.  We also reviewed other supporting documentation,
such as worksheets and schedules, that the Agency used in
preparing its financial statements.  In addition, we applied
certain analytical review procedures to account balances.

The financial management records and supporting documentation we
reviewed were maintained by Financial Management Centers in
Research Triangle Park, Cincinnati and Las Vegas; and the Office
of Pesticide Programs, the Office of Emergency and Remedial
Response, the Headquarters Accounting Operations Branch and the
Financial Reports and Analysis Branch in Washington, D.C.  To
gain an understanding of established internal control procedures,
we also interviewed personnel in these offices and reviewed
applicable policies and procedures.

To evaluate controls in place to safeguard assets, we interviewed
personnel in the Facilities Management and Services Division and
the Office of Pesticide Programs, both located in Washington,  .
D.C.  We also reviewed applicable policies and procedures.  In
addition, we conducted a physical inventory o'f randomly selected
FIFRA funded property items.

Our fieldwork for the audit of the fiscal 1992 financial
statements was performed from March 31, 1992, through
April 7,1993, and our fiscal 1993 audit work was performed from
June 28, 1993, through January 31, 1994.
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Our audit was conducted in accordance with Government Auditing
Standards,  issued by the Comptroller General of the United
States;  and OMB Bulletin 93-06, "Audit Requirements for Federal
Financial Statements,11 except as previously discussed in this
report.   These standards require that we- plan and perform our
audits to obtain reasonable assurance about whether the financial
statements  are free of material misstatement.  We believe that
our audit provides a reasonable basis for our opinions.

           1
 Unneth A.  Ko
Assistant Inspec
U.S.  Environment
January 31,  1994
ir General  for Audit
 Protection Agency
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  EPA'i FY 1993 Annual Financial Suiementi

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