United States
       Environmental Protection
       Agency
            Office of
            Inspector General (2441)
            Washington, DC 20460
May 1995
x>EPA
Office of Inspector General
Semiannual Report
to the Congress

October 1,1994 through
March 31,1995

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  Foreword


                                     Uuring this semiannual reporting period, the Office of
                                 Inspector General continued to perform analyses of EPA
                                 programs and operations and  make constructive
                                 recommendations necessary to help the Agency with its
                                 reinvention process. As part of its strategic plan, EPA has
                                 committed itself to streamlining and a "Common Sense
                                 Initiative" for finding cleaner, cheaper and smarter strategies for
                                 tackling environmental problems. The real challenge of
                                 reinvention and change is a rigorous examination of ways to
                                 reduce costs, assess risks, identify customer needs and
                                 measure performance. Thus, never have the needs and focus of
                                 EPA management been more closely aligned with  the objectives
                                 and mission of the Office of Inspector General.  EPA managers
                                 are seeking our assistance, more than  ever, as evaluators and
                                 management consultants in a  partnership for change to help
                                 implement EPA's strategic plan.

    As exemplified in this report, we are identifying areas where there are vulnerabilities, changes
needed, and opportunities for savings. We have also reported on  areas where EPA has taken
corrective actions, where additional corrective action is needed, and where the Agency is
successfully initiating changes to further environmental goals.  We in the Office  of Inspector
General have also embraced the concept of streamlining and reinvention with decisive action for
greater staff empowerment, operational efficiency, and improved work processes.

    This is a unique time of change throughout government.  I believe that the role of the Inspector
General in identifying opportunities for change, along with the Agency's own initiatives for
promoting needed changes is a potent formula for meaningful reinvention.  This  cooperative
approach and shared commitment is necessary to protect the environment as efficiently and
effectively as possible.
                                     r
                                     \
                                            John C Martin
                                            Inspector General

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  Contents
Executive Summary   .      .            .    .           	
Major Laws Administered by EPA  .                  ...
Profile of Activities and Results         ...
Establishment of the OIG in EPA-lts Role and Authority
Purpose  and Requirements of the Office of Inspector General
       Semiannual Report     ...       .       	
Who's Who in the Office of Inspector General

Section 1-Significant Findings and Recommendations
Costs and Benefits                           . . .
Agency and Financial  Management
Construction Grants
Superfund

Section 2-Report Resolution
Status Report on Perpetual Inventory of Reports in Resolution Process
 for the Semiannual Period Ending March 31, 1995
Audit  Followup
Status of Management Decisions on IG  Reports
Resolution of Significant Reports

Section 3--Prosecutive Actions
Summary of Investigative Activity
Description of Selected Prosecutive and Administrative Actions
Civil and  Administrative Actions to Recover EPA Funds

Section 4-Fraud Prevention and  Management Improvements
Review of Legislation and Regulations
Suspension and Debarment Activities
OIG Personnel Security Program
OIG Management Initiatives
President's Council on Integrity and Efficiency
Committee on Integrity and Management Improvement
Hotline Activities

Appendices

Appendix 1-Reports Issued
Appendix 2-Reports Issued Without Management Decisions
 1
 3
 4
 5

 5
 6
 7
 8
19
22
27
27
30
33
34
35
36
37
38
39
40
42
42
43
44
54

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   Executive  Summary
 Section 1--
 Significant Findings
 and
 Recommendations

 1.  EPA $126 Million Short
 of Congressional User Fee
 Targets

 EPA has not aggressively
 pursued user fee
 opportunities, and has
 collected only $22 million  of
 the congressionally directed
 $148 million in new user fees
 through fiscal 1994 (page 8).

 2.  Millions in Savings
 Possible Through
 Improved Subcontract
 Competition and Oversight

 Prime  contractor actions in
 selecting,  negotiating,  and
 awarding subcontracts, and
 the Agency's review of these
 actions, were not sufficient to
 ensure technically competent
 subcontracts, reasonable
 prices, and effective
 subcontract competition.
 Through improved
 subcontract competition and
 oversight,  contract costs
 could be potentially reduced
 by $55 million  (page 9).

 3.  Interagency Agreements
 Used Without Adequate
 Cost Consideration

 EPA often executed
 Economy Act Interagency
 Agreements (lAGs) without
 considering the
 reasonableness of their
 costs.  In addition, EPA did
 not recover its  full costs of
 performing  work  for other
 agencies (page 10).
4. Region 7 Disregarded
Approved Allocations in
Implementing  Their Budget

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 (page 11).

5. Improved Controls
Needed OverIPA
Assignments

While EPA's
Intergovernmental Personnel
Act (IPA) program has
generally met the intent of
the Act, more than  half of the
IPA assignments we
reviewed had inadequate
management controls
resulting  in excessive costs
and insufficient benefit to
EPA (page 12).

6. Further Actions Needed
to Improve Region 7 Public
Water Systems

Two Region 7 States,
Kansas and Missouri,
brought some small public
water systems  into
compliance with drinking
water regulations by using
innovative preventive
measures.  However,
ineffective data management
systems impeded the States'
abilities to effectively  monitor
compliance and enforcement
actions (page 13).

7. Tribal Program  in
Region 8 Inadequately
Planned

Region 8 had not clearly
identified  Tribal
environmental needs,
established a Regional
workplan and performance
measures, or efficiently
organized its Tribal staff
(page 14).

8. Application Software
Maintenance Needs Further
Improvements

Although EPA has taken
significant steps to
strengthen its management
of application software
maintenance, more needs to
be done to improve system
and software reliability, cost
effectiveness, and decisions
about operational changes
(page 15).

9. Cultural Diversity Goals
Exceeded in  Laboratory
Contractor Conversion

The Health Effects Research
Laboratory's (HERL)
contractor conversion hires
exceeded established
cultural diversity goals for
women and minorities, while
complying with applicable
Federal  and Agency
guidelines for open and
competitive recruitment
(page 16).

10.  Further Improvements
in Financial Reporting
Needed

During fiscal 1994, EPA
continued to make
improvements in its financial
systems and processes. As
a result  of these
improvements and certain
OIG assistance projects, we
issued unqualified  or
qualified opinions on several
financial statements for
which we disclaimed an
opinion last year.  However,
additional improvements are
needed to resolve  several
material internal control
weaknesses before
unqualified opinions can be
rendered on some of the
Agency's financial
statements  (page 16).

11. Los Angeles,
California, Claimed  Over
$30 Million of Ineligible
Costs

The City of Los Angeles,
California,  claimed
$30,487,741 of ineligible
construction, claim
settlement,  and indirect costs
for the  Hyperion wastewater
treatment facility (page 20).

12. Over $19 Million of
Questioned Costs Claimed
for Orangeburg, New York,
Project

The Rockland County Sewer
District,  New York, claimed
$1,721,208  of ineligible
construction, administrative,
and architectural engineering
costs for the construction of
a wastewater treatment
facility.   An  additional
$17,629,638 of unsupported
project  costs were
questioned (page 20).

13. Over $5 Million of
Questioned Costs Claimed
for Bristol,  Connecticut,
Project

The City of Bristol,
Connecticut, claimed
$2,462,057  of ineligible
architectural engineering,
construction, inspection, and
administrative costs for the
design  and  construction of a
wastewater treatment facility.
An additional $2,873,709 of
unsupported costs were
questioned  (page 21).

14. Nearly $2 Million of
Ineligible Costs Claimed
for Vernal,  Utah, Project

The Ashley Valley Sewer
Management Board, Vernal,
Utah, claimed $1,940,493 of
OCTOBER 1, 1994 THROUGH MARCH 31, 1995

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 ineligible engineering and
 construction costs for a
 wastewater treatment facility
 (page 21).

 15.  Higher Priority Needed
 for Reviews of Superfund
 Site Remedies

 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, there
 was an increasing backlog of
 unreviewed  sites (page 23).

 16.  Better Controls
 Needed Over  Region 8's
 Superfund Field Sampling
 Activities

 Region  8 needed better
 sampling controls and quality
 assurance training  of
 remedial project managers
 (RPMs), and more consistent
 RPM oversight at Superfund
 sites (page 23).

 17.  Region 9  Pilot Projects
 Speed Up Site
 Assessments

 Region  9 pilots integrating
 Superfund site assessment
 activities significantly
 improved the timeliness and
 cost effectiveness of the site
 assessment process (page
 24).


 Section  2--Report
 Resolution

 This section, required by the
 IG Act, reports  on the status
 and results of Agency
 management actions to
 resolve audit reports. At the
 beginning of the semiannual
 period, there were  230
 reports for which no
 management decision had
 been made.  During the first
 half of fiscal  1995, the Office
of Inspector General issued
448 new reports and closed
 378.  At the end of the
 reporting period, 300 reports
 remained in the Agency
 followup system  for which no
 management decision had
 been made.  Of the 300
 reports, 119 reports
 remained in the Agency
 followup system  for which no
 management decision was
 made within 6 months of
 issuance (page 26).

 For the 146 reports closed
 that  required Agency  action,
 EPA management disallowed
 $45.5 million of questioned
 costs for recovery and
 agreed with our
 recommendations that $0.2
 million be put to better use
 (page 27).  In addition, cost
 recoveries  in current and
 prior periods included $4
 million in cash collections,
 and at least $27.2 million  in
 offsets against billings
 (page 4).

 Section  3-
 Prosecutive Actions

 During this  semiannual
 reporting period,  our
 investigative efforts resulted
 in 9 convictions and  12
 indictments.  Also, during  this
 semiannual period, our
 investigative work led to $4.2
 million in fines and
 recoveries (page 34).

 Section  4--Fraud
 Prevention  and
 Management
 Improvements

 During this  semiannual
 period, we reviewed 2
 legislative and 69 regulatory
 items.  The most significant
 comments were on draft
 documents  impacting  the
 responsibilities of the
 Inspector General, Federal
Acquisition  Regulation cases,
and Agency information
resources management
policy (page 37).
The Office of Grants and
Debarment completed action
on 26 OIG-generated
suspension and debarment
cases during this reporting
period, resulting in 23
debarments, one suspension,
and two compliance
agreements (page 38).

The EPA Committee on
Integrity and Management
Improvement  (CIMI), chaired
by the Inspector General,
developed and distributed
bulletins to EPA personnel
discussing the use of the
American Express program,
Conferences and Meetings,
and Management and
Disposition of Federal
records (page 42).

Eighteen  Hotline cases were
opened and 31 were closed
during the reporting period.
Of the closed  cases, 7
resulted in environmental,
prosecutive, or administrative
corrective action (page 43).
                                                                                       OFFICE OF INSPECTOR GENERAL

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    Major Laws Administered by  EPA

    Statute

    Pollution Prevention Act



    Toxic Substances Control Act
    Federal Insecticide, Fungicide,
    and Rodenticide Act
    Federal Food, Drug and Cosmetic Act
    Resource Conservation and Recovery Act
    and Solid Waste Disposal Act

    Comprehensive Environmental Response,
    Compensation, and Liability Act
    Clean Air Act
    Clean Water Act
    Safe Drinking Water Act
   Marine Protection, Research and
   Sanctuaries Act

   Asbestos School  Hazard Abatement Act
   and Asbestos Hazard Emergency
   Response Act

   Emergency Planning and Community Right-
   to-Know Act
   Oil Pollution Act of 1990
   Environmental Research, Development, and
   Demonstration Authorization Act

   National Environmental Education Act
Provisions

Provides that pollution should be prevented or reduced at the source,
recycled safely when not preventable, treated safely when not
preventable or recyclable, and as a last resort, disposed of or
otherwise released into the environment in a safe manner.

Requires EPA notification  of any new chemical prior to its
manufacture and authorizes EPA to regulate production,  use, or
disposal of a chemical.

Authorizes EPA to register all pesticides, specify the terms and
conditions of their use, and remove unreasonably hazardous
pesticides from the marketplace.

Authorizes EPA in cooperation with FDA to establish tolerance levels
for pesticide residues on food.

Authorizes EPA to identify hazardous wastes and regulate their
generation, transportation, treatment, storage, and disposal.

Requires EPA to designate hazardous substances that can present
substantial danger and authorizes the cleanup of sites contaminated
with  such substances.

Authorizes EPA to set emission standards to limit the release of
criteria pollutants and hazardous air pollutants.

Requires EPA to establish a list of toxic water pollutants  and set
standards.

Requires EPA to set drinking water standards to protect public health
from hazardous substances.

Regulates ocean dumping of toxic contaminants.
Authorizes EPA to provide loans and grants to schools for abatement
of asbestos hazards and to establish a comprehensive regulatory
framework for controlling asbestos hazards in schools.

Requires States to develop programs for responding to hazardous
chemical releases and requires industries to  report on the presence
and release of certain hazardous substances.

Makes EPA responsible for oil spill prevention, preparedness,
response, and  enforcement activities associated with  non-
transportation-related onshore oil facilities.

Authorizes all EPA research and development programs.
Provide for a program  of education on the environment through
activities  in schools, institutions of higher education and related
educational activities, and to encourage students to pursue careers
related to the environment.
OCTOBER 1, 1994 THROUGH MARCH 31, 1995

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     Profife of ActiMties and  Results
   Office of Inspector General
                                  October 1, 1994, to
                                     March 31, 1995
Audit Operations

OIG Managed Reviews:

  Reviews Performed by EPA, Independent
  Public Accountants and State Auditors
    Questioned  Costs
      Total                              $97.5 Million
      Federal Share *                    $61.5 Million

    Recommended Efficiencies
    (Funds be Put to Better Use)
      Total Efficiencies"                    $0.7 Million
      Federal Share Efficiencies*            $0.7 Million

    Costs Disallowed to be Recovered
      Federal Share (cosfs which EPA
      management agrees are unallowable
      and is committed to recover or
      offset against future payments)       $44.7 Million

    Costs Disallowed as Cost Efficiency
      Federal Share (funds made available
      by EPA management's commitment to
      implement recommendations in OIG
      performance and preaward audits)     $0.1 Million

Other Reviews:

- Reviews Performed by another
  Federal Agency or Single Audit Act Auditors
    Questioned  Costs
      Total                               $1.1 Million
      Federal Share *                     $1.1 Million

   Recommended Efficiencies
     Total Efficiencies*                   $35.7 Million
     Federal Share Efficiencies*           $35.5 Million

    Costs Disallowed to be Recovered
      Federal Share                       $0.7 Million

    Costs Disallowed as Cost Efficiency
      Federal Share                       $0.1 Million
                                  October 1, 1994, to
                                      March 31, 1995
Agency Recoveries:

  Recoveries from Audit Resolutions of
  Current and Prior Periods (cash collections
  or offsets to future payments)**           $ 31.3 Million

Reports Issued:

  OIG Managed Reviews:
    EPA Reviews  Performed by the OIG             82
    EPA Reviews  Performed by Independent Public
    Accountants                                  12
    EPA Reviews  Performed by State Auditors         1

- Other Reviews:
    EPA Reviews  Performed by
    another Federal  Agency                       231
    Single Audit Act Reviews                      122

Total Reports Issued                             448

Reports Resolved (agreement by Agency officials  146
to take satisfactory corrective action)***
investigative Operations
                                          $4.2 Million
                                                 89
                                                 75
                                                 12
                                                  9
                                                 13
    Fines and Recoveries (including civil)
    Investigations Opened
    Investigations Closed
    Indictments of Persons or Firms
    Convictions of Persons or Firms
    Administrative Actions Against EPA Employees

Fraud Detection and Prevention Operations

    Debarments, Suspensions, and Compliance
    Agreements                                   26
    Hotline Cases Opened                         18
    Hotline Cases Processed and Closed             31
    Personnel Security Investigations Adjudicated     320
   *Questioned Costs (Ineligible,  Unsupported,  and Unnecessary/Unreasonable) and Recommended Efficiencies (Funds be Put to
   Better Use) are subject to change pending further review  in the audit resolution process.
   **Information  on recoveries from audit resolution is provided from the EPA Financial Management Division and is unaudited.
   ***Reports resolved are subject to change pending further review.
                                                                                 OFFICE OF INSPECTOR GENERAL

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   Establishment of the  OIG in EPA-lts Role And Authority
The Inspector General Act of
1978 (Public Law 95-452), as
amended, created Offices of
Inspector General to
consolidate  existing
investigative and audit
resources in independent
organizations headed by
Inspectors General.

EPA established its Office of
Inspector General (OIG)  in
January 1980. As an agency
with a massive public works
budget, EPA is vulnerable to
various kinds of financial
abuses. The OIG's role  is to
review  EPA's financial
transactions, program
operations,  contracts, and
administrative activities;
investigate allegations or
evidence of possible criminal
and civil violations; and
promote economic, efficient,
and effective Agency
operations.  The OIG  is also
responsible  for reviewing EPA
regulations  and legislation.

The EPA Inspector General
reports  directly to the
Administrator and the
Congress and has the
authority to:

•  Initiate  and carry out
independent and objective
audits and investigations,
•  Issue subpoenas for
evidence and information,
•  Obtain access to any
materials  in  the Agency,
•   Report serious or flagrant
problems  to Congress,
•   Select and appoint  OIG
employees,
•   Fill Senior Executive Service
positions,
•   Administer oaths, and
•   Enter into contracts.

The Inspector General is
appointed by, and can be
removed only by, the
President. This independence
protects the  OIG from
interference  by Agency
management and
allows it to function  as
the Agency's fiscal and
operational watchdog.

Organization and
Resources

The Office of Inspector
General functions through
three major offices,  each
headed by an Assistant
Inspector  General:  Office of
Audit, Office of Investigations,
and Office of Management.
Nationally, there are eight
Divisional  Inspectors General
for Audit and three Divisional
Inspectors General for
Investigations who direct staffs
of auditors and investigators
and who report to the
appropriate Assistant
Inspector  General in
Headquarters.

For fiscal  1995, the Agency
was appropriated  $7,240,887
and authorized  19,069 full
time equivalent (FTE)
positions to conduct the
environmental programs
authorized by Congress to
restore and protect the
environment. As a separate
appropriation account, the
Office of Inspector General
(OIG) received  $44.5 million to
carry out the provisions  of the
Inspector  General Act of 1978,
as amended. Nearly $15.4
million of the OIG's
appropriation was derived
from the Hazardous
Substance Superfund trust
fund and $669,000 was
derived from the Leaking
Underground Storage Tank
trust fund.  The OIG  has a
funded staffing  level  of 447
FTE positions.
Purpose and
Requirements of the
Office of Inspector
General Semiannual
Report

The Inspector General Act of
1978 (Public Law 95-452), as
amended, requires  the
Inspector General to  keep the
Administrator and Congress
fully and currently informed of
problems and deficiencies in
the Agency's operations and
to recommend corrective
action.
              The IG Act further specifies
              that semiannual reports will be
              provided to the Administrator
              by each April 30 and October
              31, and to Congress 30 days
              later. The Administrator may
              transmit comments to
              Congress along with the
              report, but may not change
              any  part of it.

              The specific reporting
              requirements prescribed in the
              Inspector General  Act of 1978,
              as amended, are listed below.
   Source                                 Section/Page
   Inspector General Act, as amended.
   Section 4(a)(2)

   Section 5(a)(1)


   Section 5(a)(2)



   Section 5(a){3)



   Section 5(a)(4)


   Section 5(a)(5)


   Section 5(a)(6)

   Section 5(a)(7)

   Section 5(a)(8)


   Section 5(a)(9)
Review of Legislation and Regulations    4   37

Significant Problems, Abuses, and
Deficiencies                       1    7

Recommendations with Respect to
Significant Problems, Abuses, and
Deficiencies                       1    7

Prior Significant Recommendations on
Which Corrective Action Has Not
Been Completed            Appendix 2   54

Matters Referred to Prosecutive
Authorities                        3   34

Summary of Instances
Where Information Was Refused         '    *

List of Audit Reports         Appendix 1   44

Summary of Significant Reports         1    1

Statistical Table 1-Reports With
Questioned Costs
Statistical Table 2-Reports With
Recommendations That Funds Be Put
To Better Use
                                   31
                                                    32
   Section 5(a)(10)   Summary of Previous Audit
                 Reports Without Management
                 Decisions
                                         Appendix 2   54
   Section 5(a)(11)   Description and Explanation of Revised
                 Management Decisions        Appendix 2   54

   Section 5(a)(12)   Management Decisions with Which the
                 Inspector General Is in Disagreement     **

   * There were no instances where information or assistance
   requested by the Inspector General was refused during this
   reporting period.

   " There were no instances of management decisions with which the
   Inspector General was in disagreement.
OCTOBER 1, 1994 THROUGH MARCH 31, 1995

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   Headquarters
                              Office of Inspector  General-Who's Who
                                       Inspector General
                                       John C. Martin

                                       Deputy Inspector General  (Acting)
                                       Kenneth A. Konz
           Office of Audit

           Kenneth A. Konz
           Assistant Inspector General

           James 0. Rauch
           Principal Deputy
Office of Management

John C. Jones
Assistant Inspector General
Office of Investigations

Michael J. Fitzsinroons
Assistant Inspector General
                  Policy and Resources
                  Management
                  Kenneth Hockman

                  Engineering and Scientific
                  Assistance
                  Robert Eagen

                  ADP Audits and Assistance
                  Gordon Mil bourn (Acting)

                  Special Projects and Reviews
                  Gordon Mil bourn

               Acquisition and Assistance
               Elissa R. Karpf
                Internal and Performance Audits
                Michael D. Si unions
       Program Management Division
       John T. Walsh

       Resources Management Division
       Michael J. Binder
 Divisional Inspectors General for Audit
                      Divisional Inspectors General for Investigations
 Regions 1 & 2
 Paul McKechnie


 Region 3
 Paul R. Gandolfo


 Regions 4 & 6
 Mary Boyer


 Region 5
 Anthony C. Carrollo


 Regions 7 & 8
 Nikki Tinsley


 Regions 9 & 10
 Truman R  Beeler


 Headquarters:


 HQS Audit Division
 Edward Gekosky


Financial Audit Division
Melissa M  Heist
                                                            Regions 1, 2, & 3
                                                            Thomas Papineau


                                                   Regions 4, 5, 6, 7, 8, 9, & 10
                                                               Allen P. Fallin


                                                   Procurement Fraud Division
                                                           Emmett D. Dashiell
                                                WV
                                                                                   OFFICE OF INSPECTOR GENERAL

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  Section  1 -- Significant Findings and Recommendations
As required by sections 5(a)(1)
and (2) of the Inspector General
Act of 1978, as amended, this
section identifies significant
problems, abuses, and
deficiencies relating to the
Agency's programs and
operations along with
recommendations for the current
period.  The findings described
in this section resulted from
audits and reviews performed by
or for the Office of Audit.  Audit
findings are open to further
review but are the final position
of the Office of Inspector
General.  This section is divided
into three areas: Agency and
Financial Management,
Construction Grants, and
Super-fund.
                 COST BENEFITS OF TOTAL AUDIT EFFORTS
                      OCTOBER 1, 1994 THROUGH MARCH 31, 1995
               (IG AUDIT BUDGET, AUDIT RESULTS, AND EPA MANAGEMENT DECISIONS)
                                       FEDERAL COSTS
                                        QUESTIONED
                                                      EPA DECISIONS TO
                                                      RECOVER FUNDS
                      FY 95 AUDIT BUDGET
                          (Six Months)
OCTOBER 1, 1994 THROUGH MARCH 31, 1995

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Agency and Financial
Management


The Inspector General Act
requires the OIG to initiate
reviews and other activities to
promote economy and efficiency
and to detect and prevent fraud,
waste, and mismanagement in
EPA programs and operations.
Internal and performance audits
and reviews are conducted to
accomplish these objectives
largely by evaluating the
economy, efficiency, and
effectiveness of operations.
During this semiannual reporting
period, the OIG conducted a
number of major  reviews of EPA
programs,  including oversight of
subcontractors, use of
Interagency Agreements and
Intergovernmental Personnel Act
assignments, management of
application software
maintenance, one Region's
budget execution practices,
contractor conversion at an
Agency laboratory, and one
Region's oversight of Tribal
environmental programs.  The
OIG also reported on its audit of
the Agency's fiscal 1994 financial
statements. The  following are
the most significant internal
audit, performance audit, and
special review findings and
recommendations pertaining  to
Agency management resulting
from our efforts during this
semiannual reporting period.
EPA $126 Million Short of
Congressional User Fee
Targets

Findings in Brief

EPA has not aggressively
pursued user fee opportunities,
and  has collected only $22
million of the congressionally
directed $148 million in new user
fees through fiscal 1994.

Background

User fees are charges the Federal
government assesses individuals or
organizations for services or things
of value provided by Federal
agencies.  Office of Management
and  Budget (OMB) guidance
requires Federal agencies to
identify all potential fee programs,
either charge fees  or request
exceptions, and  maintain adequate
documentation supporting
established charges.  The Omnibus
Budget Reconciliation  Act of 1990
(OBRA '90) directed EPA to collect
$187.5 million in new user fees for
fiscal years 1991 through 1995.

We Found  That

EPA had not inventoried its
activities to identify all potential new
user fees because Agency
personnel were not aware of
requirements in updated OMB
guidance.  Officials did not believe
studying new fees was worthwhile
since the Agency cannot keep the
fees  they collect, and the Agency
was  slow in charging fees already
identified.  Further, EPA was
reluctant to use its existing
statutory authority to charge fees
and was $126 million short of its
OBRA '90  targets for fiscal 1991
through  1994 which we estimate
added $88 million to the national
debt. If new fees already identified
and potential new fees identified
during the  audit are charged, EPA
could fulfill its new user fee
obligations.

Because EPA has not sought to
update statutory caps on Pre-
Manufacture Notice (PMN) fees set
in  1976, 18 years of inflation (as of
1994) have effectively lowered the
value of the maximum fees EPA
can charge for PMN processing by
61 percent. If EPA had requested
a timely adjustment for inflation to
fee caps, it could have collected
$4 million more in fiscal 1994
alone.  EPA missed  more revenue
opportunities by not charging
administrative processing fees for
incomplete PMN applications, and
by not updating its 1977 policy to
grant blanket fee waivers for
biological pesticide tolerances.

Program offices had either
insufficient or outdated information
to  support fees charged.  They had
not kept adequate supporting data
because they believed fee
management did not merit
resources and because they felt
that updated support for fees with
rates set by law was unnecessary.
As a result, an April  1994 court
decision concluded that EPA did
not use reasonable care in
developing support for the Motor
Vehicle and Engine Compliance
Program fee.  In addition, the
Agency has no assurance that
Pesticide Tolerance fees cover
program costs.

We Recommended  That

The Chief Financial Officer (CFO):

•  Review EPA's activities, list all
potential fees, and institute charges
or request exceptions from OMB.

•  Develop an action plan to
implement Resource Conservation
and Recovery Act (RCRA) fees and
National Pollutant Discharge
Elimination System fees.
                                                                               OFFICE OF INSPECTOR GENFRAI

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• Encourage using EPA's existing
statutory authority to charge fees,
and make sure all user fees have
adequate supporting
documentation.

The Assistant Administrator for Air
and Radiation evaluate two
potential new fees: certification of
chlorofluorocarbon (CFC) testing
centers and the Acid  Rain  Emission
Credits Program.

The Assistant Administrator for
Prevention,  Pesticides, and Toxic
Substances:

• Initiate a legal review for a
Toxic Release Inventory form
processing fee, and request a
legislative update to PMN fee caps
to include a provision  to charge
administrative fees.

• Revise the Agency's policy for
biological pesticide tolerances to
grant waivers only based on
economic tests, and make sure fee
rates are in line with costs.

What Action Was Taken

The CFO and the Offices of Solid
Waste and Emergency Response
(OSWER), and Water generally
agreed with our conclusions and
recommendations, except that the
OSWER does not plan to dedicate
resources to further develop RCRA
fees.  The Office of Air and
Radiation agreed to implement our
recommendations,  but stated that
the report could better present the
adverse programmatic
consequences that can result from
the imposition of fees.  The Office
of Prevention, Pesticides, and Toxic
Substances did  not agree with our
recommendations and stated that:
(1) increasing fee collection efforts
would divert resources; (2) EPA
would not see the benefits since
fees go directly to the  Treasury or
offset appropriated funds; and
(3) since EPA grants waivers as a
way of providing  incentives for
registering "safer" pesticides (which
biological pesticides generally are),
changing the waiver policy for them
would send the wrong  message to
industry and the  public. We issued
our final report (5100209) on
March 27, 1995.  An Agency
response to the final report is due
by June 26, 1995.

Millions in Savings
Possible Through  Improved
Subcontract Competition
and  Oversight

Findings In Brief

Prime contractor actions in
selecting, negotiating, and
awarding subcontracts,  and the
Agency's review of these
actions, were not sufficient to
ensure  technically competent
subcontracts, reasonable prices,
and effective subcontract
competition. Through improved
subcontract competition and
oversight, contract costs could
be potentially reduced by $55
million.

Background

The Federal Acquisition Regulation
(FAR) requires the use of
competition for Federal contract
and subcontract awards with few
exceptions. The  FAR also provides
guidelines for subcontract awards
and governs the  Agency's oversight
and the prime contractor's
management and use of
subcontracts. In  prior years,  EPA
has reported that up to 99 percent
of its  prime contract dollars were
awarded through  full and open
competition.  However, prior OIG
reports related to certain prime
contracts indicated that the vast
majority of subcontracts were
awarded sole source or through
other noncompetitive procedures.

We Found That

Over 78 percent of the subcontracts
we reviewed were awarded
noncompetitively, and 93 percent of
these were not properly justified.
Contracting officers routinely
approved prime contractor requests
for consent to award a subcontract
sole  source without supporting
documentation.  For the five prime
contracts reviewed, we estimated
that EPA could reduce contract
costs between $15.0 and $54.9
million  (based on the maximum
potential value of the
noncompetitive subcontracts in our
sample) by requiring competitive
subcontract awards. Extensive use
of noncompetitive subcontract
awards (67 percent of the value of
prime contracts  in our sample)
undermine any benefits obtained
from competitive prime contract
awards.

The broad scope of work of  EPA's
large, cost-reimbursable prime
contracts encouraged extensive
and costly subcontracting. For the
five prime contracts reviewed,
subcontracts increased the prime
contractors' costs an estimated
27.9 percent, or $86.5  million,
without any identifiable substantial
value.  Further,  certain
subcontractors performed services
for such prolonged periods and to
such an extent that separate prime
contracts were justified.

EPA managers  interfered with  the
prime contractors' responsibility to
manage and competitively award
subcontracts by directing prime
contractors to use specific
subcontractors or to subcontract
specific tasks.  Sixty-five of  the 126
OCTOBER 1, 1994 THROUGH MARCH 31, 1995

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subcontracts proposed after prime
contract award exhibited evidence
of EPA involvement in the
subcontract award.  EPA program
managers used prime contractors
as subcontract brokers, avoided
competition requirements for direct
Federal procurements, and
noncompetitiveiy obtained the
services of desired contractors
through directed subcontract
awards.

EPA oversight of prime contractor
management, use and award of
subcontracts did not: (1) ensure
contracted services were procured
at the lowest cost;  (2) ensure
subcontractors proposed by prime
contractors were needed or were
the most technically qualified; (3)
identify or question  EPA
involvement in prime contractors'
decisions  to subcontract; or, (4)
monitor the degree of
noncompetitive subcontract awards
and prolonged use of certain
subcontractors.

EPA intends to reduce the scope of
selected prime contracts and award
more prime contracts to increase
competition which could reduce the
need for extensive,  costly
subcontracts to address broad
contract requirements.  Also, EPA
plans to pilot the award of
performance based, fixed price
contracts to potentially reduce and
better control contract costs.

We Recommended That

The Assistant Administrator for
Administration  and Resources
Management:

•   Extend current initiatives to
increase prime contract competition
to include  subcontracting and
realize economies from competitive
subcontract awards.

•  Reduce  the use of subcontracts
to those actually  needed.
• Limit contractors' indirect and
direct actual cost rates, negotiate
fixed labor rates, and reduce the
use of cost reimbursable contracts
when possible.

• Preclude inappropriate EPA
involvement in prime  contractor
selection and management of
subcontractors.

• Strengthen controls over
subcontracts and consistently and
properly apply Federal
requirements for subcontract
awards.

What Action Was Taken

The final report  (5100247) was
issued to the Assistant
Administrator for Administration and
Resources Management on March
31, 1995.  In response to our draft
report, Agency officials agreed with
many of the recommendations and
initiated or planned corrective
actions. Some of the findings and
recommendations still need to be
resolved. A response to the final
report is due by June 30, 1995.

Interagency Agreements
Used Without Adequate
Cost Consideration

Findings in Brief

EPA often executed  Economy
Act Interagency Agreements
(lAGs) without  considering  the
reasonableness of their costs.  In
addition, EPA did not recover  its
full costs of performing work for
other agencies.

Background

lAGs are written agreements
between Federal agencies under
which goods and services are
provided in  exchange for monetary
reimbursement.  The  Economy Act
of 1932, as amended, is  the
authority most often cited for EPA
to enter into lAGs with other
Federal agencies.

We Found That

EPA had not adequately considered
cost in determining to use Economy
Act lAGs rather than its own
procurement process.  Although
program offices varied in the
measures taken to ensure cost
reasonableness, the reason cited
most often for using lAGs was the
ease with which transactions could
be completed in comparison to the
contracting process. Independent
Government Cost Estimates
(IGCEs), cost comparisons,  and
better justification  in the Decision
Memorandum would ensure that
program offices focus on cost
reasonableness, not just
convenience.

The  Economy  Act, U.S. Comptroller
General Decisions, and Agency
policy,  all  require full cost recovery
when performing work or furnishing
materials for another agency.
Despite these  requirements, EPA
did not bill other agencies for EPA's
indirect costs related to performing
work or furnishing materials.  Other
Federal agencies, when providing
goods and services to  EPA, charge
indirect cost rates between 3.2
percent and 15 percent.  If EPA
charged other  agencies at these
rates, EPA could have recouped
between $5 million and $23.4
million.

For disbursement (funds-out) lAGs,
project officers were generally not
obtaining and reviewing cost
information before approving
invoices for payment.  Most project
officers interviewed acknowledged
that they did not know the basis for
the amounts invoiced by the
performing agencies, but approved
the invoices anyway. Also,  the
Agency paid contractors with whom
it had no contractual relationship.
10
                                           OFFICE OF INSPECTOR GENERAL

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 For certain lAGs, EPA made
 payments directly to the contractor
 rather than to the agency providing
 the goods or services.  The other
 agencies' indirect costs cover
 services such as processing and
 paying invoices, and there is no
 indication that they  have reduced
 their rates.  Therefore, EPA could
 be paying twice for  these services.

 We Recommended That

 The Assistant Administrator for
 Administration and  Resources
 Management:

 •  Require that  IAG  packages
 explain  the benefit to EPA of
 purchasing through  other agencies
 instead  of using EPA's own
 procurement process,  and
 document cost  comparisons.

 •  Require IGCEs for lAGs
 consistent with  the Agency's current
 requirement for EPA contracts, and
 refuse to pay any invoices which
 lack supporting cost detail.

 •  Develop a standard clause for
 inclusion in all disbursement lAGs
 stating that EPA will not pay
 invoices without supporting cost
 detail, including  a breakout of direct
 and indirect  costs, and instruct
 project officers  to notify the
 payment office  to withhold/retract
 payments when the  performing
 agency  does not adhere to this
 clause.

 •  When performing  work for other
 agencies, establish  EPA indirect
 cost rates, amend existing lAGs to
 include the rate established or
 cancel the IAG, and not enter into
 any new lAGs until  indirect cost
 rates are established.

 What Action Was Taken

 The final report (5400051) was
 issued to the Assistant
Administrator on March 31, 1995.
Although formal written comments
were not received in response to
the draft report, Agency officials
indicated that they were in general
agreement with requiring IGCEs,
but would not cease accepting or
cancel existing reimbursable lAGs
until indirect costs rates could  be
established and put in place.  A
response to the final report is due
by June 30, 1995.

Region 7 Disregarded
Approved Allocations in
Implementing Their 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 for 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 workyears
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 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
operation budget). Regional
financial reports were not  provided
timely or often enough to  manage
program operations.  For example,
two program managers  had to
develop their  own financial tracking
OCTOBER 1, 1994 THROUGH MARCH 31, 1995
                                                                                                   11

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systems to monitor their budgets.
However, recognizing this need, in
fiscal 1995, the Region's budget
staff provided program managers
with complete operating plan
information.

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.

• Provide managers with complete
and timely budget and financial
information.

What Action Was Taken

The final report (5100250) was
issued to the Regional
Administrator on March 31, 1995.
A response to the final report is due
by June 29,  1995.

Improved Controls  Needed
Over IPA Assignments

Findings in Brief

While EPA's Intergovernmental
Personne! Act (IPA) program has
generally met the intent of the
Act, more than half of the UFA
assignments we reviewed had
inadequate management controls
resulting in excessive costs and
insufficient  benefit to EPA.

Background

The Intergovernmental Personnel
Act authorizes Federal agency
heads to approve temporary
assignments of their personnel to
eligible non-Federal organizations
and vice versa.  IPA assignments
are to be of mutual benefit to the
organizations involved, and
participating  Federal employees are
required to return to Federal
service upon completion of the
assignments. Chapter 1 of EPA's
IPA Manual indicates that the
organization  benefiting more from
the assignment should absorb the
larger share  of the cost.

We Found That

Generally, EPA's IPA program has
benefitted EPA and the
environmental community  as a
whole. Payments were accurate
and supported for almost all of the
IPA assignments reviewed, most
assignees met the eligibility criteria,
and the majority of  Federal
assignees returned  to Federal
service.

However, weak management
controls over individual
assignments resulted in at least
one problem with 96 of 160 IPA
assignments (totaling $5.5 million)
which we reviewed.  For 43 of the
assignments, EPA paid all of the
costs, even though  the benefits
were mutual or predominantly
accrued to the non-Federal
organization.  Also,  23 of the
assignees did not, or do not plan
to, return to their home
organizations after their IPAs.
Consequently, EPA may never
receive any benefit  from the
expertise presumably acquired on
those IPA assignments.

