«EPA
United States Office of the Inspector General September 1996
Environmental Protection 401 M Street. S.W. (2421)
Agency Washington, D.C. 20460
EPA's Office of the
Inspector General
Annual
Superfund Report
to the Congress
for Fiscal 1995
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ANNUAL
SUPERFUND REPORT
TO THE CONGRESS
FOR FISCAL 1995
September 1996
Required by
Section 111 (k) of the
Comprehensive Environmental Response, Compensation,
and Liability Act of 1980 (CERCLA),
as amended by the Superfund Amendments and
Reauthorization Act of 1986 (SARA)
OFFICE OF THE INSPECTOR GENERAL
U.S. ENVIRONMENTAL PROTECTION AGENCY
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EPA Office of the Inspector General Annual Superfund Report to the Congress for Fiscal 1995 i
FOREWORD
This report covers fiscal 1995 activities, and is our ninth Annual Superfund Report to the
Congress. The Superfund Amendments and Reauthorization Act of 1986 (SARA) requires the
Office of the Inspector General (OIG) to audit the Superfund program annually arid to report to
Congress annually on these audits.
In addition to reviewing Agency performance, we also take a proactive role to help the
Environmental Protection Agency (EPA) management prevent future problems. During fiscal
1995, we assisted EPA management in a number of ways. We actively participated in the
Agency's Superfund Senior Regional Management Acquisition Council to help the Agency
continue to improve its contract procurement and management. We worked with the Agency as
it sought to improve its information resources management. We provided assistance in
determining the financial capability of potentially responsible parties (PRPs) at one Superfund
site.
We have worked closely with the Agency on matters related to Superfund reauthorization. In
support of the Administration's efforts to streamline reporting, we noted to Congress that many
sections of the Agency's annual Superfund progress report to Congress could be eliminated, as
could the requirement that we audit it. We also identified our own annual Superfund report to
Congress, this report, as one that largely duplicated the semiannual reporting requirement, and
could be eliminated. We urged Congress to eliminate the specific Superfund auditing
requirements in order to allow us to use our discretion to focus audit resources where most
needed.
Pending reauthorization of Superfund, the Agency has implemented a number of initiatives to
improve the functioning of the Superfund program within current statutory constraints. We
continue to find that these efforts appear to be achieving their objectives. We found that
Region 9 pilots integrating Superfund site assessment activities significantly improved the
timeliness and cost effectiveness of the site assessment process. We also found that the Early
Action pilot at a Wisconsin Superfund site allowed for rapid reduction of risk from contaminants
through early, aggressive control measures. In addition, we found a Design Accelerated
Remedial Target (DART) pilot in Connecticut improved cooperation with PRPs, appeared to
have reduced transaction costs and increased remedy selection flexibility, and may accelerate
cleanup.
The beginning of the Superfund program created new and unique cost accounting
requirements. Although EPA has continued to improve its site-specific accounting and
documentation of Superfund costs, significant weaknesses remained to be corrected. In our
fourth review of the Hazardous Substance Superfund under the Chief Financial Officers (CFO)
Act requirements, we again disclaimed an opinion on the financial statements because of
material weaknesses in EPA's financial management system and accounting controls. The
primary reasons we could not determine whether the statements were fairly presented were
weaknesses concerning accounting for property, accounting for the cpmponents of net position,
recording reimbursable Superfund oversight costs as assets, accounting for grants funded from
more than appropriations, and allocating expenses to show the full cost of the Fund.in the
financial statements.
Our reviews of the Agency's performance in managing the Superfund program indicated that
the Agency has made significant improvements in some areas we have been reviewing for
several years, but that it needs to continue efforts to rectify longstanding problems. In the area
of contract management, our review of management of Environmental Services Assistance
Team (ESAT) contracts found many aspects were well managed but EPA still needed to make
improvements. EPA officials did not adequately determine whether costs claimed by
contractors were reasonable and appropriate before recommending payment. EPA was also
providing government equipment to contractors without following Federal regulatory
requirements.
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EPA Office of the Inspector General Annual Superfund Report to the Congress for Fiscal 1995 ii
We found that the Agency gave low priority to reviews required by Congress to make sure site
remedies continued to protect human health and the environment. These reviews are an
important control since some EPA did conduct found failures in the remedies. We also found
EPA Region 9 failed to adequately oversee data quality assurance at Department of Defense
Superfund sites, resulting in millions of dollars of data having to be rejected and long delays in
cleanups. In addition, we found that Region 8 needed better sampling controls and more
consistent oversight of sampling at Superfund sites.
We found that Region 7 funded management and support.activities with resources.meant to
operate environmental programs, disregarded reprogramming rules, routinely overobligated
program elements, and did not provide program managers with sufficient budget and financial
information. We also found that EPA used outdated cost factors which may have substantially
underestimated response costs and budgets for Superfund sites.
Our follow-up reviews to see how well the Agency had done in making improvements we had
recommended in earlier reports showed a mixed picture. We found the Agency had completed
or was nearing completion of corrective actions to address significant problems in repprting its
Superfund accomplishments. But we also found that Region 7 still needed to do considerable
work to improve its PRP search program. While the Region had taken some steps to address
our earlier recommendations, it could not demonstrate effective monitoring or improved
timeliness of PRP searches, and could not provide a complete list of searches conducted and in
progress:
Our Superfund investigative efforts resulted in several indictments, convictions, and
administrative actions. One firm received EPA payments for pollution self-insurance although it
did receive a quote for such insurance from an insurance company, and continued to receive
these payments even after it purchased such insurance. The firm repaid the entire cost of the
contract, in addition to costs of auditing, investigating, and prosecuting the case. The
President of another firm pled guilty to submitting false certifications with respect to required
hazardous materials training, and the firm made restitution to EPA.
We continued to achieve successes in our efforts to respond to problems of fraudulent data
analysis and sampling. A laboratory used by a number of government agencies to analyze
samples from hazardous waste sites pled guilty to fraudulently manipulating data, and two of its
managers went to prison for the offenses. An EPA subcontractor settled with the Government
on charges of submitting false claims for soil sample analysis not complying with EPA
specifications.
We will continue to help Agency management deliver the most effective and efficient Superfund
program through a comprehensive program of audits, investigations, fraud prevention, and
cooperative efforts with Agency management.
JohnC. Martin
Inspector General
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EPA Office of the Inspector General Annual Super-fund Report to the Congress for Fiscal 1995 ill
TABLE OF CONTENTS
PURPOSE ....... . . . .. 1
BACKGROUND 2
ASSISTANCE TO EPA MANAGEMENT , .....' 3
HAZARDOUS SUBSTANCE SUPERFUND '. 5
Further Improvements in Financial Reporting Needed 5
RESPONSE CLAIMS . . . 8
Few Costs Questioned in Re-Solve Claim 8
COOPERATIVE AGREEMENTS . , , 10
Louisiana's Management Systems Lack Adequate Controls to Protect EPA's Interest... 10
Florida Failed to Retain Records 11
University Misuses Millions of Cooperative Agreement Funds .11
REMEDIAL INVESTIGATIONS AND FEASIBILITY STUDIES 13
Early Action Pilot Reduces Risk at Better Brite Site, Wl 13
Design Accelerated Remedial Target (DART) Pilot Improved Cleanup Process at
Linemaster Switch Site, CT 13
EPA Incompletely Characterized Alternatives at Circuitron Site, NY 14
Remedial Planning for FCX Sites, NC, Technically Sound 14
CONTRACTS 16
Improvements Needed in Management of Contractor Activities 17
INTERNAL AUDITS AND SPECIAL REVIEWS , 19
Higher Priority Needed for Reviews of Superfund Site Remedies 19
Millions of Dollars in Superfund Site Data Rejected 20
Better Controls Needed Over Region 8's Superfund Field Sampling Activities ,. 21
Region 7 Disregarded Approved Allocations in Implementing Its Budget 22
CERCLIS Internal Controls Strengthened 23
Improvement Still Needed in Region 7's Potentially Responsible Party Search Program
. . . 24
Superfund Cost Estimates May Be Unreliable 25
Region 9 Pilot Projects Sped Site Assessments 26
INVESTIGATIVE ACTIVITY '....' 27
EXHIBIT 1: SUPERFUND REVIEW REPORTS ISSUED DURING FISCAL 1995 29
APPENDIX: ACRONYMS AND ABBREVIATIONS 36
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EPA Office of the Inspector General Annual Superfund Report to the Congress for Fiscal 1995 1
PURPOSE
We provide this report pursuant to section 111 (k) of the Comprehensive Environmental
Response, Compensation, and Liability Act (CERCLA) of 1980, as amended. The Superfund
Amendments and Reauthorization Act (SARA) of 1986 amended that section of CERCLA to
add several annual requirements for the Inspector General of each Federal agency carrying out
CERCLA authorities. These requirements include four audit areas and.an.annual report to
Congress about the required audit work. This report covers fiscal 1995 audits of Superfund
activities. We discuss the required four audit areas below.
This report contains chapters on the mandated audit areas, except claims. We also summarize
other significant Superfund audit work, assistance to EPA management, and Superfund
investigative work performed during fiscal 1995. We exceed the statutory requirements by
providing Congress with the significant results of Superfund work beyond that specifically
mandated in section 111 (k).
Trust Fund
CERCLA requires ". . . an annual audit of all payments, obligations, reimbursements, or other
uses of the Fund in the prior fiscal year. . . ." We now meet this requirement through the
financial statement audit required by the Chief Financial Officers Act of 1990.
Claims
CERCLA requires an annual audit to assure "... that claims are being appropriately and
expeditiously considered ..." Since SARA did not include natural resource damage claims
as allowable Fund expenditures, the only claims provided in CERCLA, as amended, are
response claims.
Cooperative Agreements
CERCLA requires audits ". .. of a sample of agreements with States (in accordance with the
provisions of the Single Audit Act) carrying out response actions under this title ..." We
perform financial and compliance audits of cooperative agreements with States and political
subdivisions. Some of our audits also review program performance.
Remedial Investigations/Feasibility Studies (RI/FS)
CERCLA requires our". . . examination of remedial investigations and feasibility studies
prepared for remedial actions ..." Our RI/FS examinations review the adequacy of the
studies to provide a sound technical basis for remedial action decisions. We usually perform
these examinations as special reviews by our technical staff.
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EPA Office of the Inspector General Annual Superfund Report to the Congress for Fiscal 1995 2
BACKGROUND
The Comprehensive Environmental Response, Compensation, and Liability Act of 1980
(CERCLA), Public Law 96-510, enacted on December 11, 1980, established the "Superfund"
program. The purpose of the Superfund program is to protect public health and the
environment from the release, or threat of release, of hazardous substances from abandoned
hazardous waste sites and other sources where-other federal -laws do not require response.
CERCLA established a Hazardous Substance Response Trust Fund to provide funding for
responses ranging from control of emergencies to permanent remedies at uncontrolled sites.
CERCLA authorized a $1.6 billion program financed by a five-year environmental tax on
industry and some general revenues. CERCLA requires EPA to seek response, or payment for
response, from those responsible for the problem, including property owners, generators, and
transporters.
The Superfund Amendments and Reauthorization Act of 1986 (SARA), Public Law 99-499,
enacted October 17, 1986, revised and expanded CERCLA. SARA reinstituted the
environmental tax and expanded the taxing mechanism available for a five-year period. It
authorized an $8.5 billion program for the 1987-1991 period. It renamed the Trust Fund the
Hazardous Substance Superfund. The Budget Reconciliation Act of 1990 reauthorized the
program for three additional years and extended the taxing mechanism for four additional years.
The basic regulatory blueprint for the Superfund program is the National Oil and Hazardous
Substances Contingency Plan (NCP), 40 CFR Part 300. The NCP was first published in 1968
as part of the Federal Water Pollution Control Plan, and EPA has substantially revised it three
times to meet CERCLA requirements. The NCP lays out two broad categories of response:
removals and remedial response. Removals are relatively short-term responses and modify an
earlier program under the Clean Water Act. Remedial response is long-term planning and
action to provide permanent remedies for serious abandoned or uncontrolled hazardous, waste
sites,
CERCLA recognized that the Federal Government can only assume responsibility for remedial
response at a limited number of sites representing the greatest public threat. Therefore, EPA
must maintain a National Priorities List (NPL), and must update it at least annually. The NPL
consists primarily of sites ranked based on a standard scoring system, which evaluates their
threat to public health and the environment. In addition, CERCLA allowed each State to
designate its highest priority site, without regard to the ranking system.
CERCLA section 104(c)(3) does not allow EPA to fund remedial actions unless the State in
which the release occurs enters into a contract or cooperative agreement with EPA to provide
certain assurances, including'cost sharing. At most sites, the State must pay 10 percent of the
costs of remedial action. EPA may fund 100 percent of site assessment activities (preliminary
assessments, site inspections), remedial planning (remedial investigations, feasibility studies,
remedial designs), and removals. For facilities operated by a State or political subdivision at
the time of disposal of hazardous substances, the State must pay 50 percent of all response
costs, including removals and remedial planning previously conducted.
