!     UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

  '/                 WASHINGTON, D.C. 20460
                         JAN 2 4 1989
                                                     OFFICE OF

                                                 THE INSPECTOR GENERAL
MEMORANDUM

SUBJECT:  Audit Report No. M5BFL9-11-0022-9100168
          Audit of Interagency Agreements with
          the Department of Energy for Superfund
          Activities - Fiscal 1987
FROM:     Kenneth D.
          Divisional Inspector General for Audit
          Internal Audit Division (A-109)

TO:       Harvey G. Pippen, Director
          Grants Administration Division (PM-216)

          Gary M. Katz
          Director, Financial Management Division


At our request the Office of Inspector General, Department of
Energy, performed the subject audit.  The Department's summary
report and individual reports are attached.  The reports discuss
problems with ( 1 ) costs incurred after the period of performance
for an agreement had expired, (2) not accounting for Superfund
costs separately, and (3) costs incorrectly charged to one agree-
ment.  The report also discusses differences in fiscal 1987
expenditures between EPA and Department of Energy records for
six interagency agreements.  We believe that Financial Management
Division personnel should verify EPA records for amounts expended
during fiscal 1987 and contact the Department of Energy to resolve
any remaining discrepancies .  Accordingly, we are making the
following recommendations .

RECOMMENDATIONS

We recommend that the Director, Grants Administration Division:

     1.  Amend the period of performance for Interagency
         Agreement DW8993070901 to cover costs incurred during
         fiscal 1987.

     2.  Include, in future interagency agreements, requirements
         for the Department of Energy to account for Superfund
         costs separately and maintain documentation necessary
         for cost recovery actions .

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     3.  Not reimburse the Department of Energy for $2,035 of
         costs incorrectly charged to Interagency Agreement
         DW8993173901.

We recommend that the Director, Financial Management Division
verify fiscal 1987 expenditures for the six subject interagency
agreements and work with the Department of Energy to resolve any
discrepancies.

ACTION REQUIRED

In accordance with EPA Directive 2750, the action official is
required to provide this office with a copy of the proposed
determination on the findings within 150 days of the audit report
date.  The Director, Grants Administration Division, is the action
official for this report.

Should your staff have any questions concerning this report,
please have them contact John Walsh on 475-6753.

Attachment

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                                             APPENDIX
                     DISTRIBUTION OF REPORT
Chief,  Financial and Administrative Management
  Section, Office of Emergency and Remedial Response (WH-548D)
Director, Financial Management Division (PM-226)
Director, Procurement and Contracts Management
  Division (PM-214)
Chief,  Grants Information and Analysis Branch (PM-216F)
Regional Administrator,  Region 1
Divisional Inspector General for Audit, Eastern Division
Regional Counsel, Region 1
Agency Followup Official (PM-208)
Agency Followup Official (PM-225)
  Attn:  Resource Management Division

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I r U2S i
nited States Government	Department of Energy


nemorandum

 DATE:     October 28, 1988
1YTO
TNOf:     IG-34

        Summary Report on "Superfund  Costs  Claimed by the Department
        of Energy Under Interagency  Agreements with the Environmental
        Protection Agency - Fiscal Year  1987"
  T0     Letter Report No.: CR-L-89-1

        Controller


        The Superfund Amendments and  Reauthor1zat1on Act of 1986
        (SARA) requires the Departmental  Inspectors General to
        annually audit and report on  Superfund payments, obligations
        and reimbursements.

        Although the  Department of Energy  (DOE) has not received a
        direct Superfund appropriation,   1t has received approxi-
        mately $2.7 million as of Fiscal  Year  (FY) 1987 through
        Interagency agreements with  the  Environmental Protection
        Agency (EPA).

        The purpose of our review was to determine (1) 1f Interagency
        agreement obligations of Superfund  monies were recorded
        correctly on  DOE records and   (11)  whether costs claimed by
        DOE under Individual Interagency agreements were fair and
        reasonable, adequately supported,  equitably allocated, and
        met generally accepted accounting  principles and standards.