Several IPA  assignments  had
multiple problems which were
indicative of program abuse. The
intent and cost of some
assignments were questionable, as
were the  benefits to the Agency
and the eligibility  of the assignee.
These multiple abuses most
frequently involved  IPAs of senior
Agency officials  (SES and GM-15
employees) authorized primarily at
the Assistant Administrator level or
higher. In our opinion, the IPA
mechanism was being used in
these cases specifically for the
convenience and benefit of the
employees or to "farm out"
unwanted employees.

Serious problems existed with
Region 9's IPA program, largely
due to blanket IPAs which were
incomplete and did not contain valid
certifications. In several cases,
EPA employees assigned through
blanket IPAs were performing some
of their EPA duties and functions
while  being paid salaries and/or
travel expenses with grant funds,
thus allowing Region 9 to preserve
its own travel funds for other uses.
Conflict of interest situations were
created on some blanket IPAs
because  project officers (POs)
charged with grant oversight
responsibilities subsequently acted,
while  on  IPAs, as employees of the
grantee for which they were POs.

Region 9 also augmented State
staff on a long-term basis at
significant costs using  IPA
agreements.  At any time over the
last five years, from 7  to 11 full-
time EPA employees were serving
on IPA assignments to the State of
Hawaii.  In our opinion, easy
access to IPA assignees has
contributed to Hawaii's lack of
urgency in replacing them with its
own staff.

Overall, the  problems which we
found were primarily due to
inadequate internal controls or not
adhering  to controls in place. We
believe that the cause for
assignments with multiple problems
and excessive costs was the
hesitancy of IPA program officials
to say "no" to EPA's most senior
managers. In addition, the blanket
agreements used by Region 9 were
not reviewed for legality or
completeness, and neither
Headquarters nor the Region
performed effective oversight
reviews.
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                                           OFFICE OF INSPECTOR GENERAL

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We Recommended That

The Assistant Administrator for
Administration  and Resources
Management:

• Review the decision to centralize
the IPA program function under a
national coordinator.

• Develop and apply management
controls which  will justify costs and
maximize benefits to EPA,
especially for agreements involving
senior managers, and ensure that
assignments meet the intent, cost,
eligibility, and service obligations
required  by the Act.

• Prohibit project officers from
participating in IPA assignments
funded by grants they oversee and
monitor.

What Action Was Taken

The final report (5400052) was
issued to the Assistant
Administrator for Administration and
Resources  Management on March
30, 1995. While formal written
comments were not received in
response to our draft report, EPA
officials indicated that they
generally agreed with the report
and that  management controls can
be improved.  A response to the
final  report  is due by June 30,
1995.

Further Actions Needed to
Improve Region  7  Public
Water Systems

Findings in Brief

Two Region 7 States, Kansas
and Missouri,  brought some
small public water systems into
compliance with drinking water
regulations  by using innovative
preventive  measures.  However,
ineffective  data  management
systems impeded the States'
abilities to effectively monitor
compliance and enforcement
actions.

Background

Congress enacted the Safe
Drinking Water Act (SDWA) in 1974
to protect the nation's water from
various harmful  contaminants.
Congress amended the SDWA in
1986 to significantly increase  the
number of regulated contaminants
and strengthen enforcement
authority.  EPA  relies on the
integrity  of data  received from
States.  In 1992, EPA formulated
its plan to automate public water
system information and began
developing the Safe Drinking  Water
Information System (SDWIS).
Unlike the Federal Reporting  Data
System (FRDS) which is an
enforcement tracking system,
SDWIS will provide a
comprehensive automated data
system for EPA and States to
manage public drinking water
programs.

We Found That

Region 7 encouraged State
emphasis on innovative, preventive
measures to help small,
underfunded public water systems
improve drinking water quality, and
allowed States to be flexible in
selecting  enforcement actions.
Region 7 agreed with the States
that escalation of enforcement
actions against small systems was
not productive, and worked with
States to help the smaller systems
achieve compliance  rather than
penalize them for noncompliance.
For instance, Missouri developed a
State waiver program through a
university grant of $350,000 that
reduced small system monitoring
burdens and saved Missouri about
$12.3 million.  Missouri successfully
assisted small communities in
identifying financing  sources to
enable them to consolidate small
systems to reduce compliance
problems and costs. Missouri,
Kansas, and Iowa consolidated
some small systems to reduce
overall compliance problems and
monitoring, and to provide a larger
customer base to absorb the high
cost of testing and water treatment.
These cooperative approaches
resulted in improvements which
brought some systems back into
compliance.

However, we found that the States
needed to develop written
corrective  action plans with
milestones to assist chronic non-
compliers  in returning to
compliance.  These action plans
would help the States and Regions
monitor progress  and establish a
more  effective, results-oriented
process.  Additionally, these plans
could  help resolve deficiencies
Region 7 identified in State
programs that had remained
uncorrected since the 1992
program evaluation.

Kansas and Missouri did not have
data management systems
designed to facilitate effective
enforcement and  program
improvement decisions.  Ineffective
systems have impacted  both
States' abilities to provide Region 7
with accurate enforcement data and
to obtain small systems' timely
compliance.  Neither State's system
has provided the  cost and historical
data to enable the State to make
decisions for managing its safe
drinking water program more
effectively and efficiently.  Kansas
and Missouri are  not moving as
quickly toward more
comprehensive, automated data
management systems because of
current systems' incompatibility  with
SDWIS. States may have adopted
automated technology more quickly
if Region 7 had provided
information about currently
available  technology in other
regions and States.
OCTOBER 1, 1994 THROUGH MARCH 31, 1995
                                                                                                  13

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We Recommended That

The Regional Administrator, Region
7:

• Continue to stress to States the
use of preventive measures and
reasonable alternatives to reduce
small systems' monitoring costs.

• Continue to work with the States
to design enforcement actions with
achievable, enforceable milestones.

•  Help States develop  corrective
action plans with milestone dates
for problems  identified  in annual
program evaluations.

•  Help States update data
management systems,  while
Headquarters completes SDWIS;
help States determine and acquire
the most cost beneficial information
and tracking systems; and
emphasize States adopt SDWIS
modules as they become available.

What Action Was Taken

The final report (5100226) was
issued to the Regional
Administrator on March 24,  1995.
In response to the draft report,
Region 7's Director, Water,
Wetlands, Pesticides Division
concurred with the findings and
recommendations, and  initiated
corrective actions.  For example,
the Region issued detailed and
specific guidance to the States,
encouraging the  use of waivers to
reduce the costs of monitoring, and
asked States to include  remedies to
problems identified in program
evaluations during negotiations for
the next year's workplan. Also, the
Director indicated that two states
(Iowa and  Nebraska) are fully
committed to  adopting SDWIS
modules as they  become available;
Missouri is seriously considering
dropping work on their system and
using  SDWIS; and the Region will
continue to work  with Kansas and
encourage them to consider using
SDWIS.  As a result, we closed out
the audit report in our tracking
system.

Triba! Program  in Region 8
inadequately Planned

Findings in Brief

Region 8 had not clearly
identified Tribal environmental
needs, established a Regional
workplan and performance
measures, or efficiently
organized  its Tribal staff.

Background

In 1984, EPA adopted a formal
Indian  Policy to enhance
environmental protection for over
500 Tribes  in the United States.
The Agency made a commitment to
incorporate Indian Policy goals into
its planning and  management
activities, including its budget,
operating guidance, legislative
initiatives, management
accountability system, and ongoing
policy and regulation development
processes.  In August 1994, the
Regional Administrator established
the Tribal program  as one of the
Region's top three program
priorities.

We Found  That

Region 8 made significant efforts to
implement a Tribal  program that
supported EPA's policy.  For
example, the Region appointed a
Tribal Coordinator,   established  a
Tribal Work Group, and initiated
Tribal policy papers.  However,
Region 8 did  not have an accurate
assessment of Tribal environmental
needs since prior assessments
were not complete, objective, up-to-
date, or comprehensive.

In addition,  the Region had not
developed a workplan to establish
strategies for addressing Tribal
environmental problems and
achieving goals. Regional staff
lacked needed direction to establish
quantifiable goals and develop
meaningful performance measures
to evaluate progress.

Region 8 could not fulfill its goal of
a meaningful  presence on all
reservations.  Although resources
were limited,  the Region did not
allocate all available funds for some
Tribes' grant  requests.  Also, the
Region did not adequately support
EPA or Regional priorities for
building Tribal expertise.

Region 8's organizational structure
did not focus  adequate attention on
Tribal environmental needs or
permit effective and efficient
oversight of Tribal program
development  by clearly designating
who had  responsibility for
implementation of EPA's Indian
Policy. The Region did not have a
focal point that was familiar with
Tribal political structures and
environmental needs, or a central
point of management accountability
for the Region's Tribal expen-
ditures. Tribal representatives were
frustrated with the Region's
organization and the limited amount
of time the Regional staff had  to
provide technical assistance.

We Recommended That

The Regional Administrator, Region
8:

•   Conduct a  comprehensive
assessment of Tribal environmental
needs, develop a Regional
workplan, and establish time-
specific and quantifiable
performance  measures.

•   Evaluate grant funding options
and allocate travel funds to provide
adequate technical assistance.
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                                                                                  OFFICE OF INSPECTOR GENERAL

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 •  Assign a single Tribal program
 manager the responsibility to
 implement and monitor the
 program, and identify primary Tribal
 coordinators  within each Regional
 program division.

 What Action Was Taken

 The final report (5100141) was
 issued to the Regional
 Administrator on January 23, 1995.
 In responding to the  draft report,
 the Regional Administrator agreed
 with our recommendations and
 provided an acceptable action plan
 with milestone dates to correct the
 identified weaknesses. Based on
 our audit report, EPA declared,  as
 an Agency level Federal Managers'
 Financial Integrity Act weakness, its
 administration of environmental
 issues on Indian reservations,
 particularly due to EPA's not
 providing appropriate technical
 support to the Tribes. We closed
 this audit in our tracking system
 and all corrective actions will now
 be tracked in the Agency's
 Management Audit Tracking
 System.

 Application Software
 Maintenance Needs Further
 Improvements

 Findings in  Brief

 Although EPA has taken
 significant steps to strengthen
 its management of application
 software maintenance, more
 needs to be  done to improve
 system and software reliability,
 cost effectiveness, and decisions
 about operational changes.

 Background

 EPA has over 500 information
 systems  as well as computer
 models to support its mission.
 Each year,  EPA spends almost
 $100 million operating and
 maintaining  its information systems,
 and at least $1  billion  over their life
 cycles.  This audit is part of a
 Government-wide review of
 application software maintenance
 being conducted under the
 auspices of the President's Council
 on  Integrity and Efficiency.

 We Found That

 EPA has taken  steps in recent
 years to improve its management of
 application software maintenance,
 including establishing  a Systems
 Development Center and guidance
 outlining the requirements for
 system  life cycle management.
 However,  application software
 maintenance is  still not adequately
 managed  in areas  such as
 recording  and analyzing system
 failures, tracking changes dictated
 by  new  legislation or evolving  user
 needs, or  monitoring resource
 utilization.  As a result, managers
 do  not have information they need
 to make critical  decisions about
 system  maintenance priorities,
 resource utilization, removal of
 software defects, or whether to
 replace  or maintain a major
 information system.

 A working capital fund, which
 includes Automated Data
 Processing and  telecommunications
 services, is being created to
 administer services in  a cost-
 effective manner.  However, it is
 questionable whether the fund will
 be able  to track maintenance costs
 separately from  operations costs.
 The Agency has not developed,
 reviewed,  or updated software
 maintenance costs by  individual
 system throughout the life cycles of
 its information systems.
 Consequently, EPA officials do not
 have the necessary cost
 information to make informed
 system and budget decisions
 regarding the operation and
 maintenance of  its  systems. In
addition, EPA's  financial statements
did not accurately reflect
capitalization of application
software maintenance costs and
some system costs were not
accurately reported to the Office of
Management and Budget (OMB).

Although EPA has initiated efforts
to better manage software
modifications, we found that
management did not  use adequate
performance measurement
indicators, tracking techniques,
quality assurance procedures, or
supplemental software tools.  In
most cases, management
involvement was focused on the
initial  stages of review and
approval, with the Agency
relinquishing control over the final
test and review stages to contractor
personnel.  As a result, changes to
major national systems were  not
performed in a structured and
controlled manner.

We Recommended That

The Assistant Administrator for
Administration and Resources
Management:

•  Promote a more consistent and
structured approach to managing
application software maintenance.

•  Identify appropriate metrics for
use in managing application
software maintenance, and
incorporate them into  the existing
management and periodic ADP
review processes.

•  Enhance  EPA's ability to identify
and capture all costs, including
application software maintenance,
at the information system level, and
report these costs to OMB.

•  Improve controls over the
process of changing and modifying
application software, including
identifying measurable performance
indicators.
OCTOBER 1, 1994 THROUGH MARCH 31, 1995
                                                                                                   15

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What Action Was Taken

The final report (5100240) was
issued on March 31, 1995. In
response to the draft report, the
Assistant Administrator for
Administration and  Resources
Management generally agreed with
the findings and recommendations.
A response to the final report is due
by June 29, 1995.

Cultural  Diversity Goals
Exceeded in Laboratory
Contractor Conversion

Findings  in Brief

The Health Effects Research
Laboratory's (HERL)  contractor
conversion hires exceeded
established cultural diversity
goals for women and minorities,
while complying with applicable
Federal and Agency guidelines
for open and competitive
recruitment.

Background

The Office of Management and
Budget approved EPA's  1995
request to convert contractor
activities into new permanent
Government positions, and HERL
was allocated  151 of the initial
contract conversion vacancies.  The
OIG received an anonymous
complaint alleging that the job
vacancies created by the contractor
conversion at HERL were filled by
predominantly white male
contractor support personnel,
without regard for established
cultural diversity goals.

We Found That

The distribution of HERL's
contractor conversion hires
exceeded the minimum goals
established by the Raleigh Area
Office of Civil Rights (AOCR) for
women and minorities.  At the time
of our review, women and minority
hires totaled 81 of 137 (59 percent)
positions filled under HERL's
contractor conversion effort,
exceeding the established goal by
almost one-third. The remaining 56
(41 percent) conversion hires were
white males.  With the exception of
Hispanics, minority hires exceeded
or fell within 3 percentage points of
their representation in the relevant
civilian labor force.

Although granted direct  hire
authority by OPM, HERL officials
relied upon an open and
competitive recruitment  process to
fill contractor conversion vacancies.
The HERL initiative consisted of an
extensive nationwide recruitment
effort both within (merit  promotion)
and outside Government.  A
detailed evaluation of candidates
followed, which scored and ranked
applicants, to produce the final
certificate of candidates. All normal
recruitment procedures were
followed.

We Recommended  That

No recommendations were
necessary as we believe that this is
a successful example of affirmative
action for application throughout
EPA.

What Action Was Taken

Since no written response was
required from Agency officials, we
closed our report (5400046) upon
issuance to the Assistant
Administrator for Research and
Development on March  8, 1995.

Further Improvements in
Financial Reporting Needed

Findings in Brief

During fiscal 1994,  EPA
continued to make improvements
in its financial systems and
processes.  As a result of these
improvements and certain OIG
assistance projects, we issued
unqualified  or qualified opinions
on several financial statements
for which we disclaimed an
opinion last year. However,
additional improvements  are
needed to resolve several
material internal control
weaknesses before unqualified
opinions can  be rendered on
some of the Agency's financial
statements.

Background

The Chief Financial Officers Act
requires EPA to prepare financial
statements for  the Superfund,
Leaking Underground Storage Tank
(LUST), and Oil Spill Trust  Funds,
the Federal Insecticide, Fungicide,
and Rodenticide Act (FIFRA) and
Tolerance Revolving Funds, and
the Asbestos Loan Program. The
Act also requires the Inspector
General, or an  independent public
accounting firm selected by the
Inspector General, to audit the
financial statements.

We Found That

Following are the results of our
audit of the fiscal 1994 financial
statements for  these funds.

Superfund Trust Fund. We
disclaimed an opinion on the
financial statements primarily
because of weaknesses in
accounting for  property, accounts
payable, and accrued liabilities,
grants funded from multiple
appropriations,  and Superfund
State cost share credits.

LUST Trust  Fund. We qualified
our opinion on  the LUST Trust
Fund primarily  because of
weaknesses  in  the recording of
accounts payable and accrued
liabilities.
16
                                           OFFICE OF INSPECTOR GENERAL

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Oil Spill Trust Fund.  We
disclaimed an opinion on the
financial statements for this fund
primarily because of weaknesses in
the accounting for grants funded
from multiple appropriations.

Asbestos Loan Program.  The
Statements of Financial  Position
and Cash Flow for this fund were
fairly presented. We qualified our
opinion on the Statements of
Operation and Changes in Net
Position and  Budget and Actual
Expenses, solely because we
chose  not to  audit costs allocated
from other Agency appropriations to
the loan program due to the
substantial audit effort that would
have been required.

FIFRA  Fund. We qualified our
opinion on the Statements of
Financial Position and Cash Flows
because of weaknesses in
accounting for property.  We
disclaimed an opinion on the
Statements of Operation  and
Changes in Net Position and
Budget and Actual Expenses
because of these weaknesses and
because we also chose not to audit
the costs allocated from other
appropriations to the FIFRA Fund
due to the substantial audit effort
that would have been  required.

Tolerance Fund.  The Statements
of Financial Position and Cash Flow
for this  fund were fairly presented.
We disclaimed  an opinion on the
Statements of Operation and
Changes in Net Position, and
Budget and Actual Expenses
because we chose not to audit the
costs allocated from other
appropriations to the Tolerance
Fund due to the substantial audit
effort that would have been
required.
Material Internal Control
Weaknesses

Financial Reporting. The
Agency's financial activities could
be more effectively managed if
additional information was
available,  provided in more useful
formats, and better used to analyze
the Agency's financial activities.
Lack of adequate information and
reports resulted in Agency officials
being unable to effectively monitor
some asset and  liability accounts.
In some cases, to obtain timely
information, Agency officials
operated systems that duplicated
the Agency's Integrated Financial
Management System (IFMS).  The
lack of financial information and
reports has the greatest impact on
those general ledger accounts
containing  dollar amounts that
carried forward from  one year to
the next.

Property.  The procedures used to
capitalize  property did not identify
all property that should have been
capitalized, and when property was
taken out of service it was not
deleted from the accounting
records.  Therefore, we were
unable to determine if the Agency's
property balances reported in the
financial statements ($11.7 million
for Superfund and $353,000 for
FIFRA) were fairly stated.  The
same condition was also noted in
audit reports on the fiscal 1992 and
1993 financial  statements.

Accounts  Payable and Accrued
Liabilities. We identified a net
understatement of $833,000 in
accounts payable and accrued
liabilities that affected the
Superfund, LUST, Oil Spill, and
FIFRA Funds.  This misstatement
was caused in  part by problems
with the accuracy and timeliness of
data from a tracking system used
by two of the Agency's finance
offices.  In  addition,  for the six
audited funds,  we found that 34 out
of 336 liability  accounts
payable/accrued had a debit
balance when  they should have had
a credit or zero balance.

Grant Payments.  Due to a lack of
accounting  information from grant
recipients, the Agency processed
disbursements for multi-funded
grants using a first-in/first-out
method, i.e., the oldest available
funding was used first.  This could
result in some appropriations being
improperly charged since it does
not take into consideration which
appropriation benefitted from the
work performed.

Accounts Receivable.  Emphasis
by Agency management on
recording receivables, and work
performed by our contract
independent public accounting firm,
succeeded  in reducing the number
of unrecorded  accounts receivable.
However, we did identify: (1) five
receivables that were not recorded
in  a timely manner, including two
receivables totaling $4.7 million  that
were not initially included in the
fiscal  1994  financial statements, (2)
an understatement of $346,701 in
the allowance  for doubtful accounts,
and (3) $4.7 million of marketable
securities accepted in settlement of
approximately  $19 million of
existing accounts receivable that
had not been recorded resulting in
an overstatement of receivables.

Superfund  State Cost Share
Credits.  When EPA takes the lead
in  cleaning  up  a Superfund site, it
enters into a contract with the State
for the State to share in the cost of
the cleanup. Rather than make
payments to EPA for their share of
cleanup costs, States can receive
credits for amounts they incurred
for remedial actions prior to
entering into a contract with EPA.
Although Agency guidance requires
that the credits be recorded in
IFMS, no instructions or procedures
were provided  to finance offices
OCTOBER 1, 1994 THROUGH MARCH 31, 1995
                                                                                                    17

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 and, consequently, the credits were
 not being recorded.  One State
 contract we identified disclosed
 $1.4 million in unrecorded credits,
 and others may exist.

 We Recommended That

 The Chief Financial  Officer:

 •  Provide financial management
 offices with general  ledger reports
 and hold them accountable for the
 accuracy of their account balances.

 •  Revise the Agency's
 capitalization policies and
 procedures to assure that
 disbursements necessitating
 capitalization are being identified
 and properly capitalized.

 •  Determine why  liability  accounts
 have debit balances and make any
 necessary adjustments to the
 account balances.

 •  Require a clause  in grants
 funded from more than  one
 appropriation that specifies how the
 payments should be charged to  the
 various appropriations.

 •  Provide guidance to finance
 offices on (1) notifying
 Headquarters if unrecorded
 receivables are identified  after the
 close of the year; and (2)
 identifying potentially
 uncollectible receivables for
 inclusion  in  the allowance for
 doubtful  accounts.

 •  Develop guidance for recording
 Superfund State cost share credits
 and assure that credits are properly
 recorded.

 What Action Was Taken

 The final report (5100192) was
 issued on February 28,  1995.  In
 response to the draft report, the
 Chief Financial  Officer concurred
with most of our recommendations
or identified  alternative corrective
actions that  would be taken to
resolve the issues discussed  in the
report. A response to the final
report is due by May 30,  1995.
18
                                            OFFICE OF INSPECTOR GENERAL

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Construction  Grants
EPA's wastewater treatment
works construction grants and
State Revolving Fund (SRF)
programs are the largest
programs the Agency
administers.  Under the
provisions of Public Law 92-500,
as amended, the Agency was
authorized to make construction
grants covering 55 percent and,
in some instances, up to 85
percent of the eligible costs of
constructing wastewater
treatment facilities.  During this
semiannual period,  $67 million
was obligated on one new
construction grant award and 58
increases to existing grants.  As
of March 31, 1995, there was
$11.2 billion in grants that were
potentially subject to audit.  Of
this total, there were 271 active
construction grants, representing
$2.5 billion in  Federal
obligations.

Amendments to the construction
grants program are covered in
Title II of the Water Quality Act of
1987.  Section 212 created a new
Title VI in the Clean Water Act,
which addresses the process of
phasing out the construction
grants program by providing
incentives for  development of
alternative funding mechanisms
by the States.  The new Title  VI
charges EPA with developing
and implementing a program  to
provide grants to capitalize State
revolving funds  for financing
wastewater projects.  During  this
semiannual period, $989 million
was awarded for 38 continuation
SRF grants.
As of March 31, 1995, EPA had
obligated $10.8 billion to 50
States and Puerto Rico under the
State Revolving Fund program.

One of the Agency's goals is to
substantially close out the
construction grant program by
September 30, 1997.  To assist
the Agency in  this effort, the OIG
implemented a revised strategy
in October 1994 that focuses
effort on the most vulnerable
grants, based  on a
risk analysis of each remaining
grant subject to audit.  This
identified 400 grants valued at
$6.5  billion which are expected to
receive OIG review during the
next three years.  Summaries of
several audits of construction
grants with significant issues
follow.
OCTOBER 1, 1994 THROUGH MARCH 31, 1995
                                                           19

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Los Angeles, California,
Claimed Over $30  Million of
Ineligible  Costs

Findings in Brief

The City of Los Angeles,
California, claimed $30,487,741 of
ineligible construction, claim
settlement,  and indirect costs for
the Hyperion wastewater
treatment facility.

We Found That

EPA awarded four grants totaling
$104.3 million for site work, design,
and construction of the Hyperion
Energy Recovery System, including
the Carver-Greenfield sludge drying
process and associated facilities.
The grantee claimed $30,487,741
of ineligible costs under the grant,
including:

•  $27,063,311 of construction costs
previously declared  ineligible by the
California  State Water Resources
Control Board (SWRCB) because
they included understated
deductions for change orders,
claims, and settlement  costs; and

•  $3,424,430 for costs  claimed in
excess of the approved grant
amount; and indirect costs that
exceeded the City's  actual indirect
cost rates.

The Carver-Greenfield sludge
drying process,  funded  under one
of the grants, has been declared a
failure by the SWRCB and EPA.
The process was funded as an
innovative technology that was to
remove almost all of the water from
sewage sludge.  The system was
designed to treat 265 tons of dried
sludge per day,  but has only been
able to process  about 37 tons per
day. The City is eligible to receive
a 100 percent grant  to replace the
failed innovative process.  Despite
the lack of additional available
grant funding, the City has
expended its own funds for a
sludge truck loading facility so the
sludge which was to be dried by
the Carver-Greenfield process
could be loaded on trucks for land
disposal.

We Recommended That

The Regional Administrator, Region
9, not participate in the Federal
share of ineligible costs
($25,580,260), and recover the
applicable amount from the
grantee.

What Action Was Taken

The audit report (5200012) was
issued to the Regional
Administrator, Region 9,  on March
27, 1995.  A response to the audit
report is due by June 26, 1995.

Over $19 Million of
Questioned Costs Claimed
for Orangeburg, New York,
Project

Findings  in Brief

The Rockland County Sewer
District, New York, claimed
$1,721,208 of ineligible
construction, administrative, and
architectural engineering costs
for the construction of  a
wastewater treatment facility. An
additional $17,629,638 of
unsupported project costs were
questioned.

We Found That

EPA awarded a grant of
$61,831,824 to the Rockland
County Sewer District, New York,
for the construction of a wastewater
treatment  facility.  The grantee
claimed $1,721,208 of ineligible
costs under the grant, including:
• $1,360,171 of construction costs
disallowed by New York State
Department of Environmental
Conservation (NYSDEC) based on
its final payment review, and
understatement of the ineligible
portion of an eight-bay garage;

• $192,870 of administrative costs
declared ineligible by NYSDEC
based on its final  payment review,
legal services related to review of
the grant application, grant
conditions which are ineligible for
Federal participation, and incorrect
application of the  construction
eligibility factor; and

• $168,167 of engineering costs
related to overbilling by the
consulting engineer, costs
disallowed by NYSDEC based on
its final  payment review, and
incorrect application of the
construction  eligibility factor.

We also questioned $1,840,701 of
unsupported costs, including
administrative expenses for indirect
costs, costs attributed to cleaning
digesters, and costs related to
litigation settlements. Additionally,
we questioned $15,788,937 of
innovative/alternative technology
costs pending EPA's evaluation.

We Recommended That

The Regional Administrator, Region
2, not participate in the Federal
share of ineligible costs
($1,290,906), determine the
eligibility of the Federal share of
unsupported costs ($2,959,420),
and recover the applicable amount
from the grantee.

What Action Was Taken

The audit report (5100190) was
issued  to the Regional
Administrator, Region 2, on
February 21, 1995.  A response  to
the audit report is due by May 22
1995.
20
                                           OFFICE OF INSPECTOR GENERAL

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Over $5 Million of
Questioned Costs Claimed
for Bristol, Connecticut,
Project

Findings in Brief

The City of Bristol, Connecticut,
claimed $2,462,057 of ineligible
architectural engineering,
construction,  inspection, and
administrative costs for the
design and construction of a
wastewater treatment facility. An
additional  $2,873,709 of
unsupported costs were
questioned.

We Found That

EPA awarded a grant of
$19,071,076 to the City of Bristol,
Connecticut, for the design and
construction of a wastewater
treatment facility.  The grantee
claimed $2,462,057 of ineligible
costs under the grant,  including:

• $1,365,596 of preliminary design
costs which exceeded  the
allowance awarded in the grant
agreement;

• $823,451 of construction costs
related to bid items and change
orders which exceeded the State
agency approved costs, and costs
representing abandonment of the
previous  sewage treatment plant
which were not included in the
grant agreement;

• $259,320 of inspection costs
incurred after the State-approved
project completion date, costs not
related to the approved project, and
costs allocable to the ineligible
portion of the construction project;
and

•  $13,690 of equipment,
engineering, and administrative
costs deemed ineligible due to
unallowable ordinary operating
expenses and an improper
proration factor.

We also questioned $2,873,709 of
unsupported costs that exceeded
the maximum basic funding
amount.

We Recommended That

The Regional Administrator,  Region
1,  not participate in the Federal
share of ineligible costs
($1,841,540), determine the
eligibility of the Federal share of
unsupported costs ($2,155,282),
and recover the applicable amount
from the grantee.

What Action Was Taken

The report (5100230) was issued to
the Regional Administrator, Region
1,  on  March 27, 1995. A response
to  the report is due by June 26,
1995.

Nearly $2 Million of
Ineligible Costs Claimed for
Vernal, Utah, Project

Findings in Brief

The Ashley Valley Sewer
Management Board, Vernal, Utah,
claimed $1,940,493 of ineligible
engineering and construction
costs for a wastewater  treatment
facility.

We Found  That

EPA awarded two grants totaling
$13,284,409 to the Ashley Valley
Sewer Management Board, Vernal,
Utah.  The grants provided for
construction of a wastewater
treatment facility including collection
and interceptor sewers, pump
station, lagoons,  storage reservoir,
and a pivot irrigation system for
disposal of the treated effluent.
The grantee claimed $1,940,493 of
ineligible costs under the grant,
including:

•  $887,950 of acquisition costs for
land that was not used for the
intended purpose of effluent
disposal;

•  $434,528 of construction costs
for an unused pump station and
force main intended to transport the
wastewater from the treatment
facility to the land disposal  site;

•  $314,186 of alternative funding
provided for unused land disposal;

•  $150,432 of engineering project
inspection costs that were incurred
beyond the scheduled completion
of construction; and

•  $153,397 of construction costs
related to unallowable change
orders and design engineering
costs that exceeded the approved
engineering agreement or related to
the unused pump station and force
main.

We Recommended That

The Regional Administrator, Region
8, not participate in the Federal
share of ineligible costs
($1,533,914), and recover the
applicable amount from the
grantee.

What Action Was Taken

The audit report (5100107) was
issued to the Regional
Administrator, Region 8, on
December 1,  1994.  A response to
the audit report was due by
March 1, 1995, but  has not been
received.
OCTOBER 1, 1994 THROUGH MARCH 31, 1995
                                                                                                  21

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 Superfund
 The Superfund program was
 created by the Comprehensive
 Environmental Response,
 Compensation, and Liability Act
 of 1980 (CERCLA).  The Act
 provided a $1.6 billion trust fund
 to pay for the costs associated
 with the cleanup of sites
 contaminated with hazardous
 waste.  Taxing authority for the
 trust fund expired on September
 30, 1985.  For more than a year,
 the Superfund program operated
 at a reduced level from carryover
 funds and temporary funds
 provided by Congress.

 On October 17, 1986, the
 Superfund Amendments and
 Reauthorization Act of 1986
 (SARA) was enacted.  It provided
 $8.5 billion to continue the
 program for 5 more years and
 made many programmatic
 changes.  On November 5, 1990,
 the Omnibus Budget
 Reconciliation Act of 1990 was
 enacted, authorizing
 appropriations for 3 additional
 years and extension of the taxing
 authority for 4 years.  The
 authorization expired September
 30, 1994, and the  taxing authority
 will expire on December 31, 1995,
 unless extended.

 The parties responsible for the
 hazardous substances are liable
 for cleaning up the site or
 reimbursing the Government for
 doing so.  States in which there
 is a release of hazardous
 materials are required to pay 10
percent of the costs of Fund-
 financed remedial actions, or 50
percent if the source of the
hazard was operated by the State
or local government.
The enactment of SARA
increased the audit requirements
for the Inspector General. In
addition to providing a much
larger and more complex
program for which the OIG needs
to provide audit coverage, SARA
gave the Inspector General a
number of specific
responsibilities.  Mandatory
annual audit areas include:

• Audit of all payments,
obligations, reimbursements, or
other uses of the Fund;

• Audit of Superfund claims;

• Examination of a sample of
agreements with States carrying
out response actions; and
• Examination of remedial
investigations and feasibility
studies.

The Inspector General is required
to submit an annual report to the
Congress regarding the required
Superfund audit work, containing
such recommendations as the
Inspector General deems
appropriate. The eighth annual
report, covering fiscal 1994, will
be issued no later than
September 1995.
22
                                         OFFICE OF INSPECTOR GENERAL

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 Higher Priority Needed for
 Reviews of Super-fund 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,
 there was an increasing backlog
 of unreviewed sites.

 Background

 In order to protect human health
 and the environment, the
 Comprehensive Environmental
 Response, Compensation, and
 Liability Act (CERCLA) requires the
 Agency to review, at  least every
 five  years, any post-Superfund
 Amendments and Reauthorization
 Act site where pollutants remain
 after the completion of remedial
 action.

 We Found That

 The required five-year reviews that
 were completed effectively
 identified successes or failures of
 remedies  at Superfund hazardous
 waste sites.  However, a substantial
 increasing backlog exists of such
 reviews due to the low priority
 placed by Agency management.
 Additionally,  the completion  of five-
 year reviews is not a  target in the
 Superfund Comprehensive
 Accomplishments Plan nor is it 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 is 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, there
appeared to be 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 potential
hazards or  problems with the
remedies which were not discussed
adequately  in the 1a 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 target in the Superfund
Comprehensive Accomplishments
Plan.

•  Clarify the guidance for the use
of 1a five-year reviews and require
sufficient information to support
conclusions.

What Action Was Taken

The final report (5100229) was
issued to the  Assistant
Administrator for Solid Waste and
Emergency  Response on March 24,
1995. In response  to the draft
report, the Assistant Administrator
agreed to give increased attention
to the five-year reviews, and
generally agreed to make
appropriate changes to the
guidance.  A response to the final
report is due by June 24, 1995.

Better Controls Needed
Over Region 8's Superfund
Field Sampling Activities

Findings in Brief

Region 8 needed better sampling
contrails and quality assurance
training of remedial project
managers (RPMs), and more
consistent RPM oversight at
Superfund sites.

Background

Federal regulations require EPA to
review and approve sampling and
analysis plans (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 a removal action,  site
evaluation, and hazard ranking
system activities. Region 8 requires
a contractor's SAP to be submitted
30 days prior to 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.
OCTOBER 1, 1994 THROUGH MARCH 31, 1995
                                                                                                  23

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 The majority of plans we reviewed
 were not signed by RPMs to
 indicate review,  modification as
 needed, and approval necessary 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 training records were
 inaccurately compiled.

 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.

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.

•  Ensure  RPMs periodically
observe contractor field sampling
activities and consider using field
audits as a part of their oversight
strategy and work plans.

•  Provide adequate staff with
quality assurance expertise to
assist in RPM's reviews.

•  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

The final  review report (5400034)
was issued 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.  A  response to
the final report is due  by April 27,
1995.
Region 9 Pilot Projects
Speed Up 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 (PA) and site
inspections (SI) 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
to the SWIFT process an expanded
PA  for earlier decision-making on
potential site listings, and an
Integrated Assessment (IA) which is
an expanded SI with multi-program
data gathering.

We Found  That

SWIFT site assessments were
completed in an average of 8.5
months  as compared to 31.7
months  under the previous
methodology, and the average cost
of a SWIFT PA/SI was $11,856 as
compared to $38,710 for pre-
SWIFT site assessments. These
savings were primarily attributable
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.
24
                                            OFFICE OF INSPECTOR GENERAL

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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,
quarterly  reports submitted by
Region 9 to the Superfund
Revitalization  Office (SRO) could
be improved to better inform the
SRO of the effectiveness of SACM
pilots.  This would provide
opportunities for program
improvements to be implemented
at other program offices.
We Recommended That

Since the pilot projects were
meeting their goals and objectives,
we made no formal
recommendations.

What Action Was Taken

The final report (5400018) was
issued to the Regional
Administrator, Region 9, on
November 28, 1994.
                                 ^^  fa

OCTOBER 1, 1994 THROUGH MARCH 31, 1995
                                                            25

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As required by the Inspector
General Act, as amended, this
section contains information on
reports in the resolution  process
for the semiannual period. This
section also summarizes OIG
reviews of the Agency's follow-
up actions on selected
reports completed in prior
periods. In addition, information
is presented on the resolution of
significant reports issued by the
OIG involving monetary
recommendations.

Current Period

As of March 31,  1995, EPA had
300 OIG reports requiring
resolution which was 30 percent
more than the beginning balance of
230 reports six months ago. The
number of past due responses
(over six months from report issue
date) rose 63 percent from  73 to
119 during  this six-month reporting
period.  At the end of September
1994, the number of past due
responses was 32  percent of the
reports to be resolved compared to
40 percent  of the reports in the
follow-up system as of the end of
this reporting period. Over the past
six years, with one exception, the
number of past due responses
have been higher in the March
semiannual report.

The costs questioned on the OIG
reports for which management
decisions were past due as of
March 31, 1995,  represented 80
percent of total questioned costs to
be resolved.

These reports need to be resolved
and the funds recovered more
expeditiously.  While the OIG
recognizes that it takes time to
reach a management decision on
some reports, swift, appropriate
resolution makes the government
run better and saves taxpayers the
added cost  of financing Agency
operations through  borrowing.
During this reporting period six EPA
Action Officials-Region 9; Region
10; the Office of Acquisition
Management's (OAM) Contracts
Management Division, Research
Triangle Park,  North Carolina; and
three OAM's Cost Advisory and
Financial Analysis Division
branches-had 77 percent (92) of
the 119 unresolved OIG reports
exceeding 180 days.

EPA is one of the few agencies that
reports on resolution of audits
conducted on pre-award contract
proposals.  There may be multiple
pre-award audits for any particular
EPA contract solicitation.
Resolution of these audits occurs
when the contracting officer makes
the contract award. Where there
are lengthy negotiations required  or
when there are a series of
proposals required from the
contractor, it is common for these
audits to remain in the "unresolved"
pre-award stage for longer than 180
days. It is therefore crucial that
EPA takes every step possible to
ensure that pre-award  audits  are
resolved quickly.