CERCLA sections 104(c)(3) and 104(d) authorize EPA to enter into cooperative agreements
with States or political subdivisions to take, or to participate in, any necessary actions provided
under CERCLA. A cooperative agreement serves to delineate EPA and State responsibilities
for actions to be taken at the site, obtains required assurances, and commits Federal funds.
EPA uses cooperative agreements to encourage State participation in the full range of
Superfund activities - site assessment, remedial, removal, and enforcement.
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EPA Office of the Inspector General Annual Superfund Report to the Congress for Fiscal 1995 3
ASSISTANCE TO EPA MANAGEMENT
Besides performing audits and investigations, the OIG responds to EPA management requests
for OIG input in the development of regulations, manuals, directives, guidance and
procurements. These are proactive efforts to prevent problems that might later result in
negative audit findings or investigative results. The OIG reviews and comments on draft
documents prepared by Agency offices. Sometimes an OIG staff persoa attends meetings of
an EPA work group to provide input. Fiscal 1995 was an active year for OIG preventive
assistance to EPA management in the Superfund area. Besides helping EPA management, we
coordinate with other Federal agencies. We also seek to improve Superfund audit and
investigative capabilities of our OIG and of other Federal OIGs, and minimize overly detailed or
excessive audit and reporting requirements. We summarize below some of the major activities
in these areas. We also responded to numerous requests for assistance from the Agency
which did not develop into major projects.
Contract Management
We actively participate in the Agency's Superfund Senior Regional Management Acquisition
Council (SRMAC), which includes senior representatives of EPA Headquarters and regional '
program and contract management staff. SRMAC meetings provide a forum for participants to
learn from each other, and to share success stories and good ideas. Discussions cover such
issues as standardization of user guides, evaluation of future contract needs, and Agency wide
issues. We discuss reports we have recently issued and their effect on Superfund procurement
and contract management. We review the recommendations and programmatic impacts of
their implementation. We encourage EPA officials to give us feedback on the impact our
recommendations have on their day-to-day operations.
Information Resources Management (IRM)
Several prior audits identified concerns with EPA's IRM program which provides Agency
policies and guidance for Superfund and other programs. During fiscal 1995, we reviewed
drafts of several revisions to the Agency's IRM policies. We reviewed several parts of Directive
2100 which establishes Agency policies for Telecommunications, Information and Data
Management, and Security. We also reviewed Guidance on Federal Information Processing
(FIP) Procurements and IRM Policy Directive 2195, Information Security Manual. During the
course of these reviews we met with Agency IRM officials to discuss ways to improve or
enhance the draft policy documents. We also met with the General Accounting Office (GAO)
and the Agency regarding GAO's review, SUPERFUND: System Enhancements Could
Improve the Efficiency of Cost Recovery.
Financial Evaluation
In response to a request from Region 10's Office of Regional Counsel, we evaluated financial
documents to help determine the ability to pay for two potentially responsible parties at the
Tulalip Landfill Superfund site. Our report on this evaluation helped the Region in its cost
recovery efforts at that site.
Superfund Reporting and Audit Requirements
As the Congress considers reauthorization, we recommended revision of certain sections of the
Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA), as
amended by the Superfund Amendment and Reauthorization Act. First, we recommended
reconsideration of the annual audit and reporting requirements of section 301 (h), which
requires EPA to annually report its progress in implementing CERCLA and for the OIG to audit
the report for reasonableness and accuracy. We pointed out that many sections of the current
report could be eliminated because the information is available elsewhere, and recommended
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EPA Office of the Inspector General Annual Superfund Report to the Congress for Fiscal 1995 4
removing the audit requirement for the report because of the extensive auditing of the financial
and performance aspects of Superfund.
We also recommended eliminating the audit requirements of section 111 (k) and allowing the
OIG to use discretion in auditing Superfund. We commented that:
• The audit requirements of the Chief Financial Officers Act superseded the Trust Fund audit
requirement; .......
• The small number of response claims makes the annual audit requirement in that area
excessive;
• The cooperative agreement audit requirement should be made discretionary;
• The remedial investigation/feasibility study audit requirement is too narrow because the
program has moved more into the construction phase while streamlining the study phase;
and
• The OIG's annual Superfund reporting requirement (this report) duplicates the semiannual
reporting requirement of the Inspector General Act.
Superfund Orientation Course
As the Superfund program has expanded and developed, the OIG has recognized a need to be
sure that its auditors and investigators who review Superfund have a good understanding of the
program. Therefore, we developed a special orientation course explaining the key aspects of
the Superfund program, including:
• Superfund and related legislation and regulations;
• The removal, remedial and enforcement parts of the Superfund program;
• Organizational structure and functions of EPA offices delegated specific Superfund
responsibilities; and
• The OIG's role and responsibilities concerning Superfund and the type of Superfund
audits the OIG performs.
We ask all OIG employees and OIG audit services contractor employees performing Superfund
audits to take this course. We also offer the course to other Federal OIGs and audit
organizations who perform audits in their own agencies. We include the course in the OIG
Training and Development Sources course catalog. In fiscal 1995, we updated the course and
presented it once.
Audit Planning
The Office of Audit conducted a major planning effort on Superfund audits. As a part of this
effort, we analyzed Superfund activities and trends. Auditors from around the country met
together to determine performance audit priorities for different Superfund activities. As a result
of this work, the Inspector General approved emphasizing five areas: long-term actions,
sampling and analysis, Federal facilities, contract management, and short-term actions. The
OIG based its fiscal 1996 Superfund performance audit planning on this approach.
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EPA Office of the Inspector General Annual Superfund Report to the Congress for Fiscal 1995 5
HAZARDOUS SUBSTANCE SUPERFUND
The Chief Financial Officers (CFO) Act of 1990 requires Federal agencies to prepare annual
financial statements covering their trust funds, revolving funds and commercial activities. For
EPA, the Hazardous Substance Superfund was the largest activity requiring an annual financial
statement for fiscal 1995. The CFO Act also requires audits of the financial statements by the
OIG or an independent public accounting firm selected.by the OIG. The EPA OIG's
requirement to audit EPA's financial statements also meets our CERCLA requirement to audit
annually the Superfund, which we previously called our Trust Fund audit. The summary below
of our fiscal 1995 financial statement audit concentrates on findings related to the financial
statements of the Hazardous Substance Superfund.
Further Improvements in Financial Reporting Needed
Findings in Brief
During fiscal 1995, EPA continued to make improvements in its financial systems and
processes. However, some remaining weaknesses continue to prevent us from being
able to issue unqualified opinions on the Agency's Superfund financial statements. OIG
.and Agency financial management officials continue to work together on a number of
projects to achieve a shared objective of OIG unqualified opinions on all financial
statements as soon as possible.
We Found That
We disclaimed an opinion on the Superfund financial statements primarily due to weaknesses in
the areas of accounting for property, accounting for the components of net position, recording
reimbursable Superfund oversight costs as assets, accounting for grants funded from more ~~
than one appropriation, and allocating expenses to show the full cost of the Fund in the financial
statements. In addition, EPA did not require grantees to provide information on the amount of
expenses they had incurred, but for which they had not requested reimbursement by
September 30. Therefore, we could not assess the reasonableness of EPA's estimate of
accrued liabilities for grantee expenses.
Internal Controls
Property. EPA needed to make further improvements in accounting for the Agency's property.
We found that EPA had not capitalized some leases, EPA had not completed inventories at
some locations, and some contractors did not provide reports on the value of EPA property in
their possession. We also found EPA had not recorded items in the Agency's Personal
Property Accountability System (PPAS), and differences existed between the PPAS and the
Integrated Financial Management System values for capitalized property. PPAS was the
source of property information reported in the Agency's financial statements. .
Superfund Net Position. The components of Superfund net position continue to be
unreconcilable. Historically, EPA processed accounting transactions for the Superfund Trust
Fund in a manner consistent with accounting for appropriated funds. Thus, equity, budget, and
revenue accounts were affected when finance officials recorded various transactions for non-
appropriated funds, distorting relationships that should exist between the components of net
position.
Superfund Oversight Costs. The Agency did not record as assets Superfund oversight costs
recoverable from potentially responsible parties until it prepared billings. Our audit work in
Regions 3, 5, 6, and 9 identified $6.7 million in reimbursable oversight costs for 37 active sites
that EPA had not recorded as assets. The understatement could be considerably higher if
oversight costs for all active sites in all regions were analyzed.
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EPA Office of the Inspector General Annual Superfund Report to the Congress for Fiscal 1995 6
Grant Payments. EPA makes payments for grants funded from more than one appropriation
using a first-in first-out (FIFO) method when it does not have information from the recipient
showing which appropriation benefited from the work performed. Under this method, EPA
used the oldest available funding first regardless of which appropriations benefitted from the
work performed under the grant. Using the FIFO method could result in a material
misstatement of expenses for the Agency's various appropriations.
Expense Allocation. As requiredybythe-Office t>f-Management and-Budget, EPA allocates
expenses from its other appropriations to its various funds to show the full cost of these funds in
its' financial statements. In reviewing the supporting documentation for these allocations, we
found minimal information documenting these decisions. EPA obtained input on how it should
allocate costs from only one Headquarters program office and none of the regional offices.
EPA had not formalized policies and procedures identifying which costs it should allocate and to
which funds it should allocate the costs.
Compliance with Laws and Regulations
We did not identify any instances of noncompliance with laws and regulations that would result
in material misstatements to the audited financial statements. There were a number of ongoing
investigations involving EPA's grantees and contractors which could reveal violations of laws
and regulations, but-no determination about these cases had been made. We also identified
the significant issues below concerning the Agency's compliance with laws and regulations
which, while not resulting in material misstatements to the Agency's Superfund.financial
statements, EPA's management needed to address.
We found that the Agency stopped allocating certain support costs to the Hazardous Substance
Superfund before year-end, as it had also done in earlier years. In response to a prior audit
recommendation, the CFO asked the Office of General Counsel for an opinion on whether it is
proper for the Agency to stop allocating these Superfund support costs to the Superfund before
year-end and instead charge them to the Agency's general support appropriation. The CFO
had not received a response from the Office of General Counsel at the time of our audit. EPA
told us it intended to make the necessary adjustments if the Office of General Counsel
determined that EPA should have charged these costs to the Superfund appropriation.
Also, in many cases, the Agency's standard practice had been to provide contractors with
general purpose equipment without meeting the Federal Acquisition Regulations' requirements
or obtaining approvals to deviate from the Federal Acquisition Regulations. The Agency
recognizes the problem with its use of government furnished property and is taking corrective
actions. The Agency did not include this equipment in its financial statements before fiscal
1995.
We Recommended That
The Acting Chief Financial Officer:
• Expedite the revision of the Agency's capitalization procedures,
• Value all capitalized property at historical cost to the extent possible,
• Complete the necessary analyses and reconciliations of accounts, so the components
of net position can be audited.
• Implement policies and procedures to accrue Superfund reimbursable oversight costs,
• Obtain a legal opinion from the Office of General Counsel on whether it is proper to
use the FIFO grant disbursement method, and if it is, whether EPA needs to make
adjustments at year-end,
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EPA Office of the Inspector General Annual Superfund Report to the Congress for Fiscal 1995 7
• Use the Office of General Counsel's opinion on the FIFO grant disbursement method
to implement policies and procedures for accounting for grant disbursements, and
• Develop policies and procedures for the expense allocation performed to show the full
cost of funds in the financial statements and obtain input from regional and
Headquarters program offices to help ensure that expenses are accurately and
consistently allocated.
The Acting Assistant Administrator for Administration and Resources Management ensure:
• Completion of annual physical inventories of capitalized property,
• Timely and accurate recording of capitalized property in the PPAS by property
accountable officers, and
• Timely submission of annual inventory reports by Agency contractors.
What Action Was Taken
We issued our final report (6100200) to the CFO on May 3, 1996. In its July 2, 1996, response
to our report, EPA concurred with most of our recommendations or identified alternative
corrective actions that would resolve the issues discussed in the report. However, we asked
the CFO to supplement the response with additional milestone dates for corrective actions.
Also, on July 11, 1996, the OGC provided to the CFO an opinion that the Agency should not
stop allocating certain support costs to the Hazardous Substance Superfund before the end of
the year. The OGC maintained that once the Agency decides what types of costs to charge to
Superfund in a fiscal year, it must abide by that decision.
Additionally, the OIG initiated special projects to work with EPA officials on making
improvements in two areas - property and the expense allocation process. The QIC's special
projects in these two areas should help EPA reach its goal of receiving an unqualified opinion
on the Superfund financial statements.
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EPA Office of the Inspector General Annual Superfund Report to the Congress for Fiscal 1995 8
RESPONSE CLAIMS
Section 111 (a)(2) of CERCLA, as amended by SARA, authorizes EPA to pay any claim for
response costs incurred by "any other person" as a result of carrying out the NCR. Additionally,
section 122(b)(1) of CERCLA, as amended by SARA, authorizes the President to reimburse
Potentially Responsible Parties (PRPs) for "certain costs of actions under the agreement that
the parties have agreed to perform-but-which thePresidenthas.agreed,to.finance." The
President delegated this authority to the EPA Administrator under Executive Order 12580,
January 26, 1987, who furtherdelegated it to EPA's Office of Solid Waste and Emergency
Response (OSWER). Authority for decisions regarding claims against the Fund is currently
delegated to the Director, Office of Emergency and Remedial Response.
During fiscal 1995, we began our review of a claim for the Re-Solve, Inc. Superfund site. EPA
requested this review during fiscal 1994, but we did not receive the detailed information needed
to do our review until fiscal 1995. The report was issued in fiscal 1996. We summarize our
report below.
Few Costs Questioned in Re-Solve Claim
Findings in Brief
We questioned less than 1 per cent of claimed costs by potentially responsible parties
(PRPs) for Superfund response at the Re-Solve site. We could not express an opinion
on legal fees claimed because a report from EPA's Office of Regional Counsel (ORC)
failed to address whether these costs complied with the terms and conditions of the
settlement agreement with the PRPs.
Background
A Preauthorization Decision Document (PDD) authorized EPA payment of 30.14% of the costs
of Superfund response at the Resolve, Inc. site in North Dartmouth, Massachusetts, conducted
by a group of PRPs. The PRPs submitted a claim for costs of $14,196,070, of which
$4,278,695 would be EPA's proportionate share. EPA requested the OIG's assistance in
adjusting this claim. -
We Found That
We questioned $136,572 of the claim. The questioned amount included costs related to
analysis work not specified in the PDD, excavation and backfilling costs determined ineligible by
EPA's Remedial Project Manager for the site, and costs of a security fence which were not
adequately documented.
In its report on the claim, EPA's Region 1 ORC did not address whether claimed legal fees of
$678,893 were in accordance with the terms and conditions of settlement agreement, nor
whether they were necessary and reasonable. Therefore, we could not determine whether
these costs should be accepted or questioned.
We Recommended That
We considered this 'review to be advisory service rather than an audit, so we did not include
formal recommendations in our report. However, the questioned costs represented costs we
found EPA should not reimburse. We also suggested the ORC review the legal costs to make
sure they were reasonable and necessary for the project.
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EPA Office of the Inspector General Annual Superfund Report to the Congress for Fiscal-1995 9
What Action Was Taken
We issued our final report (6400008) on November 2, 1995, to the OSWER official designated
to be responsible for response claims. EPA requested the PRPs to remove the $136,572 we
questioned from their claim, and they agreed. EPA's Region 1 ORC found the legal services
claimed to be reasonable and necessary for completing the response action. On December 21,
1995, OSWER approved payment of the adjusted claim.
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EPA Office of the Inspector General Annual Superfund Report to the Congress for Fiscal 1995 10
COOPERATIVE AGREEMENTS
In fiscal 1994, we issued 13 review reports on Superfund cooperative agreements and grants.
The combined financial results of the 10 reviews that reviewed costs were as follows:
FINANCIAL RESULTS OF FISCAL 1995 SUPERFUND
COOPERATIVE AGREEMENT AND GRANT REVIEW REPORTS
Amount audited
Ineligible costs1
Unsupported costs2
Unnecessary/unreasonable costs3
Federal Share
$47,204,875
4,051,081
5,135,284
11,414
Total Costs
$52,366,129
4,441,572
5,488,068
14,267
1 . Costs questioned because of an alleged violation of a provision of a law, regulation,
contract, grant, cooperative agreement or other agreement or document governing the
expenditure of funds.
2. Costs questioned because, at the time of the audit, they were not supported by adequate
documentation and/or had not been approved by responsible program officials.
3. Costs questioned because they were not necessary or not reasonable.
We summarize two significant reviews of Superfund cooperative agreements with states and
one significant review of a Superfund research cooperative agreement with a university below.
Louisiana's Management Systems Lack Adequate Controls to Protect
EPA's Interest
Findings in Brief
The Louisiana Department of Environmental Quality (LDEQ) did not establish adequate
controls over their procurement and property management systems to protect EPA's
interest under the Old Inger and multi-site cooperative agreements. LDEQ issued
noncompetitive contracts without justification, failed to document required cost analyses,
and could not identify Superfund property purchased with EPA funds.
Background
We audited two Superfund cooperative agreements EPA awarded to LDEQ. One was for remedial
design and remedial action at the Old Inger site near Darrow. The other funded State assistance at
EPA-managed Superfund sites, and preliminary assessment and site investigation activities to
determine if sites merited Superfund response.
We Found That
LDEQ did not satisfactorily resolve findings we reported in prior audits. LDEQ's procurement and
property management systems did not meet EPA regulatory requirements. LDEQ did not
adequately document or justify sole source procurements. LDEQ also could not substantiate that it
performed independent cost analysis on 3 contracts and 17 change orders; or that it engaged in
required profit negotiations with contractors Further, LDEQ included ambiguous language in its
contracts. In two instances, LDEQ's contractors billed separately for pollution liability insurance
although the contracts prohibited that practice. We also found that LDEQ's property management
system did not properly account for Superfund property purchased under cooperative agreements.
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EPA Office of the Inspector General-Annual Superfund Report to.the Congress for fiscal1.99S -11
We Recommended That
The Assistant Regional Administrator for Management, Region 6, reduce the allowable costs by the
amount questioned, $2,314,943 ($2,100,818 Federal share), and take appropriate action to recover
the balance due.
What Action Was Taken
We issued our final report (5300012) to the Assistant Regional Administrator for Management,
Region 6, on March 30, 1995. Region 6 submitted a request for deviation from EPA's assistance
regulations to EPA Headquarters on January 18, 1996, to cover $983,160 in questioned sole
procurement contract costs for which the Region had relied on a class deviation issued in 1983
under a prior set of regulations. The Region postponed a final determination on our audit pending
receipt of that deviation. As of August 23, 1996, we had not received a final response to our report
from Region 6.
Florida Failed to Retain Records
Findings in Brief
The Florida Department of Environmental Protection (FDEP) did not retain records
supporting costs it claimed under a Superfund cooperative agreement with EPA.
Background
EPA, Region 4, awarded a cooperative agreement to enable FDEP to conduct preliminary
assessments and site investigation of uncontrolled hazardous waste sites in the State of Florida.
The agreement provided $5,922,880 for FDEP's activities between January 1, 1985 and June.30,
1993.
We Found That
FDEP did not comply with Federal regulations requiring retention of records supporting costs
claimed for at least three years after project completion. We therefore questioned unsupported
costs claimed by FDEP totaling $2,149,111. Due to a bookkeeping error, FDEP also claimed an
additional $28,911 of ineligible costs related to another project.
We Recommended That
The Acting Assistant Regional Administrator for Policy and Management, Region 4, disallow the
questioned costs.
What Action Was Taken
We issued our final report (5100490) to the Assistant Regional Administrator on September 19,
1995. FDEP provided additional documentation to Region 4 on questioned costs. We reviewed
this documentation at Region 4's request. As of August 23, 1996, Region 4 had not issued a Final
Determination Letter to FDEP.
University Misuses Millions of Cooperative Agreement Funds
Findings in Brief
Clark Atlanta University (CAU) mismanaged congressionally earmarked funds provided
under an EPA cooperative agreement to establish a hazardous substance research center.
As a result, the center was not properly established and serious control weaknesses
contributed to $3.6 million of ineligible or unsupported costs.
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EPA Office of the Inspector General Annual Superfund Report to the Cdngress for Fiscal 1995 12
Background
EPA awarded CAD a noncompetitive cooperative agreement funded under a congressional
earmark of the Agency's fiscal 1991 Superfund appropriation to establish a Center for
Environmental Policy, Education, and Research, the Center received additional earmarked funds
in fiscal 1992, 1993, and 1995, and was included in EPA's base budget in fiscal 1994. At the end
of fiscal 1994, CAU had received over $10.7 million in assistance awards.
We Found That
Almost four years after the awant of the-cooperative agreement and expenditure of millions of
dollars in EPA funds, CAU had not formally or physically established the Center required by the
agreement. Specifically, CAU had not properly or adequately: (1) designated a Center Director or
Fiscal Officer to direct the operations and expenditures of the Center; (2) established administrative
offices for support of the Center; (3) established an advisory board to plan, advise, and monitor
Center activities; (4) ensured that Center activities directly related to hazardous waste policy,
education, and research; and (5) controlled Center activities and costs. Consequently, the Center
did not accomplish Center objectives and many projects were outside the scope of the authorizing
statute.
CAU substantially mismanaged the cooperative agreement both financially and administratively.
CAU top management circumvented University internal controls and requirements related to Center
procurements, contracts and disbursements. Also, CAU management disregarded many special
conditions, EPA regulations, and agreement objectives related to Center oversight and monitoring.
CAU's noncompliance with requirements for progress reports and financial status information
precluded effective EPA oversight of the Center. .
CAU did not establish and maintain an adequate system of controls over agreement funds and
property, nor did CAU ensure that costs claimed were allowable and adequately supported. Our
review of $5,132,757 in costs claimed disclosed ineligible costs of $3,373,619 and unsupported
costs of $299,422 for the first two-year budget period of the Center (October 1991-September
1993).
We Recommended That
The Director, National Center for Environmental Research & Quality Assurance, Office of Research
and Development:
• Require Clark Atlanta to properly establish the research center as proposed to EPA.
• Assist Clark Atlanta in revising work plans and preparing budgets for funded projects
to ensure agreement funds are effectively used within the scope of the authorizing
statute under which EPA awarded the agreement.
• Instruct Clark Atlanta to implement adequate controls and oversight for research
center programs, projects, property, and expenditures.
The Director, Grants Administration Division, Office of Grants and Debarment, recover the Federal
share of ineligible costs ($3,002,521), determine the eligibility of the Federal share of unsupported
costs ($266,486), and recover, the applicable amount from CAU.
What Action Was Taken
We issued our final report (5100526)'to the Director, Grants Administration Division, Office of
Grants and Debarment, on September 30, 1995, for coordination of the Agency's overall response.
In response to our draft report, Agency officials generally agreed with our findings and
recommendations. The involved Agency offices suspended final audit resolution due to an ongoing
investigation of CAU.
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EPA Office of the Inspector General Annual Superfund Report to the Congress for Fiscal 1995 13
REMEDIAL INVESTIGATIONS AND FEASIBILITY STUDIES
In fiscal 1995, we issued four technical reports on remedial investigation/feasibility study (RI/FS)
activities covering five sites. The OIG Engineering and Science Staff conducted these reviews.
The reports contained no recommendations, and required no response from the Agency. We
summarize these reviews below. .
Early Action Pilot Reduces Risk at Better Brite Site, Wl
Findings in Brief
The Early Action pilot at the Better Brite Plating Chrome & Zinc Superfund site allowed for
rapid reduction of risk from contaminants through early, aggressive control measures.
Background
EPA Region 5 chose the Better Brite Chrome & Zinc site in De Pere, Wisconsin as an "Early
Action" pilot site. Early Action is part of the Superfund Accelerated Cleanup Model (SACM)
initiative to improve site response. It emphasizes early reduction of risk, using either removal or
remedial authorities. Region 5 formed a team of Federal and Wisconsin officials to coordinate
rapid reduction of risk. The team chose to conduct a time-critical removal action with several
components, which EPA approved and implemented.
We Found That
Regional staff focused on reducing risk at this Fund-lead site faster than at non-pilot sites using a
cross-program strategy. The cross-program approach allowed for rapid reduction of risk from
contaminant sources (soil), and from contaminant migration (ground water) through early,
aggressive control measures. While site cleanup activities did not follow the usual procedural
sequence for a National Priorities List (NPL) site, since no formal RI/FS was conducted, the
existing data was extensive enough to allow for sound decision-making in choosing an interim
action.
From a planning perspective, the site information was sufficient to make good decisions, and the
Region made sure that all participants were actively involved in the decision-making. Risk
information obtained from the preliminary health assessment was adequate for making decisions,
and the decision to implement an Interim Action Record of Decision (ROD) to address the
immediate threats to drinking water supplies and to nearby residents was logical.
Although the Administrative Record for the site was readily accessible at the local repository, the
local repository did not include the ROD. The Region should have paid more attention to making
sure that remedial program documents were placed timely into the local repository.
Design Accelerated Remedial Target (DART) Pilot Improved Cleanup
Process at Linemaster Switch Site, CT
Findings in Brief
EPA successfully used the DART process to improve cooperation with potentially
responsible parties (PRPs). The Linemaster Switch DART pilot appeared to have reduced
transaction costs and increased remedy selection flexibility, and may accelerate cleanup.
Background
EP, A developed the DART process to accelerate the design and implementation of remedies by
PRPs, and to foster cooperative relations between EPA and PRPs. The DART process greatly
reduces the number of deliverables required from the PRPs, substituting periodic meetings with the
PRPs for EPA review of multiple interim design deliverables. It also includes more flexible RODs,
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EPA Office ofthe Inspector General Annual Saperfund Report to the Congress fbrTiscaM 995 14
allowing PRPS to design a remedy within performance standards and a general technology type
EPA specifies in the ROD. EPA Region 1 selected the Linemaster Switch Corporation site in
Woodstock, CT, as one of its three DART pilot sites.