Region 9 and Region 10 have not
been  timely in  resolving reports
with large dollar issues.  Together
these two regions account for 21.8
percent (26) of all the unresolved
reports exceeding 180 days which
amounts to 48 percent ($117.2
million) of $243.3 million of the total
questioned costs needing
resolution.

Region 9 believes that the six-
month timeframe set forth in  EPA
Directive 2750 is not sufficient to
assure quality decisions necessary
to protect auditees, avoid legal
challenges, and avoid appeals.
Therefore, Region 9 has
disregarded this timeframe for audit
resolution.  After meetings with the
OIG, Region 9 indicated that it
plans to issue 11 of the 14 overdue
reports awaiting resolution by June
30, 1995, and two more of the
overdue reports by September 30,
1995.  The remaining report is
dependent on the California State
Water  Resources Control  Board
completing  its research for EPA.
During this reporting period, the
Region 10 Audit  Follow-up
Coordinator position was vacant.
The position was filled in April 1995
and the Region plans to provide
draft resolutions  to the OIG on all
past due reports  by July 1, 1995.

Trends

Timely action on  OIG reports-
resolving issues  raised  by auditors
within six months of report
issuance-continues to be a
problem.

From March 31,  1992, through
March  31, 1995,  the number of
reports with past due management
decisions increased from 34
percent to 40 percent.  During this
period  the number of reports
requiring resolution averaged about
300 each year.

The overall trends show
that more action  is needed at all
management levels to (1) make
audit follow-up a top priority, (2)
ensure that report resolution is
timely,  and (3) reduce  the growing
backlog of past due reports.
26
                                                                                  OFFICE OF

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Status Report On Perpetual Inventory of Reports in Resolution Process For The Semiannual Period  Ending
March 31, 1995 (Dollar Values in Thousands)
                                                 Report Issuance
                                   Number
A. For which no management decision
   has been made by the commencement
   of the reporting period*                 230

B. Which were issued during the
   reporting period                       448

C. Which were issued during the reporting
   period that required no resolution         232

   Subtotals (A + B - C)                   446

D. For which a management decision was
   made during the reporting period         146

E. For which no management decision has
   been made  by the end of the reporting
   period                               300

   Reports for  which no management
   decision was made within six months  of
   issuance                            119
         Questioned
            Costs
             363,519


              62,559


                231

             425,847


             121,211



             304,636



             243,256
Recommended
Efficiencies
   27,005


   36,205


        0

   63,210


    4,648



   58,562



   22,393
Report Resolution
Costs Sustained
 To Be     As
Recovered  Efficiencies
   45,496
190
   * Any difference in number of reports and amounts of questioned costs or recommended efficiencies between this report and
   our previous semiannual report results from  corrections made to data in our audit tracking system.
Audit Followup
 The Inspector General Act
 Amendments of 1988 requires
 Agency management to rep'ort
 semiannually, in a separate report
 to Congress,  the corrective actions
 taken in response to the OIG's
 reviews.  The Office of Inspector
 General reviews the Agency's
 followup actions on selected
 reviews.  Through other means, the
 OIG also learns of Agency actions
 taken in response to IG work which
 go beyond implementing those
 specific recommendations made in
 review reports.
Despite Over $570 Million in
EPA Grants for 30 Years,
PRASA's Poor Operations
Continue

Previous Problems and Findings

Our followup of a January 1992
report concluded that the Puerto
Rico Aqueduct and Sewer
Authority (PRASA) was still
experiencing major difficulties in
administering a wastewater
management program capable of
achieving a consistently
acceptable level of water
pollution control.  We reported
that PRASA's (1) financial
condition was worsening, (2)
management of its wastewater
               program operations was
               unstable, and (3) plant
               operations and maintenance had
               major deficiencies. We have
               reported these same conditions
               with little improvement since
               1986.

               Followup Findings

               Region 2 had followed a strategy of
               providing financial assistance to
               PRASA to deal with its
               administrative, technical,  and
               operational  problems together with
               increased enforcement actions
               against  noncompliance.  However,
               corrective actions promised by the
               prior Executive Director of PRASA
               were not always implemented,
               progress was slow, and the positive
OCTOBER 1, 1994 THROUGH MARCH 31, 1995
                                                                   27

-------
steps taken by PRASA to correct
many of the prior findings achieved
only minimal improvement.
Therefore, we are again reporting
on the same longstanding
problems.

PRASA's financial condition
continued to worsen and it has
been unable to generate sufficient
revenue to adequately run its
operations.  Difficulties with
collections,  rising operating
expenses, and the absence of a
realistic capital improvement plan
have made PRASA heavily
dependent on outside financial
infusions.  PRASA has received
over $1.5 billion worth of assistance
from various sources, including
over $570 million from EPA.  The
current Executive Director has not
formalized PRASA's corrective
action plan with specific steps and
milestone dates, and PRASA is
continuing to struggle to provide
minimal service to its customers,
while incurring ever-increasing
operating losses.

Management of PRASA's
wastewater treatment program
remained unstable.  PRASA did not
implement the reorganization plan
which it promised in response to
our prior audit, and it experienced a
70 percent turnover of upper
management in  1993.  In  our
opinion, the primary  cause of
PRASA's historically unstable
management is the change in  key
positions every time a new
Executive Director is appointed.

Failure to address longstanding
operations and maintenance
deficiencies prevented PRASA from
achieving continuous compliance
with  National Pollutant Discharge
Elimination System permit
requirements, and from providing
dependable protection of public
health and water quality.   PRASA
did not provide sufficient training for
wastewater treatment facility
operators in activated sludge
process control, and did not have a
comprehensive sludge
management plan.  Continuing
inability to implement an effective
preventive maintenance program
kept PRASA in a catch-up mode of
maintenance.  We found major
deficiencies at pump stations and
bypasses resulting in a high
potential for raw sewage overflows.
Critical units typically were run until
they failed,  rather than being
carefully evaluated and
reconditioned  on  a schedule.

For years, Region 2  has approved
grant funds despite PRASA's
inability to function as a responsible
grantee, and the  Region's
enforcement actions to date, while
numerous,  have not  resulted in the
corrections  expected. In our
opinion, Region 2 must continue  its
involvement, but  assume a stronger
role in  monitoring PRASA's
operation to assure meaningful
change is brought about. This is
especially important  in view of the
possible award of 27 new
construction grants to PRASA and
the awarding of State Revolving
Funds.  The Region advised that
they have further addressed our
concerns by prompting the
Governor to create the position of
Comptroller to independently
oversee PRASA's operations. The
Region and PRASA's Board of
Directors finalized a Memorandum
of Agreement  which included the
details  of the Comptroller's
responsibilities.

Followup Recommendations

We recommended that Regional
Administrator, Region 2:

•  Classify PRASA as a "high risk"
grantee and offer expertise to
PRASA during its effort to formulate
a recovery plan.
• Obtain from PRASA a detailed
corrective action plan with specific
steps and milestone dates, and
closely monitor progress towards
implementation.

• Work with senior PRASA and
Puerto Rico government officials to
ensure that PRASA will operate
with continuity.

• Perform monitoring to determine if
PRASA's promised corrective
actions were implemented and
effective.

• Encourage PRASA to address
structural problems causing
noncompliance, and use
enforcement actions if PRASA
continues in noncompliance.

What Action Was Taken

The final report (5400060) was
issued to the Regional
Administrator, Region 2,  on March
30, 1995.  In responding to the
draft report, the Regional
Administrator stated that PRASA
will be encouraged to make
improvements, but that the extent
of recommended EPA involvement
is not their role.  In addition to the
actions surrounding the
Comptroller's position, we were
informed that Region 2 plans to
increase the size and responsibility
of the Caribbean Field Office during
the next four years.  A response to
the final report is due by June 30,
1995.

Improvement Still Needed
In Region 7's  Potentially
Responsible Party Search
Program

Previous Problems and Findings

Our March 1992 report concluded
that searches  for potentially
responsible parties (PRP) in
Region 7 were not timely,
28
                                           OFFICE OF INSPECTOR GENERAL

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complete, or well documented,
resulting in  unnecessary costs
and delays in getting  polluters to
accept responsibility for cleaning
up their hazardous waste sites.
We reported that searches for 3
of 5 National Priorities List (NPL)
sites reviewed exceeded the
Superfund program standard by
more than four years, and
searches for 3 of 4 non-NPL sites
reviewed exceeded the program
standard by 8 times.  Also, many
of the work  assignments,
statements of work, work plans,
documentation of completed
tasks, and search reports could
not be found.

Followup  Findings

The Region attempted to address
the intent of the audit report
recommendations by improving the
PRP search acquisition practices,
management controls, and by
specializing and focusing contractor
work assignments on essential
search activities.  However, the
Region did not accomplish all  the
actions in  its implementation  plan
and response to the 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 standards are  for such
searches to take no more than 6
months. In addition, the Region
had not performed any  full baseline
searches since fiscal 1992.

Although the Region developed
new procedures, the 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.

Followup 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.

•  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

The final report (5400032) was
issued 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 include
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.
Accordingly, no further response
was required and the  report was
closed upon issuance.

CERCLIS Internal Controls
Strengthened

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. These
inaccuracies were attributable to
weak internal controls including
a failure 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.

Followup Findings

We found that the  corrective
actions recommended in our fiscal
1992 and 1993 reports had either
been completed or were nearing
completion.  Specifically, a
definition Reform Workgroup
developed clarifying language for
each accomplishment for inclusion
in the Superfund Program
Management Manual. An Office of
Solid Waste and Emergency
Response (OSWER) Directive was
issued 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.  Data
fields were added and definitions
were automated to provide users
with  information on the proper
OCTOBER 1, 1994 THROUGH MARCH 31, 1995
                                                                                                       29

-------
 methods for coding and entering
 CERCLIS data.  In addition,
 supplemental guidance was issued
 in April  1994 which outlined the
 methodology for developing and
 documenting estimated settlement
 amounts.

 Followup 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

 On November 15, 1994, the final
 report (5400014) was issued to the
 Assistant Administrator for Solid
 Waste and Emergency Response.

 Agency Actions In
 Response To Other OIG
 Work

 The OIG's reports and cooperative
 efforts with program officials
 frequently have positive impacts
 that reach beyond the
 implementation of specific report
 recommendations. These impacts
 are not  normally verified  by formal
 OIG followup reviews. For
 example:

 •  During this reporting period the
 OIG's efforts were instrumental in
 EPA's development of performance
 measurement information  for
 inclusion in the Agency's fiscal
 1994 financial statements.  In
 particular, the OIG assisted the
 Office of Prevention, Pesticides and
 Toxic Substances in revising its
 measures for the Asbestos Loan
 and Grant Program. In addition,
 the Agency used the results of the
 OIG's audits of the Leaking
 Underground Storage Tank
 Program as a mechanism to
evaluate the program's
performance, as required by the
Government Performance and
Results Act.

• In response to the OIG's inquiry
into allegations  of improper
Interagency Agreement (IAG)
oversight and management at a
Superfund site,  Region 8 officials
reviewed their IAG financial and
management controls.  They
confirmed the OIG's concerns
about inadequate  IAG monitoring,
identified additional IAG
management problems, and
developed corrective actions to
eliminate the vulnerabilities.
Status of Management
Decisions on IG  Reports


This section presents statistical
information as required by the
Inspector General Act Amendments
of 1988 on the status of EPA
management decisions  on reports
issued by the OIG involving
monetary recommendations.  In
order to provide uniformity in
reporting between the various
agencies,  the President's  Council
on Integrity and Efficiency issued
guidance on reporting  the costs
under required statistical tables of
sections 5(a)(8) and (9) of the Act,
as amended.

As presented, information
contained in Tables 1 and 2 cannot
be used to assess results of
reviews performed  or controlled by
this office.  Many of the reports
counted were performed by other
Federal auditors or independent
public accountants  under the
Single Audit Act. EPA OIG staff
does not manage or control such
assignments.  In addition, amounts
shown  as costs questioned or
recommended  to be put to better
use contain amounts which were at
the time of the review unsupported
by adequate documentation or
records.  Since auditees frequently
provide  additional documentation  to
support the allowability of such
costs subsequent to report
issuance, we expect that a high
proportion of unsupported  costs
will not be sustained.  EPA OIG
controlled reports resolved during
this period resulted in $33.1 million
being sustained out of $46.3 million
considered ineligible in reports
under OIG control.  This is 71
percent sustained rate.
30
                                                                                OFFICE OF INSPECTOR GENERAL

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Table 1 -- Inspector General Issued Reports With Questioned Costs

Semiannual Period Ending:  March 31, 1995

                                                                     Dollar Vaiues(thousands)
Questioned*
Number Costs
A.
B.

C.


D.

For which no management decision has been made by
the commencement of the reporting period**
New reports issued during period
Subtotals (A + B)
For which a management decision was made during
the reporting period
(i) Dollar value of disallowed costs
(ii) Dollar value of costs not disallowed
For which no management decision has been
made by the end of the reporting period
Reports for which no management decision was
made within six months of issuance
124
49
173
62
48
39***
111
74
363,519
62,328
425,847
121,211
45,496
75,715
304,636
243,256
Unsupported
Costs
100,796
23,210
124,006
22,888
8,438
14,450
101,118
77,976
     Questioned costs include unsupported costs.

     Any difference in number of reports and amounts of questioned costs or recommended efficiencies between this
     report and our previous semiannual report results from corrections made to data in our audit tracking system.

     14 audit reports totaling $3,630 were not agreed to by management.
OCTOBER 1, 1994 THROUGH MARCH 31, 1995                                                                    31

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Table 2 -- Inspector General Issued Reports With Recommendations That Funds Be Put To Better Use

 Semiannual Period Ending:  March 31, 1995

                                                        Number      Dollar Value
                                                                      (in thousands)
 A. For which no management decision  has been made by
    the commencement of the reporting  period*                34            27,005

 B. Which were issued during the reporting period              35            36,205

    Subtotals (A + B)                                       69            63,210

 C. For which a management decision was made during
    the reporting period                                     16             4,648

     (i)  Dollar  value of recommendations that
were agreed to by management
based on proposed management action
based on proposed legislative action
(ii) Dollar value of recommendations that were
not agreed to by management
(iii) Dollar value of non-awards or unsuccessful
bidders
D. For which no management decision has been made by
the end of the reporting period
Reports for which no management decision was
made within six months of issuance
5
n/a
n/a
9**
4
53
19
190
n/a
n/a
1,590
2,868***
58,562
22,393
   Any difference in number of reports and amounts of questioned costs or recommended efficiencies between this
   report and our previous semiannual report results from corrections made to data in our audit tracking system.

   Two reports were included in C(i) and C(ii).  Only the related dollars disallowed were included in C(i), whereas the
   dollars which  were not disallowed were included in  C(ii).

   This amount represents the dollar value of recommendations that funds be put to better use.
32                                                                             OFFICE OF INSPECTOR GENERAL

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Resolution of Significant Reports
                                      Report Resolution
Report Number
Report Date
E2CWL2-
4100431
REPORT
6/27/94
P2CWLO-
4100330
REPORT
5/27/94
P2CWL1-
4100414
REPORT
6/21/94
P2CWL1-
3100118
REPORT
3/ 2/93
P2CWL1-
3100169
REPORT
4/29/93
P2CWL3-
41C0412
REPORT
6/21/94
E2CWM1-
4200017
REPORT
7/11/94
P2CWM2-
4200012
REPORT
4/ 5/94
P2CWN1-
4300044
REPORT
8/24/94
E2BWL3-
02-0115

DATE

02-0232

DATE

02-0019

DATE

02-0104

DATE

02-0104

DATE

02-0177

DATE

03-0169

DATE

03-0293

DATE

03-0098

DATE

09-0190
3300072
REPORT
9/29/93
E2CWM2-
DATE

09-0202
4200020
REPORT
9/26/94
S2CWN2-
4300023
REPORT
1/13/94
S2CWN9-
1300118
REPORT
DATE

09-0126

DATE

09-0032

DATE
Grantee/
Contractor
NASSAU
COUNTY NY


CARTERET
NJ


CAPE MAY
COUNTY NJ


NYCDEP
NY


NYCDEP
NY


ONONDAGA
COUNTY NY


CHALFONT
TUP PA


ANNE
ARUNDEL
COUNTY MD

FAIRFAX
COUNTY VA


SAN DIEGO
OUTFALL CA


CENTRAL
MARIN CA


MODESTO
CA


MONTEREY
CA

9/30/91
S2CWN9-
1300117
REPORT
9/30/91
E9BHP2-
3400095
REPORT
9/29/93
09-0039

DATE

10-0024

DATE

LOS ANGELES
CA


RES -SELF
INSURANCE
OR

Report
. Issuance
FS Questioned/ t
Recommended
Efficiency
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UNUR
RCOM
1 ,











1
6


12
10
2

1
2










2



4








1,


5,

38,

6,

7,

294 ,



562,



517,
820,


, 337,
, 380,


, 895,
, 014,
, 160,

, 038,
, 125,


838,
11,


497,
321,


,650,
564,


, 996,
67,


698,



184,
,161,


621,

348,

098,

460,

966
0
0
0
082
0
0
0
747
808
0
0
198
330
0
0
788
698
202
0
675
053
0
0
177
936
0
0
541
029
0
0
367
072
0
0
690
546
0
0
753
0
0
0
079
015
0
0
855
0
260
0
282
0
741
0
3, 709, 794






0
0
0
Federal Share
o be Recovered/
Sustained
Łf f : ciency
INEL
UNSP
UNUR
SUST
INEL
UNSP
UNUR
SUST
INEL
UNSP
UNUR
SUST
INEL
UNSP
UNUR
SUST
INEL
UNSP
UNUR
SUST
INEL
UNSP
UNUR
SUST
INEL
UNSP
UNUR
SUST
INEL
UNSP
UNUR
SUST
INEL
UNSP
UNUR
SUST
INEL
UNSP
UNUR
SUST
INEL
UNSP
UNUR
SUST
INEL
UNSP
UNUR
SUST
INEL
UNSP
UNUR
SUST
INEL
UNSP
UNUR
SUST
INEL
UNSP
UNUR
SUST
1, 294 ,



562,



511,
1,


1, 115,
2, 242,


9, 049,
4,429,
712,

1, 038,



838 ,
11,


481,



2, 610,
544 ,


4, 996,
67,


698,



184,
995,


3, 755,

2, 381,

1,425,



2, 800,



966
0
0
0
082
0
0
0
461
300
0
0
819
271
0
0
323
590
124
0
175
0
0
0
177
936
0
0
448
0
0
0
617
973
0
0
690
546
0
0
753
0
0
0
079
272
0
0
605
0
277
0
256
0
0
0
000
0
0
0
                                                        NOTE:  INEL      INELIGIBLE COST
                                                              UNSP      UNSUPPORTED COST
                                                              UNUR      UNNECESSARY/UNREASONABLE COST
                                                              RCOM      RECOMMENDED EFFICIENCIES
                                                              SUST     RECOMMENDED EFFICIENCIES SUSTAINED
OCTOBER 1, 1994 THROUGH MARCH 31, 1995
33

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                     ^
  The following is a summary of
  investigative activities during this
  reporting period.  These include
  investigations of alleged criminal
  violations which  may result in
  prosecution and  conviction,
  investigations of alleged
  violations of Agency regulations
  and policies, and 0!G personnel
  security investigations.  The
  Office of Investigations tracks
  investigations in the following
  categories:  preliminary inquiries
  and investigations, joint
  investigations with other
  agencies, and OIG background
  investigations.
Summary Of Investigative
Activities
Pending Investigations as
of September 30, 1994          157

New Investigations
Opened This Period             89

Investigations Closed
This Period                     75

Pending Investigations as
of March 31, 1995              171
    Prosecutive and
    Administrative Actions

    In this period, investigative efforts
    resulted in 9 convictions and 12*
    indictments.  Fines and recoveries,
    including those associated with civil
    actions, amounted to $4.2 million.
    Thirteen administrative actions**
    were taken as  a result of
    investigations:

    Reprimands                      5
    Resignations/Removals           1
    Restitutions                      6
    Other                           1
                                                                                     TOTAL
                                                                     13
                                                                              * Does not include indictments obtained in
                                                                              cases in which we provided investigative
                                                                              assistance.

                                                                              ** Does not include suspensions and
                                                                              debarments resulting from Office of
                                                                              Investigations activities or actions resulting
                                                                              from reviews of personnel security
                                                                              investigations.
                                  Profiles of Pending Investigations by Type
                                                   (Tota!»171)
                  General EPA Programs
                              Superfund and Lust
                                        Program Integrity
                                              38
                      Procurement Fraud
                            33
Procurement Fraud
       34
            Employee Integrity
                  1,9
 Construction
     15.
                                                                                                 Employee Integrity
                                                                                                       2

                                                                                               Other
                                                                                                 4
                       Total Cases: 116
 Program Integrity
      16
Total Cases:  55
  34
                                           OFFICE OF INSPECTOR GENERAL

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 Description of Selected
 Prosecutive and
 Administrative Actions


 Below is a brief description of some
 of the prosecutive actions which
 occurred during the reporting period.
 Some of these actions resulted from
 investigations initiated before
 October 1, 1994.

 Former Maryland Chief
 Fiscal Officer Ordered to
 Repay $1.2 Million

 As reported in our Semiannual
 Report for the period ending
 September 30, 1994, Rufus O.
 Ukaegbu, former chief fiscal officer
 for the State of Maryland
 Department of the Environment,
 Water Quality Financing
 Administration (WQFA), pleaded
 guilty to Federal charges of money
 laundering and State of Maryland
 charges of theft.

 In October 1994 Ukaegbu was
 sentenced on the Federal charges to
 41  months imprisonment and repaid
 the State $100,000 in addition to
 $1,000 that was seized during a
 search.  In November 1994,
 Ukaegbu was sentenced on the
 State charges to 20 years
 imprisonment (10 years suspended),
 5 years probation,  and was ordered
 to pay the remaining restitution of
 $1,105,901.

 Using a combination of State and
 Federal grants as well as revenues
 from bonds maintained in various
 bank accounts, WQFA finances the
 construction of sewage treatment
 plants and other water quality
 projects by local governments.
 Ukaegbu, who had the authority to
 approve disbursements to
contractors, used his position to
cause the WQFA's  bank to generate
fraudulent payment authorizations in
names similar to legitimate
contractors, but with addresses of
bank accounts that he controlled.

Through the use of wire transfers
and monetary instruments, the
stolen funds were used to purchase
numerous automobiles and other
items of value which were shipped to
Nigeria for resale, home remodeling,
and to reduce personal debt.

Additionally, in January 1995,
Ukaegbu was debarred for five years
as result of the Federal and State
charges.

Conspirator Pleads Guilty
on State Charges

Keith Westbrook pleaded guilty to
felony theft charges by the State of
Maryland as a  conspirator with
Rufus O. Ukaegbu, relative to the
$1.2 million embezzlement described
in the above case.  Westbrook was
sentenced to 3 years  imprisonment
(suspended), 5 years  probation, with
the first six months as home
detention, and ordered to pay
$12,000 restitution.

Both cases, Ukaegbu and
Westbrook, were investigated jointly
by the EPA OIG, FBI, and the
Maryland State Police.

Project Manager  Convicted
of Writing Checks to Himself

James Speer, project manager with
Olympic View Environmental Review
Council (OVER-C), Kitsap County,
Washington, was convicted
on March 30, 1995, for embezzling
over $46,500 from OVER-C.

OVER-C, a nonprofit organization,
was awarded an  EPA technical
assistance grant  (TAG) involving
three Superfund sites in Kitsap
County.  Speer gained control of the
organization's finances including
records, checkbooks,  incoming bills,
and  outgoing payments and
subsequently was able to write
checks in excess of $86,000 to
himself. Speer would write the
OVER-C checks and take them to
two board members for authorization
signatures.  He then replaced the
names of the legitimate payees on
the check with his own name to
remove cash from the OVER-C bank
account.  The cash was traced to his
girlfriend's account and her mother's
account.  Speer paid portions of
legitimate expenses while holding
back funds for himself, allowing him
time  to continue obtaining and using
additional Federal, State and private
grants funds to "lap" expenses,
staying ahead of the creditors.

Speer's "lapping"  scheme collapsed
when some of the technical advisors
on the projects complained that they
had not been paid completely for
their  work.

Firm and President
Sentenced

T.  Head and Company, Inc., known
as THI, and Toney Head, Jr., the
firm's owner, president, and chief
executive officer,  were sentenced in
October 1994, after being convicted
of  filing 41 false claims.  Head was
sentenced to 4 months prison in a
work release program, 4 months
home confinement, 2 years
probation, and ordered to pay
restitution of $18,515 and a $2,000
special assessment.  THI was fined
$10,000 and ordered to pay an
$8,000 special assessment.

As reported in our previous
semiannual report, THI, of Herndon,
Virginia, a subcontractor on a prime
contract between  the Small Business
Administration and EPA, was to
establish and monitor national
accounts for shipping  laboratory
samples of hazardous waste and
other materials to certain contract
OCTOBER 1, 1994 THROUGH MARCH 31, 1995
                                                                                                 35

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laboratories for analysis. However,
our investigation  revealed that Head
directed four former THI employees
to falsify  records which  showed the
number of hours these employees
worked on the EPA contract.  Head
used the false information to inflate
numerous THI invoices  submitted to
EPA.

Three  Public  Health  Officers
Guilty of Hiding Interest In
EPA Contractor

William Burkhardt III, Scott R.
Rippey and William D. Watkins,
Commissioned Officers of the  U.S.
Public Health Service assigned to
the U.S.  Food and Drug
Administration, North Kingstown, Rl,
plead guilty to knowingly filing  false
confidential statements  of
employment and financial  interest.
All three  willfully  failed to disclose
their controlling  ownership and
employment interest in  Biosearch
Limited, New England Scientific, and
Biological Analytical Laboratories
(BAL). BAL received  contracts and
funds from EPA for work on the
Narragansett Bay Project through
one of the defendants and used
equipment and supplies from the
FDA.  Each defendant was fined
$500 plus a $25  assessment.  This
case was investigated jointly by the
EPA OIG, HHS  DIG and the Postal
Inspection Service.

Office Equipment Pawned

A former Region  4 Stay-in-School
participant pleaded guilty in
December 1994 to misdemeanor
theft of government property.  The
former employee was sentenced to 5
years  probation, the first year to be
supervised, and  ordered to pay
restitution of $2,922. While
employed with EPA, he had
removed  several  pieces of EPA
electronic and photographic
equipment including portable
computers, video cameras, and
transceivers, and pawned them in
various Atlanta area pawn shops.
Civil and Administrative
Actions to Recover EPA
Funds


Investigations and audits conducted
by the Office of Inspector General
provide  the basis for civil and
administrative actions to recover
funds fraudulently obtained from
EPA.  Through the Inspector
General Division (IGD) of the Office
of General Counsel  (OGC), the OIG
uses a variety of tools to obtain
restitution.  These include
cooperative efforts with the
Department of Justice in filing civil
suits under the False Claims Act,
the Program Fraud Civil Remedies
Act, and other authorities:  working
with grantees using  their own civil
litigation authorities: invoking the
restitution provisions of the Victim
and Witness Protection  Act during
criminal sentencing:  using  the
Agency's authority to
administratively offset future
payments and to collect debts: and
negotiating  voluntary settlements
providing for restitution  in the
context of suspension and
debarment actions.  Civil and
administrative actions to recover
funds usually extend over several
semiannual reporting periods.

Riedel Environmental
Services, Inc. to Repay More
Than $2.8 Million

The Department of Justice's Civil
Division, working with attorneys from
EPA's OGC, 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 a 3 year period,
plus interest accruing on the unpaid
principal  balance,  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 plus 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.  In
addition,  the OIG audit and
investigation revealed that RES
continued to receive payments from
EPA for pollution self-insurance even
after RES purchased pollution
liability insurance.

Subcontractor Enters Civil
Settlement

EPS Analytical Services, of Canton
Mississippi, an EPA subcontractor,
paid $5,000 in a civil settlement on
charges of submitting false claims
for payment to EPA. EPS Analytical
Services,  a subcontractor for OHM,
the prime contractor on the
Southeast Wood Processing
Superfund Site,  was charged with
making false claims for payment
from EPA through OHM, for soil
sample analysis that did not comply
with EPA specifications.
36
                                           OFFICE OF INSPECTOR GENERAL

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  Section  4 -- Fraud Prevention And  Management Improvements
This section describes several
activities of the Office of
Inspector General to promote
economy and efficiency and to
prevent and  detect fraud, waste,
and abuse in the administration
of EPA programs and operations.
This section includes information
required by statute,
recommended  by Senate report,
or deemed appropriate by the
Inspector General.
Review of Legislation and
Regulations

Section 4(a)(2) of the Inspector
General Act of 1978, as amended,
directs the Office  of Inspector
General to review existing and
proposed legislation and regulations
relating to Agency programs and
operations to determine their effect
on economy and efficiency and the
prevention and detection of fraud
and abuse.  During this semiannual
period, we reviewed 2 legislative
and 69 regulatory items.  The most
significant items reviewed are
summarized below.

Regulations Implementing
the Federal Acquisition
Streamlining Act

Section 6006 of the Federal
Acquisition Streamlining Act of 1994
(Act),  Public Law  103-355,  provides
whistleblower protection for
contractor employees of civilian
agencies. The Inspectors General of
executive agencies must review
allegations of reprisals against
contractor employees,  and, if
warranted, issue a report

We reviewed the proposed  rule
published in the December 1, 1994,
Federal Register,  for implementing
the whistleblower  protection
provisions of the Act.  Section
3.905(c) of the proposed rule stated
that "Upon completion  of the
investigation, the  head of the
Agency shall ensure that the
Inspector General provides a report
of findings to..."  We commented
that such language was
unnecessary and  appeared to
infringe upon the  independent status
of the Inspector General. We
recommended that the section be
revised to eliminate reference to the
Agency head in relation to  the
distribution of the IG's  report.
Proposed Executive Order
on Classified National
Security Information

We reviewed the subject document
at OMB's request, and objected to
the section requiring an Inspector
General  to conduct periodic
evaluations of his/her agency's
classified national security
information program.  With the
exception of audits required by
statute, we believe audits should
result from a planning process
which involves risk assessments of
agency programs and activities.

Interim Rule Governing
Entertainment, Gift, and
Recreation Costs for
Contractor Employees

We reviewed the interim  rule under
Federal Acquisition Regulation
(FAR) case 94-750. Among other
things, the interim rule would revise
the FAR to indicate that the costs of
wellness/fitness centers are
allowable and that other recreation
costs, with the exception of
employee sports teams, are
unallowable. We agreed that the
costs of wellness/fitness  centers
should be allowable as a means of
improving employee morale,
performance, and fitness, but do not
believe that the Government should
pay the additional expense of
subsidizing a contractor's employee
sports teams.  We recommended
that all  recreation costs, with the
exception of wellness/fitness
centers, should be unallowable.
OCTOBER 1, 1994 THROUGH MARCH 31, 1995
                                                          37

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 Information Resources
 Policy Manual Directive
 2100 - Information and Data
 Management Policy

 We reviewed the Agency's draft
 policy and did not concur primarily
 because the document did not
 reflect the Agency's commitment to
 implementing a strong and effective
 data management program. Many
 of the recommendations which the
 Assistant Administrator for
 Administration and Resources
 Management agreed to implement
 following a congressionally
 requested Inspector General review
 were not implemented.  We were
 particularly concerned that the
 document failed to define the
 responsibilities of the Information
 and  Data Management  Officer as
 they relate to establishing a
 "structure" to effectively share data
 Agency-wide. We believe that this
 position should be afforded the
 authority necessary to effectively
 centralize control over the Agency's
 decentralized systems development
 activities.  Accordingly,  we
 recommended that the document be
 revised to reflect several
 responsibilities of this position.

 We also recommended  clarification
 of various terms; identification  of the
 ultimate goal or purpose of
 information and data management;
 and inclusion of several additional
 responsibilities for certain officials.
 At the end of the reporting period,
 the Office of Information Resources
 Management was addressing our
 concerns.

 Information Resources
 Policy Manual Directive
 2100 - Records  Management
 Policy

We reviewed  the Agency's draft
policy and recommended that it be
revised to reflect the unique storage
and retirement considerations of
electronic records.  We also
recommended that the document be
revised to (1) better describe the
roles and responsibilities  of systems
managers and ADP managers
concerning the management of
electronic records and (2) specify
that electronic records which are not
copied to standard tapes  must be
maintained according to general
records schedules.

Amendment  to  EPA  Order
3120.1, Conduct and
Discipline

We did not concur with the
proposed revision because not all
penalties appeared to be
commensurate with the offense and
not all prohibited actions were
addressed.   At  the end of the
reporting period, the Office of
Human Resources Management
was addressing  our comments.

FAR Case 94-721

We recommended clarification of
certain provisions implementing the
Federal Acquisition  Streamlining Act
of 1994 and revising the Truth in
Negotiations  Act. Our primary
recommendation related to a
provision which  could result in
numerous instances where certified
cost or pricing data would not be
required, despite inadequate
competition.  We recommended
that, in those cases,  the offeror be
required to submit such data so that
the Government could  perform cost
or price analysis and ultimately
negotiate a fair and reasonable
price.
Suspension and
Debarment Activities
EPA's policy is to do business only
with contractors and assistance
recipients who are honest and
responsible.  EPA enforces this
policy by suspending or debarring
contractors, assistance recipients,
or individuals within those
organizations,  from further EPA
contracts or assistance if there has
been a conviction of, or civil
judgment for:

• commission of a fraud or a
criminal offense in  connection with
obtaining,  attempting to obtain, or
performing a public contract or
subcontract;

• violation  of Federal or State
antitrust statutes relating to the
submission of offers:

• commission of embezzlement,
theft, forgery, bribery, falsification or
destruction of records,  making a
false statement, or receiving stolen
property; or

• commission of any other offense
indicating  a lack of business
integrity or business honesty that
seriously and directly affects the
present responsibility of a
Government contractor or
subcontractor.

A contractor may also be debarred
for violating the terms of a
Government contract or
subcontract, such as willful failure
to perform  in accordance with the
terms of one or more contracts, or
a history of failure  to perform, or of
unsatisfactory performance on one
or more contracts.   A contractor
may also be debarred for any other
cause of so serious or  compelling a
nature that it affects the present
responsibility of the contractor.
Thus, a contractor need not have
38
                                          OFFICE OF INSPECTOR GENERAL

-------
committed fraud or been convicted
of an offense to warrant being
debarred.  Debarments are to be
for a period commensurate with the
seriousness of the cause, but
generally do not exceed 3 years.

The effectiveness of the suspension
and debarment (S&D) program has
been enhanced by regulations that
provide all Federal agencies  a
uniform system for debarring
contractors from receiving work
funded by Federal grants, loans, or
cooperative agreements.   The
system, required by Executive
Order 12549, provides that a non-
procurement debarment or
suspension by one  agency is
effective in all agencies and
requires the General  Services
Administration  to publish monthly
"Lists of Parties Excluded from
Federal Procurement or Non-
procurement Programs." Formerly,
a non-procurement  debarment  was
effective only in the programs
administered by the debarring
agency,  and each agency
maintained its own list.  The  EPA
Suspension and Debarment
Division in the  Office  of Grants and
Debarment operates the  S&D
program at EPA. The OIG assists
the EPA S&D program by providing
information from audits,
investigations,  and engineering
studies: and obtaining documents
and evidence used  in determining
whether there is a cause for
suspension or debarment.  During
this period, cases with direct OIG
involvement led to 23 debarments,
one suspension, and  two
compliance agreements,  a total of
26 actions.

The following  are examples:

•  On  February 2, 1995, EPA
suspended Brian Burns, the former
head of the Northeast Rural Water
Association (NERWA), a recipient of
EPA grant funds through the
National Rural Water Association.
EPA based this action on a criminal
indictment resulting from an OIG
investigation.  According to the
indictment,  Mr. Burns attended
Trinity College and Harvard
University as  a full-time student,
while he allegedly claimed his EPA-
funded salary from NERWA and his
educational expenses as NERWA-
related.

•  On March 7, 1995, EPA approved
a compliance agreement with  PRC
Environmental Management, Inc.
(PRC EMI), in which PRC EMI
agreed to reimburse EPA $300,000
for damages resulting from its
submittal of premature bills for
subcontractor costs.  PRC EMI also
agreed to implement several
remedial measures designed to
ensure that its future performance
and administration of Federal
contracts and assistance
agreements fully comply with all
applicable laws and regulations.

•   On November 21, 1994, EPA
debarred Stanley L.  Peters and
Stanley L. Peters and Associates,
Inc. for 3 years.  On January 31,
1995, AET  Collaborative,  Inc.  of
which Mr. Peters was president,
was  debarred for 3 years.  The
debarment  arose from a joint OIG
and FBI investigation which resulted
in criminal charges alleging  that Mr.
Peters had  received kickbacks from
Nebraska schools for his assistance
in obtaining Asbestos School
Hazardous  Abatement Act
grants/loans from EPA. He was
convicted of conspiracy to defraud
by submitting false and fraudulent
claims, and theft of Government
funds.  Dean  Curtis, a co-
conspirator, was debarred effective
October 31, 1994.

• EPA debarred EKOTEC,  Inc., its
President, Steven Self,  and
company officials, Sharon Self and
Steven Miller, for a period of five
years, effective October 4, 1994.
Mr. Self was convicted of improper
disposal of hazardous waste by
dumping waste in diesel automobile
tanks and ordering the falsification
of documents regarding its disposal.
In addition,  he was responsible for
illegal discharge of oil, grease, and
industrial wastewater into the Salt
Lake City sewer system in violation
of the Clean Water, Clean Air, and
Resource and Conservation
Recovery Acts.
OIG  Personnel Security
Program
This program is one of the first-line
defenses against fraud by using
background investigations and
National Agency Checks and
Inquiries  to review the integrity of
EPA employees and contractors.

During this reporting period,
reviewed 320 investigations.

• One employee was allowed to
resign pending administrative
removal for falsification of
the SF-171  used to gain
employment, by claiming a degree
not earned.  The degree was
required for the position.