We Found That
The use of the DART approach had a marked positive effect on the timeliness and quality of
deliverables the PRPs submitted to EPA. EPA reviewers were much less likely to find deficiencies
in PRP deliverables requiring rejection after the site became a DART pilot. This decreased
transaction costs for both EPA and the PRPs.
The PRPs produced a thorough FS consistent with EPA requirements. EPA approved a
contingency ROD that allows the PRPs to switch to another acceptable technology if initial
technologies do not meet cleanup levels on schedule, costs vary radically from estimates, available
technologies improve, etc. EPA gives the PRPs flexibility, while still making the key decisions and
determining the critical goals.
EPA Incompletely Characterized Alternatives at Circuitron Site, NY
Findings in Brief
Although EPA generally followed applicable regulations and guidance in conducting the
Circuitron Corporation RI/FS, we found some weaknesses in the remedial planning process.
Most notably, EPA's failure to more fully characterize the extent of contamination left two
parts of the remedial alternative potentially in conflict with each other.
We Found That
EPA conducted remedial planning activities for this site in compliance with the National
Contingency Plan (NCP) and applicable guidance. However, we did note several weaknesses in
the process, including:
• EPA could have better characterized the contamination at the site. Characterization
of soil contamination beneath the site building was incomplete. As a result, the
decision to salvage the building was potentially in conflict with the cleaning up of soil
to specified levels. The Rl also did not include collection of soil samples beneath
sources of contamination, or sampling of storm drains which were likely source
areas.
• Neither the FS nor the ROD explained apparent inconsistencies in the application of
soil cleanup goals to the selection of areas requiring remediation. Although the FS
stated soil cleanup goals were used to determine excavation locations, over half of
the source areas identified for remediation did not have soil contamination in excess
of cleanup goals.
• Neither the FS nor the ROD clearly presented how land disposal requirements under
the Resource Conservation and Recovery Act (RCRA) applied to the soil remedies
discussed and to the different types of hazardous waste. .
Remedial Planning for PCX Sites, NC, Technically Sound
Findings in Brief .
EPA's remedial planning activities at the FCX-Statesville and PCX-Washington Superfund
sites in North Carolina were technically sound and consistent with applicable regulations
and guidance. The minor deficiencies we noted did not appear to have significantly affected
the remedy selection process.
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EPA Office of the Inspector General Annual Superfund Report to the Congress for Fiscal 19.95 .15
We Found That
We generally found that EPA's scoping, preliminary planning, site characterization, risk
assessment, and remedial alternatives analysis at the two sites were technically sound, well
organized, and consistent with the NCR. However, there were a few aspects of remedial planning
that could have been improved, including:
• Several sections of the Statesville Quality Assurance Program Plan (QAPP) were missing,
although the treatment of the data appeared to be adequate.
• We noted a few instances where EPA did not characterize contamination as completely as it
should have. EPA did not characterize shallow water table conditions at Statesville or
adequately define either the lateral or vertical extent of contaminated ground water at •
Washington.
• EPA did not use risk assessment default values consistently between the two FCX sites.
EPA chose nonstandard exposure factor default values for three exposure factors.
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EPA Office of the Inspector General Annual Superfund Report to the Congress f of FiscaM 995 16
CONTRACTS
The OIG is responsible for conducting and supervising independent and objective audits of
Superfund programs and operations. To carry out this responsibility, the OIG performs financial
and compliance audits of EPA contractors. Each Public Law authorizing EPA to award contracts
provides the Agency authority to audit and examine the books and records of the contractors and
subcontractors receiving Federal funds. Each EPA contract also contains audit provisions. Our
primary audit objectives are to determine (1) whether the controls exercised by the contractors and
subcontractors through their accountirrg.-procuremeTrtrcontract administration, and property
management systems are adequate to account for costs claimed; andr(2) costs claimed are
reasonable, allowable, and allocable, in accordance with applicable laws and regulations, to the
sponsored project.
Audits of contracts not only yield financial benefits to the Agency, but also aid in improving Agency
management. We expect to devote increased resources to auditing EPA contractors and
subcontractors given the increased size of the program and EPA's conduct of more actual
cleanups. These audits also play an integral part in supporting EPA's cost recovery actions.
Of the 194 contract review reports we issued in fiscal 1995, 59 covered incurred costs under EPA
contracts. The financial results of these reviews were as follows:
FINANCIAL RESULTS OF FISCAL 1995 SUPERFUND
INCURRED COST CONTRACT REVIEW REPORTS
Amount audited
Ineligible costs1
Unsupported costs2
Unnecessary/unreasonable costs3
$709,572,220
11,539,123
5,599,102
3,667
1 . Costs questioned because of an alleged violation of a provision of a law, regulation,
contract, grant, cooperative agreement or other agreement or document governing
the expenditure of funds.
2. Costs questioned because, at the time of the audit, they were not supported by ade-
quate documentation and/or had not been approved by responsible program officials.
3. Costs questioned because they were not necessary or not reasonable.
Another 45 of our reviews were initial pricing reviews in which we reviewed costs proposed by
offerers or bidders seeking EPA contract awards. Because these are only proposed costs, our
reviews do not question costs but rather recommend as efficiencies costs that we believe EPA
should not incur. The combined financial results of the initial pricing reviews were as follows:
Total Costs Audited
Total Recommended Efficiencies
$2,000,393,371
$38,469,805
We also issued 7 reports on proposed indirect cost rates, 25 system survey reports, and 4 program
review reports on EPA contractors.
The OIG can choose to have the reviews performed by in-house staff, independent public
accounting firms or another Federal audit agency. During fiscal 1995, our Superfund contract
reviews were performed as follows:
By OIG Staff
By Defense Contract Audit Agency
By Independent Public Accountants
39
152
3
Exhibit I contains a listing of all Superfund review reports issued by the OIG during fiscal 1995.
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EPA Office of the Inspector General Annual Superfund Report to the Congress for Fiscal 1995 17
We also conduct performance reviews of EPA's management of contracts and procurement.
During fiscal 1995, we issued three reports on such performance reviews. We summarize one of
those reports below.
Improvements Needed in Management of Contractor Activities
Findings in Brief
Many aspects of the Environmental Services Assistance Team (ESAT) contract management
activities performed at EPA's Lexington, MA, and Edison, NJ, facilities were well managed.
However, EPA needed to improve financial management and controls over contractor work
products, government furnished property (GFP), costs, and resources.
Background
EPA entered into ESAT contracts to assist Headquarters and regions in many analysis-related
activities, including samples and extensive laboratory data for remedial decisions under the
Superfund Amendments and Reauthorization Act.
We Found That
Although EPA effectively administered many aspects of the ESAT contract, improvements were
necessary in the financial management of the ESAT contract at the Lexington, MA, and Edison, NJ,
laboratories to assure that EPA paid only reasonable and authorized contractor charges. We found
that regional project officers (RPOs) and the national project officer (NPO) did not adequately
determine whether costs were reasonable and appropriate before recommending payment.
Instead, they generally relied on the contractor's submission without performing independent
verifications for questionable items.
EPA routinely provided general purpose equipment provided to contractors at both facilities without
meeting Federal Acquisition Regulation (FAR) requirements, and EPA did not take effective action
to make sure that contractors properly accounted for, maintained, safeguarded, reported, and used
GFP for its intended purpose. EPA had not clearly defined roles and responsibilities of the RPO,
NPO, contracting officer, and the property administrator, and EPA did not review, approve, or
periodically analyze the contractor's property control system. In addition, RPOs at both facilities
had limited knowledge of GFP procedures and regulations.
In addition, the planning, monitoring and evaluation process used for contractor work products at
the Lexington, MA, facility was inadequate to assure that all costs incurred were necessary and
reasonable. Actual time charged for tasks could not be accurately measured, .procedures were not
being followed for labor hour estimate overruns, and completed tasks were not always reviewed
and evaluated in a timely manner. These conditions were caused by inadequate priority, oversight,
and control over technical instruction documents (TIDs), and by the lack of an effective system to
track the status of TIDs and acknowledgment of completion forms.
We Recommended That
The Acting Assistant Administrator for Administration and Resources.Management:
• Clearly define roles and responsibilities of EPA contract management officials to
provide effective administrative oversight.
• Develop and implement an Agency strategy for GFP to comply with the FAR,
address incentives to encourage contractors to provide their own equipment, include
review and approval of the contractor's management system, and require
contractors to perform an accurate annual inventory and reconcile it against property
records.
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EPA- Office of-the-lnspector General Annaal'Superfund'RepOrt to the Cdngress for Fiscal 1995 18
The Assistant Administrator for Solid Waste and Emergency Response:
• Enforce controls directing the RPOs and NPO to not recommend or authorize
payment of questionable contractor costs until documented.
• Instruct RPOs to track estimated and actual hours assigned and used for contractor
work assignments.
What Action Was Taken
We issued the final audit report (5100515) to the Acting Assistant Administrator for Administration
and Resources Management and the Assistant.Administrator for Solid Waste and Emergency
Response on September 29, 1995. In its February 12, 1996, response to the final report, the
Agency generally agreed with our recommendations and took steps to implement them. EPA
structured the new ESAT contract to improve contract management oversight by strengthening
reporting requirements, as we recommended.
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EPA Office of the Inspector General Annual Superfund Report to the Congress for Fiscal 1995 19
INTERNAL AUDITS AND SPECIAL REVIEWS
In addition to reviews required by CERCLA, as amended, we conduct other reviews of EPA's
management of the Superfund program. We summarize below some particularly significant
internal audits and special reviews completed in fiscal 1995 not summarized elsewhere in this
Report. .
Higher Priority Needed for Reviews of Superfund Site Remedies
Findings in Brief
The Agency gave low priority to five-year reviews of Superfund site remedial actions needed
to assure the continued environmental protection of the remedy or additional timely
corrective action. As a result, EPA's backlog of unreviewed sites was increasing.
Background
In order to protect human health and the environment, the Superfund law requires the Agency to
review, at least every five years, each Superfund site where contamination remains after the
completion of remedial action, for remedies selected after October 17, 1986.
We Found That
The required five-year reviews that EPA completed effectively identified successes or failures of
remedies at Superfund hazardous waste sites. However, the low priority placed by Agency
management on the reviews was producing a substantial and increasing backlog of overdue
reviews. EPA had also not made the completion of five-year reviews a Superfund Comprehensive
Accomplishments Plan target or a goal agreed to by regional and Headquarters officials.
Agency guidance did not include a requirement that the reviews result in a final determination about
the protectiveness of remedies. Some of the reports did not contain any information regarding the
need for timely corrective action. Without this assurance, EPA was unable to provide adequate
assurance regarding the continued protectiveness of remedies.
The Agency developed an abbreviated form of review, called the 1a review, for use at certain types
of sites. However, we found considerable confusion regarding when and how to perform the 1a
reviews and what to document in the reports. The review guidance did not require the reviewer to
describe the conditions found at the site or provide adequate technical data. During our site visits,.
we found a potential hazard with one remedy which was not discussed adequately in the 1 a report.
The 1a reports often lacked vital information to support their conclusions regarding the
protectiveness of remedies.
We Recommended That
The Assistant Administrator for Solid Waste and Emergency Response:
• Increase the priority for performing the reviews by making them a Superfund
Comprehensive Accomplishments Plan target.
• Clarify the guidance for the use of 1a five-year reviews and require sufficient
information to support conclusions.
What Action Was Taken
We issued our final report (5100229) to the Assistant Administrator for Solid Waste and Emergency
Response on March 24, 1995. In its June 29, 1995, response to the final report, the Agency
agreed to institute a corrective action plan for implementing five-year review recommended actions.
EPA also agreed to clarify guidance on 1a reviews.
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EPA Office of the Inspector General Annual Superfund Report to the Corigfiess for Rscal 1995 20
Millions of Dollars in Superfund Site Data Rejected
Findings in Brief
Region 9 had not significantly strengthened its oversight program over Department of
Defense (DOD) laboratories or required DOD to improve its quality assurance project plans
(QAPPs). Partly as a result of this, hazardous waste cleanups at five DOD Superfund sites in
Region 9 were delayed up to 21/a years, and $5.5 million in data were rejected due to the poor
quality of laboratory analyses.
Background
DOD has 100 bases on the Superfund national priorities list 24 of which are in Region 9. EPA,
DOD, and states signed Federal facility agreements for the cleanup of DOD Superfund sites.
These agreements required DOD to prepare QAPPs to help ensure that laboratory analyses
produced data of sufficient quality and quantity for cleanup remedy decision making. EPA was
responsible for approving QAPPs and verifying implementation.
We Found That
Lack of adequate EPA oversight of quality assurance activities contributed to serious problems,
surfacing in 1992, with the quality of laboratory data on DOD cleanups in Region 9. These
problems eventually caused the rejection of $5.5 million of environmental data and cleanup delays
of up to 2Y2 years at the five DOD bases we reviewed. At one DOD base, extensive laboratory
fraud was found, and DOD later determined that the laboratory involved had performed analyses
for 24 military installations in the Region since 1989. At another DOD site, the Region certified a
portion of the cleanup effort as complete although the laboratory data was of unknown quality.