• One employee received a 14-day
suspension for a felony conviction.

• One employee was terminated
during probationary period for
falsification  of the SF-171  by failing
to  list  a previous termination, and
for unprofessional conduct.

• One employee was reassigned to
a low-risk position after an arrest
report disclosed a conviction for
theft.
OCTOBER 1, 1994 THROUGH MARCH 31, 1995
                                                             39

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 OIG Management
 Initiatives
 Reinventing Offices of
 Inspector General

 The EPA OIG has continued the
 process of reinvention, in
 accordance with the following vision
 statement adopted by the Inspectors
 General:  "We are agents of positive
 change striving for continuous
 improvement in our agencies'
 management and program
 operations and in our own offices."
 In fulfilling this vision and carrying
 out the mission responsibilities set
 forth  in the Inspector General Act,
 the IGs have pledged to:

 •  work with management and the
 Congress to improve program
 management.

 •  use our investigative and program
 compliance reviews to improve the
 effectiveness of program operations,
 increase Government integrity, and
 recommend improved systems to
 prevent fraud, waste, and abuse.

 •  be  innovative and question
 existing procedures and suggest
 improvements.

 • build relationships with program
 managers based on a shared
 commitment to improve program
 operations.

 • continue to improve the quality
 and usefulness of our products.

 • work together to identify  and
 address Government-wide  issues.

 We believe that the OIG has always
 taken a cooperative approach with
 EPA management in resolving and
 implementing results of our audits
 and investigations.  In this regard,
 the OIG has begun to place even
 greater emphasis on building
 partnerships with Agency program
 managers based on a shared
 commitment to improving
 operations.  The OIG has taken or
 planned a number of other initiatives
 to enhance this cooperation.  More
 OIG resources are being directed to
 conducting performance audits to
 analyze how well programs are
 meeting their goals and
 recommending changes in program
 design and management techniques
 to increase efficiency and improve
 program results.

 We are focusing more on causes of
 problems and  provide more
 balanced reporting by identifying
 effective corrective actions taken by
 Agency management and examples
 of good management practices,
 when possible.

 We have begun a streamlining
 process within OIG that has three
 themes:

 • Increased Delegation and
  Decentralization of Authority

 The OIG is working to delegate to
 the lowest practical level the
 responsibility and authority to  make
 managerial decisions and increase
 autonomy over its audits,
 investigations,  and administrative
 support activities.

 • Increased Empowerment of
  Employees with Appropriate
  Accountability

 We will continue empowering the
 field divisions with more authority
 and autonomy  in personnel matters,
 and by empowering Divisional  IGs
 and Headquarters Directors to sign
 major audits, investigations,  and
 management reports..

 • Improvement of Work Processes
  and Systems

The OIG has devoted considerable
time soliciting ideas from our staff at
all levels to improve work
 processes.  Several major theme
 areas have emerged from these
 discussions. First, as stated above,
 we are focusing more attention  on
 assisting EPA managers to achieve
 their program objectives. While we
 will continue to conduct compliance
 reviews as part of our audits, we
 are working more cooperatively  with
 our customers to ensure that our
 products meet their needs.
 Internally,  we are comprehensively
 reviewing our policies and
 procedures to ensure that each
 requirement in the audit process
 adds value to our products.

 Relative to the three themes, we
 have completed or currently have
 in process several streamlining
 initiatives.  Examples of these
 initiatives  follow.

 Organizational Structure, Size,
 and  Composition

 • The OIG has streamlined its
 organization through consolidation
 of field offices, transferring and
 realigning positions and by
 eliminating  supervisory positions.
 All three components of the OIG
 have either achieved or are in the
 process of achieving the supervisory
 ratio of 1:11 as  mandated by the
 Administrator.

 • Office of Investigations
 consolidated seven investigations
 field  divisions into three divisions,
 eliminating  a supervisory level and
 has already achieved a 1:11
 supervisory  ratio.

 • Office of Audit has flattened its
 organization by  reassigning
 Headquarters administrative and
 management staff to audit field
offices and by eliminating ,
supervisory positions and levels  of
review. This office now has a
supervisory ratio of 1:8 and will
achieve a 1:11 ratio during 1996.
40
                                           OFFICE OF INSPECTOR GENERAL

-------
•  Office of Management has
streamlined its structure by
eliminating supervisory  positions to
reduce supervisory levels by 50
percent thus achieving the 1:11
ratio.

•  We made  liberal use  of early-out
and buy-out  opportunities to reduce
staff size.

•  The  OIG has made great strides
in diversifying its workforce and is
taking  steps  to maintain and
strengthen diversity while meeting
its streamlining  requirements.

•  The  OIG has implemented a
policy supporting our Affirmative
Action  Plan resulting in  minorities
and women accounting  for 75
percent of all new hires and
promotions during fiscal 1994,
including new hires and promotions
at grades 13 to 15.

Management and Administration

• The  OIG has taken the greatest
initiative in EPA to streamline its
employee performance  appraisal
system. This is being done by
reducing the number of rating levels
and using generic summary Critical
Job Elements focusing  on outcomes
and standards at only the Fully
Successful level.  We are requiring
summary appraisal justifications
only for Outstanding and
Unsatisfactory ratings.  This will
reduce the time devoted to this
activity by at least fifty percent while
improving its effectiveness.

• The  OIG is in the process of
increasing delegation and
decentralizing authority to the lowest
practical level to make  managerial
decisions and increasing the
empowerment of employees.
Work Processes

•  The OIG is improving its work
processes and systems by working
with our customers to ensure that
our products meet their needs and
provide consultative services to
promote more economic,  efficient,
and effective Agency management.

•  OIG has included EPA
management directly in our audit
planning process.

•  We are developing performance
measures which include customer
surveys and other external
feedback.   The  most recent issue of
our IG HIGHLIGHTS publication
contains a  customer survey.  Since
this publication  is distributed  nation-
wide to all  EPA employees, we will
receive valuable feedback.

•  The OIG is implementing the use
of electronic data exchange to
facilitate reporting between the field
offices and Headquarters in order to
reduce the use  of paper.

•  We are reviewing OIG policy
manuals to identify and eliminate
policies  in preference to existing
Agency or  Federal policy.

•  OIG revised its reporting format to
provide more concise and better
balanced presentations to Agency
management and Congress.

•  The OIG, by invitation,  has
worked on  cooperative  projects with
Agency  managers to improve the
integrity of scientific and financial
information and Superfund
accounting.

Remaining Steps Toward
Continuing Reinvention

The OIG recognizes that reinvention
is a dynamic  process.  We are
extremely satisfied with the results
of our reinvention efforts  so far.
However, we recognize that
constant monitoring is  necessary to
identify both potential problems and
opportunities for improvements.

The areas that we believe need
additional assistance in bringing our
reinvention  efforts to fruition remain
in team building, development of
performance indicators within our
offices, reduction of internal policy
guidance, and conversion of a
number of our auditors to
management analyst positions.

Training

OIG Developed  Courses

•  Statistical Sampling Training

This course was designed to
provide skills necessary to perform
statistical sampling in connection
with EPA contract audits.  The
emphasis is on elementary sampling
procedures with some additional
direction for those who encounter
more difficult sampling problems
and need references to more
complete sources.  This course was
presented in Washington, DC.

• Internal Controls  and Fraud
Prevention

At the request of the Agency, the
OIG presented a unit called a
"Prescription for Prevention"  as part
of continuing professional education
for Senior Executives. This
presentation was designed to help
EPA Senior Executives understand
the nature and need for internal
controls in  preventing  and detecting
vulnerability to loss  of resources
and raise their consciousness to the
elements and indicators of fraud.
During this reporting period the unit
was presented at five Senior
Executive Workshops.

This presentation is an example of
how the OIG is working with EPA
and providing assistance to promote
economy and efficiency.
OCTOBER 1, 1994 THROUGH MARCH 31, 1995
                                                              41

-------
 Peter Rosenberg, Assistant Director,
 Communications, Office of Enforcement and
 Compliance Assurance (CECA), speaks at
 Brown Bag gathering (photo by Dana
 Sharon)
OIG Staff members engaged in lively
discussions with Peter Rosenberg (photo by
Dana Sharon)
The Brown Bag Institute of
Learning

As part of our effort to do more in-
house training, we continued a
lunchtime training program called
the Brown Bag Institute of Learning.
This program, hosted by various
OIG managers, features videotapes,
case studies, discussions, and
presentations by experts on
subjects pertinent to OIG work.

During this reporting period,
presented reorganization of EPA's
Office of Enforcement.  Peter
Rosenberg, Assistant Director of
Communication,  OECA, and Mark
Charles, Branch  Chief, Water
Enforcement, OECA, were the
instructors/facilitators.

OIG Contracted Courses

• Accounting and Auditing
Update

This course was designed to
provide EPA OIG personnel with an
update and review of Generally
Accepted Accounting Principles with
FAR and CAS cost principles as
thqy relate specifically to EPA
leases, pensions, mergers,
acquisitions, compensated
absences and post retirement
benefits.  This course was
presented in Memphis, TN.
President's Council on
Integrity and Efficiency


• PCIE Performance Measures
Task Force

We participated on a special PCIE
working group to develop draft
standard performance measures for
Federal Offices of Inspector
General.  The purpose of this
ongoing project is to define output
and outcome measures of OIG
efficiency and effectiveness in
                                                                          relation to the recently published
                                                                          OIG Vision Statement and
                                                                          Strategies to Apply Reinvention
                                                                          Principles.  OIGs also must develop
                                                                          and report on performance in
                                                                          relation to budgetary requests and
                                                                          strategic plans in compliance with
                                                                          the requirements of the Chief
                                                                          Financial Officers Act of 1990 and
                                                                          the Government Performance and
                                                                          Results Act of 1993.
Committee on Integrity
and Management
Improvement

The Committee on Integrity and
Management Improvement (CIMI)
was established in 1984 by EPA
Order 1130.1.  Composed of senior
EPA program  officials and chaired
by the Inspector General, CIMI
strives to continually increase
employee awareness and
understanding  of various Agency
policies and procedures and to
improve the economy,  efficiency,
and effectiveness of Agency
operations.

AWARENESS BULLETINS

American Express
Government Program

The American Express Government
Program was implemented at EPA
on November  30, 1993, and
provides eligible EPA employees
with an American Express
Government credit card (Amex card)
to pay for expenses related to
official Government travel, such as
common passenger carrier tickets,
lodging,  meals, and automobile
rentals.  Because of known and
potential abuses, CIMI  prepared this
awareness bulletin to inform EPA
employees of the requirements, and
benefits of the program.

Employees  may not use the
Government Amex card to pay for
42
                                         OFFICE OF INSPECTOR GENERAL

-------
personal travel expenses or for any
purchase that is not related to
official Government travel.  In
addition to using the card only for
authorized purposes and  paying the
bill in full upon receipt,  employees
are responsible for securing the
card, reporting a lost or stolen card,
returning the card upon cancellation
or suspension of cardholder
privileges or leaving Agency
employment, and contacting
American Express  to resolve any
disputed charges.

Conferences and Meetings

In an effort to reduce administrative
expenses, President Clinton
targeted Government meetings and
conferences for close scrutiny.  As a
result, the Office of Management
and Budget (OMB) issued OMB
Bulletin 93-11, instructing agencies
to keep conference costs to a
minimum and to document
alternatives considered and the
rationale used  in selecting
conference sites.  On September
14, 1994. the Agency issued Office
of the Comptroller  Policy
Announcement 94-10 to provide
implementing guidance. Agency
policy dictates  that a conference or
meeting, and related travel, can be
authorized only if it will provide a
direct benefit to achieving EPA's
mission. In addition, a written cost
comparison must be prepared for all
conferences and meetings involving
travel by 30 employees or more and
the final site selection must be
approved by the Assistant or
Regional Administrator.  CIMI
prepared an awareness bulletin to
highlight EPA's policy and to stress
the importance of avoiding even the
appearance of improprieties in this
area.
Management and
Disposition of Federal
Records

Federal records are Government
property and may not be disposed
of except in accordance with
approved disposition schedules.
EPA employees have three specific
records management
responsibilities.  They must create
records sufficient to document
activities; maintain official Agency
records separately from their
personal files and other nonrecord
materials;  and follow the retention
and disposition guidance specified
in the records disposition schedules
and the recordkeeping requirements
documented for their organization
within EPA.  Managers  or
supervisors should ensure  that
recordkeeping requirements exist for
all records and that  the records are
maintained according to Federal
regulations and Agency policy.
CIMI developed this bulletin to
inform  Agency employees of the
requirements associated with the
maintenance and disposition of
official  Agency records  and their
responsibilities in this regard.
Hotline Activities
The OIG Hotline opened 18 new
cases and closed 31 cases during
the reporting period.  Of the cases
closed, 7 resulted in environmental,
prosecutive, or administrative
corrective action, while 24  did not
require action.  Cases that did not
have immediate validity because  of
insufficient  information may be used
to identify trends or patterns of
potentially vulnerable areas for
future review. The Hotline also
referred 2,533 telephone callers to
the appropriate program office,
State agency, or other Federal
agency for assistance.
The following are examples of
action taken as a result of
information provided by the OIG
Hotline.

•  A complainant alleged that an
EPA employee obtained travel
advance funds without authorization
by forging a supervisor's signature.
An inquiry determined that the
employee  had obtained such funds
without authorization on four
separate occasions. Three of the
four advances were repaid to the
Imprest Fund before the employee
became aware of the inquiry. The
fourth repayment was made by  the
employee  after being confronted by
management. The employee
received a 60-day suspension.

•  A complainant alleged that an oil
company  in Ford, Virginia,  was
operating in violation of EPA
regulations.  Inspections of the
company's facilities disclosed that
the company  had failed to  prepare,
certify, and implement  Spill
Prevention, Control, and
Countermeasures (SPCC)  plans.
The company was issued a notice
of non-compliance and given a
grace period of  120 days to achieve
compliance.
OCTOBER 1, 1994 THROUGH MARCH 31, 1995
                                                             43

-------
  Appendix 1  ^Rspoits  Issued
APPENDIX 1  REPORTS ISSUED

     THE INSPECTOR GENERAL ACT REQUIRES A LISTING, SUBDIVIDED ACCORDING TO SUBJECT MATTER, OF EACH REPORT
ISSUED BY THE OFFICE DURING THE REPORTING PERIOD  AND FOR EACH REPORT, WHERE APPLICABLE, THE DOLLAR VALUE
OF QUESTIONED COSTS AND THE DOLLAR VALUE OF RECOMMENDATIONS THAT FUNDS BE PUT TO BETTER USE.
                                                                              Questioned Costs
                                                                                    Recommended
                                                                                    Efficiencies
 Assignment Control Number
                               Title
                                                    Final Report
                                                        Issued
                                             Ineligible   Unsupported    Unreasonable  (Funds Be Put
                                              Costs	Costs	Costs	To Better Use)
 1.  INTERNAL & MANAGEMENT ASSIGNMENTS

 Grants Administration Division

 E1XMG5-11-0003-5400028  COMPLIANCE WITH RESTRICTIONS
                       ON  LOBBYING
                                1/ 6/95
 Assistant Administrator for Administration and Resources Management
 E1KAG4-03-0068-5400037

 E1BMF2-04-0373-5100247


 E1FMG4-13-0061-5400051

 E1MMG4-13-0064-5400052

 E1SFL4-20-8001-5100192

 E1AMF4-20-7002-5100209

 E1NMF3-15-0072-5100240
REVIEW OF ETS RISK ASSESSMENTS     2/ 2/95

IMPROVEMENTS NEEDED IN SUBCON-
TRACTOR COMPETITION & OVERSIGHT    3/31/95

IAGS: OFF-LOADING AT EPA HQ        3/31/95

ADMINISTRATION OF IPA ASSIGNMENTS  3/30/95

FY 94 FINANCIAL STATEMENTS         2/28/95

EPA'S COLLECTION OF USER FEES      3/27/95

EPA'S MANAGEMENT OF APPLICATION
SOFTWARE MAINTENANCE              3/31/95
 Assistant Administrator for Research and Development

 E1SKF4-02-0059-5400029  CONTRACT MONITORING ACTIVITIES
                       AT RREL-EDISON                    1/12/95

 E6ABG5-11-0009-5400046  ORD CONTRACTOR CONVERSION EFFORTS   3/ 8/95


 Assistant Administrator for Solid Waste & Emergency Response

 E1SFF4-11-0029-5100229  EPA'S MANAGEMENT OF 5  YR REVIEWS    3/27/95

 E1SFG5-11-5005-5400014  FOLLOW UP ON FY 92/93  SUPERFUND
                       PERFORMANCE MEASURES             11/15/94


 Regional Administrator - Region 1

 E1SGG4-14-0010-5400042  LINEMASTER RI/FS REVIEW     CT     2/16/95


 Regional Administrator - Region 2

 E1HWR5-02-0015-5400030  DRINKING WATER DATA INTEGRITY--
                       REGION 2                         1/12/95

 E1SGG4-14-0011-5400040  CIRCUITRON RI/FS REVIEW     NY     2/ 7/95
 Director Air & Hazardous Wastes - Region 4

 E1SGG4-14-0008-5400022  FCX SITES RI/FS REVIEW
                               12/ 6/94
   44
                                                                  OFFICE OF INSPECTOR GENERAL

-------
                                                                                     Questioned Costs
                                                                                   Recommended
                                                                                   Efficiencies
Assignment  Control  Number
Title
Final  Report     Ineligible    Unsupported    Unreasonable  (Funds Be Put
    Issued	Costs	Costs	Costs      To Better Use)
Regional  Administrator  -  Region  5

E1SFL4-05-8000-5100216   CFO  ACT  FY  94  REGION  5
E1SFG4-05-0250-5400024   SFAI  BASE  CLOSURES — REGION  5
                          3/17/95
E1KAB4-05-0212-5400013   AIR  STATE  IMPLEMENTATION  PLANS
                        REGION  5                           11/10/94
                         12/16/94
Regional  Administrator  -  Region  7

E1HWF4-07-0036-5100226   REGION 7'S  PUBLIC  WATER  SYSTEM
                        SUPERVISION PROGRAM                 3/24/95

E1SFF4-07-0066-5100250   BUDGET EXECUTION — REGION 7         3/31/95

E1SJG4-07-0050-5400032   FOLLOWUP PRP SEARCH  PROGRAM         1/17/95
Regional  Administrator  -  Region 8

E1XMF4-08-0036-5100141   BETTER  PLANNING  & ORGANIZATIONAL
                        CHANGES COULD  IMPROVE  REGION  8'S
                        TRIBAL  PROGRAM                     1/23/95
E1SKG4-08-0045-5400034   SUPERFUND  FIELD  SAMPLING
                        ACTIVITIES
                                                           1/27/95
Regional  Administrator  -  Region 9
E1SFG4-09-0028-5400018 SFAI SWIFT PILOT
Regional Administrator - Region 10
E1SFG4-10-0078-5400035 REVIEW OF SFAI IN REGION
TOTAL INTERNAL AND MANAGEMENT ASSIGNMENTS
2. CONSTRUCTION GRANT ASSIGNMENTS
E2CWL2-01-0170-5100233 MWRA
P2CWL2-01-0353-5100230 BRISTOL
TOTAL OF REGION 01 2
E2CWL2-02-0130-5100123 PERTH AMBOY
E2FWP3-02-6000-5400060 PRASA FOLLOW-UP
P2CWL1-02-0128-5100190 ROCKLAND COUNTY SD1
P2CWL3-02-0083-5100191 FLORHAM PARK SEWERAGE
P2CWL4-02-0060-5100217 MIDDLETOWN
P2CWL3-02-0128-5100231 HUDSON COUNTY UA
TOTAL OF REGION 02 6
E2CWM4-04-0245-5200001 MOULTON
E2CUM5-04-0050-5200005 FLORENCE
E2CWM5-04-0042-5200006 STARKE
TOTAL OF REGION 04 3
E2CWL3-08-0038-5100124 LONGMONT
E2CWM2-08-0092-5200003 BOULDER
P2CWL3-08-0039-5100107 ASHLEY VALLEY

10


MA
CT

NJ
PR
NY
NJ
NY
NJ

AL
AL
FL

CO
CO
UT
11/28/94
1/31/95
26

3/29/95
3/27/95

12/27/94
3/30/95
2/21/95
2/21/95
3/21/95
3/28/95

11/ 3/94
1/11/95
1/20/95

12/28/94
12/ 9/94
12/ 1/94


0

343,947
1,841,540
2,185,487
166,123
0
1,290,906
1,211,660
699,268
0
3,367,957
22,387
15,562
1,029,423
1,067,372
16,229
64,848
1,533,914


0

0
2,155,282
2,155,282
309,423
0
2,959,420
0
0
13,064,288
16,333,131
0
0
0
0
0
0
0
              TOTAL  OF  REGION  08
                                         1,614,991
  OCTOBER 1, 1994 THROUGH MARCH 31, 1995
                                                                                                                             45

-------
Assignment Control  Number
                       Title
                                Final  Report
                                	Issued
                                                                                    Questioned Costs
                     Ineligible
                       Costs
                             Unsupported
                                Costs
                             Unreasonable
                                Costs	
                                                                                                          Recommended
                                                                                                          Efficiencies
                                                                                                          (Funds  Be Put
                                                                                                          To  Better Use]
E2CWM3-09-
E2CWM3-09-
E2CWM2-09-
E2CWM3-09-
E2CWM3-09-
E2CWM2-09-
E2CWN2-09-
S2CWN1-09-
0072-5200002
0116-5200007
0093-5200008
0136-5200009
0189-5200011
0244-5200012
0266-5300002
0174-5300011
FRESNO, CITY OF
SANTA BARBARA, COUNTY OF
SOUTH TAHOE PUD
FRESNO, COUNTY OF
OAKLAND, CITY OF
LOS ANGELES, CITY OF
MAUI, COUNTY OF
CRESCENTA VALLEY CWD
              TOTAL OF REGION 09
E2CWM4-10-0079-5200004
P2CWN4-10-0015-5300006
              SPOKANE,  CITY  OF
              JUNEAU,  CITY & BOROUGH  OF
CA
CA
CA
CA
CA
CA
HI
CA
                            WA
                            AK
11/22/94
 1/24/95
 2/ 9/95
 3/ 7/95
 3/21/95
 3/27/95
11/ 9/94
 3/30/95
       M 3/95
       1/10/95
              TOTAL OF REGION 10
    15,825
   457,325
   731,772
   185,427
   206,803
25,580,260
 1,094,241
    46,806

28,318,459

   171,131
   130,298

   301,429
     0
     0
     0
     0
38,861
     0
     0
     0

38,861

     0
     0
              TOTAL CONSTRUCTION  GRANT  ASSIGNMENTS
                                                         24
                                                              36,855,695
                                                                18,527,274
3. OTHER GRANT ASSIGNMENTS
C3HVK4-01-0182-5500006
G3HVK4-01-0188-5500014
G3HVK4-01-0197-5500015
G3HVK3-01-0184-5500041
G3HVK5-01-0031-5500051
G3HUK5-01-0027-5500060
G3HVK5-01 -0065-5500079
G3HVK5-01 -0075-5500103
G3HVK5-01 -0082-5500104
N3HUK4-01-0172-5500016
N3HUK4-01-0171-5500017
N3HMK1-01-0128-5500020
N3HVK4-01 -0073-5500021
N3HVK3-01-0130-5500022
N3HMKO-01 -0259-5500023
N3HVK1-01-0187-5500024
N3HMK1-01-0120-5500025
N3HVK2-01-0119-5500026
N3HVK2-01-0056-5500027
N3HVK5-01-0030-5500040
N3HVK5-01-0034-5500042
N3HVK5-01 -0033-5500043
N3HVK5-01 -0049-5500061
N3HVK5-01-0041-5500072
N3HUK4-01-0170-5500077
N3HVJ4-01-0158-5500078
N3HVK5-01 -0070-5500105
TOTAL OF
G3HVK5-02-0024-5500012
G3HUK4-02-0204-5500019
G3HVK5-02-0070-5500038
G3HVK5-02-0084-5500068
G3HVK5-02-0098-5500074
G3HVK5-02-0112-5500101
G3HUK5-02-0117-5500117
N3HVK5-02-0012-5500001
N3HVK5-02-0013-5500002
N3HVK4-02-0177-5500011
N3HUK4-02-0171-5500013
N3HUK5-02-0059-5500018
N3HVK5-02-0068-5500029
N3HVK5-02-0061 -5500030
N3HUK5-02-0065-5500031
N3HUK5-02-0074-5500036
N3HUK5-02-0072-5500037
N3HVK5-02-0062-5500044
N3HVK5-02-0030-5500045
N3HVK5-02-0079-5500052
N3HVK5-02-0081-5500054
N3HEK4-02-0138-5500058
N3HVK4-02-0178-5500062
PITTSFIELD, CITY OF
YORK SEWER DISTRICT
PIONEER VALLEY PLAN COMM
EXETER, TOWN OF
MAINE MUNICIPAL BOND BANK
HEALTH EFFECTS INSTITUTE
MATTABASSETT DISTRICT
BENNINGTON
PIONEER VALLEY PLAN COMM
UNIVERSITY OF VERMONT
DARTMOUTH COLLEGE
ARLINGTON
ARLINGTON, TOWN OF
ARLINGTON, TOWN OF
ATHOL
CAMBRIDGE
BURLINGTON
ARLINGTON
DALTON
RUTLAND REGIONAL PLAN COMM
SOUTHEASTERN REG PLAN & DEV
MA
ME
MA
NH
ME
MA
CT
VT
MA
VT
NH
MA
MA
MA
MA
MA
MA
MA
NH
VT
MA
CENTRAL CONNECTICUT REG PLANCT
BERKSHIRE COUNTY REG PLAN,
MASHANTUCKET PEQUOT TRIBE
BOSTON UNIVERSITY
CONNECTICUT, STATE OF
BARNSTABLE
REGION 01 27
EFC
NJIT FDN
LOVE CANAL AREA REV. AGCY.
HUDSON REGL HLTH COMM
DELAWARE RVR. BSN. COMM.
ALEXANDRIA
RENSSELAERVILLE INST
BROOME COUNTY
RENSSELAER COUNTY
NEW YORK CITY
RUTGERS ST UNIV
RPI
ESSEX COUNTY
ESSEX COUNTY
ROCKEFELLER UNIVERSITY
NEW YORK BOT GARDEN
STEVENS INST OF TECH
WESTCHESTER COUNTY
ERIE COUNTY
MONROE COUNTY
MADISON COUNTY
NATL AUDUBON SOC
ONONDAGA COUNTY
MA
CT
MA
CT
MA

NY
NJ
NY
NJ
NJ
NY
NY
NY
NY
NY
NJ
NY
NJ
NJ
NY
NY
NJ
NY
NY
NY
NY
NY
NY
10/ 6/94
10/31/94
11/ 2/94
11/29/94
12/ 5/94
12/27/94
2/ 8/95
3/10/95
3/10/95
11/ 2/94
11/ 2/94
11/ 4/94
IV 4/94
1V 4/94
1V 4/94
1V 4/94
1V 4/94
1V 4/94
1V 4/94
11/28/94
11/29/94
11/29/94
12/27/94
2/ 6/95
2/ 8/95
2/ 8/95
3/10/95

10/31/94
11/ 3/94
11/22/94
V 4/95
2/ 7/95
3/ 3/95
3/21/95
10/ 5/94
107 5/94
10/27/94
10/31/94
1V 2/94
1V 7/94
1V 7/94
IV 7/94
11/22/94
11/22/94
11/30/94
11/30/94
12/ 5/94
12/12/94
12/20/94
V 3/95
                                                                                                                0
                                                                                                                0
                                                                                                                0
                                                                                                                0
                                                                                                                0
                                                                                                                0
                                                                                                                0
                                                                                                                0
                                                                                                                0
                                                                                                                0
                                                                                                                0
                                                                                                                0
                                                                                                                0
                                                                                                                0
                                                                                                                0
                                                                                                                0
                                                                                                                0
                                                                                                                0
                                                                                                                0
                                                                                                                0
                                                                                                                0
                                                                                                                0
                                                                                                                0
                                                                                                                0
                                                                                                                0
                                                                                                                0
                                                                                                                0
                                                                                                                                0
                                                                                                                                0
                                                                                                                                0
                                                                                                                                0
                                                                                                                                0
                                                                                                                                0
                                                                                                                                0
                                                                                                                                0
                                                                                                                                0
                                                                                                                                0
                                                                                                                                0
                                                                                                                                0
                                                                                                                                0
                                                                                                                                0
                                                                                                                                0
                                                                                                                                0
                                                                                                                                0
                                                                                                                                0
                                                                                                                                0
                                                                                                                                0
                                                                                                                                0
                                                                                                                                0
                                                                                                                                0
  46
                                                                                     OFFICE OF INSPECTOR GENERAL

-------
Questioned Costs
Assignment Control Number Title
N3HUK4-02-0068-5500063
N3HVK4-02-0063-5500064
N3HVK4-02-0044-5500065
N3HUK4-02-0190-5500066
N3HUK4-02-0162-5500067
N3HUK5-02-0089-5500069
N3HVK4-02-0135-5500070
N3HUK5-02-0100-5500080
N3HVK5-02-0101-5500081
N3HVK5-02-0102-5500082
N3HVK5-02-0088-5500083
N3HVK5-02-0097-5500084
N3HUK4-02-0179-5500086
N3HVK5-02-0106-5500092
N3HUK5-02-0071 -5500093
N3HVK5-02-001 1-5500099
N3HVK4-02-0188-5500100
N3HVK5-02-0116-5500106
N3HVK4-02-0205-5500107
N3HUK4-02-0196-5500108
N3HUK5-02-0113-5500109
N3HUK4-02-0194-5500110
N3HUK4-02-0187-5500111
N3HVK5-02-0083-5500112
N3HVK5-02-0108-5500113
N3HUK5-02-0076-5500114
N3HUK5-02-0077-5500115
N3HUK5-02-0063-5500116
TOTAL OF
C3HVK5-03-01 18-5500075
C3HVK5-03-0119-5500076
C3HVK5-03-0192-5500120
C3HVK5-03-0193-5500121
C3HVK5-03-0194-5500122
G3HVK5-03-0155-5500096
N3HVK5-03-0055-5500032
N3HVK5-03-0056-5500085
N3HVJ5-03-0154-5500095
N3HVK5-03-0156-5500097
N3HVJ5-03-0157-5500098
TOTAL OF
C3HVK4-04-0272-5500033
C3HVK5-04-0064-5500071
C3HVK5-04-0045-5500118
G3HVK5-04-0046-5500046
G3HVK4-04-0060-5500053
G3HVK5-04-0057-5500056
G3HVK5-04-0058-5500057
N3HVJ4-04-0228-5500034
N3HUK4-04-0257-5500035
N3HVK5-04-0043-5500039
N3HVJ5-04-0019-5500047
N3HVJ4-04-0226-5500048
TOTAL OF
C3HVJ5-05-0017-5500003
G3HVK5-05-0018-5500004
G3HVJ5-05-0034-5500010
N3HUK4-05-0283-5500005
TOTAL OF
C3HVJ5-06-0010-5500009
C3HVK5-06-0016-5500028
G3HVK5-06-0012-5500007
G3HVK5-06-001 1-5500008
N3HVK5-06-0021 -5500055
SYRACUSE UNIVERSITY
NASSAU COUNTY
CHAUTAUQUA
PUERTO RICO UNIV
RPI
ALBANY MEDICAL COLLEGE
SOUTH TIER CENT PLN & OEV
ROCHESTER INST OF TECH
PUERTO RICO DEPT OF AGR
CHAUTAUQUA COUNTY
SARATOGA COUNTY
BURLINGTON COUNTY
MANHATTAN COLLEGE
NASSAU COUNTY
SYRACUSE UNIVERSITY
ROCKLAND COUNTY
ONONDAGA COUNTY
CUMBERLAND COUNTY
SALEM
BOYCE THOMPSON INST
NEW YORK UNIVERSITY
CUNY RES FDN.
HEALTH RESEARCH INC
MIDDLESEX COUNTY
CLINTON COUNTY
ROCHESTER UNIVERSITY
ROCHESTER UNIVERSITY
NYU MEDICAL CENTER
REGION 02 51
PRINCE UILLIAN COUNTY
FAIRFAX COUNTY
ANNE ARUNDEL COUNTY
SUSSEX COUNTY
CARROLL COUNTY
VA RESOURCES AUTHORITY
MARYLAND STATE OF
PA COMMONWEALTH OF
VA COMMONWEALTH OF
WEST VIRGINIA STATE
DELAWARE STATE
REGION 03 11
PENSACOLA
DEICALB COUNTY
ATLANTA
MICRO
MICRO
METTER
METTER
FLORIDA STATE OF
VANDERBILT UNIVERSITY OF
BROWARD COUNTY
ALABAMA STATE OF
SOUTH CAROLINA STATE OF
REGION 04 12
FT WAYNE FY 93
NORTH SHORE SD FY 94
SMITH-GREEN CSC FY 92/93
MICHIGAN U OF FY 93
REGION 05 4
NY
NY
NY
PR
NY
NY
NY
NY
PR
NY
NY
NJ
NY
NY
NY
NY
NY
NJ
NJ
NY
NY
NY
NY
NJ
NY
NY
NY
NY

VA
VA
MD
DE
MD
VA
MD
PA
VA
WV
DC

FL
GA
GA
NC
NC
GA
GA
FL
TN
FL
AL
SC

IN
IL
IN
MI

ARK. DEPT OF POLLUTION CONTRAR
PSB EL PASO WATER UTILITIES
RIO HONDO
SUNSET VALLEY
TX
TX
TX
TERREBONNE PARISH CONSOLIDATLA
Final Report
Issued
I/ 3/95
M 3/95
M 3/95
1/ 3/95
1/ 3/95
1/ 9/95
1/11/95
2/10/95
2/10/95
2/10/95
2/16/95
2/16/95
2/22/95
2/23/95
2/23/95
3/ 3/95
3/ 3/95
3/13/95
3/14/95
3/14/95
3/14/95
3/16/95
3/16/95
3/16/95
3/16/95
3/16/95
3/16/95
3/16/95

2/ 7/95
21 7/95
3/30/95
3/30/95
3/30/95
2/27/95
11/14/94
2/21/95
2/27/95
2/27/95
2/27/95

11/14/94
1/23/95
3/21/95
12/ 1/94
12/ 6/94
12/16/94
12/16/94
11/14/94
11/16/94
11/25/94
12/ 1/94
12/ 1/94

10/ 6/94
10/ 6/94
10/18/94
10/ 6/94

10/12/94
1V 7/94
10/12/94
10/12/94
12/14/94
Recommended
Efficiencies
Ineligible Unsupported Unreasonable (Funds Be Put
Costs Costs Costs To Better Use)
0
0
0
0
0
0
0
0
980
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
980
0
0
0
0
0
0
0
0
161,977
0
0
161,977
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
36,592
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
36,592
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
          TOTAL  OF REGION  06 =
OCTOBER 1, 1994 THROUGH MARCH 31, 1995
47

-------
                                                                                     Questioned Costs
Assignment Control Number
                                 Title
                                                        Final Report
                                                            Issued
                     Ineligible
                       Costs
                             Unsupported
                                Costs
                                                                                                      Unreasonable
                                                                                                         rnsts
                                        Recommended
                                        Efficiencies
                                        (Funds Be Put
                                        To Better Use^
N3HVJ4-07-0074-5500087  MISSOURI
N3HVJ4-07-0075-5500094  STATE OF IOWA

              TOTAL OF REGION 07
N3WK4-08-0066-5500088
N3HVJ4-08-0065-5500089
N3HVJ4-08-0056-5500119
                        NORTHERN CHEYENNE TRIBE
                        STATE OF SOUTH DAKOTA
                        MONTANA
                                                    MO
                                                    IA
MT
SD
MT
              TOTAL OF REGION 08
C3HVK5-09-0053-5500090  LAS VEGAS, CITY OF          NV
C3HVK5-09-0054-5500091  HONOLULU, CITY & COUNTY OF  HI
N3HVK3-09-0228-5500049  COMMONWEALTH UTILITIES CORP MP
N3HVK4-09-0189-5500050  COMMONWEALTH UTILITIES CORP MP
N3HVK5-09-0039-5500073  PYRAMID LAKE PAIUTE TRIBE   NV
              TOTAL OF REGION 09
G3HVJ5-10-0023-5500059
G3HVJ5-10-0036-5500102
P3LLL3-10-0097-5100120
                        BLACK DIAMOND,  CITY OF
                        SPOKANE COUNTY
                        OREGON DEQ-LUST
WA
WA
OR
       2/22/95
       2/23/95
 2/22/95
 2/22/95
 3/24/95
                                                           2/22/95
                                                           2/22/95
                                                          12/ 1/94
                                                          12/ 1/94
                                                           2/ 6/95
12/23/94
 3/ 9/95
12/22/94
              TOTAL OF REGION 10
      0
      0
 17,179
130,749
  1,442

149,370

 14,419
      0
 12,747

 27,166
              TOTAL OTHER GRANT ASSIGNMENTS
                                                         123
                                                                            339,493
                                        36,592
5. SUPERFUND GRANT ASSIGNMENTS

E5FGL4-01-0132-5100220  REGION 1 SF AGREEMENTS      MA

              TOTAL OF REGION 01      1

E5CKL4-02-0134-5100198  COLUMBIA UNIVERSITY         NY

              TOTAL OF REGION 02 =    1

E5FGF4-05-0261-5100144  CA'S ILLINOIS               R5

              TOTAL OF REGION 05 =    1

E5BGN4-06-0075-5300012  LA. SF CO-OP AGREEMENTS     LA

              TOTAL OF REGION 06 =    1

E5BGG4-11-0035-5400044  UV SF COOPERATIVE AGREEMENTS
M5BFL5-11-0011-5100136  SF IAG-FY93 BUREAU OF REC
M5BFL5-11-0012-5100137  SF IAG-FY93 ENRD
M5BFL4-11-0037-5100138  SF IAG FY92 USGS
M5BFL5-11-0013-5100140  SF IAG FY93 ARMY AUDIT

              TOTAL OF HDQ   HAD REPORTS  =    5
                                                           3/22/95
                                                           3/  6/95
                                                           1/31/95
                                                           3/30/95
                                                           3/23/95
                                                           1/11/95
                                                           1/11/95
                                                           1/11/95
                                                           1/18/95
                              0

                              0

                             47

                             47

                              0

                              0

                              0

                              0

                              0
                              0
                              0
                              0
                              0
                                  37,232

                                  37,232

                                       0

                                       0

                                       0

                                       0

                                       0

                                       0

                                       0
                                       0
                                       0
                                       0
                                       0
              TOTAL SUPERFUND GRANT ASSIGNMENTS
                                                                                 47
                                                                                            37,232
8. OTHER CONTRACT ASSIGNMENTS

D8AML4-01-0193-5100042  TASHMOO TECHNOLOGIES INC.    MA
D8DML4-01-0205-5100044  ABT ASSOCIATES INC.          MA
D8DML5-01-0021-5100046  CAMP DRESSER & MCKEE INC.    MA
D8CML5-01-0020-5100048  ABB ENVIRONMENTAL SERVICES  ME
D8DML5-01-0025-5100052  ARTHUR D. LITTLE INC.        MA
D8AML4-01-0165-5100054  ABT ASSOCIATES              MA
D8DML3-01-0038-5100055  ABB ENVIRONMENT SERVICES    ME
D8AML4-01-0185-5100056  SYRACUSE RESEARCH CORP      NY
D8DML3-01-0223-5100057  COMBUSTION ENGINEERING      ME
D8DML5-01-0022-5100092  METCALF & EDDY INC          MA
D8AML5-01-0048-5100235  NEW ENGLAND ELECTRIC RESOUR MA
D8APL5-01-0060-5100243  EASTERN RESEARCH GROUP      MA
D8DML5-01-0023-5100246  ABB POWER LABORATORIES      CT
                                                          10/31/94       *  The  dollar  value  of  contract  audits have not been shown.
                                                          11/  2/94         Public  disclosure of the dollar value of financial
                                                          11/  2/94         recommendations could prematurely reveal the
                                                          11/  2/94         Government's  negotiating positions or release of this
                                                          11/  2/94         information is not routinely  available under the Freedom
                                                          11/  3/94         of  Information Act.   The number of these reports and
                                                          11/  3/94         dollar  value  of the  findings  have been included in the
                                                          11/  3/94         aggregate data displayed below.  Such data individually
                                                          11/  3/94         excluded  in this  listing will  be provided to the
                                                          11/29/94         Congress under separate memorandum within 30 days of the
                                                           3/30/95         transmittal of the semiannual  report to the Agency head.
                                                           3/30/95         The  transmitted data will  contain appropriate cautions
                                                           3/30/95         regarding disclosure.
  48
                                                                                                OFFICE OF INSPECTOR GENERAL

-------
Assignment Control Number
E8EMN3-01 -0282-5300008 TRC
E8AXP5-01 -0602-5400017 TRC
Title
FY 94 FLOORCHECK
ENVIRONMENTAL CORP
Final Report
Issued
CT 2/24/95
MA 11/28/94

I ne I i g i b I e
Costs

Questioned Costs
Unsupported Unreasonable
Costs Costs

Recommended
Efficiencies
(Funds Be Put
To Better Use)

             TOTAL OF REGION 01
                                    15
D8DML5-02-0019-5100045
D8DML4-02-0170-5100053
D8AML4-02-0202-5100105
D8DHL3-02-0149-5100134
D8BML5-02-0073-5100215
D8CHL5-02-0018-5100237
D8DHL4-02-0108-5100249
D8EMP5-02-0069-5400059
E8AXP5-02-0401 -5400019
E8AXP5-02-0507-5400023
E8AXP5-02-0404-5400026
TOTAL OF
D8AML4-03- 0478-51 00004
D8BML5-03-0049-51 00029
D8BML2-03-0156-5100031
D8CML4-03-0468- 5 100032
D8EML5-03-0048-5100033
D8EML5-03-0068- 51 00084
D8EHL5-03-0046-5100086
D8AML5-03-0028-5100087
D8EML5-03-0045-5100088
D8AML4-03-0532-5100089
D8CML4-03-0400-5100108
D8AML5-03-0026-5100109
D8AML4-03-0506-5100110
D8AML4-03-0531-5100111
D8AML4-03-0527-5100114
D8AHL5-03-0025-5100116
D8AML5-03-0024-5100121
D8EML5-03-0083-5100126
D8EHL5-03-0110-5100157
D8BML5-03-0112-5100158
D8BML5-03-0114-5100159
D8EHL5-03-0111-5100161
D8AAL5-03-0079-5100164
D8BML4-03-0071-5100165
D8CHL4-03-0112-5100166
D8BHL2-03-0155-5100167
D8CML4-03-0144-5100168
D8AAL5-03-0081 -5100169
D8BML4-03-0288-5100170
D8AML4-03-0533-5100171
D8CML4-03-0422-5100172
D8AML5-03-0029-5100173
D8EML5-03-0059-5100174
D8AML5-03-0077-5100176
D8AML5-03-0060-5100177
D8AML5-03-0041 -5100178
D8CML3-03-0215-5100179
D8CML4-03-0098-5100180
D8EML5-03-0163-5100196
D8APL5-03-0091 -5100197
D8AML5-03-0027-5100224
D8EMP2-03-0313-5400006
P8BML2-03-0507-5100022
CORNELL UNIVERSITY NY
GERAGHTY & MILLER NY
MARTIN MARIETTA SERVICES NJ
EBASCO NY
MARTIN MARIETTA TECH. SERVICNJ
MATHTECH INC. NJ
TAMS CONSULTANTS INC NY
ENSERCH ENVIRONMENTAL CORP NY
MALCOLM PIRNIE NY
ECOLOGY & ENVIR NY
MALCOLM PIRNIE INC NY
REGION 02 11
NCI INFORMATION SYSTEMS INC VA
WESTAT, INC. MD
ROW SCIENCES MD
GENERAL SCIENCE CORPORATION
AMERICAN MANAGEMENT SYSTEMS VA
QUALITY TECHNOLOGY, INC. MD
MANTECH TECHNOLOGY VA
INFORMATION MANAGEMENT VA
MANTECH ALM JOINT VENTURE VA
QUALITY TECHNOLOGY INC. MD
WESTAT, INC. MD
PERFORMANCE ENGINEERING CORPVA
HUGHES STX CORPORATION MD
COMPUTER DATA SYSTEMS, INC. MD
DYNCORP INC. VA
I -NET INCORPORATED MD
OGDEN GOVERNMENT SERVICES VA
COMPUTER SCIENCE CORP VA
LABAT SERVICES SEGMENT VA
EG&G WASHINGTON ANALYTICAL MD
SCIENCE APPLICATIONS INTER. VA
TASCON, INC. MD
ALTERNATIVE ENERGY DEVELOP MD
JACA CORPORATION PA
THE BIONETICS CORPORATION VA
DIVERSIFIED TECHNOLOGY VA
DYNAMAC MD
ENERGY SYSTEMS ASSOCIATES PA
HYDROGEOLOGIC, INC. VA
INFORMATION DYNAMICS INC. MD
JACA CORPORATION PA
LABAT ANDERSON, INC. VA
LABAT ANDERSON, INC. VA
METROPOLITAN ARCHITECTS VA
PLEXUS SCIENTIFIC CORP. MD
TASCON INC. MD
TECHNICAL RESOURCES, INC. MD
TECHNICAL RESOURCES MD
BOOZ ALLEN HAMILTON VA
DYNAMAC MD
PLANNING ANALYSIS CORP VA
COMPUTER SCIENCE CORP VA
ASCI CORPORATION VA
11/ 2/94
IV 2/94
12/ 1/94
M 9/95
3/16/95
3/30/95
3/30/95
3/30/95
11/30/94
12/ 9/94
12/20/94

10/ 6/94
10/24/94
10/24/94
10/24/94
10/24/94
11/28/94
11/28/94
11/28/94
11/28/94
11/28/94
12/ 6/94
12/ 9/94
12/ 9/94
12/ 9/94
12/19/94
12/19/94
12/23/94
12/29/94
2/ 9/95
2/ 9/95
2/ 9/95
2/ 9/95
2/10/95
2/10/95
2/10/95
2/10/95
2/10/95
2/10/95
2/10/95
2/10/95
2/10/95
2/10/95
2/10/95
2/10/95
2/10/95
2/10/95
2/10/95
2/10/95
3/ 1/95
3/ 1/95
3/24/95
10/ 6/94
10/19/94
             TOTAL OF REGION 03 =   43

E8ANX5-22-0058-5300004  ICF-DOE PROPOSAL
             TOTAL OF REGION 22 =
                                     1
D8EML4-04-0270-5100006
D8BML3-04-0045-5100007
D8BML4-04-0031-5100008
D8AHL4-04-0211-5100017
ADVANCED SYSTEMS TECHNOLOGY GA
ADVANCED SYSTEMS            GA
ADVANCED SYSTEMS TECHNOLOGY GA
TECHNOLOGY PLANNING & MGMT. NC
                                   V  5/95
10/ 6/94
10/ 6/94
10/ 7/94
10/18/94
  OCTOBER 1, 1994 THROUGH MARCH 31, 1995
                                                                                                    49

-------
Assignment Control Number Title
D8BML5-04-0022-5100018 RESEARCH & EVALUATION ASSOC NC
D8BML5-04-0023-5100019 RESEARCH & EVALUATION ASSOC NC
D8AML4-04-0254-5100038 TWM SERVICE INC NC
D8AML4-04-0264-5100066 MANTECH TECHNOLOGY NC
D8EML4-04-0249-5100068 EQUITY ASSOCIATES INC TN
D8CML4-04-0250-5100070 MANTECH TECHNOLOGY NC
D8AML5-04-0025-5100074 INTEGRATED LABORATORY SYSTEMNC
D8BML5-04-0044-5100103 ADVANCED SYSTEMS TECHNOLOGY GA
D8AML4-04-0273-5100106 TECHNOLOGY PLANNING NC
D8AML5-04-0060-5100143 TRIPLE P SERVICES INC. NC
D8BML3-04-0318-5100150 EC/R INCORPORATED NC
D8CML4-04-0262-5100207 KILKELLY ENVIRONMENTAL ASSOCNC
D8BML5-04-0093-5100210 MANTECH ENVIRONMENTAL NC
D8BML3-04-0196-5100214 MANTECH TECHNOLOGY NC
D8AML5-04-0072-5100222 DYNAMIC RESOURCES INC. GA
D8EML5-04-0095-5100223 DYNAMIC RESOURCES GA
D8BML3-04-0063-5100241 INTEGRATED LABORATORY SYSTEMNC
D8BML5-04-0021-5100244 INTEGRATED LABS NC
TOTAL OF REGION 04 = 22
D8CML3-05-0336-5100021 FEV ENG TECH FY 93 MI
D8CML3-05-0220-5100051 ESE FY 90/91 IL
D8AML5-05-0020-5100100 AUTO TESTING LAB OH
D8AML5-05-0042-5100118 ALPHA-OMEGA CHEM OH
D8CML4-05-0202-5100131 BATTELLE OH
D8CML5-05-0040-5100152 TRIAD ENG 68-W1-0041 UI
D8CML4-05-0307-5100251 COLEJON MECH OH
D8AAP4-05-0309-5400011 AUTO TESTING LAB FY 94P IL
D8AWP5-05-0081 -5400058 GRACE ANALYTICAL LAB IL
E8ABP4-05-0314-5400010 PRC EMI (EPA-AIRMS) IL
E8AXP5- 05 -0089- 5400048 PRC EMI (INDIAN HEAD) IL
E8AXP5- 05 -0067- 5400049 EARTH TECH (FT MCCOY) MI
E8AXP5-05-0077-5400050 PRC EMI (SAVANNAH RIVER) IL
E8AXP5- 05 -0078- 5400054 PRC EM! (TECH SUPPORT-CHI) IL
TOTAL OF REGION 05 14
E8CMP2-23-0178-5400001 PEI ASSOC OH
E8CMP3-23-0208-5400007 PEI ASSOC OH
E8CMP3-23-0006-5400008 PEI ASSOC OH
E8CMP3-23-0014-5400009 PEI ASSOC OH
TOTAL OF REGION 23 = 4
D8AML4-06-0171 -5100012 LOCKHEED ENVIRONMENTAL TX
D8EML5-06-0013-5100035 LOCKHEED ENGINEERING TX
D8EML5-06-0017-5100069 LOCKHEED ENVIRONMENTAL TX
D8AML4-06-0173-5100101 IBM TX
D8CML5-06-0018-5100104 RADIAN CORPORATION TX
D8CML4-06-0116-5100142 RADIAN CORPORATION TX
D8AML5-06-0023-5100147 SOUTHWEST RESEARCH TX
D8AML5-06-0022-5100148 LOCKHEED ENVIRONMENTAL TX
D8CML4-06-011 1-5100149 RADIAN CORPORATION TX
D8EML5-06-0031 -5100204 LEE WILSON & ASSOCIATES NM
TOTAL OF REGION 06 = 10
D8DML4-07-0046-5100003 MRI MO
D8AML5-07-0018-5100187 MIDWEST RESEARCH MO
D8AAL5-07-0022-5100202 MIDWEST RESEARCH MO
TOTAL OF REGION 07 3
D8CML5-08-0020-5100119 KAMAN SCIENCES CORPORATION CO
D8AAL5-08-0023-5100153 RESOURCE ENTERPRISES, INC. UT
D8AAL5-08-0023-5100154 RESOURCE ENTERPRISES, INC. UT
D8AAL5-08-0022-5100199 RAVEN RIDGE RESOURCES CO
TOTAL OF REGION 08 = 4
D8CML4-09-0231 -5100002 RI ROCKETDYNE DIV FC CA
D8AML4-09-0237-5100016 SAIC PA CA
D8BML2-09-0347-5100020 ECOS CI 1992 CA
Final Report
Issued
10/18/94
10/18/94
10/26/94
11/10/94
11/10/94
11/10/94
11/14/94
11/30/94
12/ 1/94
1/26/95
2/ 2/95
3/10/95
3/16/95
3/16/95
3/22/95
3/22/95
3/30/95
3/30/95

10/18/94
1V 2/94
11/30/94
12/20/94
V 4/95
21 3/95
3/31/95
1V 4/94
3/29/95
10/31/94
3/ 9/95
3/21/95
3/21/95
3/24/95

10/ 3/94
10/ 7/94
10/ 7/94
10/18/94

10/14/94
10/26/94
11/10/94
11/30/94
11/30/94
1/26/95
2/ 2/95
2/ 2/95
2/ 2/95
3/ 8/95

10/ 5/94
2/17/95
3/ 7/95

12/22/94
2/ 3/95
2/ 3/95
3/ 7/95

10/ 3/94
10/17/94
10/18/94
Recommended
Questioned Costs _ Efficiencies
Ineligible Unsupported Unreasonable (Funds Be Put
Costs Costs Costs To Better Use]
























































&





50
OFFICE OF INSPECTOR GENERAL

-------
                                                                                  Questioned Costs
                                                                                                                Recommended
Assignment Control Number Title
D8BML5-09-0027-5100034
08AML5-09-0029-5100059
D8AML5-09-0022-5100060
D8AHL4-09-0239-5100064
D8CPL3-09-0089-5100076
D8CWL4-09-0095 -51 00077
D8AML4-09-0238-5100083
D8BML5-09-0040-5100132
D8BML3-09-0241-5100133
D8BML5-09-0046-5100182
D8BML5-09-0051-5100183
D8CML4-09-0236-5100208
D8AMN5-09-0024-5300001
D8FMN5-09-0028-5300007
D8FMP4-09-0241 -5400033
TOTAL OF
D8BML4-10-0038-5100010
D8AML5-10-0027-5100203
D8EMP5-10-0028-5400041
IT CORP CI 1990-1991
IT CORP PA
ENVIR SYS RESEARCH PA
GEO INSIGHT INTL PA
SAIC FC
SAIC FC
STERLING SOFTWARE PA
JACOBS CI FY 1990
J & S CI 1992
GEO/R CI 1987
GEO/R CI 1989
EERC FC
SAIC PA
EERC FL
SAIC MS
REGION 09 18
PTI CI FY 90 & 91
COLUMBIA ENV SCI PA
CH2M 1C
CA
CA
CA
CA
CA
CA
CA
CA
CA
CA
CA
CA
CA
CA
CA

WA
WA
OR
Final Report Ineligible Unsupported Unreasonable (Funds Be Put
Issued Costs Costs Costs To Rpttpr lisp)
10/25/94
1V 4/94
1V 8/94
1V 9/94
11/16/94
11/16/94
11/18/94
V 4/95
V 4/95
2/14/95
2/14/95
3/14/95
10/28/94
1/18/95
1/23/95

10/ 7/94
3/ 7/95
2/ 9/95
             TOTAL OF REGION 10 =
             TOTAL OTHER CONTRACT ASSIGNMENTS
                                                       148
                                                                         638,592
502,906
16,410,387
9.  SUPERFUND CONTRACT ASSIGNMENTS
D9CKL4-01 -0189-5100043
D9BFL4-01-0175-5100078
D9AKL5-01-0061-5100239
D9AGL5-01-0058-5100245
D9AFL5-01 -0063-5100248
P9DGL2-01-0237-5100135
TOTAL OF
D9BFL5-02-0038-5100047
D9EGL5-02-0037-5100050
D9AGL5-02-0092-5100236
D9AFL5-02-0093-5100238
D9AGL5-02-0091-5100242
E9AGP4-02-0180-5400012
E9AGP5-02-0504-5400016
E9AFP5-02-0511-5400039
E9AFP5-02-0512-5400043
E9AFP5-02-0518-5400056
E9AFP5-02-0517-5400061
P9BGL1-02-0155-5100122
P9DGL1-02-0154-5100125
TOTAL OF
D9BFL5-03-0031-5100005
D9BFL2-03-0403-5100030
D9AFL5-03-0030-5100085
D9BFL4-03-0225-5100090
D9EFL5-03-0069-5100102
D9EFL5-03-0084-5100127
09AFL5-03-0042-5100128
D9BFL3-03-0168-5100129
D9BFL2-03-0583-5100139
D9CFL5-03-0113-5100160
D9EFL5-03-0108-5100162
D9EFL5-03-0109-5100163
D9EFL5-03-0072-5100175
D9BFL3-03-0316-5100184
D9AGL5-03-0085-5100185
D9AGL5-03-0082-5100186
D9AFL5-03-0093-5100205
D9AFL5-03-0095-5100206
MITRE CORPORATION
LOCKHEED
STONE & WEBSTER ENV TECH
ARTHUR D. LITTLE
MA
TX
MA
MA
LEGGETTE, BRASHEARS & GRAHAMCT
TRC ENVIRONMENTAL CONSULT.
REGION 01 6
EBASCO SERVICES
EBASCO SERVICES
LOUIS BERGER & ASSOCIATES
EDER ASSOCIATES
URS CONSULTANT CORP.
ECOLOGY & ENVIR
ECOLOGY & ENVIR
ECOLOGY & ENVIR
ECOLOGY & ENVIR
ECOLOGY & ENVIR
ECOLOGY & ENVIR
ECOLOGY & ENVIR
ECOLOGY & ENVIRONMENT
REGION 02 13
VIAR
ROY F. WESTON
SANFORD COHEN & ASSOCIATES
BOOZ ALLEN HAMILTON
ROY f. WESTON
ROY F. WESTON
DYNAMAC
DYNAMAC
UNISYS GOVERNMENT SYSTEMS
THE WASHINGTON CONSULTING
NUS
NUS
MARASCO NEWTON GROUP LTD.
VIAR
C.C. JOHNSON & HALHOTRA
COM FEDERAL PROGRAMS
S. COHEN & ASSOCIATES
GROUNDWATER TECHNOLOGY GOVT
CT

NY
NY
NJ
NY
NJ
NY
NY
NY
NY
NY
NY
NY
NY

VA
PA
VA
VA
PA
PA
MD
MD
VA
DC
MD
MD
VA
VA
CO
VA
VA
.PA
1V 2/94
11/17/94
3/30/95
3/30/95
3/30/95
V 9/95

11/ 2/94
11/ 2/94
3/30/95
3/30/95
3/30/95
11/ 4/94
11/22/94
2/ 6/95
2/22/95
3/27/95
3/30/95
12/23/94
12/28/94

10/ 6/94
10/24/94
11/28/94
11/28/94
11/30/94
12/29/94
12/29/94
12/29/94
1/13/95
21 9/95
2/ 9/95
2/ 9/95
2/10/95
2/17/95
2/17/95
2/17/95
3/10/95
3/10/95
 OCTOBER 1, 1994 THROUGH MARCH 31, 1995
                                 51

-------
                                                                                    Questioned Costs
Assignment Control  Number
                                Title
                                                       Final Report
                                                           Issued
                                                 Ineligible
                                                  Costs
                                   Unsupported
                                  	Costs	
                                           Unreasonable
                                              Costs	
Recommended
Efficiencies
(Funds Be Put
To Better Use]
D9AGL5-03-0086-5100219
D9AFL5-03-0094-5100221
D9AFL5-03-0044-5100225
TECHLAU,  INC.
AEPCO, INC.
SCIENTEX  CORP.
                                                   VA
VA
              TOTAL  OF  REGION  03
                                    21
E9EFN4-22-0179-5300005
E9BFP3-22-0314-5400045
ICF-FY 1994 LABOR FLOORCHECK
ICF ESTIMATING SYS.VULNERA.
              TOTAL OF  REGION  22
3/22/95
3/22/95
3/24/95
       1/10/95
       2/27/95
D9BKL3-04-0348-5100009
D9BKL5-04-0028-5100036
D9BKL3- 04 -0349- 5 100037
D9BKL5-04-0035-5100067
D9AKL5-04-0052-5100098
D9AKL5-04-0051-5100099
D9BKL3-04-0022-5100146
D9BKL5-04-0077-5100193
D9BKL5-04-0078-5100194
D9AGL5-04-0066-5100211
D9EGL5-04-0092-5100212
D9BKL4-04-0116-5100213
D9EGL5-04-0094-5100218
TOTAL OF
D9AGL4-05-0295-5100049
D9AKL4-05-0316-5100072
D9AJL5-05-0019-5100073
D9EHL5-05-0052-5100151
D9AKP5-05-0070-5400062
E9DKL4-05-0064-5100079
E9EKN4-05-0272-5300003
E9AKP5-05-0051-5400038
E9AKP5-05-0090-5400053
TOTAL OF
E9EFP4-23-0018-5400005
E9BHP4-23-0002-5400015
E9BHP4-23-0003-5400020
E9BHP4-23-0004-5400025
E9BHP4-23-0005-5400027
E9BHP4-23-0006-5400031
E9AHP5-23-0005-5400047
TOTAL OF
D9AKL3-06-0187-5100097
D9AKL5-06-0019-5100130
TOTAL OF
D9BJL4-07-0061-5100011
D9AGL4-07-0081-5100013
09AGL4-07-0082-5100014
D9AGL4-07-0081 -5100023
D9AGL4-07-0081-5100024
D9AGL4-07-0081-5100025
D9AGL4-07-0082-5100026
D9AGL4-07-0082-5100027
D9AGL4-07-0082-5100028
D9AGL4-07-0082-5100039
D9AGL4-07-0082-5100040
D9AGL4-07-0082-5100041
D9AGL4-07-0082-5100071
D9AGL5-07-0019-5100188
D9AKL5-07-0025-5100227
EQUITY ASSOCIATES
EQUITY ASSOCIATES, INC.
EQUITY ASSOCIATES
PC ENGINEERING
PRECISION ENVIRONMENTAL
PRECISION ENVIRONMENTAL
EC/R
MANTECH TECHNOLOGY
MANTECH TECHNOLOGY
ENTECH, INC.
ENTECH, INC.
MANTECH RESEARCH
COMMUNITY RELATIONS PLUS
REGION 04 = 13
OHM REM 68-W9-0053
LIFE SYSTEMS INC
AT KEARNEY
SUPERIOR HAZ WASTE
BATTELLE
PRC EMI FY 92
PRC EMI CAS 409
PRC EMI (PCHEM TECH)
PRC EMI (R10)
REGION 05 9
OHM REM EQUIP USE
OHM REM FY 87
OHM REM FY 88
OHM REM FY 89
OHM REM FY 90
OHM REM FY 91
EQMI
REGION 23 = 7
VERTEC INC.
HALFF ASSOCIATES
REGION 06 2
DPRA
B & V WASTE SCIENCE & TECH
SVERDRUP ENVIRONMENTAL INC.
B & V WASTE SCIENCE & TECH
B & V WASTE SCIENCE & TECH
B & V WASTE SCIENCE & TECH
SVERDRUP ENVIRONMENTAL INC.
SVERDRUP ENVIRONMENTAL INC.
SVERDRUP ENVIRONMENTAL INC.
SVERDRUP ENVIRONMENTAL INC.
SVERDRUP ENVIRONMENTAL INC.
SVERDRUP ENVIRONMENTAL INC.
SVERDRUP ENVIRONMENTAL INC.
SVERDRUP ENVIRONMENTAL
BRAL ENVIRONMENTAL SERVICES
TN
TN
TN
TN
GA
GA
NC
NC
NC
GA
GA
NC
GA

OH
OH
IL
WI
OH
IL
IL
IL
IL

OH
OH
OH
OH
OH
OH
OH

AK
TX

KS
MO
MO
MO
MO
MO
MO
MO
MO
MO
MO
MO
MO
MO
MO
10/ 7/94
10/26/94
10/26/94
11/10/94
11/29/94
11/29/94
2/ 2/95
2/24/95
2/24/95
3/16/95
3/16/95
3/16/95
3/21/95

11/ 2/94
11/14/94
11/14/94
2/ 3/95
3/31/95
11/17/94
11/17/94
2/ 3/95
3/24/95

10/ 5/94
11/18/94
12/ 6/94
12/14/94
12/22/94
1/13/95
3/ 9/95

11/29/94
M 4/95

10/11/94
10/17/94
10/17/94
10/20/94
10/20/94
10/20/94
10/20/94
10/20/94
10/20/94
10/26/94
10/26/94
10/26/94
11/14/94
2/17/95
3/24/95
              TOTAL OF REGION 07
                                    15
  52
                                                                       OFFICE OF INSPECTOR GENERAL

-------
Assignment Control Number
Title
 Final  Report
	  Issued
                                                                                                                   Recommended
                                                                                                        	  Efficiencies
                                                                         Ineligible    Unsupported    Unreasonable  (Funds Be Put
                                                    Questioned Costs
                                                                           Costs
                                                                                         Costs
                                                                                                        Costs	T_p_B e 11 e r
D9AKL5-08-0015-5100080  HARRIS GROUP,  INC.                 11/17/94
D9AKL5-08-0016-5100081  WATKINS JOHNSON ENVIRONMENT  CO     11/17/94
D9AKL5-08-0017-5100082  AGUIRRE ENGINEERS            CO     11/17/94
D9AKL5-08-0014-5100093  JAMES GRANT &  ASSOC.,  INC.   CO     11/29/94
D9AKL5-08-0014-5100094  JAMES GRANT &  ASSOC.,  INC.   CO     11/29/94
D9AKL4-08-0073-5100095  TOEROEK ASSOCIATES,  INC.     CO     11/29/94
D9AKL5-08-0015-5100096  HARRIS GROUP,  INC.                 11/29/94
D9AGL5-08-0027-5100181  PACIFIC WESTERN TECHNOLOGIESCO     2/13/95
D9AGL5-08-0025-5100201  AQUIRRE ENGINEERING  INC.     CO     3/ 7/95
D9AGL5-08-0029-5100252  MSE, INC                     MT     3/31/95
             TOTAL OF REGION 08
                                     10
D9BGL2-09-0142-5100001
D9BGL3-09-0111-5100015
D9AJL5-09-0033-5100112
D9BGL5-09-0034-5100113
D9CGL5-09-0032-5100117
D9AGL5-09-0036-5100145
D9BGL2-09-0154-5100189
D9AGL5-09-0041 -5100195
D9BGL5-09-0048-5100228
D9FGP5-09-0019-5400003
D9FGP5-09-0020-5400004
TOTAL OF
D9AGL5-10-0008-5100058
D9AGL5-10-0012-5100061
D9AJL5-10-0010-5100062
09AJL5-10-0009-5100063
D9AJL5-10-0007-5100075
D9AKL5-10-0030-5100234
D9FGN5-10-0037-5300009
D9AKN5-10-0032-5300010
E9BGL3-10-0110-5100232
JACOBS CI FY '91
BECHTEL CI 1991
SCS ENGINEERS PA
CET CI 1991
GEO/R FC
SAIC PA
S-CUBED CI 1990 AND 1991
RESEARCH MGMT PA
SAIC CO. 6 MS
CET MS
CET FL
REGION 09 11
ESA CONSULTANTS PA
EVS CONSULTANTS PA
ENVIROS PA
ENV. ISSUES MGMT. PA
OLYMPUS ENVIRONMTL. PA
CHUGACH DEVELOPMENT PA
CH2M 1C
HERRERA ENVIRO CONSULT-PA
CH2M CI 1985-86
CA
CA
CA
CA
CA
CA
CA
CA
CA
CA
CA
MT
WA
WA
WA
WA
AK
OR
WA
OR
10/ 3/94
10/17/94
12/ 9/94
12/ 9/94
12/20/94
1/31/95
2/17/95
2/28/95
3/24/95
107 4/94
107 4/94
117 4/94
117 9/94
117 9/94
117 9/94
11/16/94
3/29/95
3/15/95
3/29/95
3/28/95
             TOTAL OF REGION 10 =
             TOTAL SUPERFUND CONTRACT ASSIGNMENTS
                                                     =  118
                                                                         1,434,688
                                                        4,182,512
                                                     3,667
19,794,175
             TOTAL REPORTS
                               448
                                                                        39,268,515     23,286,516
                                                                           3,667
                                                                36,204,562
  OCTOBER 1, 1994 THROUGH MARCH 31, 1995
                                                                                           53

-------
      Appendix  2  -  Reports  Issued Without  Management Decision
    THE INSPECTOR GENERAL ACT REQUIRES A SUMMARY OF EACH REPORT ISSUED BEFORE THE COMMENCEMENT OF THE REPORTING
    PERIOD FOR WHICH NO MANAGEMENT DECISION HAS BEEN MADE BY THE END OF THE REPORTING PERIOD (INCLUDING THE DATE AND
    TITLE OF EACH SUCH REPORT), AN EXPLANATION OF THE REASONS SUCH MANAGEMENT DECISION HAS NOT BEEN MADE, AND A
    STATEMENT CONCERNING THE DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION ON EACH SUCH REPORT. (The IG
    provides the summary, the date and title of each such report.  The Agency provides the explanation of the reasons why such management decision
    has not been made, and a statement concerning the desired timetable for achieving a management decision on each such report.)

    IG Followup  Status Codes of Agency's Response at 3/31/95:
    1. No Response
    2. Incomplete Response Received
    3. Proposed Response Received Awaiting Final Determination
    4. Proposed Response Received in Review Process
    5. Final Response Received in Review Process
    6. Resolution Under Negotiation in Headquarters
 ASSIGNMENT CONTROL
 NUMBER
                            TITLE
 FINAL REPORT
       ISSUED
ASSIGNMENT CONTROL
NUMBER	
                                           TITLE
 FINAL REPORT
	ISSUED
 Assistant Administrator  for Administration & Resources Management   IG FOLLOWUP STATUS AS OF   3/31/95    [1]
 E3CML3-03-0201-4100523   TEMPLE UNIVERSITY          PA   9/15/94
  Summary:  EPA ERRONEOUSLY AWARDED A COOPERATIVE  AGREEMENT TO
 TEMPLE UNIVERSITY AND MISMANAGED THE AGREEMENT  BY NOT CONTROLLING
 EXPENDITURES AND ALLOWING UNAUTHORIZED TRAVEL.

   EXPLANATION OF THE REASONS MANAGEMENT DECISION  HAS NOT BEEN
 MADE:  THE DIG REQUESTED A COMPTROLLER GENERAL  OPINION REGARDING
 THE USE OF NON-FEDERAL  TRAVEL UNDER COOPERATIVE AGREEMENTS.  EPA
 MANAGEMENT, THE DIG AND THE OFFICE OF GENERAL COUNSEL ARE WORKING
 TOGETHER TO DEVELOP A REQUEST FOR GAO TO PROVIDE  ITS OPINION ON
 THIS AND OTHER OUTSTANDING ISSUES.  EPA WILL DELAY  FINAL ACTION
 ON THIS AUDIT UNTIL RECEIPT OF THE COMPTROLLER  GENERAL OPINION.

 = DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT  DECISION:
 RESOLUTION CANNOT BE DETERMINED AT THIS TIME.

 IG FOLLOWUP STATUS AS OF 3/31/95   [1]

 E1FMF4-19-0618-4100407   UNIVERSITY OF KANSAS        KS   6/17/94
  *Summary:  EPA CIRCUMVENTED ASSISTANCE REGULATIONS AND MISUSED
 FEDERAL FUNDS BY AWARDING A COOPERATIVE AGREEMENT TO THE
 UNIVERSITY OF KANSAS WHICH INCLUDED INELIGIBLE  AND UNNECESSARY
 COSTS SUCH AS TRAVEL, ALCOHOL, AND ENTERTAINMENT.  *

   EXPLANATION OF THE REASONS MANAGEMENT DECISION  HAS NOT BEEN
 MADE:  THE OIG REQUESTED A COMPTROLLER GENERAL  OPINION REGARDING
 THE USE OF NON-FEDERAL  TRAVEL UNDER COOPERATIVE AGREEMENTS.  EPA
 MANAGEMENT, THE OIG AND THE OFFICE OF GENERAL COUNSEL ARE WORKING
 TOGETHER TO DEVELOP A REQUEST FOR GAO TO PROVIDE  ITS OPINION ON
 THIS AND OTHER OUTSTANDING ISSUES.  EPA WILL DELAY FINAL ACTION
 ON THIS AUDIT UNTIL RECEIPT OF THE COMPTROLLER  GENERAL OPINION.

  DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT  DECISION:
 RESOLUTION CANNOT BE DETERMINED AT THIS TIME.

 IG FOLLOWUP STATUS AS OF  3/31/95   [1]
               D8AML4-01-0129-4100429  ARTHUR D. LITTLE
                *Sumniary:  (PREAWARD AUDIT UNDER NEGOTIATION)
                                                   MA  6/27/94
Contracts Management Division - RTP

D8AML4-01-0085-4100247  EASTERN RESEARCH  GROUP
 *Sunmary:   (PREAWARD AUDIT UNDER NEGOTIATION)
                 EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN MADE:
               A.D. LITTLE IS A SUBCONTRACTOR TO VERSAR.  VERSAR SUBMITTED A BID
               WHICH WAS UNSUCCESSFUL.  AN AWARD WAS MADE ON THIS RFP ON 9/30/94
               TO RADIAN CORP,  CONTRACT 68D40092. THE CONTRACT SPECIALIST DID NOT
               PROVIDE A COPY OF  THE  RECORD OF PROCUREMENT ACTION (ROPA)  AND
               TRANSMITTAL LETTER TO  COST ADVISORY.  THE CONTRACT FILE  HAS BEEN
               TRANSFERRED TO HEADQUARTERS.

               = DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION:
               RESOLUTION CANNOT  BE DETERMINED AT THIS TIME.

               IG FOLLOWUP STATUS AS  OF  3/31/95    [1]

               D8AML4-02-0139-4100430 ENSERCH ENVIRONMENTAL CORP.  NJ   6/27/94
                *Summary:   (PREAWARD  AUDIT UNDER NEGOTIATION)

                 EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN MADE:
               NO AWARD HAS BEEN  MADE.

                 DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION:   THE
               CONTRACT SPECIALIST PROJECTS TO MAKE AN AWARD  ON  THIS RFP  BY
               5/31/95.

               IG FOLLOWUP STATUS AS  OF  3/31/95    [1]

               D8CPL2-03-0432-2100620 MIRANDA ASSOCIATES INC       DC   9/16/92
                Summary:   DCAA QUESTIONED $278,979  DUE TO (1) THE LIMITATIONS OF
               FUNDS CLAUSE, (2)  OVERSTATED OVERHEAD COSTS, AND  (3) A
               COMPUTATIONAL ERROR.

                 EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN MADE:
               THE CONTRACTING OFFICER'S DECISION HAS BEEN COMPLETED.  QUESTIONED
               COST HAS BEEN SUSTAINED.

                 DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION:   FINAL
               REVIEW BY THE OFFICE OF GENERAL COUNSEL EXPECTED  BY 4/15/95.

MA   4/13/94    IG FOLLOWUP STATUS AS  OF  3/31/95    [1]
  EXPLANATION OF THE REASONS MANAGEMENT  DECISION HAS NOT BEEN
MADE:   NO AWARD HAS BEEN MADE.

  DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION:  THE
CONTRACT  SPECIALIST PROJECTS TO AWARD  A  CONTRACT ON THIS RFP BY
4/15/95.
               D8CPL2-03-0441-4100108  KENDRICK & COMPANY           DC   12/6/93
                Summary:  COSTS OF $202,352 WERE QUESTIONED DUE TO LIMITATIONS OF
               FUNDS CLAUSE AND  OVERSTATED INCURRED COSTS.

                 EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN MADE:
               EPA CONTRACTING OFFICER IS TRYING TO LOCATE THE  BUSINESS TO
               INITIATE THE CLOSE  OUT PROCESS.  KENDRICK & COMPANY HAS  EITHER
               MOVED, GONE  OUT OF  BUSINESS, OR HAS BEEN PURCHASED.
   54
                                            OFFICE OF INSPECTOR GENERAL

-------
ASSIGNMENT CONTROL
NUMBER	
TITLE
                        FINAL REPORT
                              ISSUED
ASSIGNMENT  CONTROL
NUMBER
  DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT  DECISION:
 RESOLUTION CANNOT BE DETERMINED AT THIS  TIME.