Region 9's remedial project managers were unfamiliar with DOD's specific laboratory quality
assurance procedures, and they accepted the description of procedures provided by DOD's ~
activities at face value. Site-specific data quality objectives, a prerequisite to QAPPs, were
generally not prepared at all. QAPPs were typically not designed to detect poor laboratory work,
and not always officially approved or fully implemented. Further, the Region did not effectively
monitor compliance with QAPPs, or perform sufficient oversight to verify the quality of laboratory
data. In addition, QAPPs were not modified to correct deficiencies after laboratory data problems
were found.
We Recommended That
The Regional Administrator, Region 9, improve the Region's oversight and assist DOD in avoiding
future data quality problems and cleanup delays by:
s
• Strengthening oversight of quality assurance activities;
• Including key quality assurance activities in the QAPPs; and
• Ensuring compliance with the QAPPs.
What Action Was Taken
We issued the final audit report (5100505) to the Regional Administrator, Region 9, on
September 26, 1995. In its June 27, 1996, response to the final report, the Region agreed to take
a number of steps to help DOD improve its quality assurance activities and to improve the Region's
oversight of DOD quality assurance activities at Superfund sites.
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EPA Office of the Inspector General Annual Superfund Report to the Congress for Fiscal 1995 21
Better Controls Needed Over Region 8's Superfund Field Sampling
Activities
Findings in Brief
Region 8 needed better sampling controls and quality assurance training of remedial project
managers (RPMs), and more consistent RPM oversight at Superfund sites.
Background
Federal regulations require sampling and analysis plans (SAPs) that provide a process for
obtaining environmental data of sufficient quality and quantity to satisfy data needs. EPA must
review and approve SAPs, which consist of a field sampling plan and a quality assurance project
plan (QAPP). A QAPP describes policy, organization, and functional activities necessary to
develop adequate data for planning and documenting site response activities. To allow for
adequate review time, Region 8 requires contractors to submit SAPs 30 days before collecting
samples.
We Found That
Region 8 experienced continued problems with untimely contractor submissions and
undocumented approvals of contractor-prepared SAPs. Contractors sometimes submitted SAPs
close to the sampling event which did not give RPMs enough time to properly review them and ask
for technical expertise if needed. Inadequately reviewed SAPs could result in inappropriate or
incomplete sampling results. In some instances, this could cause a need for rework, a loss of
valuable samples that cannot be duplicated, and unnecessary costs.
RPMs had not signed a majority of the plans we reviewed to indicate the Region had reviewed,
modified as needed, and approved all necessary steps to prevent the collection of unreliable data.
Also, RPMs had not always received timely technical assistance from other Regional staff, thus
delaying sample collection or hindering the RPM's ability to incorporate comments in modified
plans.
Some RPMs did not adequately oversee contractor activities at Superfund sites to help achieve
Regional quality assurance goals. Also, some RPMs relied on contractors' expertise and did not
routinely observe field sampling activities or take advantage of independent field audits in
evaluating contractors' performance. Without appropriate oversight, RPMs could not ensure proper
contractor performance or enhance their own experience levels.
The majority of RPMs did not attend all mandatory training courses offered in July 1994 and, in our
opinion, did not. recognize the importance of quality assurance training. They did not fully
understand quality assurance procedures required for all individuals involved in sampling activities.
Also, RPM training in quality assurance methods did not include sufficient examples to help RPMs
effectively and consistently apply quality assurance principles, and Region 8 had not accurately
compiled training records.
The Region demonstrated certain good oversight practices that resulted in cost savings.
Specifically, an RPM recognized that a sampling program proposed by a contractor was excessive.
She worked with the Regional Quality Assurance Officer to develop and implement a sampling
strategy and methodology that followed Superfund Accelerated Cleanup Model guidance and
saved about $200,000 in cleanup costs.
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EPA Office of the InspectorOeneral Annual Superfund Report to thfe Congrfess for Fiscal 1995 22
We Recommended That
The Regional Administrator, Region 8, require the Hazardous Waste Management Division Director
to:
• Ensure RPMs request and receive draft plans in time to allow thorough reviews and
appropriate approvals;
• Provide adequate staff with quality assurance expertise to assist in RPM's reviews;
• Ensure RPMs periodically observe contractor field sampling activities and consider
using field audits as a part of their oversight strategy and work plans; and
• Require RPMs to take mandatory training, strengthen training by including examples
and good practices, and ensure the accuracy of training records.
What Action Was Taken
/
We issued our final report (5400034) to the Regional Administrator, Region 8, on January 27, 1995.
In discussions held before issuance of the report, the Region agreed with the findings and
recommendations. It began corrective actions and established a management system review work
group to address the recommendations. In its May 4, 1995, response to the final report, the
Region stated it had issued guidance to RPMs to strengthen the quality of field sampling activities.
Region 7 Disregarded Approved Allocations in Implementing Its Budget
Findings in Brief
Region 7 funded management and support activities with resources meant to operate
environmental programs, disregarded reprogramming rules, routinely overobligated
program elements, and did not provide program managers with sufficient budget and
financial information.
Background
Congress annually gives EPA a budget to protect human health and the environment, and provides
funds within EPA's appropriations to operate environmental programs and conduct management
and support activities. The Headquarters Budget Division, in consultation with the National
Program Managers, provides the Regional Administrator with a budget for regional operations.
EPA must obtain congressional approval to reprogram funds in excess of $500,000, and the
Region must obtain Headquarters approval to reprogram funds in excess of $250,000.
We Found That
Region 7 used funds allocated for environmental programs on management and support activities.
The Region did not use work years and personnel funds as EPA represented in its budget request
to Congress and did not reprogram them to reflect planned and actual use. In fiscal 1994, the
Region supplemented its management and support budget by $1.1 million in personnel costs.
The Region exceeded reprogramming limitations contrary to EPA policy. The Region exceeded
planned expenditures in 25 of 113 program elements (allocations for specific purposes) in fiscal
1993 (including $567,739 in the Hazardous Substance Financial Management program element),
and 24 of 145 program elements in fiscal 1994. While the Region did not exceed appropriation
limitations, it disregarded reprogramming requirements. Funds certifying officers verified that funds
were available in the appropriation, but did not determine if funds in the program elements would
cover proposed expenditures. Region 7's budget monitoring procedures were not designed to
manage available funds within the limits of program elements to prevent overobligations.
Region 7 did not have an inclusive process for allocating and disseminating budget and financial
information to program managers. Program managers did not know the personnel budgets
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EPA Office of the Inspector General Annual Superfund Report to the Congress for Fiscal 1995 23
available through the operating plan to support their environmental programs. Region 7 budget
staff provided program managers with information on travel, overtime, and other operating
expenses (13 percent of the Region's internal operations budget). The Region did not provide
financial reports timely or often enough to manage program operations. For example, two program
managers had to develop their own financial tracking systems to monitor their budgets. However,
recognizing this need, the Region's budget staff provided program managers with complete
operating plan information in fiscal 1995.
We Recommended That
The Regional Administrator, Region 7:
• Follow EPA budget guidelines and reprogram funds to accurately reflect Regional
activities;
• Develop required Regional budget execution procedures; and
• Provide managers with complete and timely budget and financial information.
What Action Was Taken
We issued our final report (5100250) to the Regional Administrator, Region 7, on March 31, 1995.
In its response to our draft report, the Region indicated it was taking a number of steps io address
the problems we found. In its September 20, 1995, response to the final report, the Region further
reported it was developing an automated system so that each responsibility center could download
detailed object class information.
CERCLIS Internal Controls Strengthened
Findings in Brief
EPA had taken significant actions to address problems with Superfund accomplishments
reporting we had found in prior reports.
Previous Problems and Findings
For fiscal 1992 and fiscal 1993, we performed detailed reviews of accomplishments claimed by the
Superfund program in the Comprehensive Environmental Response, Compensation, and Liability
Information System (CERCLIS). Our audit of fiscal 1992 CERCLIS data showed that the data used
to support Superfund accomplishments was not always accurate. We attributed these inaccuracies
to weak internal controls including failures to: (1) adequately train personnel; (2) provide written
policies and procedures; (3) adequately document events; (4) correctly record and properly classify
events; and'(5) authorize and approve transactions at the appropriate level of authority. Also,
definitions of accomplishments were unclear and thus open to interpretation. Our fiscal 1993 report
indicated that the Agency was in the process of implementing the recommendations from our fiscal
1992 review, but had not developed guidance for estimating and documenting response settlement
amounts.
Follow-up Findings
We found that the Agency had completed or was nearing completion of corrective actions
recommended in our fiscal 1992 and 1993 reports. Specifically, a Definition Reform Workgroup
developed clarifying language for each accomplishment for inclusion in the Superfund Program
Management Manual. The Office of Solid Waste and Emergency Response (OSWER) issued a
Directive in June 1994 on the required standard elements for CERCLIS data entry and
accomplishment reporting. Also, OSWER Headquarters officials conducted training sessions in the
regional offices on CERCLIS reporting and developed quick reference guides on accomplishment
reporting and documentation requirements. OSWER added data fields and automated definitions
to provide users with information on the proper methods for coding and entering CERCLIS data. In
-------
EPA Office of the Inspector General Annual Superfund Report to the Cbngress'fbr Fiscal 1995 24
addition, OSWER issued supplemental guidance in April 1994 which outlined the methodology for
developing and documenting estimated settlement amounts.
Follow-up Recommendations
Since we considered the actions taken and underway sufficient to address the recommendations
from the fiscal 1992 and fiscal 1993 reports, we did not make any further recommendations.
What Action Was Taken
We issued our final report (5400014) to~the Assistant Administrator for Solid Waste and Emergency
Response on November 15, 1994. Since we made no further recommendations, the Agency did
not need to respond to our report.
Improvement Still Needed in Region 7's Potentially Responsible Party
Search Program
Findings in Brief
Region 7 had taken steps in response to our March 1992 report to make searches for
potentially responsible parties (PRPs) more timely, complete and well documented.
However, the Region had not implemented all of its planned actions, and significant
deficiencies continued.
Previous Problems and Findings
Our March 1992 report concluded that PRP searches in Region 7 were not timely, complete, or well
documented, resulting in unnecessary costs and delays in getting polluters to accept responsibility
for cleaning up their hazardous waste sites. Searches for three of five National Priorities List (NPL)
sites reviewed and three of four non-NPL sites reviewed exceeded the Superfund program
standard time frames. Also, we could not find many of the work assignments, statements of work,
work plans, documentation of completed tasks, and search reports.
Follow-up Findings
The Region attempted to address the intent of the audit report recommendations by improving PRP
search acquisition practices, management controls, and focusing contractor work assignments on
essential search activities. However, the Region did not accomplish all the actions in its
implementation plan responding to our audit recommendations.
The Region was unable to demonstrate effective monitoring or improved timeliness of PRP
searches and could not provide a complete list of searches conducted and in progress. Our
analysis of a PRP search report indicated that non-NPL searches were averaging 22 months to
complete even though the EPA standard was for such searches to take no more than six months.
In addition, the Region had not performed any extensive searches since fiscal 1992.
Although the Region developed new procedures, its staff did not always implement them and had
not improved search file documentation. The eight PRP search files we reviewed did not contain
adequate documentation to support search decisions.
Follow-up Recommendations
We recommended that the Regional Administrator, Region 7, direct the Acting Superfund Division
Director to:
• Establish effective procedures to monitor PRP search timeliness and documentation;
and
-------
EPA Office of the Inspector General Annual Superfund Report to the Congress for Fiscal 1995,- 25
• Improve the cost effectiveness of PRP searches through better contracting methods,
conducting searches in-house, and developing procedures to monitor contractor
efforts.
What Action Was Taken
We issued our final report (5400032) to the Regional Administrator, Region 7, on January 17, 1995.
In responding to the draft report, the Acting Assistant Regional Administrator generally agreed with
our findings and recommendations. Corrective actions by the Region included evaluating PRP
search timeliness and documentation on a quarterly basis, using its civil investigators to conduct
searches, and providing contract training to work assignment managers. Therefore, we needed no
further response and closed our final report upon issuance.
Superfund Cost Estimates May Be Unreliable
Findings in Brief
EPA used outdated cost factors which may have substantially underestimated response
costs and budgets for Superfund sites. Further, the incompatibility of management
information systems may have limited managers' abilities to properly monitor the Superfund
program.
Background
For each event in the Superfund cleanup process, EPA developed cost factors for budgeting funds.
A cost factor is the amount of funds the Agency plans to spend on a cleanup event such as a
Remedial Investigation/Feasibility Study (RI/FS), Remedial Design (RD), Remedial Action (RA), or
oversight of RD/RA performed by potentially responsible parties. EPA used the Comprehensive
Environmental Response, Compensation, and Liability Information System (CERCLIS), the
Integrated Financial Management System (IFMS), and its predecessor, the Financial Management
System (FMS), to track Superfund cost data.
We Found That
In the three years before our review, the Agency had not updated the RI/FS, RD, and RD/RA
oversight cost factors used to estimate funding needs for the Superfund program. As a result, EPA
may have understated the ongoing program costs and did not account for the wide range of costs
associated with Superfund site cleanups. The Agency used the same cost factors for relatively
inexpensive cleanups (less than $1 million) and mega-site cleanups (more than $100 million), even
though a single cost factor may not be appropriate for every site.