 IG  FOLLOWUP STATUS AS OF  3/31/95    [1]

 D8AML4-03-0213-4100274  VERSAR                       VA    5/10/94
  *Sunnary:  (PREAWARD AUDIT UNDER NEGOTIATION)

  EXPLANATION OF THE REASONS MANAGEMENT  DECISION  HAS NOT  BEEN
 MADE:  NO AWARD HAS BEEN MADE.

  DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT  DECISION:   THE
 CONTRACT SPECIALIST PROJECTS TO AWARD A  CONTRACT  ON  THIS  RFP  BY
 4/15/95.
                                                                    TITLE
 FINAL  REPORT
	ISSUED
 IG  FOLLOUUP STATUS AS OF  3/31/95    [1]

 D8AML4-03-0215-4100275  ENERGETICS  INC.
  Summary:  (PREAWARD AUDIT UNDER NEGOTIATION)
                       MD   5/10/94
   EXPLANATION OF THE REASONS MANAGEMENT DECISION  HAS  NOT  BEEN
 MADE:  NO AWARD HAS BEEN MADE.

   DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION:   THE
 CONTRACT SPECIALIST PROJECTS TO AWARD A CONTRACT  ON THIS  RFP BY
 4/15/95.
 IG FOLLOWUP STATUS AS OF  3/31/95    [1]

 D8AML4-03-0211-4100290  AVANTI CORPORATION
  Summary:  (PREAWARD AUDIT UNDER NEGOTIATION)
                       VA   5/16/94
   EXPLANATION OF THE REASONS MANAGEMENT DECISION  HAS  NOT  BEEN
 MADE:  NO AWARD HAS BEEN MADE.

   DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION:   THE
 CONTRACT SPECIALIST PROJECTS TO AWARD A CONTRACT  ON THIS  RFP BY
 4/15/95.

 IG FOLLOWUP STATUS AS OF  3/31/95    [1]

 D8AML4-03-0280-4100355  COASTAL ENVIRONMENTAL       MD    6/1/94
  *Summary:  (PREAWARD AUDIT UNDER NEGOTIATION)

   EXPLANATION OF THE REASONS MANAGEMENT DECISION  HAS  NOT  BEEN
 MADE:  NO AWARD HAS BEEN MADE.

   DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION:   THE
 CONTRACT SPECIALIST PROJECTS TO MAKE AN AWARD ON  THIS RFP BY
 5/31/95.

 IG FOLLOWUP STATUS AS OF  3/31/95    [1]

 D8AML4-03-0278-4100360  GANNETT FLEMING             PA    6/7/94
  *Summary:  (PREAWARD AUDIT UNDER NEGOTIATION)

   EXPLANATION Of THE REASONS MANAGEMENT DECISION  HAS  NOT  BEEN
 HADE:  NO AWARD HAS BEEN MADE.

   DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION:   THE
 CONTRACT SPECIALIST PROJECTS TO MAKE AN AWARD ON  THIS RFP BY
 5/31/95.
 IG FOLLOWUP STATUS AS OF  3/31/95   [1]

D9AFL4-03-0273-4100364  DYNCORP VIAR
 Summary:   (PREAWARD AUDIT UNDER NEGOTIATION)
                       VA   6/7/94
  EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN
MADE:  THE CONTRACTING OFFICER NEGOTIATED A MODIFICATION TO
CONTRACT NO.  68D90135 ON MAY 31, 1994.  NO TRANSMITTAL LETTER
EXPLAINING ACTION TAKEN ON THE AUDIT REPORT WAS PREPARED AT
THAT TIME.

  DESIRED TIMETABLE  FOR ACHIEVING A MANAGEMENT DECISION:  THE
APPROPRIATE TRANSMITTAL LETTER WAS GIVEN TO COST ADVISORY AND
 FINANCIAL ANALYSIS DIVISION AND MAILED TO DCAA AND THE DIG ON APRIL
 13,  1995.

 IG FOLLOWUP STATUS AS  OF   3/31/95    [1]

 D8AML4-03-0296-4100405  WASTE POLICY INSTITUTE       VA   6/14/94
 Sunmary:  (PREAWARD AUDIT  UNDER NEGOTIATION)

  EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN MADE:
 THE  CONTRACT  SPECIALIST EXPECTS NO  AWARD  TO  BE  MADE.

  DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT  DECISION:   THE
 CONTRACT SPECIALIST EXPECTS THIS RFP TO BE CANCELLED BY 5/31/95.

 IG FOLLOWUP STATUS AS  OF   3/31/95    [1]

 D8AML4-03-0282-4100434  RMC ENVIRONMENTAL  SERVICE    PA   6/28/94
 *Summary:  (PREAWARD AUDIT UNDER NEGOTIATION)

  EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN MADE:
 NO AWARD HAS  BEEN MADE.

  DESIRED TIMETABLE FOR ACHIEVING A  MANAGEMENT  DECISION:   THE
 CONTRACT SPECIALIST PROJECTS TO MAKE AN AWARD ON THIS RFP  BY
 5/31/95.

 IG FOLLOWUP STATUS AS OF  3/31/95    [1]

 D8AML4-03-0281-4100438  GREELEY-POLHEMUS GROUP       PA   6/30/94
 Summary:  (PREAWARD AUDIT UNDER NEGOTIATION)

  EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN MADE:
 NO AWARD HAS  BEEN MADE.

  DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT  DECISION:   THE
 CONTRACT SPECIALIST PROJECTS TO MAKE AN AWARD ON THIS RFP  BY
 5/31/95.

 IG FOLLOWUP STATUS AS OF  3/31/95    [1]

 D8ABL4-03-0301-4100446  UNIVERSAL  SYSTEMS            VA    7/14/94
 *Sunnary:  (PREAWARD AUDIT UNDER NEGOTIATION)

  EXPLANATION  OF THE REASONS MANAGEMENT DECISION  HAS NOT BEEN MADE:
 THE CONTRACT  SPECIALIST EXPECTS NO AWARD TO BE  MADE.

  DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT  DECISION:   THE
 CONTRACT SPECIALIST EXPECTS THIS RFP TO BE CANCELLED BY 5/31/95.

 IG FOLLOWUP STATUS AS OF  3/31/95    [1]

D8AML4-03-0371-4100485  INFORMATION  VENTURES,  INC.    PA   8/12/94
 *Summary:  (PREAWARD AUDIT UNDER NEGOTIATION)

  EXPLANATION  OF THE REASONS MANAGEMENT DECISION  HAS NOT BEEN MADE:
COMPETITIVE RANGE HAS BEEN ESTABLISHED.

  DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT  DECISION:   THE
 CONTRACT SPECIALIST EXPECTS AWARD BY 6/30/95.

 IG FOLLOWUP STATUS AS OF  3/31/95    [1]

D8AML4-03-0279-4100487  COM FEDERAL  PROGRAMS          VA   8/12/94
 *Summary:  (PREAWARD AUDIT UNDER NEGOTIATION)

  EXPLANATION  OF THE REASONS MANAGEMENT  DECISION  HAS NOT BEEN MADE:
NO AWARD HAS  BEEN MADE.

  DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT  DECISION:   THE
 CONTRACT SPECIALIST PROJECTS TO MAKE AN AWARD ON THIS RFP  BY
 5/31/95.

 IG FOLLOWUP STATUS AS OF  3/31/95    [1]

D8EML4-03-0498-4100557  QUANTECH,  INC.                VA   9/23/94
 *Summary:  SOME OF THE CONTRACTOR'S ESTIMATING PRACTICES  REQUIRE
   OCTOBER 1, 1994 THROUGH MARCH 31, 1995
                                                                                          55

-------
ASSIGNMENT CONTROL
NUMBER
TITLE
 FINAL  REPORT
	ISSUED
CORRECTIVE ACTION TO IMPROVE THE RELIABILITY OF THEIR FUTURE COST
ESTIMATES.

  EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN
MADE:  THE MANAGEMENT DECISION WAS MADE ON THIS AUDIT ON
FEBRUARY 3, 1995.  CONTRACT NO. 68D50008 WAS AWARDED TO BATTELLE.
QUANTECH,  INC. IS A SUBCONTRACTOR ON THIS CONTRACT.  THIS IS AN
OPPTS CONTRACT WHICH WAS AWARDED AT RTP THEN TRANSFERRED TO EPA
HEADQUARTERS  IN WASHINGTON, DC.

  DESIRED  TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION:
RESOLUTION IS EXPECTED SHORTLY.
 IG  FOLLOWUP STATUS AS OF  3/31/95    [1]

 D8BML3-04-0272-3100202  INTEGRATED LABORATORY SYS
 *Summary:
                       NC   6/2/93
   EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN
MADE:  CONTRACTOR HAS AGREED WITH COST QUESTIONED.

   DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION:
RESOLUTION CANNOT BE DETERMINED AT THIS TIME.
 IG  FOLLOWUP STATUS AS OF  3/31/95    [1]

 D8BML3-04-0282-3100207  SYSTEMS RESEARCH & DEV.
 *Summary:
                       NC   6/4/93
   EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN
MADE:  THE REPORT COVERS DIRECT AND INDIRECT COSTS FOR CALENDAR
YEAR  1988.  COST QUESTIONED ON TWO CONTRACTS.  CONTRACTOR HAS
AN APPROVED BANKRUPTCY PLAN.  ANY RECOVERY MUST BE ESTABLISHED
THROUGH THE COURT.

   DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION:  FINAL
ACTION EXPECTED BY JUNE 1,  1995.
 IG  FOLLOWUP STATUS AS OF  3/31/95    [2]

 D8AML4-04-0219-4100478  TWM SERVICES INC.
 Summary:  (PREAWARD AUDIT UNDER NEGOTIATION)
                       NC   8/11/94
  EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN
MADE:  CONTRACTOR WAS NOT FINANCIALLY CAPABLE OF PERFORMING
JANITORIAL SERVICES WORK AT THE HUMAN STUDIES BUILDING IN CHAPEL
HILL, NC.  AWARD WAS MADE TO ANOTHER CONTRACTOR, TRIPLE P
SERVICES, INC. ON FEBRUARY 10, 1995.  THE CONTRACT SPECIALIST
FAILED TO SEND DCAA, DIG, OR COST ADVISORY STAFF A COPY OF THE
TRANSMITTAL LETTER STATING RESULTS OF AUDIT.

  DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION:
RESOLUTION IS EXPECTED SHORTLY.
 IG FOLLOWUP STATUS AS OF  3/31/95   [1]

 D8AML4-05-0265-4100467  GREAT LAKES ENVIRO CENTER   MI
 Suirroary:  (PREAWARD AUDIT UNDER NEGOTIATION)
                            7/27/94
  EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN
MADE:  COMPETITIVE RANGE HAS BEEN ESTABLISHED.
= DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION:
CONTRACT SPECIALIST EXPECTS AWARD BY 6/30/95.
                             THE
IG FOLLOWUP STATUS AS OF  3/31/95   [1]

D9AKL4-08-0048-4100279  RESOURCE TECHNOLOGY CORP
 *Summary:  (PREAWARD AUDIT UNDER NEGOTIATION)
                       WY   5/10/94
  EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN
MADE:  RESOURCE TECHNOLOGY CORP. WAS A SUBCONTRACTOR ON THE SAIC
(PRIME CONTRACTOR) PROPOSAL SUBMISSION.  SAIC PROPOSAL SUBMISSION
WAS UNSUCCESSFUL.  SAIC, DCAA, OIG AND COST ADVISORY STAFF WERE
NOTIFIED THAT SAIC WAS UNSUCCESSFUL.  HOWEVER THE DCAA OFFICE,
OIG AND COST ADVISORY STAFF WERE NOT SENT A TRANSMITTAL LETTER
ASSIGNMENT CONTROL
NUMBER
                                                                                                 TITLE
                                                                                            FINAL  REPORT
                                                                                           	ISSUED
               REGARDING THE UNSUCCESSFUL  RESOURCE  TECHNOLOGY CORPORATION
               SUBCONTRACT BID.

                 DESIRED TIMETABLE  FOR ACHIEVING A  MANAGEMENT DECISION:
               RESOLUTION IS EXPECTED SHORTLY.
               IG FOLLOWUP STATUS AS OF  3/31/95    [1]

               D8BBL4-09-0053-4100510  EARTH METRICS, INC FC        CA   8/26/94
                Summary:  QUESTIONED DIRECT  COSTS OF  $259,919 REPRESENT
               SUBCONTRACTS AWARDED TO COMPANIES NOT SPECIFIED IN THE CONTRACT AND
               FOR AMOUNTS IN EXCESS OF CONTRACT LIMITS.   SOME INTERNAL CONTROL
               WEAKNESSES ARE ALSO  IDENTIFIED  IN THE  REPORT.

                 EXPLANATION OF  THE  REASONS MANAGEMENT DECISION HAS NOT BEEN MADE:
               THE CONTRACTING OFFICER DECISION IS  PENDING ADDRESSING QUESTIONED
               COSTS.  THE CONTRACTING OFFICER'S DECISION IS EXPECTED BY MAY 31,
               1995.

               = DESIRED TIMETABLE  FOR ACHIEVING A MANAGEMENT DECISION:  CONTRACT
               CLOSEOUT IS EXPECTED BY JULY 31, 1995.

               IG FOLLOWUP STATUS AS OF  3/31/95    [1]

               D8CAN3-09-0259-4300037  IT  FC                       CA   6/13/94
                Summary:  THE QUESTIONED AMOUNT REPRESENTS COSTS BILLED AFTER THE
               SPECIFIED CONTRACT DATE,  PLUS ADJUSTMENTS  FOR  INDIRECT RATE
               DIFFERENCES BETWEEN THE  BILLED AND THE  LOWER OF THE NEGOTIATED OR
               CEILING RATE.

                 EXPLANATION OF  THE REASONS MANAGEMENT  DECISION HAS NOT BEEN MADE:
               IT, INC. PURCHASED HYDRA-SCIENCE, INC.  THE ENTIRE  PERFORMANCE
               PERIOD OF THE  CONTRACT WAS  WITH HYDRA-SCIENCE.  INC.  IT,  INC.  HAS
               LIMITED INFORMATION RELATIVE TO THE QUESTIONED  COSTS.

               = DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT  DECISION:
               RESOLUTION IS EXPECTED BY SEPTEMBER  15, 1995.
               IG FOLLOWUP STATUS AS OF  3/31/95    [1]

               D8AMN4-09-0230-4300048  SAIC PA
                *Summary:  (PREAWARD AUDIT UNDER NEGOTIATION)
                                                                                           CA   9/19/94
                 EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN MADE:
               AN AWARD HAS BEEN  MADE ON  THIS RFP TO ANOTHER  OFFEROR --  SYRACUSE
               RESEARCH -- ON 1/30/95.  CONTRACT SPECIALIST  ERRONEOUSLY DID NOT
               PROVIDE DCAA, OIG OR COST ADVISORY STAFF A COPY OF TRANSMITTAL
               LETTER.  THE CONTRACT IS AN OPPTS AWARD AND HAS BEEN  TRANSFERRED
               TO EPA HEADQUARTERS IN WASHINGTON, DC.

               = DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION:
               RESOLUTION IS EXPECTED SHORTLY.

               IG FOLLOWUP STATUS AS OF  3/31/95    [1]

               E1P8CMP2-23-0180-3400071  PEI ASSOC                  OH  8/25/93
                Summary:  UNSUPPORTED LABOR AND TRAVEL COSTS OF $332,746 WERE
               QUESTIONED DUE TO  INADEQUATE DOCUMENTATION.  WE ALSO QUESTIONED AS
               INELIGIBLE $513 BECAUSE OF LACK OF SUPPORT FOR  INTER-COMPANY
               TRANSACTIONS.

                 EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN MADE:
               AN EPA LETTER DATED 3/1/94 ADVISED THE CONTRACTOR OF  COSTS
               QUESTIONED AND REQUESTED A REFUND OR SUPPORTING DOCUMENTATION. THE
               CONTRACTOR RESPONDED ON 3/29/94 THAT  THE  SUPPORTING  DOCUMENTATION
               WAS AVAILABLE.  ON 4/12/94, EPA SENT A LETTER TO THE  OIG ASKING
               THAT IT REVIEW THE NEW DATA AND PROVIDE A REVISED AUDIT  REPORT.
               EPA IS CURRENTLY AWAITING OIG RESPONSE.

                 DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION:
               RESOLUTION CANNOT BE DETERMINED AT THIS TIME.

               IG FOLLOWUP STATUS AS OF  3/31/95    [3]

               P8CMP2-23-0176-3400072  PEI ASSOC                    QH  8/26/93
                Summary:  QUESTIONED $839,416 OF UNSUPPORTED LABOR AND  TRAVEL
               COSTS THAT COULD NOT BE SUPPORTED BY ADEQUATE DOCUMENTATION.
   56
                                                                    OFFICE OF INSPECTOR GENERAL

-------
ASSIGNMENT  CONTROL
NUMBER	
TITLE
                        FINAL REPORT
                              ISSUED
  EXPLANATION  OF  THE  REASONS MANAGEMENT DECISION HAS NOT BEEN
MADE:   AN  EPA  LETTER  DATED  3/1/94 ADVISED THE CONTRACTOR OF
COSTS  QUESTIONED  AND  REQUESTED  A REFUND OR SUPPORTING
DOCUMENTATION.  THE CONTRACTOR  RESPONDED ON 3/29/94 THAT THE
SUPPORTING DOCUMENTATION  WAS AVAILABLE.  ON 4/12/94, EPA SENT
A LETTER TO THE  DIG  ASKING ASSIGNMENT CONTROL

THAT IT REVIEW THE NEW  DATA AND PROVIDE A REVISED AUDIT REPORT.
EPA IS CURRENTLY  AWAITING DIG RESPONSE.

  DESIRED  TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION:
RESOLUTION CANNOT BE  DETERMINED AT THIS TIME.

IG FOLLOWUP STATUS AS OF  3/31/95   [3]

P8CMP2-23-0181-3400074  PEI ASSOC                   OH   8/27/93
 *Suim\ary:  QUESTIONED  UNSUPPORTED LABOR AND TRAVEL OF $40,498
DUE TO MISSING DOCUMENTATION.  WE ALSO QUESTIONED AS INELIGIBLE
$254 DUE  TO LACK  OF SUPPORT FOR INTERCOMPANY TRANSACTIONS.

  EXPLANATION  OF  THE  REASONS MANAGEMENT DECISION HAS NOT BEEN
MADE:   AN  EPA  LETTER  DATED  3/1/94 ADVISED THE CONTRACTOR OF
COSTS QUESTIONED  AND  REQUESTED  A REFUND OR SUPPORTING
DOCUMENTATION.  THE CONTRACTOR  RESPONDED ON 3/29/94 THAT THE
SUPPORTING DOCUMENTATION  WAS AVAILABLE.  ON 4/12/94, EPA SENT A
LETTER TO  THE  DIG ASKING  THAT IT REVIEW THE NEW DATA AND PROVIDE
A REVISED  AUDIT REPORT.  EPA IS CURRENTLY AWAITING OIG RESPONSE.

  DESIRED  TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION:
RESOLUTION CANNOT BE  DETERMINED AT THIS TIME.

 IG  FOLLOWUP STATUS AS OF  3/31/95   [3]

P8CMP2-23-0177-3400077  PEI ASSOC                   OH   9/1/93
  Summary:   INADEQUATE ACCOUNTING SYSTEM RESULTED IN COST
QUESTIONED INELIGIBLE OF  $20,359.  MISSING DOCUMENTATION
RESULTED   IN $1,863,579  OF QUESTIONED UNSUPPORTED COSTS.  WE
ALSO QUESTIONED $1,992  AS INELIGIBLE DUE TO LACK OF SUPPORT FOR
 INTERCOMPANY TRANSACTIONS.

  EXPLANATION  OF  THE  REASONS MANAGEMENT DECISION HAS NOT BEEN
MADE:  AN  EPA  LETTER  DATED  3/1/94 ADVISED THE CONTRACTOR OF
COSTS QUESTIONED  AND  REQUESTED  A REFUND OR SUPPORTING
DOCUMENTATION.  THE CONTRACTOR  RESPONDED ON 3/29/94 THAT THE
SUPPORTING DOCUMENTATION  WAS AVAILABLE.  ON 4/12/94, EPA SENT A
LETTER TO  THE OIG ASKING THAT  IT REVIEW THE NEW DATA AND PROVIDE
A REVISED  AUDIT REPORT.  EPA IS CURRENTLY AWAITING OIG RESPONSE.
  DESIRED TIMETABLE  FOR  ACHIEVING A MANAGEMENT DECISION:
 RESOLUTION CANNOT  BE DETERMINED AT THIS TIME.

 IG FOLLOWUP STATUS AS Of  3/31/95   [3]

 P8CMP2-23-0179-3400082  PEI  ASSOC                   OH   9/3/93
 Summary: INADEQUATE ACCOUNTING SYSTEM RESULTED IN COST
 QUESTIONED INELIGIBLE OF $35,443.  MISSING DOCUMENTATION
 RESULTED IN UNSUPPORTED  COSTS OF $512,794.

  EXPLANATION  OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN
 MADE:  AN EPA  LETTER DATED 3/1/94 ADVISED THE CONTRACTOR OF
 COSTS QUESTIONED AND REQUESTED A REFUND OR SUPPORTING
 DOCUMENTATION.  THE  CONTRACTOR RESPONDED ON 3/29/94 THAT THE
 SUPPORTING DOCUMENTATION WAS AVAILABLE.  ON 4/12/94, EPA SENT A
 LETTER TO  THE  OIG ASKING THAT IT REVIEW THE NEW DATA AND PROVIDE
 A REVISED AUDIT REPORT.   EPA IS CURRENTLY AWAITING OIG RESPONSE.

  DESIRED TIMETABLE  FOR  ACHIEVING A MANAGEMENT DECISION:
 RESOLUTION CANNOT  BE DETERMINED AT THIS TIME.

 IG FOLLOWUP STATUS AS OF  3/31/95   [3]
Grants Administration  Division

E3CBP4-04-0252-4400116  REVIEW OF CA WITH NELHA- HI      9/29/94
 *Summary:
ASSIGNMENT CONTROL
NUMBER
                                                                    TITLE
 FINAL  REPORT
	ISSUED
                                         EXPLANATION OF  THE REASONS MANAGEMENT DECISION HAS NOT BEEN MADE:
                                       THE PROGRAM OFFICE DID NOT RECEIVE A  COPY OF  THE AUDIT REPORT
                                       TIMELY.  THE OFFICE IS CURRENTLY REVIEWING AUDIT REPORT.

                                         DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION:
                                       ANTICIPATES RESOLUTION BY 6/30/95.

                                       IG FOLLOWUP STATUS AS OF  3/31/95    [1]

                                       E6EML4-07-0023-4100581  FAIRBURY                    NE    9/30/94
                                        Summary:  THE GRANT/LOAN WAS AWARDED  FOR ASBESTOS ABATEMENT IN TWO
                                       FAIRBURY SCHOOLS.  WE DETERMINED THAT THE GRANTEE CLAIMED AN
                                       UNREASONABLE AMOUNT FOR ADMINISTRATIVE COSTS.  THE GRANTEE CLAIMED
                                       INELIGIBLE ENGINEERING AND CONSTRUCTION COSTS.

                                         EXPLANATION OF  THE REASONS MANAGEMENT DECISION HAS NOT BEEN MADE:
                                       AUDIT INVOLVES SEVERAL COMPLEX  ISSUES AS A RESULT OF CRIMINAL
                                       PROCEEDINGS TAKEN AGAINST A CONTRACTOR UNDER  THE PROJECT.   THE
                                       PROGRAM IS CURRENTLY REVIEWING  THE AUDIT FINDINGS.

                                         DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION:
                                       ANTICIPATES RESOLUTION BY 07/31/95.
                                       IG FOLLOWUP STATUS AS OF  3/31/95   [1]

                                       E6EML4-07-0022-4100582  OGALALLA
                                        *Summary:
                                                    NE    9/30/94
                                         EXPLANATION OF THE REASONS MANAGEMENT  DECISION HAS NOT BEEN MADE:
                                       AUDIT INVOLVES SEVERAL COMPLEX ISSUES AS A RESULT OF CRIMINAL
                                       PROCEEDINGS TAKEN AGAINST A CONTRACTOR UNDER THE PROJECT.  THE
                                       PROGRAM IS CURRENTLY REVIEWING THE AUDIT FINDINGS.

                                         DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION:
                                       ANTICIPATES RESOLUTION BY 07/31/95.

                                       IG FOLLOWUP STATUS AS OF  3/31/95   [1]

                                       E3CBL3-08-0088-4100497  MONTANA STATE UNIVERSITY     MT   8/23/94
                                        Surmary:  THE COOPERATIVE AGREEMENTS WERE USED TO FUND AN EPA
                                       EMPLOYEE'S ADVANCED EDUCATION CONTRARY TO THE PURPOSE OF THE
                                       COOPERATIVE AGREEMENTS AND INTERGOVERNMENTAL PERSONNEL ACT
                                       AGREEMENT.

                                         EXPLANATION OF THE REASONS MANAGEMENT  DECISION HAS NOT BEEN MADE:
                                       OIG INVESTIGATION IS ON-GOING.

                                         DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION:
                                       RESOLUTION CANNOT BE DETERMINED AT THIS TIME.

                                       IG FOLLOWUP STATUS AS OF  3/31/95   [1]

                                       E1FBF3-10-0069-4100214  AUDIT OF  CO-OPS/IAGS  ERL-C   OR   3/21/94
                                        Sumnary:  ERL-C DIDN'T ALWAYS COMPLY WITH  FGCA ACT & EPA GUIDANCE.
                                       SEVEN OF 18 GRANTS SHOULD HAVE BEEN CONTRACTS AND 2 GRANTS WERE
                                       INAPPROPRIATELY USED.  THREE OF 6  IAGS WERE FOR MULTIPLE INSTEAD OF
                                       DISTINCT PROJECTS.  SOME IAG COSTS WERE OVERPAID OR UNRECOVERED.

                                         EXPLANATION OF THE REASONS MANAGEMENT  DECISION HAS NOT BEEN MADE:
                                       THE GRANTS DIVISION WAS FORMALLY  ASSIGNED  AS  THE  ACTION  OFFICE  IN
                                       SEPTEMBER 1994.  THE DIVISION  FORWARDED MANAGEMENT'S FINAL DECISION
                                       TO THE OIG ON 3/20/95 AND IS AWAITING THE OIG'S RESPONSE.

                                         DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION:
                                       RESOLUTION CANNOT BE DETERMINED AT THIS TIME.

                                       IG FOLLOWUP STATUS AS OF  3/31/95    [1]
                                       Grants Financial Management - Region 5

                                       P2CWP6-05-0298-2400004  W LAKE SUPERIOR            MN    12/12/91
                                        Sutrmary:  THE GRANTEE CLAIMED $8,595,588 OF  INELIGIBLE
                                       CONSTRUCTION, ENGINEERING AND ADMINISTRATIVE COSTS, AND $166,834 OF
                                       UNSUPPORTED COSTS.
   OCTOBER 1, 1994 THROUGH MARCH 31, 1995
                                                                                                                       57

-------
ASSIGNMENT CONTROL
NUMBER
                             TITLE
                             FINAL REPORT
                                   ISSUED
  EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN
MADE:  DIG DID NOT ACCEPT PROPOSED FINAL DETERMINATION LETTER
OF 1/7/92.  AUDIT ELEVATED TO HQ DIG AND PROGRAM OFFICE ON
7/24/92  TO RESOLVE ISSUES.  DIG AND OFFICE OF GENERAL COUNSEL
MET AND DETERMINED THAT ISSUES ARE REGULATORY.  01G IS
RESEARCHING THE REGULATIONS AT THE TIME OF AWARD.

  DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION:
RESOLUTION CANNOT BE DETERMINED AT THIS TIME.

IG FOLLOWUP STATUS AS OF  3/31/95   [3]

E2CWL9-05-0262-3100397  FLINT                       MI   9/30/93
 Summary:  FLINT CLAIMED $2.8 MILLION UNNECESSARY/UNREASONABLE
COSTS  INCURRED TO RENEGOTIATE A CONTRACT.  FLINT CLAIMED
$10,416,828 UNSUPPORTED COSTS FOR ADMINISTRATION, ENGINEERING
AND CONSTRUCTION.  WE QUESTIONED $415,339 INELIGIBLE ENGINEERING
COSTS  INCURRED AFTER CONSTRUCTION COMPLETION DATE.

  EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN
MADE:  SINCE OVER $13 MILLION OF COSTS WERE QUESTIONED, EPA
PROVIDED THE CITY WITH ADDITIONAL TIME TO PROVIDE SUPPORTING
DOCUMENTATION.  ALSO, DUE TO RELATED LEGAL ISSUES, ASSISTANCE
WAS NECESSARY FROM THE OFFICE OF REGIONAL COUNSEL.

= DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION:
RESOLUTION CANNOT BE DETERMINED AT THIS TIME.

IG FOLLOWUP STATUS AS OF  3/31/95   [3]

E2BWL5-05-0136-7000980  SAUGET                      IL   3/31/87
 Sumnary:  WE QUESTIONED OVER $7 MILLION FOR INELIGIBLE AND
UNNECESSARY PROJECT COSTS.

  EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN
MADE:  THE REGIONAL OFFICE ISSUED A PROPOSED FINAL DETERMINATION
TO THE DIG ON 3/22/94.  ON 4/6/94, THE DIG AGREED WITH THE
PROPOSED ACTIONS ON ALL MATTERS EXCEPT DECISION TO ACCEPT THE
COSTS ASSOCIATED WITH THE TRANSFER SEWERAGE.  THE LOCAL DIG HAS
ELEVATED DISAGREEMENT TO HEADQUARTERS DIG.

  DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION:
RESOLUTION CANNOT BE DETERMINED AT THIS TIME.
 IG FOLLOWUP STATUS AS OF  3/31/95    [1]

 E2CUL2-23-0299-4100539  ALLOUEZ TWP
                            WI   9/22/94
CONSTRUCTION AND LAND ACQUISITION COSTS AND $127,798 INELIGIBLE
ARCHITECT/ENGINEERING (A/E) COSTS.  THE GRANTEE DID NOT ADJUST
ITS CLAIMS FOR $34,655 PRIOR AUDITED INELIGIBLE COST AND
UNSUPPORTED A/E COSTS OF $272,489.

  EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN
MADE:  RESOLUTION IS DELAYED PENDING PROGRAM RESPONSE BASED ON
PROJECT FILE INFORMATION.

= DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION:
RESOLUTION CANNOT BE DETERMINED AT THIS TIME.

IG FOLLOWUP STATUS AS OF  3/31/95   [1]
0AM Cost Advisory and Financial Analysis Division
Cost Review and Rate Negotiation Branch
D9BFL4-03-0338-4100352
 •Summary:
C.C. JOHNSON & MALHOTRA
MD   6/1/94
  EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN
MADE:  CONTRACTOR HAS OUTSTANDING BID AND PROPOSAL, AND STATE
TAX ISSUES TO BE RESOLVED BEFORE FINAL RATES CAN BE NEGOTIATED.
RESOLUTION TRANSFERRED TO EPA BY COGNIZANT AGENCY ON 3/8/95.
PRIOR COGNIZANT AGENCY USED QUICK CLOSEOUT PROCEDURES TO CLOSE
THEIR CONTRACT(S) AND DID NOT RESOLVE OUTSTANDING AUDIT ISSUES.
                ASSIGNMENT CONTROL
                NUMBER
                                                                                                TITLE
                                                     FINAL REPORT
                                                    	ISSUED
                                              DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION:
                                            RESOLUTION CANNOT BE DETERMINED AT THIS TIME.
                                            IG FOLLOWUP STATUS AS OF  3/31/95   [1]

                                            D9BKL3-04-0034-3100010  EHRT
                                             •Summary:
                                                                    KY   10/9/92
                                             EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN MADE:
                                            NEGOTIATIONS WERE SUSPENDED DUE TO OTHER MATTERS CONCERNING THE
                                            CONTRACTOR.   NEGOTIATIONS HAVE RESUMED.   THERE ARE MANY COMPLEX
                                            ISSUES  TO  BE RESOLVED  BUT A  NEGOTIATED SETTLEMENT CAN  BE REACHED.
                                            IT  IS DIFFICULT  TO CONTACT  AUTHORIZED REPRESENTATIVES.

                                             DESIRED  TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION:
                                            RESOLUTION ANTICIPATED BY MAY 1,  1995.
                                            IG  FOLLOWUP  STATUS AS OF   3/31/95   [1]
                                            E8DML3-04-0260-4100357
                                             •Summary:
                                                                    EHRT
                                                                    KY    6/2/94
                                             EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN MADE:
                                            NEGOTIATIONS  WERE  SUSPENDED  DUE TO OTHER MATTERS CONCERNING THE
                                            CONTRACTOR.   NEGOTIATIONS  HAVE  RESUMED.   THERE ARE MANY COMPLEX
                                            ISSUES  TO BE  RESOLVED BUT A NEGOTIATED SETTLEMENT  CAN BE REACHED.
                                            IT  IS DIFFICULT  TO CONTACT AUTHORIZED REPRESENTATIVES.

                                            = DESIRED TIMETABLE FOR  ACHIEVING A MANAGEMENT DECISION:
                                            RESOLUTION ANTICIPATED BY MAY  1,  1995.
                                            IG  FOLLOWUP  STATUS  AS  OF   3/31/95    [1]

                                            S5DGN2-09-0047-4300033 CA DEPT OF HLTH ICRP
                                             •Summary:
                                                                    CA    3/31/94
  EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN MADE:
THERE ARE COMPLEX ISSUES WHICH WILL TAKE MUCH DISCUSSION.  HOWEVER,
A NEGOTIATED SETTLEMENT IS POSSIBLE.

= DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION:  EXPECT
RESOLUTION BY 8/31/95.

IG FOLLOWUP STATUS AS OF  3/31/95   [1]

P8BMPO-23-0422-2400046  PEI ASSOC FY 90              OH   6/2/92
 •Summary:   WE QUESTIONED AS  INELIGIBLE $91,483 OF COSTS BILLED IN
EXCESS OF COSTS INCURRED UNDER VARIOUS EPA CONTRACTS.
ADDITIONALLY, THE 1990 INDIRECT RATES HAVE NOT BEEN NEGOTIATED AND
FINALIZED.

  EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN  MADE:
QUESTIONED DIRECT COSTS HAVE BEEN REFERRED TO  THE APPROPRIATE
CONTRACTING OFFICER.   HOWEVER, THE QUESTIONED DIRECT COSTS WILL NOT
BE RESOLVED UNTIL CLOSE OUT AUDITS ARE COMPLETE.  PER  DIG,  CLOSE
OUT AUDITS ARE IN PROGRESS.

= DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT  DECISION:
RESOLUTION CANNOT BE DETERMINED AT THIS TIME.

IG FOLLOWUP STATUS AS OF  3/31/95   [1]

P8BMP1-23-0335-2400073  PEI ASSOC FY 85              OH   9/9/92
 Summary:  THE REVIEW  FOUND $224,781 OF INELIGIBLE AND $195,886 OF
UNSUPPORTED COSTS.

  EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN MADE:
QUESTIONED DIRECT COSTS HAVE BEEN REFERRED TO  THE APPROPRIATE
CONTRACTING OFFICER.   HOWEVER, THE QUESTIONED DIRECT COSTS WILL NOT
BE RESOLVED UNTIL CLOSE OUT AUDITS ARE COMPLETE.  PER  DIG,  CLOSE
OUT AUDITS ARE IN PROGRESS.

= DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT  DECISION:
RESOLUTION CANNOT BE DETERMINED AT THIS TIME.

IG FOLLOWUP STATUS AS OF  3/31/95   [1]
   58
                                                                         OFFICE OF INSPECTOR GENERAL

-------
 ASSIGNMENT CONTROL
 NUMBER	
TITLE
                        FINAL REPORT
                              ISSUED
 P8BMP1-23-0339-3400050  PEI ASSOC  FY 89               OH     5/13/93
  Summary:  THE QUESTIONED COSTS DO NOT REFLECT AN  ADJUSTMENT  FOR
 INDIRECT COSTS.  INELIGIBLE COSTS OF $284,000 ARE  DUE  TO  AN
 INADEQUATE BILLING SYSTEM.  UNSUPPORTED COSTS OF $530,000 WERE
 DUE TO INTER-COMPANY TRANSFERS.

   EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS  NOT  BEEN
 MADE:  QUESTIONED DIRECT COSTS HAVE BEEN REFERRED  TO  THE
 APPROPRIATE CONTRACTING OFFICER.  HOWEVER, THE QUESTIONED DIRECT
 COSTS WILL NOT BE RESOLVED UNTIL CLOSE OUT AUDITS  ARE  COMPLETE.
 PER OIG, CLOSE OUT AUDITS ARE  IN PROGRESS.

   DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION:
 RESOLUTION CANNOT BE DETERMINED AT THIS TIME.

 IG FOLLOWUP STATUS AS OF  3/31/95    [1]

 P8BMPO-23-0175-3400053  PEI ASSOC FY 86             OH    5/14/93
  Summary:  WE HAVE QUESTIONED  INELIGIBLE $940,755, 53  PERCENT
 WAS DUE TO COST BILLED IN EXCESS OF WHAT WAS  INCURRED.  THE
 REMAINING 47 PERCENT WAS THE ADJUSTMENT OF INDIRECT RATES TO
 ACTUAL.

   EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS  NOT  BEEN
 MADE: QUESTIONED DIRECT COSTS  HAVE BEEN REFERRED TO THE
 APPROPRIATE CONTRACTING OFFICER.  HOWEVER, THE QUESTIONED DIRECT
 COSTS WILL NOT BE RESOLVED UNTIL CLOSE OUT AUDITS  ARE  COMPLETE.
 PER OIG, CLOSE OUT AUDITS ARE  IN PROGRESS.

   DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION:
 RESOLUTION CANNOT BE DETERMINED AT THIS TIME.

 IG FOLLOWUP STATUS AS OF  3/31/95    [1]

 P8BMPO-23-0177-3400062     PEI ASSOC FY 87/88       OH    6/14/93
  Summary:  WE QUESTIONED AS INELIGIBLE $759,941 OF COST BILLED
 BUT NOT  INCURRED.  WE ALSO QUESTIONED AS UNSUPPORTED  $1,224,486,
 48 PERCENT OF WHICH WAS DUE TO USING CATALOG PRICES.   COSTS WERE
 NOT ADJUSTED FOR AUDITED INDIRECT RATES.

   EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS  NOT  BEEN
 MADE:  QUESTIONED DIRECT COSTS HAVE BEEN REFERRED  TO  THE
 APPROPRIATE CONTRACTING OFFICER.  HOWEVER, THE QUESTIONED DIRECT
 COSTS WILL NOT BE RESOLVED UNTIL CLOSE OUT AUDITS  ARE  COMPLETE.
 PER OIG, CLOSE OUT AUDITS ARE  IN PROGRESS.  UNSUPPORTED COST  IN
 THE AMOUNT OF $626,555 HAVE BEEN RESOLVED UNDER CONTRACT  NO.
 68-01-7084.

   DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION:
 RESOLUTION CANNOT BE DETERMINED AT THIS TIME.

 IG FOLLOWUP STATUS AS OF  3/31/95   [1]
ASSIGNMENT CONTROL
NUMBER
                                                                    TITLE
 FINAL REPORT
	ISSUED
 0AM Cost Advisory and Financial Analysis Division
 Financial Analysis Branch

 P9CGL2-02-0283-4100397  ECOLOGY & ENVIR             NY   6/9/94
 •Summary:  THE CONTRACT CLAIMED $2,399,182 AS ALLOWABLE COSTS
 OF WHICH WE QUESTIONED $62,711  AS UNALLOWABLE.

  EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN
 MADE:  NEGOTIATION POSITION FOR DIRECT COSTS HAS BEEN
 ESTABLISHED AND NEGOTIATIONS ARE CONTINUING.  NEGOTIATIONS BY
 THE COST POLICY AND RATE NEGOTIATION BRANCH FOR SETTLEMENT OF
 THE 89-90 INDIRECT RATES ARE IN PROCESS.

  DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION:
 RESOLUTION CANNOT BE DETERMINED AT THIS TIME.

 IG FOLLOWUP STATUS AS OF  3/31/95   [1]

P8BMN1-03-0146-2300014  O&R MANAGEMENT CORPORATION  MD   11/5/91
 Summary:   WE QUESTIONED $557,442 OF OTHER DIRECT COSTS.  ONE
HUNDRED  PERCENT OF THE CONTRACT WAS QUESTIONED BECAUSE O&R DID
NOT  MAINTAIN  RECORDS.
                                         EXPLANATION OF  THE REASONS MANAGEMENT DECISION HAS NOT BEEN MADE:
                                       RESOLUTION HAS BEEN DELAYED DUE TO THE COMPANY NO LONGER  BEING  IN
                                       BUSINESS.  THE CONTRACTING OFFICER WROTE A DECISION ON  DISALLOWANCE
                                       OF COST CLAIMED BY CONTRACTOR IN AUDIT REPORT.  FURTHER ACTION  IS
                                       DEPENDENT ON THE OUTCOME OF AN OIG  INVESTIGATION WHICH IS  IN
                                       PROCESS.

                                         DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT  DECISION:
                                       RESOLUTION EXPECTED BY 4/30/95.

                                       IG FOLLOWUP STATUS AS OF  3/31/95    [1]

                                       D9BKL2-03-0599-4100295  KEYDATA SYSTEMS INC         VA   5/18/94
                                        Summary:  DCAA QUESTIONED 233,278 OF  COSTS  INCURRED.  DCAA ALSO
                                       CONSIDERS $431,395 TO BE EXCESS COSTS  BILLED  TO EPA.

                                         EXPLANATION OF  THE REASONS MANAGEMENT DECISION  HAS NOT BEEN MADE:
                                       CONTRACTING OFFICER CANNOT RESPOND TO  AUDIT  REPORT SINCE THE
                                       CONTRACTOR IS UNDER AN OIG INVESTIGATION.  CLAIM HAS BEEN  FILED
                                       WITH DEPARTMENT OF INTERIOR BOARD OF CONTRACT APPEALS.  WE ARE
                                       AWAITING INVESTIGATION RESULTS TO PROCEED WITH  INTERIOR BOARD OF
                                       CONTRACT APPEALS CASE AND AUDIT RESOLUTION.

                                         DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION:
                                       RESOLUTION CANNOT BE DETERMINED AT THIS TIME.
                                       IG FOLLOWUP STATUS AS OF  3/31/95   [1]

                                       D8CML4-05-0019-4100246  TRIAD ENG FY 92/93
                                        *Summary:
                                                   WI
                                                         4/12/94
                                         EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN MADE:
                                       ORIGINAL ACTION OFFICE DID NOT TRANSMIT  REPORT TO CURRENT ACTION
                                       OFFICIAL FOR RESOLUTION UNTIL  MARCH  1995.  REPORT WAS TRANSMITTED
                                       TO THE APPROPRIATE CONTRACTING OFFICER FOR RESOLUTION ON 3/15/95
                                       WHO IS CURRENTLY NEGOTIATING WITH CONTRACTOR.

                                         DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION:
                                       RESOLUTION EXPECTED BY 4/30/95.

                                       IG FOLLOWUP STATUS AS OF  3/31/95   [1]

                                       P9BGL4-10-0083-4100309  CH2M REM  IV  87-89 C.I.       OR    5/19/94
                                        Summary:  INELIGIBLE/UNSUPPORTED COSTS  CONSIST OF:   $408,618 IN
                                       DIRECT LABOR,  $3,254,566 IN TRAVEL,  $3,458,995 IN OTHER DIRECT
                                       COSTS, $2,292,817 IN OVERHEAD  AND $3,333 IN LABORATORY SERVICES.

                                         EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN MADE:
                                       OIG IS REVIEWING CONTRACTOR'S RESPONSE TO THE  AUDIT AND ADDITIONAL
                                       SUPPORTING DOCUMENTATION PROVIDED BY THE  CONTRACTOR.  NEGOTIATIONS
                                       WILL COMMENCE  WHEN SUPPLEMENTAL REPORT  IS ISSUED.

                                         DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION:
                                       RESOLUTION CANNOT BE DETERMINED AT THIS  TIME.

                                       IG FOLLOWUP STATUS AS OF  3/31/95   [1]

                                       P9BGL4-10-0107-4100398  CH2M REM/FIT 87-89 C.I.      CA    6/10/94
                                        Sumnary:  NET  COSTS  QUESTIONED OF $173,335 CONSIST OF INELIGIBLE
                                       OVERTIME COSTS  OF $20,178,  INELIGIBLE MOVING COSTS OF $8,323,
                                       INELIGIBLE PUBLICATIONS COSTS  OF  $128, INELIGIBLE OVERHEAD CREDIT
                                       OF $3,045, UNSUPPORTED TRAVEL  COSTS OF  $16,027, AND UNSUPPORTED
                                       COMPUTER COSTS  OF $131,724.

                                         EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN MADE:
                                       OIG IS REVIEWING CONTRACTOR'S RESPONSE TO THE  AUDIT AND ADDITIONAL
                                       SUPPORTING DOCUMENTATION PROVIDED BY THE  CONTRACTOR.  NEGOTIATIONS
                                       WILL COMMENCE  WHEN SUPPLEMENTAL REPORT  IS ISSUED.

                                         DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION:
                                       RESOLUTION CANNOT BE DETERMINED AT THIS  TIME.

                                       IG FOLLOWUP STATUS AS OF  3/31/95   [1]

                                       P9BGL4-10-0117-4100417  CH2M TECH 1  C. I .  1987-88     OR   6/22/94
                                        Summary:  NET  COSTS QUESTIONED OF $212,587 CONSIST  OF  INELIGIBLE
                                       OVERTIME LABOR  OF $7,754,  UNSUPPORTED TRAVEL COSTS OF $108,035,
   OCTOBER 1, 1994 THROUGH MARCH 31, 1995
                                                                                                                       59

-------
ASSIGNMENT CONTROL
NUMBER	
TITLE
 FINAL REPORT
	ISSUED
UNSUPPORTED COMPUTER COSTS OF $115,975, AND INELIGIBLE OVERHEAD
CREDIT OF $19,177.

  EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN
MADE:  DIG IS REVIEWING CONTRACTOR'S RESPONSE TO THE AUDIT AND
ADDITIONAL SUPPORTING DOCUMENTATION PROVIDED BY THE CONTRACTOR.
NEGOTIATIONS WILL COMMENCE WHEN SUPPLEMENTAL REPORT IS ISSUED.

  DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION:
RESOLUTION CANNOT BE DETERMINED AT THIS TIME.

IG FOLLOWUP STATUS AS OF  3/31/95   [1]

P9BGL4-10-0124-4100436 CH2M ARCS V C.I. 1988 & 89   OR   6/29/94
 Summary:  NET COSTS QUESTIONED OF $322,262 CONSIST OF INELIGIBLE
OVERTIME LABOR OF $5,417, INELIGIBLE OVERHEAD CREDIT OF $32,857,
UNSUPPORTED TRAVEL COSTS OF $144,373,  AND UNSUPPORTED COMPUTER
COSTS OF $205,329.

  EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN
MADE:  DIG IS REVIEWING CONTRACTOR'S RESPONSE TO THE AUDIT AND
ADDITIONAL SUPPORTING DOCUMENTATION PROVIDED BY THE CONTRACTOR.
NEGOTIATIONS WILL COMMENCE WHEN SUPPLEMENTAL REPORT IS ISSUED.

= DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION:
RESOLUTION CANNOT BE DETERMINED AT THIS TIME.

IG FOLLOWUP STATUS AS OF  3/31/95   [1]

D9BGL3-10-0088-4100471     URS   FY 1989  AC        WA   8/2/94
 •Summary:  THE AUDITOR QUESTIONED $15,725 OF DIRECT COSTS ON
EPA CONTRACT NOS. 68-W9-0053 AND 68-W9-0054.  THE QUESTIONED
COSTS ARE DUE TO AUDIT EXCEPTIONS TO THE ALLOCATION OF INTERNAL
SERVICES COSTS.

  EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN
MADE:  SETTLEMENT OF INDIRECT COST ISSUES WILL BE HANDLED BY THE
DEPARTMENT OF DEFENSE ADMINISTRATIVE CONTRACTING OFFICER.  THE
EPA CONTRACTING OFFICER WILL RESOLVE THE DIRECT COST ISSUES BY
OBTAINING CREDITS ON THE CONTRACTS.  THE CREDIT ON ONE OF THE
TWO CONTRACTS HAS BEEN NEGOTIATED.

  DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION:
RESOLUTION CANNOT BE DETERMINED AT THIS TIME.

IG FOLLOWUP STATUS AS OF  3/31/95   [2]

P9BGL4-10-0129-4100489  CH2M TECH II C.I. 1988-89   OR   8/16/94
 Summary:  NET COSTS QUESTIONED OF $92,160 CONSIST OF INELIGIBLE
OVERTIME LABOR OF $2,507, UNSUPPORTED  TRAVEL COSTS OF $40,650,
UNSUPPORTED COMPUTER COSTS OF $69,820,  AND INELIGIBLE OVERHEAD
CREDIT OF $20,817.

  EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN
MADE:  DIG IS REVIEWING CONTRACTOR'S RESPONSE TO THE AUDIT AND
ADDITIONAL SUPPORTING DOCUMENTATION PROVIDED BY THE CONTRACTOR.
NEGOTIATIONS WILL COMMENCE WHEN SUPPLEMENTAL REPORT IS ISSUED.

  DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION:
RESOLUTION CANNOT BE DETERMINED AT THIS TIME.

IG FOLLOWUP STATUS AS OF  3/31/95   [1]

P9BGL4-10-0132-4100512  CH2M ARCS WEST  1989 COSTS   OR   8/30/94
 •Summary:

  EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN
MADE:  DIG IS REVIEWING CONTRACTOR'S RESPONSE TO THE AUDIT AND
ADDITIONAL SUPPORTING DOCUMENTATION PROVIDED BY THE CONTRACTOR.
NEGOTIATIONS WILL COMMENCE WHEN SUPPLEMENTAL REPORT IS ISSUED.

= DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION:
RESOLUTION CANNOT BE DETERMINED AT THIS TIME.

IG FOLLOWUP STATUS AS OF  3/31/95   [1]
                                       ASSIGNMENT  CONTROL
                                       NUMBER
                                                                   TITLE
FINAL REPORT
      ISSUED
                                       P9BGL4-10-0149-4100560  CH2M ARCS VI  1988 & 89 COSTS  OR  9/26/94
                                        Summary:  UNSUPPORTED COSTS OF $157,000 CONSIST OF TRAVEL COSTS OF
                                       $76,000 AND  COMPUTER  COSTS  OF $81,000.

                                        EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN MADE:
                                       DIG  IS REVIEWING CONTRACTOR'S RESPONSE TO THE  AUDIT AND ADDITIONAL
                                       SUPPORTING DOCUMENTATION PROVIDED BY THE  CONTRACTOR.  NEGOTIATIONS
                                       WILL COMMENCE  WHEN  SUPPLEMENTAL  REPORT  IS ISSUED.

                                        DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION:
                                       RESOLUTION CANNOT BE  DETERMINED  AT THIS  TIME.

                                       IG FOLLOWUP  STATUS  AS OF 3/31/95   [1]

                                       P9BGL4-10-0147-4100566   CH2M ARCS  III 1988-89 COSTS  OR   9/28/94
                                        Summary:  UNSUPPORTED COSTS OF $115,000 CONSIST OF TRAVEL COSTS OF
                                       $42,000 AND COMPUTER COSTS OF $73,000.  INELIGIBLE COSTS OF $4,000
                                       CONSIST OF OVERHEAD COSTS.

                                        EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN MADE:
                                       DIG  IS REVIEWING CONTRACTOR'S RESPONSE TO THE  AUDIT AND ADDITIONAL
                                       SUPPORTING DOCUMENTATION PROVIDED BY THE  CONTRACTOR.  NEGOTIATIONS
                                       WILL COMMENCE  WHEN  SUPPLEMENTAL  REPORT  IS ISSUED.

                                       = DESIRED TIMETABLE FOR ACHIEVING A  MANAGEMENT DECISION:
                                       RESOLUTION CANNOT BE  DETERMINED  AT THIS  TIME.
                                       IG  FOLLOWUP  STATUS AS OF  3/31/95    [1]

                                       P9AHN9-23-0347-0300036  OH MATERIALS (PR EQ RATES)
                                       Summary:  (PREAWARD AUDIT UNDER NEGOTIATION)
                                                                    OH   3/27/90
                                        EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN MADE:
                                      NEGOTIATIONS ARE CONTINUING.   CONTRACTOR  HAS SUBMITTED A COUNTER
                                      OFFER.

                                        DESIRED TIMETABLE FOR ACHIEVING A  MANAGEMENT DECISION:
                                      RESOLUTION SCHEDULED TO BE COMPLETED BY 9/30/95.

                                      IG  FOLLOWUP STATUS AS OF  3/31/95    [1]
                                      P9AHN1-23-0143-2300024  OHM REM ERCS2 Z1  FY 89
                                       •Summary:   (PREAWARD AUDIT UNDER  NEGOTIATION)
                                                                   OH   12/27/91
                                        EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN MADE:
                                      NEGOTIATIONS ARE CONTINUING.

                                        DESIRED TIMETABLE FOR ACHIEVING A  MANAGEMENT DECISION:
                                      RESOLUTION EXPECTED BY 9/30/95.

                                      IG FOLLOWUP STATUS AS OF  3/31/95    [1]

                                      P9AHP2-23-0021-4400002  OHM REM ERCS2 Z1 FY 90 EQ    OH   10/7/93
                                       •Summary:  (PREAWARD AUDIT UNDER NEGOTIATION)

                                        EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN MADE:
                                      NEGOTIATIONS ARE CONTINUING ON CONTRACT NO.  68-01-7445.

                                      = DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT  DECISION:  EXPECTED
                                      TO BE CONCLUDED BY 9/30/95.

                                      IG FOLLOWUP STATUS AS OF  3/31/95    [1]
                                      0AM Cost Advisory &  Financial Analysis  Division
                                      Washington Cost Advisory Branch

                                      D8AMN3-01-0266-4300007  ABT ASSOCIATES              MA   11/15/93
                                       •Summary:  (PREAWARD AUDIT UNDER NEGOTIATION)

                                        EXPLANATION OF THE  REASONS MANAGEMENT DECISION HAS NOT BEEN MADE:
                                      AWARD OF THIS CONTRACT WAS PLANNED  FOR  EARLY  NOVEMBER 1994
                                      CONTRACTOR WAS UNSUCCESSFUL BIDDER.   CONTRACT IS  CURRENTLY~UNDER
                                      PROTEST BY THE CONTRACTOR.
   60
                                                                    OFFICE OF INSPECTOR GENERAL

-------
ASSIGNMENT CONTROL
NUMBER	
TITLE
 FINAL  REPORT
	ISSUED
  DESIRED  TIMETABLE  FOR  ACHIEVING A MANAGEMENT DECISION:
RESOLUTION  CANNOT BE DETERMINED  AT THIS TIME.
                                       ASSIGNMENT CONTROL
                                       NUMBER
                                                                    TITLE
FINAL REPORT
      ISSUED
IG FOLLOWUP  STATUS AS  OF   3/31/95    [1]

D9AFL4-02-0173-4100515  FOSTER  WHEELER USA CORP
 *Summary:   (PREAWARD  AUDIT  UNDER  NEGOTIATION)
                         NJ   9/8/94
  EXPLANATION  OF  THE  REASONS  MANAGEMENT DECISION HAS NOT BEEN
MADE:   CONTRACT STILL IN  THE  NEGOTIATION PROCESS.  A SUMMARY OF
NEGOTIATIONS WILL  BE  PROVIDED TO THE DIG IF THE OFFEROR IS THE
SUCCESSFUL  BIDDER.

  DESIRED  TIMETABLE  FOR ACHIEVING A MANAGEMENT DECISION:
PROJECTED  AWARD AND  NEGOTIATIONS ARE EXPECTED TO BE COMPLETED BY
JUNE 1995.

IG FOLLOWUP STATUS AS OF   3/31/95   [1]

D8BML4-03-0345-4100343 PRC,  INC.                   VA   6/ 1/94
 *Summary:   DCAA  QUESTIONED  ($45.71) FOR 1991 AND ($3,322.96)
FOR 1992.

  EXPLANATION  OF  THE  REASONS  MANAGEMENT DECISION HAS NOT BEEN
MADE:   THE SUBJECT AUDIT  IS  STILL BEING NEGOTIATED.  A SUMMARY
OF NEGOTIATIONS WILL  BE FORWARDED TO THE DIG IF THE OFFEROR IS
THE SUCCESSFUL BIDDER.

  DESIRED  TIMETABLE  FOR ACHIEVING A MANAGEMENT DECISION:
RESOLUTION EXPECTED  TO BE COMPLETED BY NOVEMBER 1995.
 IG FOLLOWUP STATUS  AS  OF   3/31/95   [1]

 D9AFL4-03-0453-4100506 AE ENVIRONMENTAL SERVICES
  Summary:   (PREAWARD AUDIT UNDER NEGOTIATION)
  EXPLANATION OF  THE  REASONS MANAGEMENT DECISION HAS NOT BEEN
 MADE:  NEGOTIATIONS ON  THE  SUBJECT AUDIT ARE CONTINUING.  A
 SUMMARY OF NEGOTIATIONS WILL BE PROVIDED TO THE DIG IF THE
 OFFEROR IS THE SUCCESSFUL  BIDDER.

  DESIRED TIMETABLE FOR ACHIEVING  A MANAGEMENT DECISION:  THE
 PROJECTED CONTRACT DEFINITIZATION  DATE IS JUNE 1995.
 IG FOLLOWUP STATUS  AS  OF   3/31/95   [1]

 D9AKL4-03-0450-4100536  ROY  F.  WESTON
 *Summary:   (PREAWARD  AUDIT  UNDER NEGOTIATION)
                       PA   9/22/94
  EXPLANATION OF  THE  REASONS MANAGEMENT DECISION HAS NOT BEEN
MADE:  THE RESULTS  OF THE  SUBJECT AUDIT ARE STILL BEING
NEGOTIATED.   THE  DIG  WILL  BE PROVIDED WITH A SUMMARY OF
NEGOTIATIONS IF THE OFFEROR  IS THE SUCCESSFUL BIDDER.

  DESIRED TIMETABLE FOR  ACHIEVING A MANAGEMENT DECISION:
RESOLUTION EXPECTED BY JUNE  1995.
 IG FOLLOWUP STATUS  AS  OF   3/31/95   [1]

 E9AKP4-05-0291-4400117 PRC  EMI  (R3 SATA)
 *Summary:   (PREAWARD  AUDIT  UNDER NEGOTIATION)
                       IL   9/30/94
  EXPLANATION  OF  THE  REASONS MANAGEMENT DECISION HAS NOT BEEN
MADE:  NEGOTIATIONS ARE  CONTINUING ON THE SUBJECT AUDIT.
PROGRAM WILL PROVIDE  THE DIG WITH SUMMARY OF NEGOTIATIONS IF THE
OFFEROR IS THE SUCCESSFUL BIDDER.

  DESIRED  TIMETABLE FOR  ACHIEVING A MANAGEMENT DECISION:  THE
CONCLUSION OF  NEGOTIATIONS AND  CONTRACT AWARD IS ANTICIPATED FOR
JUNE 1995.
IG FOLLOWUP  STATUS  AS  OF   3/31/95   [1]

D8AML4-06-0039-4100101   FTN  ASSOCIATES LTD
 Summary:   (PREAWARD AUDIT UNDER NEGOTIATION)
                 EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN MADE:
               THIS AUDIT REPORT  IS CURRENTLY UNDER NEGOTIATIONS.  A COPY OF THE
               SUMMARY OF NEGOTIATIONS  WILL  BE  SENT  TO THE DIG IF FTN IS THE
               SUCCESSFUL OFFEROR.

                 DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION:  AN AWARD
               OF THIS COMPETITIVE  PROCUREMENT  WILL  NOT TAKE  PLACE UNTIL JUNE
               1995.
                                       IG FOLLOWUP STATUS AS OF  3/31/95    [1]

                                       D8AML4-07-0077-4100499  DPRA INCORPORATED
                                        *Summary:  (PREAWARD AUDIT UNDER NEGOTIATION)
                                                                    KS   8/24/94
                                         EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN MADE:
                                       CONTRACTOR WAS UNSUCCESSFUL OFFEROR.  CONTRACT WAS AWARDED  TO ABT
                                       ASSOCIATES ON 9/30/94.

                                         DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT  DECISION:
                                       RESOLUTION IS EXPECTED SHORTLY.
                                       IG FOLLOWUP STATUS AS OF  3/31/95    [1]

                                       P9AGL2-10-0089-4100225     CH2M ARCS IV TERM STLMT
                                        Summary:  (PREAWARD AUDIT UNDER NEGOTIATION)
                                                                    OR   3/28/94
                                         EXPLANATION OF THE REASONS MANAGEMENT DECISION  HAS NOT BEEN MADE:
                                       RESPONSE FAXED AND MAILED  TO OIG ON 9/15/94. THE AUDIT WILL NOT BE
                                       NEGOTIATED UNTIL MAY 15,  1995.

                                         DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION:
                                       RESOLUTION CANNOT BE DETERMINED AT THIS TIME.
                       WV   8/25/94    IG FOLLOWUP STATUS AS OF  3/31/95    [1]
               P9CGL2-10-0127-4100226  CH2M REGION IV ARCS          OR   3/29/94
                Summary:  CH2M CLAIMED $73,895 OF UNSUPPORTED COMPUTER COSTS.
               $69,559 OF UNSUPPORTED COSTS RELATED TO THE RED-PENN WORK
               ASSIGNMENT, AND $6,199 OF  INELIGIBLE INDIRECT COSTS.

                 EXPLANATION OF THE REASONS MANAGEMENT DECISION  HAS NOT BEEN MADE:
               THE PROGRAM RESPONDED TO THE  OIG ON 9/15/94 VIA FAX AND A COPY  WAS
               SENT TO THE OIG.  NEGOTIATIONS WILL NOT BE COMPLETE UNTIL  MAY  15,
               1995.

                 DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION:
               RESOLUTION CANNOT BE DETERMINED AT THIS TIME.

               IG FOLLOWUP STATUS AS OF   3/31/95    [1]
               Office of the Administrator

               E1SFE3-07-0101-4100522  FMFIA CAPPING, OSWER,  WATER        9/16/94
                •Summary:  THE AGENCY DID NOT ADEQUATELY IMPLEMENT  THE  INTEGRITY
               ACT.  THE AGENCY CHANGED  ITS  PROCESS  TO  ELIMINATE UNNECESSARY
               PAPERWORK TO MAKE THE PROCESS  MORE USEFUL.  MANAGERS' TRAINING AND
               KNOWLEDGE OF CONTROLS ARE STILL A CONCERN.

                 EXPLANATION OF THE  REASONS MANAGEMENT DECISION HAS  NOT BEEN MADE:
               THE PROGRAM OFFICE IS REVIEWING THE  OIG'S 2/13/95 COMMENTS ON EPA
               MANAGEMENT'S RESPONSE OF  12/28/94.  THE  PROGRAM  IS  PREPARING A
               FORMAL WRITTEN REPLY, EXPECTED TO BE ISSUED BY 4/30/95, TO CLARIFY
               EPA MANAGEMENT'S POSITION AND  PROVIDE ADDITIONAL  INFORMATION ON
               THOSE SPECIFIC  RECOMMENDATIONS CITED  BY  OIG TO SUPPORT ORIGINAL
               RESPONSE.

                 DESIRED TIMETABLE  FOR ACHIEVING A MANAGEMENT DECISION:
               RESOLUTION CANNOT BE DETERMINED AT THIS  TIME.

               IG FOLLOWUP STATUS AS OF  3/31/95    [2]
                       TX  12/2/93     Regional Administrator - Region 1

                                       S2CWL1-01-0024-4100179  SPRINGFIELD                 MA    1/31/94
                                        Surtinary:  THE CITY  OF SPRINGFIELD, MA CLAIMED UNALLOWABLE PROJECT
   OCTOBER 1, 1994 THROUGH MARCH 31, 1995
                                                                                          61

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ASSIGNMENT CONTROL
NUMBER
                             TITLE
 FINAL REPORT
       ISSUED
COSTS OF $4,059,671 FOR THE CONSTRUCTION OF A SECONDARY SEWAGE
TREATMENT PLANT, INCLUDING NEW INTERCEPTER SEWERS, PUMPING
STATIONS, FORCE MAIN SIPHON, AND OUTFALL SEWER.

  EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN
MADE:  THE REGION  IS MEETING WITH THE CITY'S CONSULTANT ON A
BIWEEKLY BASIS TO  REVIEW $4,060,000 IN QUESTIONED COSTS.  THE
PROPOSED FINAL DETERMINATION LETTER WAS SENT TO THE OIG ON
MARCH 3, 1995.

  DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION:
RESOLUTION CANNOT  BE DETERMINED AT THIS TIME.
ASSIGNMENT CONTROL
NUMBER
                                                                                                 TITLE
FINAL REPORT
      ISSUED
 IG  FOLLOWUP STATUS AS OF  3/31/95    [2]

 E2CWL1-01-0136-4100576  MWRA
 *Summary:
MA   9/29/94
   EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN
MADE:  EPA  IS WAITING ON THE STATE AGENCY TO PROVIDE ADDITIONAL
INFORMATION  IN ORDER TO COMPLETE THE REVIEW OF THIS AUDIT.

   DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION:  THE
FINAL DETERMINATION LETTER IS EXPECTED TO BE COMPLETED BY
APRIL 30, 1995.

IG FOLLOWUP  STATUS AS OF  3/31/95   [1]

E2CWL2-01-0029-4100578  MASS WATER RESOURCES AUTH   MA   9/29/94
  Summary:   TOTAL INELIGIBLE COSTS OF $199,984 QUESTIONED FOR
GRANT FUNDS  USED FOR OPERATION AND MAINTENANCE WORK; WORK
PERFORMED BEYOND THE SCOPE OF THE PROJECT AND OTHER INELIGIBLE
ITEMS.

   EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN
MADE:  THE  FINAL DETERMINATION LETTER WAS SENT TO THE GRANTEE
ON MARCH 30, 1995.

=  DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION:  THE
OIG CLOSED THIS AUDIT ON APRIL 5, 1995.

IG FOLLOWUP  STATUS AS OF  3/31/95   [3]
Regional Administrator - Region 2

P2CWL1-02-0104-3100374  NYCDEP                    ' NY   9/14/93
 Summary:  THE CITY OF NEW YORK, NEW YORK CLAIMED UNALLOWABLE
PROJECT COSTS OF $65,169,354 FOR THE CONSTRUCTION OF THE NORTH
RIVER SEWAGE TREATMENT PLANT AND A RECREATIONAL PARK.

  EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN
MADE:  THIS MEGA-AUDIT INCLUDED 6 EPA GRANTS WITH TOTAL GRANTEE
CLAIMED COSTS OF $683 MILLION AND AUDITOR QUESTIONED COSTS OF
$50 MILLION.  BECAUSE OF THE MAGNITUDE OF THIS OVERALL
CONSTRUCTION PROJECT, WHICH COVERED 16 YEARS (1977-1992), VERY
EXTENSIVE STAFF TIME AND EFFORT ARE REQUIRED TO RESOLVE THESE
ISSUES.
  DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION:
FINAL RESOLUTION IS JUNE 1995.

IG FOLLOWUP STATUS AS OF  3/31/95   [3]
P2CWN1-02-0028-4300034  OCEAN COUNTY UA             NJ   5/4/94
 Summary:  THE GRANTEE CLAIMED UNALLOWABLE COSTS OF $4,513,658
CONSISTING OF INELIGIBLE COSTS OF $3,057,931 (FEDERAL SHARE
$2,144,016) AND UNSUPPORTED COSTS OF $1,455,727 (FEDERAL SHARE
$883,541) FOR CONSTRUCTION OF SECONDARY WASTEWATER TREATMENT
FACILITIES AND APPEARANCES.

  EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN
MADE:  THIS AUDIT ENCOMPASSED 5 EPA GRANTS WITH TOTAL GRANTEE
CLAIMED COSTS OF $247 MILLION AND AUDITOR QUESTIONED COSTS OF
$4.5 MILLION.  THE ONGOING REGIONAL REVIEW IS ENSURING THAT ALL
                ISSUES HAVE BEEN FULLY EVALUATED,  ANALYZED, AND THAT THE GRANTEE
                IS GIVEN  FULL OPPORTUNITY TO SUBMIT ADDITIONAL SUPPORTING
                DOCUMENTATION.

                  DESIRED TIMETABLE FOR ACHIEVING  A MANAGEMENT DECISION:  TARGET
                FINAL  RESOLUTION IS MAY 1995.

                IG FOLLOWUP STATUS AS OF  3/31/95    [1]
Regional Administrator - Region 3

P2BWN3-03-0077-4300032  PHILADELPHIA CITY OF         PA    3/30/94
 Surmary:  THE CITY OF PHILADELPHIA CLAIMED $10,959,010  OF
INELIGIBLE FORCE ACCOUNT, ENGINEERING, CONSTRUCTION  AND  INDIRECT
COSTS.  AN ADDITIONAL $32,663,495 OF UNSUPPORTED  AND $794,684 OF
UNNECESSARY COSTS WERE ALSO QUESTIONED.

  EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN MADE:
THE SIZE AND  COMPLEXITY OF THIS MEGA-AUDIT (WHICH INCLUDES SEVERAL
GRANTS) WILL REQUIRE SIGNIFICANT TIME TO RESOLVE.

  DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT-DECISION:  THE
TARGET DATE FOR ISSUANCE OF A MANAGEMENT DECISION  IS 9/30/95.

IG FOLLOWUP STATUS AS OF  3/31/95   [1]

P2CWN2-03-0456-4300043  HOWARD COUNTY  DPW           MD    8/23/94
 Summary:  COSTS OF $1.5 MILLION WERE DETERMINED  INELIGIBLE
PRIMARILY BECAUSE  THE  GRANTEE  CLAIMED ARCHITECT/ENGINEERING  COSTS
IN EXCESS OF  GRANT CEILINGS  AND  COSTS  INCURRED AFTER  THE  APPROVED
COMPLETION DATES.

  EXPLANATION OF THE REASONS MANAGEMENT  DECISION HAS NOT BEEN  MADE:
AT CONGRESSIONAL REQUEST, FINAL MANAGEMENT DECISION  HAS  BEEN
DELAYED UNTIL A MEETING IS  HELD  WITH THE  GRANTEE AND  THE  STATE TO
DISCUSS THE AUDIT  FINDINGS.   THE GRANTEE  AND  STATE MET ON 4/4/95.
EPA MAY MEET  AGAIN AT THE END OF APRIL 1995.

= DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION: ESTIMATED
MANAGEMENT DECISION DATE IS 5/30/95.

IG FOLLOWUP STATUS AS OF  3/31/95   [1]

P2CWN3-03-0031-4300045  ARLINGTON COUNTY             VA    9/1/94
 Summary:  ARLINGTON COUNTY, VA CLAIMED $1.9 MILLION OF INELIGIBLE
COSTS INCLUDING $360,000  FOR A HEAT RECOVERY SYSTEM THAT WAS  NEVER
UTILIZED.

  EXPLANATION OF THE REASONS MANAGEMENT  DECISION HAS NOT BEEN  MADE:
THE OIG CHANGED (REDUCED THE DOLLAR AMOUNT) SOME OF  THE  CONTRACT
AUDITOR'S FINDINGS PRIOR TO ISSUANCE OF THE FINAL  AUDIT  REPORT,
WHILE NOT SPECIFYING WHICH  FINDINGS WERE  AFFECTED BY  THE  CHANGES.
AT A MEETING  HELD  3/8/95, THE  OIG AGREED  TO SPECIFY EXACTLY  WHICH
OF THE FINDINGS IN THE AUDIT REPORT WERE AFFECTED.
                = DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION:
                MANAGEMENT DECISION  DATE  IS  4/30/95.
                                                        ESTIMATED
      TARGET    IG  FOLLOWUP  STATUS AS OF   3/31/95    [1]
                E6FHG4-03-0266-4400110  REGIONAL VEHICLE ASSIGNMENT       9/22/94
                *Summary:   BASED ON  ACTUAL  USAGE,  THE ASSIGNMENT OF VEHICLES TO
                REGION 3 SUPERFUND ON-SCENE COORDINATORS ON A FULL-TIME BASIS WAS
                NOT ALWAYS  JUSTIFIED.

                 EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN MADE:
                AWAITING RESPONSE FROM  REGIONAL  PROGRAM OFFICE AS OF 3/31/95.

                 DESIRED TIMETABLE FOR ACHIEVING  A MANAGEMENT DECISION:
                RESOLUTION  CANNOT BE  DETERMINED  AT THIS TIME.

                IG  FOLLOWUP STATUS AS OF   3/31/95    [5]
   62
                                             OFFICE OF INSPECTOR GENERAL

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ASSIGNMENT  CONTROL
NUMBER	
TITLE
                        FINAL REPORT
                              ISSUED
Regional Administrator - Region 4

E2CWM3-04-0062-4200019  KEY WEST                     FL    9/15/94
 Sumrary:  WE  QUESTIONED THE $1,017,608 DESIGN ALLOWANCE CLAIMED
BY THE GRANTEE BECAUSE IT DUPLICATED THE STEP 2 DESIGN GRANT WHICH
UAS AWARDED FOR THE SAME PURPOSE.

  EXPLANATION  OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN
MADE: STATE OF FLORIDA IS SEARCHING FOR ADDITIONAL INFORMATION
WHICH MAY HELP RESOLVE DISPUTED AMOUNT.  THE REGION SHOULD HAVE A
RESPONSE IN 30-60 DAYS.

  DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION:
RESOLUTION CANNOT BE DETERMINED AT THIS TIME.

IG FOLLOWUP STATUS AS OF  3/31/95   [2]

E2CUP3-04-0225-4400096  BRUNSWICK                   GA   8/10/94
 Sumnary:  CONSTRUCTION COST WITH FEDERAL SHARE OF $311,250 WAS
QUESTIONED BECAUSE SOME SEWERS WERE NOT BUILT AS PLANNED.
ENGINEERING COST CLAIMED WITH FEDERAL SHARE OF $65,000 WAS
QUESTIONED BECAUSE THE GRANTEE DID NOT PROCURE THESE SERVICES IN
CONFORMITY WITH EPA REGULATIONS.

  EXPLANATION  OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN
MADE:  AS OF 3/31/95, GRANTEE HAS ASKED FOR A DELAY OF 30-60 DAYS
TO FILE A GRANT AMENDMENT TO CHANGE THE SCOPE OF WORK OUTLINED IN
THE  GRANT.

  DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION:
RESOLUTION CANNOT BE DETERMINED AT THIS TIME.

 IG FOLLOWUP STATUS AS OF  3/31/95   [2]
ASSIGNMENT  CONTROL
NUMBER
                                                                    TITLE
 FINAL REPORT
	ISSUED
 Regional Administrator -  Region 6

 E2CWN3-06-0089-4300052  HOUSTON                     TX   9/29/94
  Summary:  HOUSTON,  TEXAS CLAIMED $6,159,937 OF INELIGIBLE
 ENGINEERING AND  CONSTRUCTION  COSTS FOR THE CONSTRUCTION OF A
 WASTEWATER TREATMENT FACILITY.   AN ADDITIONAL $991,174 OF
 UNSUPPORTED COSTS OF $1,063,235 OF UNNECESSARY AND UNREASONABLE
 COSTS WERE QUESTIONED.

   EXPLANATION OF THE REASONS  MANAGEMENT DECISION HAS NOT BEEN
 MADE:  AUDIT TRANSMITTAL  LETTER (ATL) WAS SENT BY TEXAS WATER
 DEVELOPMENT BOARD TO CITY ON  02/03/95, ALONG WITH AN ANALYSIS OF
 FINAL AUDIT.  CITY REQUESTED  AN EXTENSION OF 90 DAYS TO RESPOND
 TO ATL.  THIS WAS GRANTED.  AUDIT HAS OVER 90 VERY COMPLEX
 FINDINGS WITH CLAIMED COSTS OF  $208,720,680, QUESTIONED COSTS OF
 $13,417,479, AND $3,562,938 POTENTIALLY DUE EPA.

  DESIRED TIMETABLE  FOR ACHIEVING A MANAGEMENT DECISION:
 RESOLUTION CANNOT BE DETERMINED AT THIS TIME.
 IG FOLLOWUP  STATUS  AS  OF   3/31/95    [1]

 D9AGL4-10-0072-4100269 CFS
 Summary:   (PREAWARD AUDIT UNDER  NEGOTIATION)
                       ID   5/3/94
  EXPLANATION OF  THE  REASONS  MANAGEMENT DECISION HAS NOT BEEN
MADE:   THE  TEXAS  NATURAL  RESOURCE  CONSERVATION COMMISSION (TNRCC)
AND THE CONTRACTOR  COMPLETED  THEIR PRICE NEGOTIATION IN 12/94 AND
THE CONTRACT UAS  SIGNED BY  CFS,  BUT NOT YET SIGNED BY TNRCC.  EPA
IS CURRENTLY AWAITING A COPY  OF  THE FINAL PRICE NEGOTIATION
MEMORANDUM  FROM TNRCC THAT  SHOWS THAT  ALL RECOMMENDATIONS HAVE
BEEN COMPLETED.   ONCE EPA RECEIVES IT  AND SENDS A COPY OF
NEGOTIATION MEMO  TO DCAA, THE AUDIT WILL BE CLOSED.

= DESIRED TIMETABLE FOR ACHIEVING  A MANAGEMENT DECISION:
RESOLUTION  CANNOT BE  DETERMINED  AT THIS TIME.

IG FOLLOWUP STATUS  AS OF  3/31/95    [1]
                                       Regional Administrator  - Region 8

                                       P5BGL2-08-0089-4100167  STATE OF COLORADO            CO    1/4/94
                                        Summary: WE QUESTIONED $276,188 OF INELIGIBLE PERSONNEL COSTS AND
                                       $33,366 OF INELIGIBLE INTERDEPARTMENTAL TRANSFERS.

                                         EXPLANATION OF THE REASONS MANAGEMENT DECISION  HAS NOT BEEN MADE:
                                       MAP REVIEW WAS COMPLETED ON 6/28/94.   THIS WAS  A  BASIS  FOR OUR
                                       PRELIMINARY FINAL DETERMINATION LETTER SENT TO  IG 8/10/94.
                                       DIG REJECTED PRELIMINARY DECISION.  REGION AGREED TO REDRAFT  THE
                                       LETTER.  REGION REISSUED PRELIMINARY FINAL DETERMINATION LETTER AND
                                       SENT TO DIG 1/5/95.  THE STATE DID  NOT RESPOND.   FINAL DRAFT  OF
                                       DECISION LETTER SENT TO DIG 3/23/95 FOR CONCURRENCE.

                                         DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT  DECISION:
                                       RESOLUTION CANNOT BE DETERMINED AT  THIS TIME.

                                       IG FOLLOWUP STATUS AS OF  3/31/95   [5]

                                       P2CWN1-08-0063-4300005  SOUTH VALLEY               UT    10/25/93
                                        Summary:  GRANTEE CLAIMED  COSTS PREVIOUSLY DETERMINED INELIGIBLE
                                       FOR GRANT PARTICIPATION AND MATHEMATICAL ERRORS.

                                         EXPLANATION  OF THE REASONS MANAGEMENT DECISION  HAS NOT BEEN MADE:
                                       THE MANAGEMENT DECISION  WAS DELAYED BECAUSE OF A  LACK  OF RESOURCES
                                       TO ADDRESS AUDIT RESOLUTION.  RECEIVED COMMENTS FROM WATER
                                       MANAGEMENT AND GRANTEE  ON QUESTIONED COSTS ON 9/12/94.  OFFICE IS
                                       REVIEWING DOCUMENTATION  FOR PRELIMINARY FINAL DETERMINATION LETTER
                                       FOR 10/01/94.  THE DIG HAS ASKED FOR CLARIFICATION  ON  OUR DECISION
                                       LETTER  AND REVISION OF ATTACHED SPREADSHEETS -- SENT CHANGES TO  THE
                                       DIG 4/01/95.

                                         DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION:
                                       RESOLUTION CANNOT BE DETERMINED AT THIS TIME.

                                       IG FOLLOWUP STATUS AS OF  3/31/95   [1]
Regional Administrator - Region 9

S2CW*8-09-0157-1300112  LOS ANGELES, CITY OF        CA    9/25/91
 Summary:  INELIGIBLE COSTS OF $723,627  INCLUDED: $650,255 OF
UNALLOWABLE FORCE ACCOUNT COSTS; AND $73,372 FOR UNALLOWABLE
ENGINEERING COSTS.  UNREASONABLE COSTS INCLUDE $879,630 OF
UNDOCUMENTED FORCE ACCOUNT AND $1,099,261 ARCHITECT/ENGINEERING
COSTS INCURRED UNDER PROHIBITED CONTRACT METHOD.

  EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN MADE:
THE STATE WATER RESOURCES CONTROL BOARD  IS  FINALIZING PROPOSED
FINAL DETERMINATION LETTER AND WILL SEND IT TO EPA BY 4/15/95.

  DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION:  EPA  IS
EXPECTED TO ISSUE THE FINAL DETERMINATION LETTER BY 4/30/95.

IG FOLLOWUP STATUS AS OF  3/31/95    [1]

S2CW*8-09-0156-1300119  LOS ANGELES, CITY OF        CA    9/30/91
 Summary:  INELIGIBLE COSTS OF $2,483,872 INCLUDED $2,039,554 OF
CONSTRUCTION AND FORCE ACCOUNT COST OUTSIDE SCOPE OF APPROVED
PROJECT; $444,318 OF FORCE ACCOUNT COSTS ALLOCABLE TO INELIGIBLE
CONSTRUCTION.  UNREASONABLE COSTS OF $68,150,598 RELATED  TO
EXCESSIVE LANDSCAPING,  FORCE ACCOUNT COSTS AND UNUSED  FACILITIES.

  EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN MADE:
THE STATE WATER RESOURCES CONTROL BOARD IS FINALIZING THE PROPOSED
FINAL DETERMINATION LETTER AND WILL SEND IT TO EPA BY 4/15/95.

  DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION:  EPA  IS
EXPECTED TO ISSUE THE FINAL DETERMINATION LETTER BY 5/15/95.

IG FOLLOWUP STATUS AS OF  3/31/95    [1]

S2CWN1-09-0228-2300044  LOS ANGELES, CITY OF        CA    3/13/92
 Summary:  INELIGIBLE COSTS INCLUDED $1,400,564  FOR UNUSED
EQUIPMENT ITEMS;  $202,058 FOR UNALLOWABLE ARCHITECT/ENGINEERING
(A/E) FEES; AND $572,354 FOR UNALLOWABLE FORCE ACCOUNT (F/A) COSTS;
AND UNREASONABLE  COSTS OF $1,010,586 FOR EXCESSIVE A/E AND  F/A.  AN
   OCTOBER 1, 1994 THROUGH MARCH 31, 1995
                                                                                          63

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ASSIGNMENT CONTROL
NUMBER
                             TITLE
 FINAL  REPORT
	ISSUED
ADDITIONAL $11,188,321 WAS QUESTIONED BECAUSE PLANT WAS  NOT
OPERATING  IN ACCORDANCE WITH PLANT CONCEPTS.

  EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN
MADE:  THE STATE WATER RESOURCES CONTROL BOARD AND DIG AGREE ON
PROPOSED FINAL DETERMINATION LETTER.

= DESIRED  TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION:  EPA
EXPECTS TO ISSUE FINAL DETERMINATION LETTER BY 4/30/95.

IG  FOLLOWUP STATUS AS OF  3/31/95   [1]

E2CWN1-09-0092-2300082  RUSSIAN RIVER CSD            CA    9/25/92
 Summary:  COSTS OF $8,344,066 HAVE BEEN QUESTIONED AS INELIGIBLE,
INCLUDING  INELIGIBLE CONSTRUCTION, ENGINEERING AND FORCE ACCOUNT
COSTS.  AN ADDITIONAL $18,297,400 HAVE BEEN QUESTIONED AS
UNNECESSARY BECAUSE THE PLANT WAS NOT FULLY UTILIZED.

  EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN
MADE:  THE STATE WATER RESOURCES CONTROL BOARD AND DIG REACHED
AGREEMENT  ON ALL BUT TWO  ISSUES.  THE STATE WATER RESOURCES
CONTROL BOARD SENT EPA A  LETTER OF DISAGREEMENT FOR THESE TWO
ISSUES ON  3/1/95.

  DESIRED  TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION:  EPA TO
ISSUE FINAL DETERMINATION LETTER BY 9/30/95.

IG  FOLLOWUP STATUS AS OF  3/31/95   [1]

S2CWNO-09-0262-2300089  SAN FRANCISCO, CITY & CO    CA   9/30/92
 Summary:  INELIGIBLE COSTS INCLUDE $50,015 OF UNALLOWABLE
ARCHITECT/ENGINEERING (A/E) COSTS AND $271,092 FOR COSTS ALLOCABLE
TO  OTHER FEDERAL FACILITIES RELATED TO UNSUPPORTED CONSTRUCTION
A/E  FORCE  ACCOUNT COSTS.

  EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN
MADE:  IN  THIS SAN FRANCISCO AUDIT, THE KEY ISSUE IS THE ADEQUACY
OF  COMPUTER TAPE DOCUMENTATION FOR TIME CARDS.

  DESIRED  TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION:  EPA
EXPECTS TO ISSUE THE FINAL DETERMINATION LETTER BY 5/30/95.

IG  FOLLOWUP STATUS AS OF  3/31/95   [1]

S2CWM9-09-0192-3200056  SAN FRANCISCO, CITY & CO    CA   9/30/93
 Summary:  THE AUDIT QUESTIONED COSTS OF $137,651 AS INELIGIBLE
AND  $257,228 AS UNSUPPORTED.

  EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN
MADE:  IN  THIS SAN FRANCISCO AUDIT, THE KEY ISSUE IS THE ADEQUACY
OF  COMPUTER TAPE DOCUMENTATION FOR TIME CARDS.

  DESIRED  TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION:  EPA
EXPECTS TO ISSUE THE FINAL DETERMINATION LETTER BY 5/30/95.

IG  FOLLOWUP STATUS AS OF  3/31/95   [1]

S2CWNO-09-0073-3300036  SAN FRANCISCO, CITY & CO    CA   4/26/93
 Summary:  INELIGIBLE COSTS OF $493,315 INCLUDE $3,112 OUTSIDE THE
SCOPE OF PROJECT AND $490,203 NORMAL COST OF GOVERNMENT.
UNREASONABLE COST OF $2,872,442 FOR RECONSTRUCTED FORCE ACCOUNT
COSTS NOT SUPPORTED BY ACTUAL SOURCE DOCUMENTATION.

  EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN
MADE:  IN THIS SAN FRANCISCO AUDIT, THE KEY ISSUE IS THE ADEQUACY
OF COMPUTER TAPE DOCUMENTATION FOR TIME CARDS.

  DESIRED TIMETABLE FOR  ACHIEVING A MANAGEMENT DECISION:  EPA
EXPECTS  TO ISSUE THE FINAL DETERMINATION LETTER BY 5/30/95.

IG FOLLOWUP STATUS AS OF  3/31/95   [1]

S2CWNO-09-0050-3300078  SAN FRANCISCO, CITY AND CO  CA   9/30/93
 Summary:   INELIGIBLE COSTS OF $281,859 REPRESENT COSTS IN EXCESS
OF THE APPROVED AMOUNT.   UNSUPPORTED COSTS OF $43,598 RELATE TO
FORCE ACCOUNT COSTS NOT  SUPPORTED BY ORIGINAL SOURCE
DOCUMENTATION.
ASSIGNMENT CONTROL
NUMBER
                                                                                                 TITLE
 FINAL REPORT
	ISSUED
                 EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN MADE:
                IN THIS SAN  FRANCISCO  AUDIT,  THE  KEY ISSUE IS THE ADEQUACY OF
                COMPUTER TAPE DOCUMENTATION  FOR  TIME CARDS.

                 DESIRED TIMETABLE FOR  ACHIEVING A MANAGEMENT DECISION:  EPA
                EXPECTS TO  ISSUE  THE FINAL DETERMINATION LETTER BY 5/30/95.

                IG FOLLOWUP  STATUS  AS  OF 3/31/95   [1]

                S2CWNO-09-0076-3300080  LAS  VIRGENES MWD            CA   9/30/93
                Summary:   INELIGIBLE  COSTS  OF $5,091,815 INCLUDE: $42,564 FOR
                CONSTRUCTION COSTS  NOT INCURRED;  $192,643 OF INTEREST EARNED;
                $647,791 FOR UNALLOWABLE ARCHITECT/ENGINEERING (A/E) AND
                ADMINISTRATIVE COSTS;  $1,919,244  FOR A/E AND CONSTRUCTION OUTSIDE
                SCOPE OF PROJECT; AND  $2,289,573  RELATED TO  EXCESS CAPACITY.  AN
                ADDITIONAL $757,976 WERE UNREASONABLE  A/E COSTS.

                 EXPLANATION OF  THE REASONS MANAGEMENT DECISION HAS NOT BEEN MADE:
                THE STATE WATER  RESOURCES CONTROL BOARD IS WORKING WITH  THE DIG TO
                RESOLVE AREAS OF DISAGREEMENT. MEMBERS OF THE  SWRCB MAY REFER ONE
                ISSUE TO THE FULL STATE  BOARD.

                = DESIRED TIMETABLE  FOR ACHIEVING A MANAGEMENT DECISION: THE STATE
                WATER RESOURCES CONTROL  BOARD  INTENDS  TO SEND  THE PROPOSED FINAL
                DETERMINATION LETTER TO  EPA  BY 6/30/95.

                IG FOLLOWUP STATUS AS  OF 3/31/95    [1]

                E2AWT3-09-0082-3400037  SAN DIEGO, CITY OF          CA    3/29/93
                Summary:  THE CITY OF  SAN DIEGO HAS CONSTRUCTED AN $11.8 MILLION
                LAND OUTFALL WHICH WILL  NOT BE USED  BY  THE CITY FOR  THE INTENDED
                PURPOSE OF  THE GRANT NOR  WILL IT BE USED  IN  THE FORESEEABLE FUTURE.

                 EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN MADE:
                THE OUTFALL PROJECT IS A JOINT EFFORT  WITH THE  INTERNATIONAL
                BOUNDARY AND WATER COMMISSION.  THE AUDIT CANNOT BE RESOLVED UNTIL
               A REQUIREMENT FOR SECONDARY TREATMENT  IS  DETERMINED.

                 DESIRED TIMETABLE FOR  ACHIEVING A  MANAGEMENT  DECISION:   AUDIT
               RESOLUTION TARGET DATE IS 9/30/95.

                IG FOLLOWUP STATUS AS  OF  3/31/95    [2]

               S2CWN2-09-0091-4300051   VALLEJO SAN & FLOOD CONTROL  CA   9/29/94
                Summary:  INELIGIBLE  COSTS OF $5,525,458  INCLUDE $712,246 OF
               UNALLOWABLE ARCHITECT/ENGINEERING  FEES;  $3,162,957 OF  EARNED
                INTEREST NOT CREDITED  TO THE  GRANT,  AND $1,650,255 OF UNALLOWABLE
               CONSTRUCTION.  UNREASONABLE COSTS OF $3,874,497 REPRESENT  UNUSED
                FACILITIES.

                 EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT  BEEN MADE:
               THE STATE WATER  RESOURCES CONTROL BOARD IS RESEARCHING THE ISSUES
               AND PLANS TO  SEND THE PROPOSED FINAL DETERMINATION  LETTER TO EPA BY
               5/30/95.

               = DESIRED TIMETABLE FOR  ACHIEVING A  MANAGEMENT  DECISION:
               RESOLUTION CANNOT BE DETERMINED AT THIS  TIME.

                IG FOLLOWUP STATUS AS  OF  3/31/95    [1]
               G3HVK4-09-0203-4500703
                *Summary:
                       SAN JOAQUIN VALLEY UAPC DIST  CA  7/28/94
                 EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN MADE:
               THE FINAL DETERMINATION LETTER FOR THIS SINGLE AUDIT WAS ROUTED FOR
               SIGNATURE ON 3/28/95.

               = DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT  DECISION:
               RESOLUTION IS EXPECTED SHORTLY.

               IG FOLLOWUP STATUS AS OF  3/31/95    [5]

               N3HVK4-09-0157-4500752  HAWAII,  DEPT OF AGRICULTURE  HI   8/19/94
                *Sumtnary:

                 EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN HADE:
               THE INITIAL FINAL DETERMINATION LETTER FOR THIS  SINGLE AUDIT WAS
   64
                                             OFFICE OF INSPECTOR GENERAL

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 ASSIGNMENT CONTROL
 NUMBER,	
TITLE
                        FINAL REPORT
                              ISSUED
ASSIGNMENT CONTROL
NUMBER	
TITLE
                        FINAL REPORT
                              ISSUED
 ROUTED FOR SIGNATURE IN JANUARY 1995.  HOWEVER, SUBSEQUENT
 FINANCIAL ISSUES WERE RAISED WHICH REQUIRE ADDITIONAL INFORMATION
 FROM THE GRANTEE TO RESOLVE.  CONSEQUENTLY, A SECOND FINAL
 DETERMINATION LETTER WILL BE PREPARED AFTER REVIEW AND RECEIPT OF
 THE ADDITIONAL FINANCIAL INFORMATION.

   DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION:
 RESOLUTION IS EXPECTED  BY 6/30/95.

 IG FOLLOWUP STATUS AS OF  3/31/95    [1]

 E2AUP9-09-0065-9400025   HOMELAND EARLY WARNING       CA    3/31/89
  Summary:  SPECIAL REVIEW OF CONSTRUCTION GRANT OF WASTEWATER
 TREATMENT PLANT FOUND $3,737,139 IN FEDERAL SHARE COSTS
 QUESTIONED.  AN EARLY WARNING LETTER  ADVISED THAT COSTS FOR THE
 COLLECTION SYSTEM PORTION OF THE PROJECT  DID NOT QUALIFY FOR
 FUNDING BECAUSE OF THE  "2/3 RULE".

   EXPLANATION OF THE REASONS MANAGEMENT  DECISION HAS NOT BEEN
 MADE:  EPA OFFICE OF WATER AGREES  WITH THE MAJORITY OF THE
 REGION'S TWO-THIRDS RULE INTERPRETATION.   THE PROGRAM WILL MEET
 WITH THE STATE WATER RESOURCES CONTROL BOARD TO RESOLVE THE
 REMAINING COSTS DEEMED  INELIGIBLE  BY  THE  OFFICE OF WATER.

   DESIRED TIMETABLE FOR ACHIEVING  A MANAGEMENT DECISION:  EPA
 EXPECTS TO ISSUE ITS FINAL DETERMINATION  LETTER BY 6/30/95.

 IG FOLLOWUP STATUS AS OF  3/31/95    [5]
 Regional Administrator  -  Region 10

 P2CWL9-10-0002-2100669   PIERCE  COUNTY UTILITIES DEP  WA  9/30/92
  Summary:  THE GRANTEE  CLAIMED  TOTAL QUESTIONABLE COSTS OF
 $4,496,181 FOR REIMBURSEMENT  UNDER EPA'S CONSTRUCTION GRANTS
 PROGRAM.  COST CLAIMED  OF $2,179,647 WERE FOUND TO BE INELIGIBLE
 AND CLAIMS FOR $2,316,534 WERE  UNNECESSARY AND UNREASONABLE.

   EXPLANATION OF  THE  REASONS  MANAGEMENT  DECISION HAS NOT BEEN
 MADE:  THE REGION OBTAINED ADDITIONAL DOCUMENTATION FOR REVIEW OF
 GRANT "ELIGIBILITY" AND "LACK OF  DOCUMENTATION" ISSUES IN AUDIT
 REPORT.  THIS INVOLVES  REVIEWING  16 GRANTS AND 40 LARGE BOXES OF
 DOCUMENTATION OBTAINED  FROM VARIOUS SOURCES.   THE REGION FOUND
 RELEVANT DOCUMENTATION  AND HAS  COMPLETED ITS  REVIEW.

   DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION:  FINAL
 DETERMINATION LETTER  ISSUED ON  3/14/95.

 IG FOLLOWUP STATUS AS OF   3/31/95   [4]

 P2CWN9-10-0107-2300091   FED WAY WATER AND SEW       WA   9/30/92
  Summary:  INELIGIBLE COSTS OF  $1,304,725 CONSISTED OF: $67,287
 FOR UNALLOWABLE CONSTRUCTION  COST;  $61,048 RELATED TO INELIGIBLE
 CONSTRUCTION  PERCENTAGE;  $21,243  OF UNAPPROVED ARCHITECT/
 ENGINEERING;  AND  $1,155,147 RELATED TO EXCESS CAPACITY.  ALSO
 QUESTIONED WERE $2,242,049 AS UNSUPPORTED.

   EXPLANATION OF  THE  REASONS  MANAGEMENT  DECISION HAS NOT BEEN
 MADE:  THE REGION  IS  OBTAINING  ADDITIONAL INFORMATION FROM AUDITEE
 AND STATE TO  REVIEW AND RESOLVE ISSUE OF GRANT ELIGIBLE COSTS FOR
 A  30 YEAR PLAN VS  A 20  YEAR PLAN.   ADDITIONAL DOCUMENTS ARE TIME
 CONSUMING TO  GET  BECAUSE  PROJECT  IS 15 YRS. OLD.  SENT DRAFT FINAL
 DETERMINATION LETTER  TO OIG 3/2/95.   RECEIVED OIG'S COMMENTS
 3/29/95.   REGION  EXPECTS  TO ISSUE REVISED DRAFT FINAL
 DETERMINATION LETTER  TO OIG BY  5/15/95.

  DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION:
 RESOLUTION  CANNOT  BE  DETERMINED AT  THIS  TIME.

 IG FOLLOWUP STATUS AS OF   3/31/95   [2]

P2CUN2-10-0016-3300067   PETERSBURG,  CITY OF          AK   9/21/93
 Summary:   INELIGIBLE COSTS OF  $215,893  INCLUDE:  $8,064 OF
UNALLOWABLE ADMINISTRATIVE; $43,473 OF INELIGIBLE ARCHITECT/
ENGINEERING COSTS; AND  $164,356 OF  INELIGIBLE CONSTRUCTION COSTS.
COSTS OF  $21,877 WERE NOT  SUPPORTED BY SOURCE DOCUMENTATION.
                                         EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN MADE:
                                       PETERSBURG IS OLDEST  CONSTRUCTION SITE IN REGION.   REGION HAS BEEN
                                       INVOLVED IN EXTENSIVE LITIGATION.  STATE  PROJECT  FILES  AND MUCH OF
                                       CITY'S SUPPORTING DOCUMENTATION  WERE  MISPLACED BY ATTORNEYS.
                                       REGION SENT DRAFT FINAL DETERMINATION LETTER  TO  OIG 5/5/94.
                                       ALTHOUGH THE OIG CODED THE RESPONSE  INCOMPLETE,  THE REGION
                                       DISAGREES.  NEW DOCUMENTATION WAS  FOUND.   THE REGION EXPECTS TO
                                       ISSUE REVISED DRAFT FINAL DETERMINATION  LETTER TO OIG  BY  5/1/95.

                                         DESIRED TIMETABLE FOR ACHIEVING  A MANAGEMENT DECISION:
                                       RESOLUTION CANNOT BE DETERMINED  AT THIS  TIME.

                                       IG FOLLOWUP STATUS AS OF  3/31/95    [4]

                                       P2CWNO-10-0052-3300069  SEATTLE                      WA  9/29/93
                                        Summary:  INELIGIBLE COSTS OF  $162,801  INCLUDE:  $6,904 ALLOCABLE
                                       TO INELIGIBLE CONSTRUCTION AND $155,897  COSTS  OUTSIDE  SCOPE OF
                                       APPROVED PROJECT.   COSTS OF $290,076  NOT  SUPPORTED  BY  ADEQUATE
                                       SOURCE DOCUMENTATION.

                                         EXPLANATION  OF THE REASONS MANAGEMENT DECISION HAS  NOT BEEN MADE:
                                       REGION IS OBTAINING ADDITIONAL INFORMATION FOR INCLUSION IN THE
                                       DRAFT FINAL DETERMINATION LETTER.  REGION WILL ISSUE DRAFT  FINAL
                                       DETERMINATION LETTER  TO OIG BY 06/01/95.

                                          DESIRED TIMETABLE  FOR ACHIEVING A MANAGEMENT DECISION:
                                       RESOLUTION CANNOT  BE  DETERMINED AT THIS TIME.

                                       IG FOLLOWUP STATUS AS OF  3/31/95   [2]

                                       P2CWN1-10-0049-3300076  SEASIDE,  CITY  OF             OR    9/30/93
                                        Summary:  INELIGIBLE COSTS OF  $97,155 INCLUDE: $7,889 OF
                                       UNALLOWABLE FORCE ACCOUNT AND $89,266 OF CONSTRUCTION COSTS RELATED
                                       TO SERVICE  LATERALS.  COSTS OF $188,202 ARE NOT  SUPPORTED BY SOURCE
                                       DOCUMENTATION.

                                         EXPLANATION  OF THE REASONS MANAGEMENT DECISION HAS NOT  BEEN  MADE:
                                       REGION HAS BEEN OBTAINING INFORMATION,  COMMENTS, AND DOCUMENTATION
                                       FROM  THE STATE AND PROGRAM OFFICE.   REGION SUBMITTED DRAFT  FINAL
                                       DETERMINATION  LETTER  TO OIG ON 12/16/94.   RECEIVED OIG'S COMMENTS
                                       01/23/95.  WILL ISSUE REVISED DRAFT FINAL  DETERMINATION LETTER TO
                                       OIG BY 06/01/95.

                                         DESIRED TIMETABLE  FOR  ACHIEVING A MANAGEMENT DECISION:
                                       RESOLUTION  CANNOT  BE  DETERMINED  AT  THIS TIME.

                                       IG FOLLOWUP STATUS AS  OF   3/31/95   [2]

                                       P2CWN1-10-0041-3300077  METROPOLITAN WASTEWTR.  MGT.   CA  9/30/93
                                        Summary:  INELIGIBLE COSTS OF $2,511,772  INCLUDE:  $26,970 OF MISC
                                       COSTS;  $107,481 OF INSURANCE PREMIUMS;  $181,830 ALLOCABLE  TO
                                       INELIGIBLE  PERCENT; $2,195,491  OUTSIDE SCOPE OF PROJECT.
                                       ADDITIONALLY,  WE QUESTIONED $6,657,189 WHICH WAS NOT SUPPORTED BY
                                       ADEQUATE SOURCE DOCUMENTS.

                                         EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT  BEEN MADE:
                                       THIS PROJECT HAS VERY COMPLEX ISSUES, E.G., SEGMENTATION  OF GRANTS.
                                       REGION  IS SEEKING ADDITIONAL COMMENTS AND DOCUMENTATION FROM STATE,
                                       REGION'S PROGRAM AND FROM GRANTEE. REGION  WILL  ISSUE A DRAFT  FINAL
                                       DETERMINATION  LETTER  TO OIG BY  07/01/95.

                                         DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION:
                                       RESOLUTION  CANNOT  BE DETERMINED  AT  THIS TIME.

                                       IG FOLLOWUP STATUS AS OF   3/31/95   [1]

                                       E3NLB3-10-0151-4100563  LUST-IDAHO                   ID    9/28/94
                                        *Summary:   COSTS  IN  THE  AMOUNT  OF  $711,906 WERE  QUESTIONED  AS
                                       UNSUPPORTED BECAUSE  IDAHO DID NOT HAVE ADEQUATE DOCUMENTATION TO
                                       SUPPORT THAT  THE COSTS WERE ALLOCABLE  TO  THE LUST  PROGRAM.   ALSO
                                       IDAHO NEEDED  TO  IMPROVE  SITE OVERSIGHT, COST RECOVERY,  AND
                                       REPORTING PROCEDURES.

                                         EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT  BEEN MADE:
                                       ISSUED  DRAFT FINAL  DETERMINATION LETTER TO OIG ON 1/13/95.  ON-SITE
                                       INVESTIGATION  TO BE CONCLUDED MAY 1995.   REGION EXPECTS TO  ISSUE
                                       DRAFT  FINAL DETERMINATION LETTER TO OIG 06/01/95.
   OCTOBER 1, 1994 THROUGH MARCH 31, 1995
                                                                                         65

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ASSIGNMENT CONTROL
NUMBER     	
TITLE
 FINAL REPORT
	ISSUED
  DESIRED TIMETABLE  FOR ACHIEVING A MANAGEMENT DECISION:
 RESOLUTION CANNOT BE DETERMINED AT THIS TIME.

 IG  FOLLOWUP STATUS AS OF  3/31/95    [1]

 P2CWN2-10-0068-4300013  WASILLA, CITY OF            AK    12/15/93
  Summary:  INELIGIBLE COSTS OF $306,738 INCLUDED $182,188 OF
 COSTS ALLOCABLE  TO INELIGIBLE PORTION OF CONSTRUCTION; $122,647
 OF  UNALLOWABLE ARCHITECT/ ENGINEERING COSTS; AND $1,730 OF COSTS
 CLAIMED  TWICE.   COSTS OF $97,346 WERE NOT SUPPORTED BY SOURCE
 DOCUMENTATION.

  EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT  BEEN
 MADE:   REGION, STATE, AND CITY GATHERING ADDITIONAL INFORMATION
 AND DOCUMENTATION TO BE USED.  ISSUED DRAFT  FINAL DETERMINATION
 LETTER  TO DIG ON 2/3/95.  DIG RESPONDED 2/22/95.  REGION  TO
 RESPOND  TO OIG COMMENTS BY 6/01/95.

 = DESIRED TIMETABLE  FOR ACHIEVING A MANAGEMENT DECISION:
 RESOLUTION CANNOT BE DETERMINED AT THIS TIME.

 IG  FOLLOWUP STATUS AS OF  3/31/95    [2]

 P2CWN3-10-0034-4300039  NORTH BEND, CITY OF         OR    6/27/94
  Summary:  INELIGIBLE COSTS OF $56,470 INCLUDE: $3,197 OF
 UNREFUNDED P&S DEPOSITS; $9,000 OF UNALLOWABLE CONSTRUCTION;
 $15,440  OF OPERATION AND MAINTENANCE RELATED COSTS; $28,833
 COST ALLOCABLE TO INELIGIBLE PERCENTAGE.  $88,853 OF UNSUPPORTED
 ENGINEERING AND  ADMINISTRATIVE COSTS WERE ALSO QUESTIONED.

  EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT  BEEN
 MADE:   REGION EXPECTS TO ISSUE DRAFT FINAL DETERMINATION  LETTER
 TO  OIG  BY 6/1/95.

  DESIRED TIMETABLE  FOR ACHIEVING A MANAGEMENT DECISION:
 RESOLUTION CANNOT BE DETERMINED AT THIS TIME.

 IG  FOLLOWUP STATUS AS OF  3/31/95    [1]

 P2CWN3-10-0141-4300053  MUNICIPALITY OF ANCHORAGE   AK    9/29/94
  Summary:  INELIGIBLE COSTS OF $2,649,916 INCLUDE: $41,555
 ALLOCABLE TO THE INELIGIBLE PERCENTAGE; $126,115 OF UNALLOWABLE
 CONSTRUCTION COSTS; AND $2,482,246 OF COSTS ALLOCABLE TO  FEDERAL
 FACILITIES.  COSTS OF $15,602 WERE NOT SUPPORTED BY ADEQUATE
 SOURCE DOCUMENTATION.                             *

  EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT  BEEN
 MADE:  REGION SENT DRAFT FINAL DETERMINATION LETTER TO OIG ON
 2/24/95.  OIG RESPONDED 3/9/95.  PROGRAM WILL RESPOND TO OIG
 COMMENTS BY JUNE 1,  1995.

 = DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION:
 RESOLUTION CANNOT BE DETERMINED AT THIS TIME.
                                       ASSIGNMENT  CONTROL
                                       NUMBER
                                                                   TITLE
FINAL REPORT
      ISSUED
 IG  FOLLOWUP STATUS AS OF  3/31/95    [1]

 G3HVK3-10-0167-4500605  NESKOWIN REG SANITARY AUTH
 *Summary:
                        OR  6/22/94
                                         DESIRED  TIMETABLE  FOR ACHIEVING A MANAGEMENT DECISION:  EXPECTS
                                       RESOLUTION BY MAY 1, 1995.

                                       IG FOLLOWUP STATUS AS OF   3/31/95   [6]
                                       TOTAL AUDITS ISSUED BEFORE REPORTING PERIOD FOR WHICH NO MANAGEMENT
                                       DECISION  WAS  MADE  DURING THE REPORTING PERIOD:    119

                                        *   Agency procedures do not require the IG's approval on Agency's
                                       Management  Decision on an audit (other than a preaward or an
                                       internal and management audit) with the Federal share of questioned
                                       costs of  less  than $100,000.  Therefore,  we have not provided a
                                       summary of  the audit.
  EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN
MADE:  REGION EXPECTS TO ISSUE DRAFT FINAL DETERMINATION LETTER
TO OIG BY 5/1/95.

= DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION:
RESOLUTION CANNOT BE DETERMINED AT THIS TIME.

IG FOLLOWUP STATUS AS OF  3/31/95   [1]

E3BG*6-10-0066-8100761  MOSES LAKE IRR & REHAB DIST  WA  8/31/88
 Summary:  INTERIM AUDIT OF DEMONSTRATION GRANT TO RESTORE MOSES
LAKE AND TO CONTROL NON-POINT POLLUTION SOURCES FOUND TOTAL COSTS
QUESTIONED OF $2,439,103 (F.S. $1,205,039).  GRANTEE USED STANDARD
METHODOLOGY INSTEAD OF DEVELOPING NEW INNOVATIVE TECHNIQUES.

  EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN
MADE:  EPA'S AUDIT RESOLUTION BOARD (ARB) HAS HEARD THE ISSUES
IN THE AUDIT AND IS PREPARING ITS DECISION FOR THE AGENCY.
   66
                                                                    OFFICE OF INSPECTOR GENERAL

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        PIG  MAILING ADDRESSES and  TELEPHONE NUMBERS
        PIG  HOTLINE   (800)  424-4000 or (202)  260-4977
        Headquarters
        Environmental Protection Agency
        Office of Inspector General
        401 M Street,  S.W. (2441)
        Washington, DC  20460
        (202) 260-3137

        Atlanta
        Environmental Protection Agency
        Office of Inspector General
        1475 Peachtree Street, NE
        Suite 1100
        Atlanta, GA 30309-3003
        Audit: (404) 347-3623
        Investigations' (404) 347-2398

        Boston
        Environmental Protection Agency
        Office of Inspector General
        JFK Federal Building  (OIG)
        (office at  1 Congress  St)
        Boston, MA 02203
        Audit: (617) 565-3160
        lnvestigations:(617) 565-3928

        Chicago
        Environmental Protection Agency
        Office of Inspector General
        77 West Jackson  Boulevard
        13th Floor (IA-13J)
        Chicago, IL 60604
        Audit: (312) 353-2486
        Investigations: (312) 353-2507

        Cincinnati
        Environmental Protection Agency
        Office of Inspector General
        4411 Montgomery (MS Norwood)
        Cincinnati,  OH 45268-7001
        Audit: (513) 366-4360
        Investigations: (312) 353-2507 (Chicago)

        Dallas
        Environmental Protection Agency
        Office of Inspector General (60IG)
        1445 Ross Avenue, Suite 1200
        Dallas, TX 75202-2733
        Audit: (214) 655-6621
        Investigations:  (404) 347-2398 (Atlanta)

        Denver
        Environmental  Protection Agency
        Office of Inspector General
        999 18th Street, Suite 500
        Denver, CO 80202-2405
       Audit: (303) 294-7520
       Investigations:  (312) 353-2507 (Chicago)
Kansas City
Environmental  Protection Agency
Office of Inspector General
726 Minnesota Avenue
(office at 630 Minnesota Ave)
Kansas  City, KS 66101
Audit: (913) 551-7878
Investigations:  (312) 353-2507 (Chicago)

New York
Office of Inspector General
290 Broadway, Room 1520
New York, NY  10007-1866
Audit: (212) 637-3071
Investigations:  (212) 637-3041

Philadelphia
Environmental  Protection  Agency
Office of Inspector General
841 Chestnut Street, 13th  Floor
Philadelphia, PA  19107
Audit. (215) 597-0497
Investigations:  (215) 597-9421

Research Triangle Park, NC
Environmental  Protection  Agency
Office of Inspector General
Catawba Building
Highway 54,  Mail Drop 53
Research Triangle Park, NC 27711
Audit: (919) 541-2204
Investigations:  (919) 541-1027

Sacramento
Environmental  Protection  Agency
Office of Inspector General
650 Capitol  Mall,  Suite 6309
Sacramento,  CA 95814
Audit. (916) 551-1076
Investigations:  (415) 744-2465 (SF)

San Francisco
Environmental  Protection  Agency
Office of Inspector General
75 Hawthorne St (1-1)
19th  Floor
San Francisco,  CA 94105
Audit: (415) 744-2445
Investigations:  (415) 744-2465

Seattle
Environmental  Protection  Agency
Office of Inspector General
1111 3rd Avenue, Suite 1460
Seattle, WA98101
Audit: (206) 553-4403
Investigations:  (415) 744-2465 (SF)
tit
       OCTOBER 1, 1994 THROUGH MARCH 31, 1995
                                                                                                                       67

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REPORT FRAUD, WASTE, OR ABUSE TO THE

  INSPECTOR GENERAL

       HOTLINE

  • INFORMATION IS CONFIDENTIAL


800-424-4000 or 202-260-4977

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