In addition, the Agency could not provide cost information for each event in the Superfund cleanup
process because of the incompatibility of CERCLIS, IFMS, and FMS. Consequently, managers
. may not have had the information needed to effectively oversee the Superfund program. Since
EPA had initiated efforts to improve the compatibility of the information systems, we did not make
any recommendations for corrective actions regarding the systems.
We Recommended That
The Assistant Administrator for Solid Waste and Emergency Response:
• Review and update the current Superfund cost factors for RI/FS, RD, and RD/RA
oversight to more accurately reflect ongoing costs; and
• Consider using a tiered approach for cost factors to allow for more accurate
Superfund budget requests.
-------
EPA Office of the Inspector Oeneraf Annual Superfurtd'Repbrt to the Congress for Fiscal 1995 26
What Action Was Taken
We discussed our findings with Agency officials during the review and developed our
recommendations in consultation with the Agency before we wrote our draft report. As a result,
Agency officials agreed to implement the proposed corrective actions and we closed our report
(5700005) upon issuance on August 31, 1995.
Region 9 Pilot Projects Sped Site Assessments
Findings in Brief . ,_ . ....
Region 9 pilots integrating Superfund site assessment activities significantly improved the
timeliness and cost effectiveness of the site assessment process.
Background
Region 9 initiated a Superfund pilot program, termed SWIFT, which integrated Superfund
preliminary assessments (PAs) and site inspections (Sis) to speed up the site assessment process
and eliminate duplicate activities. Under the SWIFT pilot, each site had only one contractor and
one project manager during the site assessment process. In addition, Region 9 participated in the
Superfund Accelerated Cleanup Model (SACM) with the SWIFT-ER pilot program. This program
added an expanded PA for earlier decision-making on potential site listings, and an Integrated
Assessment (IA) which expanded the SI with multi-program data gathering.
We Found That
Region 9 completed SWIFT site assessments in an average of 8.5 months compared to 31.7
months under the previous methodology, and the average cost of a SWIFT PA/SI was $11,856
compared to $38,71,0 for pre-SWjFT site assessments. These savings were due primarily to
continuous site assessment activities and combining the PA and SI into a single publication.
SWIFT-ER pilot projects were more costly than SWIFT projects due to additional sampling and
analyses. However, they were still less expensive than pre-SWIFT PA/Sls. Early involvement of
Regional Decision Teams in the site assessment process could prevent some sites from
proceeding to the more expensive IA phase, thus avoiding expenditure of limited Superfund
resources. Also, Region 9 needed to improve the quarterly reports it submitted to the Superfund
Revitalization Office (SRO) to better inform the SRO of the effectiveness of SACM pilots. This
would provide opportunities for other offices to implement program improvements.
We Recommended That
Since the pilot projects were meeting their goals and objectives, we made no formal
recommendations.
What Action Was Taken
We issued our final report (5400018) to the Regional Administrator, Region 9, on November 28,
1994.
-------
EPA Office of the Inspector General Annual Superfund Report to the Congress for Fiscal 1995 27
INVESTIGATIVE ACTIVITY
During fiscal 1995, our Superfund investigative efforts resulted in two indictments and four
convictions. In addition, OIG investigations led to six civil/administrative actions. At the end of
fiscal 1995, we had 56 active Superfund investigations, 31 percent of all active EPA OIG
investigations.
The OIG Office of Investigations (Ol) has undertaken a major proactive investigative effort with
respect to the Superfund program, with a special emphasis on contracting activities as they relate
to removals and remediation. As a result of Ol proactive efforts in prior years, criminal
investigations continue to be initiated nationwide. We expect a rise in significant civil actions as a
result of Ol's increasing investigative emphasis on major Agency contracting.
Firm Repays Contract Costs for Pollution Liability Insurance False Claim
The Department of Justice's Civil Division, working with attorneys from EPA's Office of General
Counsel, negotiated a civil settlement agreement with Riedel Environmental Services, Inc. (RES),
and its new owner, Canonie Environmental Services, Inc. Under the agreement, RES and Canonie
agreed to pay the Government $2,800,000 over three years, plus accrued interest, to resolve a
case the Government brought under the False Claims Act. The $2,800,000 settlement includes
repayment of the full contract price of approximately $2,500,000 and OIG audit, investigative, and
prosecutive costs.
The OIG audit and investigation revealed that RES had failed to disclose the existence of a
quotation for pollution liability insurance during the negotiation and award of a multi-year EPA
Superfund contract. We also found that RES continued to receive payments from EPA for pollution
self-insurance even after RES purchased pollution liability insurance.
Civil Settlement for False Claim
EPS Analytical Services of Canton Mississippi, an EPA subcontractor, paid $5,000 in a civil
settlement on charges of submitting false claims for payments to EPA. EPS, a subcontractor to
OHM, the prime contractor on the Southeast Wood Processing Superfund site cleanup, was
charged with making false claims for payment for soil sample analysis that did not comply with EPA
specifications.
Firm Owner Sentenced for False Certifications
After pleading guilty to theft of government property in January 1995, Robert Lestuk, President and
owner of Unicon, Inc., was sentenced to two years probation and 100 hours of community service,
and fined $2,000. Unicon agreed to make restitution for $141,000. The actions stemmed from an
allegation that Unicon, a subcontractor responsible for the installation of metal tank covers and a
vapor emission system at the Helen Kramer Landfill Superfund site in Mantua Township, New
Jersey, submitted false certifications with respect to hazardous materials training required by the
contract. The EPA OIG and the Department of Defense Criminal Investigative Service jointly
investigated this case.
Lab Sentenced for Falsified Test Results
Eureka Laboratories, Inc., of Sacramento, California, and two of its principal managers were
indicted on 71 counts of making false documents and filing false claims. Eureka Laboratories is an
analytical services laboratory hired by various government agencies, including EPA, the Army, the
Air Force, and the Navy, to test numerous water, soil, and air sampjes for environmental pollutants
and toxins in connection with the remediation of hazardous waste sites. Contractually required
quality control methods identified specific laboratory procedures, such as tuning, calibration, and
performance testing of laboratory equipment, designed to ensure that the data produced were
accurate and reliable.
-------
EPA Office-of the Inspector General'Annual Superfurfd~Report to the'Congrbss^for Fiscal 1995 28
The indictment alleges that the defendants routinely used sophisticated computer software
commands to make it falsely appear that Eureka had properly calibrated and maintained its
laboratory equipment. Further, Eureka concealed its fraudulent manipulations of the data by
removing various computer-generated "flags" or identifiers from the documents it delivered to its
government clients. Because of the alleged fraudulent practices, the accuracy and reliability of the
test results were compromised. -
Eureka pled guilty, and two principal managers were found guilty after a jury trial. Eureka was
sentenced in December 1995 and ordered to pay a $1,500,000 criminal fine over 5 years,'pay
restitution of $322,442 to the government, and pay a special assessment fine of $1,600. Eureka
was also placed on probation for 60 months which included terms and-condrtions restraining the
company form transferring assets. The first manager was sentenced to 5 months in prison, 5
months in a community detention center, 36 months probation, a special assessment fine of $400,
and 250 hours of community service. The second principal manager was sentenced to 24 months
in prison, 36 months probation, a special assessment fine of $400, and 250 hours of community
service.
The EPA OIG, the U.S. Army Criminal Investigation Command, the U.S. Air Force Office of Special
Investigations, and the California Environmental Protection Agency jointly investigated this case.
-------
EPA Office of the Inspector General Annual Superfund Report to the Congress for Fiscal 1995 29
SUPERFUND REVIEW REPORTS
ISSUED DURING FISCAL 1995
Exhibit 1
Page 1of7
Internal and Management Audits and Special Reviews
Final
Report
Number Description
Date
Audit Report
Control Number Issued
Reviews Related To Statutory Requirements (other than Inspector General Act)
5100192 Financial Statements - Fiscal 1994 - All EPA '
5100262 Financial Statements - Fiscal 1994 - Cincinnati
5100216 Financial Statements - Fiscal 1994 - Region 5
5400090 RI/FS Review - Better Brite. WI
5400040 RI/FS Review - Circuitron Corp.. NY
5400022 RI/FS Review - FCX Sites. NC
5400042 RI/FS Review - Linemaster Switch. CT - DART
E1SFL4-20-8001
E1SFL4-23-8000
E1SFL4-05-8000
E1SGG5-14-0007
E1SGG4-14-0011
E1SGG4-14-0008
E1SGG4-14-0010
2/28/95
4/ 5/95
3/17/95
8/ 3/95
21 7/95
12/ 6/94
2/16/95
Other Performance Audits
5100250 Budget Execution - Region 7
5100483 Contracting for Analytical Support
5100515. Envir. Services Asst. Team Zone 1 Contract Management
5100229 Five-Year Reviews Management
5100505 Oversight of Data QA at Federal Facilities
Follow-Up Reviews
5400014 Performance Measures Follow-up
5400032 PRP Searches in Region 7 Follow-up
Other Special Reviews
5400035 Administrative Improvements - Region 10
5400024 Base Closures Pilot - Region 5
5400100 Cleanup Barriers - Cost Factors
5400087 Coordination with Nat'l Inst. of Env. Health Sciences
5400034 Field Sampling Activities - Region 8
5400029 RREL-RCB Administrative Support Contract
5400018 SWIFT Pilot - Region 9
E1SFF4-07-0066
E1SKF4-07-0053
E1SKF5-02-0010
E1SFF4-11-0029
E1SKF5-09-0031
E1SFG5-11-5005
E1SJG4-07-0050
E1SFG4-
E1SFG4-
E1SFB5-
E1SFB5-
E1SKG4-
E1SKF4-
E1SFG4-
10-0078
05-0250
11-0008
11-0014
08-0045
02-0059
09-0028
3/31/95
9/18/95
9/29/95
3/24/95
9/26/95
11/15/94
1/17/95
1/31/95
12/16/94
9/ 6/95
8/ 1/95
1/27/95
1/12/95
11/28/94
-------
EPA Office of the Inspector General Annual Super-fund Report to the Congress for Fiscal 1995 30
Exhibit 1
Page 2 of 7
SUPERFUND REVIEW REPORTS
ISSUED DURING FISCAL 1995
Final
Report
Number Description
Cooperative Agreements
5300027 CA Department of Health - McColl Site
5100526 Clark Atlanta Uuniversity - Policy/Education/Research
5100198 Columbia University - Research
5100489 DE Dept. of Natural Resources & Environmental Control
5100490 FL Department of Environmental Protection - PA/SI
5100144 IL Environmental Protection Agency
5100429 IN Department of Environmental Management
5300012 LA Dept. of Environ. Quality . - Old Tnger/Multi-site
5100491 Lamar University-Gulf Coast Hazardous Research Center
5100220 RI Dept. of Environ. Management-Core/PA/SI/Multi-site
5400044 WV Office of Waste Management
Grants
5400084 Alviso, CA. Technical Assistance Grant
5300035 NC State Univ. -Hazardous Substance Research Center
Interagency Agreements
5100488 Agency for Toxic Substances & Disease Registry - FY93
5100140 Army Corps of Engineers - Fiscal 1993
5100433 Bureau of Mines - Fiscal Years 1992 and 1993
5100136 Bureau of Reclamation - Fiscal 1993
5100431 Federal Emergency Management Agency - Fiscal 1993
5100137 Justice Department - Fiscal 1993
5100487 Nat'l Inst. for Env. Health Sciences - Fiscal 1993
5100138 U.S. Geological Survey - Fiscal 1992
5100432 U.S. Geological Survey - Fiscal 1993
Audit
Control Number
S5BGN3-09-0140
E5BKL4-04-0243
E5CKL4-02-0134
E5FFL5-03-0177
E5CGL4-04-0036
E5FGF4-05-0261
E5FGF5-05-0047
E5BGN4-06-0075
E5BJL4-06-0164
E5FGL4-01-0132
•E5BGG4-11-0035
E5BGP4-09-0196
E5CKN5-24-0013
/
H5BFL5-11-0028
M5BFL5-11-0013
M5BFL5-11-0024
M5BFL5-11-0011
M5BFL5-11-0025
M5BFL5-11-0012
H5BFL5-11-0027
M5BFL4-11-0037
M5BFL5-11-0023
Date
Report
Issued
" '*
8/ 1/95
9/30/95
3/ 6/95
9/19/95
9/19/95
1/31/95
7/26/95
3/30/95
9/20/95
3/22/95
3/23/95
7/31/95
9/28/95
9/19/95
1/18/95
7/26/95
1/11/95
7/26/95
1/11/95
9/19/95
1/11/95
7/26/95
-------
EPA Office of the Inspector General Annual Superfund Report to the-Congress for Fiscal 1995 31
SUPERFUND REVIEW REPORTS
ISSUED DURING FISCAL 1995
Exhibit 1
Page 3 of 7
Contract Audits
Final
Report
Number Description
Date
Audit Report
Control Number Issued
Initial Pricing Reviews
5100221 AEPCO. Inc.. MD
5100082 Aguirre Engineers. Inc.. CO
5100201 Aguirre Engineers, Inc.. CO
5100245 Arthur D. Little, Inc.. MA - Subcontract to Techlaw
5100073 A.T. Kearney. Inc. . IL
5100013 B & V Waste Science & Technology. MO
5100023 B & V Waste Science & Technology. MO
5100024 B & V Waste Science & Technology. MO
5100025 B & V Waste Science & Technology, MO
5400062 Battell e Memorial Institute. OH
5100352 Black and Veatch, MO
5100227 Bral Environmental Services. MO
5100185 C.C. Johnson & Malhotra. MD
5100186 COM Federal Programs Corp. , VA
5100234 Chugach Development, AK
5100290 Del on. Hampton & Associates. DC - Subcontract
5100128 Dynamac Inc.. MD
5400039 Ecology & Environment, Inc. NY
5400043 Ecology & Environment, Inc. NY
5400016 Ecology & Environment. Inc. NY - Rate Review
5400012 Ecology & Environment. Inc. NY - Region 3 Site Asst.
5400056 Ecology & Environment, Inc. -NY - START Region 7
5400061 Ecology & Environment. Inc. NY - START Region 10
5100238 Eder Associates. NY
5100211 Entech. Inc.. GA
5100063 Environmental Issues Management. WA
5400047 Environmental Quality Management, Inc.. OH
5100062 Enviros. WA
.5100256 Enviroscience. MN - Sub. to Ecology & Environment
5100058 ESA Consultants. MT
5100061 EVS Consultants. WA
5100206 Groundwater Tech. Gov't Services. PA - Subcontract
5100130 Half f Associates. TX
5100080 Harris Group. Inc. . WA . •
5100096 Harris Group, Inc.. WA
5100322 Harris Group. Inc.. WA
5100286 -Hazel ean Corp.. MS
5300010 Herrera Environmental Consultants. WA
5400103 ICF Corp.. VA
5100461 Integrated Laboratories. NC
5100093 James Grant & Associates. Inc., CO
5100094 James Grant & Associates, Inc.. CO
D9AFL5-03-0094 3/22/95
D9AKL5-08-0017 11/17/94
D9AGL5-08-0025 3/ 7/95
D9AGL5-01-0058 3/30/95
D9AJL5-05-0019 11/14/94
D9AGL4-07-0081 10/17/94
D9AGL4-07-0081 10/20/94
D9AGL4-07-0081 10/20/94
D9AGL4-07-0081 10/20/94
D9AKP5-05-0070 3/31/95
D9AKL5-07-0027 6/ 6/95
D9AKL5-07-0025 3/24/95
D9AGL5-03-0085 2/17/95
D9AGL5-03-0082 2/17/95
D9AKL5-10-0030 3/29/95
D9AFL5-03-0089 4/19/95
D9AFL5-03-0042 12/29/94
E9AFP5-02-0511 21 6/95
E9AFP5-02-0512 2/22/95
E9AGP5-02-0504 11/22/94
E9AGP4-02-0180 III 4/94
E9AFP5-02-0518 3/27/95
E9AFP5-02-0517 3/30/95
D9AFL5-02-0093 3/30/95
D9AGL5-04-0066 3/16/95
D9AJL5-10-0009 III 9/94
E9AHP5-23-0005 3/ 9/95
D9AJL5-10-0010 117 9/94
D9AKL5-05-0058 47 5/95
.D9AGL5-10-0008 117 4/94
D9AGL5-10-0012.11/ 9/94
D9AFL5-03-0095 3/10/95
D9AKL5-06-0019 11 4/95
D9AKL5-08-0015 11/17/94
D9AKL5-08-0015 11/29/94
D9AKL5-08-0015 5/22/95
D9AGL5-04-0068 4/17/95
D9AKN5-10-0032 3/29/95
E9AFP5-22-0254 9/19/95
D9AKL5-04-0130 8/16/95
D9AKL5-08-0014 11/29/94
D9AKL5-08-0014 11/29/94
-------
EPA Office of the Inspector General Annual Superfund Reportto the Congress for Fiscal 1995 32
SUPERFUND REVIEW REPORTS
ISSUED DURING FISCAL 1995
Exhibit 1
Page 4 of 7
Contract Audits (continued)
Final
Report
Number Description
Date
Audit Report
Control Number Issued
Initial Pricing Reviews (continued)
5100392 Labat-Anderson, Inc.. VA - Hotline and Training
5100248 Leggette. Brashears & Graham, CT
5100072 Life Systems. Inc., OH - Subcontract to Techlaw
5100288 .Lockheed Environmental Systems, TX
5100460 Lockheed Environmental Systems, TX - Eastern
5100452 Lockheed Environmental Systems. TX - Western
5100236 Louis Berger & Associates. NJ - Techlaw Subcontract
5400067 Malcolm Pirnie. Inc.. NY
5400077 Malcolm Pirnie, Inc.,. NY - Naval Fac. Eng. Command
5400081 Malcolm Pirnie, Inc., NY - Navy Chesapeake Engineering
5100498 Mantech Env. Technologies, VA - Subcontract to 10-
5100454 Midwest Research Institute, MO
5100355 Morrison Knudsen Corp. Environmental, CO
5100387 Morrison Knudsen Corp. Environmental, CO
5100427 Morrison Knudsen Corp. Environmental, CO
5100252 MSE. Inc., MT - Accounting System
5100283 MSE, Inc.. MT - Subcontract Proposal
5100049 OHM Remediation, OH - Subcontractor to URS Consultants
5100075 Olympus Environmental, WA
5100268 Olympus Environmental, Wa
5100181 -Pacific Western Technologies. CO
5400092 PRC Environmental Management. IL - AMMSS Las Vegas
5400038 PRC Environmental Management. IL - PCHEM TECH
5400053 PRC Environmental Management, IL - Region 10
5400078 PRC Environmental Management. IL - START
5100098 Precision Environmental. GA
5100099 Precision Environmental, GA
5100473 Quanterra Environmental Services. CO
5100412 Remediation Technologies. MA
5100195 Research Management. CA
5100499 Resource Applications. Inc.. VA
5100281 Rhoads Engineering, Inc., PA - Subcontractor
5100500 Roy F. Weston, PA-Sub. to Midwest Research Institute
5100085 Sanford Cohen & Associates, VA
5100205 Sanford Cohen & Associates. VA
5100145 Science Applications International Corp.. CA
5100374 Science Applications International Corp.. CA
5100225 Scientex Corp., VA - Subcontractor to Dynamac
5100112 SCS Engineers. CA
5100239 Stone & Webster Environmental Technologies, MA
D9AFL5-03-0206 6/30/95
D9AFL5-01-0063 3/30/95
09AKL4-05-0316 11/14/94
D9AKL5-06-0032 4/17/95
D9AKL5-06-0046 8/15/95
D9AKL5-06-0047 8/ 9/95
D9AGL5-02-0092 3/30/95
E9AHP5-02-0'414 4/28/95
E9AFP5-02-0415 6/26/95
E9AFP5-02-0416 7/24/95
D9AFL5-03-0330 9/22/95
D9AGL5-07-0031 8/10/95
D9AGL5-08-0028 6/ 9/95
D9AGL5-08-0028 6/27/95
D9AGL5-08-0028 7/21/95
D9AGL5-08-0029 3/31/95
D9AGL5-08-0029 4/17/95
D9AGL4-05-0295 III 2/94
D9AJL5-10-0007 11/16/94
-D9akl5-10-0031 4/ 7/95
D9AGL5-08-0027 2/13/95
E9AKP5-05-0157 8/10/95
E9AKP5-05-0051 21 3/95
E9AKP5-05-0090 3/24/95
E9AKP5-05-0132 6/28/95
D9AKL5-04-0052 11/29/94
D9AKL5-04-0051 11/29/94
D9AGL5-08-0040 8/23/95
D9AFL5-01-0124 7/11/95
D9AGL5-09-0041 2/28/95
D9AFL5-03-0332 9/22/95
D9AFL5-03-0120 4/14/95
D9AFL5-03-0328 9/22/95
D9AFL5-03-0030 11/28/94
D9AFL5-03-0093 3/10/95
D9AGL5-09-0036 1/31/95
D9AKL5-09-0070 6/20/95
D9AFL5-03-0044 3/24/95
D9AJL5-09-0033 12/ 9/94
D9AKL5-01-0061 3/30/95
-------
EPA Office of the Inspector General Annual Superfund Report to the Congress for Fiscal 1995 33
SUPERFUND REVIEW REPORTS
ISSUED DURING FISCAL 1995
Exhibit 1
Page 5 of 7
Contract Audits (continued)
Final
Report
Number Description
Date
Audit Report
Control Number Issued
Initial Pricing Reviews (continued)
5100014 Sverdrup Environmental . Inc. MO
5100026 Sverdrup Environmental . Inc. MO
5100027 Sverdrup Environmental . Inc. MO
5100028 Sverdrup Environmental . Inc. MO
5100039 Sverdrup Environmental , Inc. MO
5100040 Sverdrup Environmental , Inc. MO '
5100041 Sverdrup Environmental , Inc. MO
5100071 Sverdrup Environmental. Inc. 'MO
5100188 Sverdrup Environmental. Inc. MO
5100219 Techlaw, Inc.. VA
5100255 TN Associates, WI - Sub. to Ecology & Environment
5100095 Toeroek Associates. Inc.. CO
5100242 URS Consultant Corp.. NJ - Subcontractor
5100097 Vertac Site Contractors. AR - Subcontractor to URS
5100259 Virogroup. Inc.. FL
5100081 Watkins Johnson Environmental. CO
5100282 Western Technology & Engineering. MT '
Interim Audits
5100015 Bechtel National. Inc.. CA - Calendar 1991
5100090 Booz, Allen & Hamilton. MD - 4/90-3/91
5100379 Booz, Allen & Hamilton, MD - 4/91-3/92
5100440 COM Federal Programs Corp. . VA - 1990/91
5100113 CET Environmental Services, CA - Fiscal 1991
5100527 CH2M Hill. Inc.. OR - REM IV - 1985-86
5100232 CH2M Hill. Inc.. OR - REM/FIT - 1985-86
5100533 CH2M Hill. Inc.. OR - TECH 1 - 1985-86
5100011 DPRA. Inc.. KS - Disclosure Statement
5100531 DPRA. Inc., KS - Fiscal 1992
5100129 Dynamac, Inc.. MD - Calendar 1990-92
5100047 Ebasco Services. Inc.. NY - Fiscal 1991
5100122 Ecology & Environment, Inc., NY - Fiscal 1988
5100036 Equity Assoc.. Inc., TN-Supp. Serv.-CERI-Fiscal 1990
5100009 Equity Assoc., Inc., TN-Supp. Serv.-CERI-Fiscal 1991
5100037 Equity Assoc. . Inc., TN-Supp. Serv.-CERI-Fiscal 1992
5100334 Fluor Daniel, Inc.. TX - ARCS
5100480 Four Seasons Industrial Services, NC - ERCS
5100333 H+GCL. Inc., NM - Fiscal 1991 - Subcontractor
5400045 ICF Corp.. VA - Estimating System
5100001 Jacobs Engineering Co.. CA - Fiscal 1991
5100078 Lockheed Environmental Systems, TX - ESAT Zone 1
5100213 Mantech Research. NC-Technical Support - Fiscal 1991
5100193 Mantech Technology. NC - Fiscal 1990
5100194 Mantech Technology. NC - Fiscal 1991
D9AGL4-07-0082 10/17/94
D9AGL4-07-0082 10/20/94
TJ9AGL4-07-0082 10/20/94
D9AGL4-07-0082 10/20/94
D9AGL4-07-0082 10/26/94
D9AGL4-07-0082 10/26/94
D9AGL4-07-0082 10/26/94
D9AGL4-07-0082 11/14/94
D9AGL5-07-0019 2/17/95
D9AGL5- 0.3 -0086 3/22/95
D9AKL5-05-0057 4/ 5/95
D9AKL4-08-0073 11/29/94
D9AGL5-02-0091 3/30/95
D9AKL3-06-0187 11/29/94
D9AGL5-04-0065 4/ 5/95
D9AKL5-08-0016 11/17/94
D9AGL5-08-0030 4/17/95
D9BGL3-09-0111 10/17/94
D9BFL4-03-0225 11/28/94
D9BFL2-03-0579 6/26/95
D9BFL2-03-0415 7/28/95
D9BGL5-09-0034 12/ 9/94
E9BGL5-10-0024 9/29/95
E9BGL3-10-0110 3/28/95
E9BGL5-10-0025 9/29/95
D9BJL4-07-0061 10/11/94
D9BJL3-07-0100 9/29/95
D9BFL3-03-0168 12/29/94
D9BFL5-02-0038 III 2/94
P9BGL1-02-0155 12/23/94
D9BKL5-04-0028 10/26/94
D9BKL3-04-0348 10/ 7/94
D9BKL3-04-0349 10/26/94
D9BGL4-06-0110 5/31/95
D9BHL3-04-0317 9/11/95
D9BKL5-06-0040 5/31/95
E9BFP3-22-0314 2/27/95
D9BGL2-09-0142 10/ 3/94
D9BFL4-01-0175 11/17/94
D9BKL4-04-0116 3/16/95
D9BKL5-04-0077 2/24/95
D9BKL5-04-0078 2/24/95
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EPA Office of the Inspector General 'Annual Superfund Report to the Congress for Fiscal 1995 34
SUPERFUND REVIEW REPORTS
ISSUED DURING FISCAL 1995
Exhibit 1
Page 6 of 7
Contract Audits (continued)
Fi nal
Report
Description
Date
Audit Report
Control Number
Interim Audits (continued)
5400015 OHM Remediation. OH - Fiscal 1987
5400020 OHM Remediation. OH - Fiscal 1988
5400025 OHM Remediation. OH - Fiscal 1989
5400027 OHM Remediation. OH - Fiscal 1990
5400031 OHM Remediation. OH - Fiscal 1991
5100067 PC Engineering, TN-Fiscal 1991-Sub. to Equity Assoc.
5100030 Roy F. Weston. PA - Calendar 1991
5100189 S-Cubed, CA - .Fiscal 1990-91
5100369 S-Cubed, CA - Fiscal 1992-93
5100228 Science Applications International Corp.. CA - MOSES
5100353 Shannon & Wilson. WA - Fiscal Years 1991-93
5100348 Southwest Research Institute. TX - Fiscal 1993
5100380 Techlaw, Inc.. VA - Enforcement Contract/subcontracts
5100139 Unisys Gov't Systems. VA - 1990 NDPD Support
5100466 Unisys Gov't Systems. VA - 1990 NDPD Support
5100462 Unisys Gov't Systems. VA - 1987 RTP Facilities/NDPD
5100465 Unisys Gov't Systems. VA - 1988. RTP Facilities/NDPD
5100459 URS Consultant Corp.. CA.-. Fiscal 1991
5100287 Vertac-VSC. TX - ARCS - Subcontractor to URS
5100005 Viar, VA - Fiscal 1990
5100184 Viar. VA - Fiscal .1991-92
Final Audits
5100301 Burlington. Environmental. IL - ARCS Region 5 Sub.
5100532 DPRA. Inc.. KS - Fiscal 1993
5300020 Environ. Health. Research & Testing. KY - Region 3
5100420 Evaluation Technologies. VA - State Training
5100117 Geo/Resource Consultants. Inc.. CA - Hotline
5100043 Mitre Corp.. MA - National Priorities List Program
5100319 Roy F. Weston. PA-ARCS Region 2 - Fiscal 1989-91
5100395 Roy F. Weston. PA-ARCS Region 4-Fiscal Years 1989-91
5100354 Sverdrup Civil, Inc., MO - Timekeeping
5100493 Sverdrup Environmental. Inc., MO - ARCS - Fiscal 1992
5100503 Sverdrup Environmental, Inc., MO - ARCS - 1991/2
5100504 Sverdrup Environmental, Inc., MO - ARCS - 1993
5100160 Washington Consulting Group. DC-Statistical Analysis
"v
E9BHP4-23-0002 11/18/94
E9BHP4-23-0003 121 6/94
E9BHP4-23-0004 12/14/94
E9BHP4-23-0005 12/22/94
E9BHP4-23-0006 1/13/95
D9BKL5-04-0035, 11/10/94
D9BFL2-03-0403 10/24/94
D9BGL2-09-0154 2/17/95
D9BGL4-09-0094 6/15/95
D9BGL5-09-0048 3/24/95
D9BGL5-10-0013 6/ .6/95
D9BKL4-06-0074 6/ 5/95
D9BFL4-03-0172 6/26/95
D9BFL2-03-0583 1/13/95
D9BFL5-03-0307 8/18/95
D9BFL5-03-0312 8/17/95
D9BFL5-03-0306 8/18/95
D9BGL5-09-0113 3/30/95
D9BGL5-06-0020 4/17/95
D9BFL5-03-0031 107 6/94
D9BFL3-03-0316 2/17/95
D9CFL4-05-0021 4/26/95
D9CJL3-07-0162 9/29/95
E9CHN4-04-0227 11 5/95
D9CFL5-03-0331 7/21/95
D9CGL5-09-0032 12/20/94
D9CKL4-01-0189 III 2/94
D9CFL5-03-0050 5/22/95
D9CFL3-03-0373 6/30/95
D9CGL4-07-0076 6/ 7/95
D9CGL4-07-0040 9/21/95
D9CGL4-07-0076 9/22/95
D9CGL4-07-0076 9/25/95
D9CFL5-03-0113 21 9/95
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EPA Office of the Inspector General Annual Superfund Report to the Congress for Fiscal 1995 35
SUPERFUND REVIEW REPORTS
ISSUED DURING FISCAL 1995
Exhibit 1
Page 7 of 7
Contract Audits (continued)
Final
Report
Number Description
Date
Audit Report
Control Number Issued
Indirect Costs
5100125 Ecology & Environment, Inc., NY - Fiscal 1987
5100340 Four Seasons Industrial Services, NC -ERCS
5100481 Morrison Knudsen Corp. Environmental. CO
5100313 PRC Environmental Management,. IL - 1987 TES/REM
'5100079 PRC Environmental Management, IL - Calendar 1992
5100492 Sverdrup Corp. , MCKentral Group-ARCS-Fiscal 1991
5100135 TRC Environmental Consultants, Inc.. CT
System Surveys
5100402 CMC. Inc.. KY
5100218 Community Relations Plus, GA - Subcontractor
5100050 Ebasco Services. Inc.. NY - CAS 401
5400064 Ecology & Environment. Inc.. NY - Accounting Change
5400075 Ecology & Environment. Inc., NY - Disclosure Statement
5100212 Entech-, Inc.. GA
5400066 ICF Corp.. VA - EDP General Application Controls
5300005 ICF Corp.. VA-Labor Floorcheck - Fiscal 1994
5400093 ICF Kaiser Int'l, Inc., VA - CAS 403 - Fiscal 1991/92
5400094 ICF Kaiser Int'l. 'Inc.. VA - CAS 403 - Fiscal 1993/94
5400091 ICF Kaiser Int'l. Inc.. VA - Insurance
5300030 Int'l Technology Corp.. CA.- Labor Cost Allocation
5100175 Marasco Newton Group. Ltd., VA - Timekeeping
5300016 Morrison Knudsen, ID - Financial Capability
5300028 Morrison Knudsen, ID - Financial Capability
5100162 NUS Corp., MD - Remedial Planning - Region 3
5100163 NUS Corp., MD - Hazmat Response Training
5400005 OHM Remediation. OH - Equipment' Utilization
5400104 PRC Environmental Management. IL - Accounting Change
5300003 PRC Environmental Management. IL - CAS 409
5100127 Roy F. Weston, PA - Compensation System
5100102 Roy F. Weston. PA - Estimating System
5100151 Superior Hazardous Waste. WI - ERCS Sub. - Equity
5400074 TRC Env. Consultants. Inc.. CT - Disclosure Statement
5100260 Virogroup, Inc.. FL
Program Reviews
5400004 GET Environmental, Inc.. CA - Labor Floorcheck
5400003 GET Environmental. Inc.. CA - Purchasing System
5300009 CH2M Hill, Inc.. OR - Labor Systems
5400106 Reidel Env. Services, OR - Disclosure Statement
P9DGL1-02-0154
D9DKL2-04-0318
D9DGL5-08-0039
E9DKL4-05-0130
E9DKL4-05-0064
D9DGL3-07-0063
P9DGL2-01-0237
D9EKL5-04-0115
D9EGL5-04-0094
D9EGL5-02-0037
E9EFP4-02-0158
E9EGP5-02-0505
D9EGL5-04-0092
E9EFP3-22-0413
E9EFN4-22-0179
E9EFP4-22-0160
E9EFP4-22-0160
E9EFP4-22-0176
D9EGN5-09-0116
D9EFL5-03-0072
D9EKN5-10-0033
D9EKN5-10-0056
D9EFL5-03-0108
D9EFL5-03-0109
E9EFP4-23-0018
E9EKP5-05-0152
E9EKN4-05-0272
D9EFL5-03-0084
D9EFL5-03-0069
D9EHL5-05-0052
E9EGP5-01-0610
D9EGL5-04-0097
D9FGP5-09-0020
D9FGP5-09-0019
D9FGN5-10-0037
E9FHP5-10-0005
12/28/94
6/ 5/95
9/12/95
5/17/95
11/17/94
9/21/95
I/ 9/95
7/ 7/95
3/21/95
III 2/94
4/10/95
6/19/95
3/16/95
4/19/95
1/10/95
8/16/95
8/16/95
8/ 9/95
8/29/95
2/10/95
5/24/95
8/22/95
21 9/95
21 9/95
10/ 5/94
9/22/95
11/17/94
12/29/94
11/30/94
21 3/95
6/14/95
4/ 5/95
10/ 4/94
10/ 4/94
3/15/95
9/29/95
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EPA Office of the Inspector General Annual Superfund Report to the Congress for Fiscal 1995 36
APPENDIX: ACRONYMS AND ABBREVIATIONS
AK Alaska
AR Arkansas
AMMSS Analytical Methods and Measurements, Systems and Support (EPA contract)
ARCS Alternative Remedial Contracting Strategy .
Assoc. Associates
Asst. Assistance
CA California
CAS , Cost Accounting Standards
CAU Clark Atlanta University
CERCLA Comprehensive Environmental Response, Compensation, and Liability Act of
1980, as amended
CERCLIS Comprehensive Environmental Response, Compensation, and Liability
Information System, the Superfund management information system
CERI Center for Environmental Research Information (EPA)
CFO Chief Financial Officer(s)
CO Colorado
Co. Company
Corp. Corporation
\
CT Connecticut
DART Design Accelerated Remedial Target
DC District of Columbia
DE Delaware
Dept. Department
DOD Department of Defense
EDP Electronic data processing
Eng. Engineering
Env. Environmental
Envir. Environmental
Environ. Environmental
EPA Environmental Protection Agency
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EPA Office of the Inspector General Annual Superfund Report to the Congress for Fiscal 1995 37
ERGS Emergency Response Cleanup Services (EPA contracts)
ESAT Environmental Services Assistance Team (EPA contracts)
Fac. Facilities
FAR Federal Acquisition Regulation
FDEP Florida Department of Environmental Protection
FIFO First-ln First-Out
FIP Federal Information Processing
FIT - Field Investigation Team
FL Florida
FMS Financial Management System
FS Feasibility Study
FY Fiscal Year
GA Georgia
GAO General Accounting Office
GFP Government Furnished Property
Gov't Government
IA Integrated Assessment
ID Idaho
IFMS Integrated Financial Management System (EPA)
IL Illinois
IN Indiana
Inc. Incorporated
Inst. Institute
Int'l International
IRM Information resources management
KS Kansas
LA Louisiana
LDEQ Louisiana Department of Environmental Quality
MA Massachusetts
MD Maryland
MN Minnesota
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EPA Office of the InspectorGeneral Annual Superfund Report to the Congress for Rscal 1995 38
MO Missouri
MOSES . Mission Oriented Systems Engineering Support (EPA contract)
MS Mississippi
MT Montana '
Nat'l National
NC' North Carolina '
NCP National Oil and Hazardous Substances Contingency Plan, 40 CFR Part 300
NJ New Jersey
NM New Mexico
NPL National Priorities List
NPO National Project Officer
NY New York
OH Ohio
Ol , Office of Investigations (EPA OIG)
OIG Office of the Inspector General
OR Oregon '
/
ORC Office of Regional Counsel (EPA)
OSWER Office of Solid Waste and Emergency Response (EPA)
PA Pennsylvania or Preliminary Assessment
PA/SI Preliminary Assessment/Site Inspection
PDD Preauthorization Decision Document
PPAS Personal Property Accountability System
PRP Potentially Responsible Party
QA Quality Assurance
QAPP Quality Assurance Program Plan or Quality Assurance Project Plan
RA Remedial Action
RD Remedial Design
REM Remedial (EPA contracts)
REM/FIT Remedial/Field Investigation Team (EPA contracts)
RES Riedel Environmental Services, Inc.
Rl Remedial Investigation or Rhode Island
-------
EPA Office of the Inspector General Annual Superfund Report to the Congress for Fiscal 1995 39
RI/FS Remedial Investigation/Feasibility Study
ROD Record of Decision
RPM Remedial Project Manager
RPO Regional Project Officer •
RREL-RCB Risk Reduction Engineering Laboratory-Releases Control Branch (EPA)
RTP Research Triangle Park, NC
SACM Superfund Accelerated Cleanup Model
SAP Sampling and Analysis Plan
SARA Superfund Amendments and Reauthorization Act of 1986 _.
SI Site Inspection
SRMAC Superfund Senior Regional Management Acquisition Council (EPA)
SRO Superfund Revitalization Office (EPA)
START Superfund Technical Assessment and Response Team (EPA contracts)
Sub. Subcontract or Subcontractor
Supp. Support
Tech. Technical
TES Technical Enforcement Support (EPA contracts)
TID * Technical Instruction Document
TN Tennessee
TX Texas
Univ. University
U.S. United States
VA Virginia
WA Washington
Wl Wisconsin
WV West Virginia
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