        The scope of  the audit was limited  to  reviewing the
        accounting records and other  documents  supporting FY 1987
        Superfund obligations and related  costs claimed by DOE. The
        audit was conducted 1n accordance  with  generally accepted
        government auditing standards and  included such tests of the
        data and records and other procedures   as were considered
        necessary to  satisfy the scope of  audit.  We reviewed
        selected controls over Interagency  agreements, but did not
        review internal control systems  of  the  Department or Its
        Integrated contractors.  Technical  aspects of the  integrated
        contractors'  contract performance  were  also evaluated.  Since
        our review was limited, 1t would not necessarily disclose all
        Internal control deficiencies that  may  exist.

        The audit Included Headquarters  and the Chicago, Oak Ridge,
        and Richland  DOE Operations  Offices, involving work at
        Argonne National Laboratory,  Oak Ridge  National  Laboratory,
        and Pacific Northwest Laboratory.   Individual reports were
        Issued to each operations office (see Attachment 1).  These
        reports address local findings and  make recommendations to
        DOE management.  This report summarizes the  results of the
        reports to the operations offices and our work at

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Headquarters on the Department's  use  of  EPA Superfund  monies
during FY 1987.

Background

Interagency agreements are cost  reimbursable contracts used
by an agency to acquire goods  or  services from another
agency.   In FY 1987, EPA entered  Into 18 Interagency
agreements with DOE to acquire environmental services  such as
assessing contamination, testing  materials, disposing  of
contaminated material, and certifying sites as decontam-
inated.   These agreements Involved approximately $2.7  million
of obligations and $1 million  of  claimed costs.

Most of  the Interagency agreements Involved only Superfund
activities.  Some, however, Included  a mixture of both
Superfund and non-Superfund work.  Since DOE Headquarters
does not centrally manage or control  Interagency agreements,
EPA enters Into the agreements directly  with DOE field
offices.

Results  of Audit

Our audit of 12 out of the 18  Interagency agreements
disclosed no material problems with the  recording of about
$2.2 million of obligations on DOE records.  These agreements
claimed  costs of $930,019.  Of this amount $680,539 was
acceptable, $122,226 was questioned,  and $127,254 was
unresolved.

The questioned costs of $122,226  Involved agreements where
work was performed by Oak Ridge  and Argonne National
Laboratories. Of this amount,  $120,191 was questioned  because
the Oak  Ridge National Laboratory accounting procedures for
EPA interagency agreements were  not adequate to document
claimed  costs.  The remainder  of  the  questioned costs
resulted because Argonne National Laboratory had Incorrectly
posted travel costs totaling $2,035 to the wrong agreement.

The $120,191 of claimed costs  at  Oak  Ridge National
Laboratory was questioned because the Operations Office did
not (1)  have adequate  controls  to accurately accummulate and
bill the employee time costs to  the specific tasks worked on
and (11) retain records of employee time charges to support
costs incurred against Interagency agreements. Four of five
Interagency agreements we audited under the Oak Ridge
Operations Office Included Superfund  and other EPA program
obligations within the same agreement.  Supporting records do

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not show the actual  cost  of  Superfund  activities  1n  the  four
agreements.  Consequently,  we could  not determine  the actual
costs.  Costs were accumulated and billed  against  the
agreements'  oldest funding source rather  than against the
specific program funding  source  to  which  they applied.

Thus,  the Oak Ridge  Operations Office's systems
did not acccurately  accumulate and  bill the cost  of  each EPA
obligation separately within each Interagency agreement.
Also,  documentation  of Individual Internal  time-cards
should  be retained for 3  years to support claimed costs  for
Superfund.  See Attachment 2 for further  details  on  Superfund
obligations, claimed costs,  and  results of audit.

The unresolved costs of $127,254 were  Incurred at Pacific
Northwest Laboratory.  Of this amount, $121,692 were
unaudited subcontract costs  and  will  be Included  in  future
reviews.  The remaining unresolved  costs  of $5,562 were
Incurred after the agreement had expired.

     Full Cost Recovery

The full costs of services and materials  for DOE's Superfund
activities were not  being billed and  collected by the three
DOE Operations Offices.  DOE charged  EPA  for the  materials
and services costs Incurred, but failed to collect an
additional 7 percent for  depredation  and 16 percent for its
administrative costs.  DOE Order 2110.1A on pricing  of
materials and services requires  full  costing of the  materials
and services when the customer 1s outside the Federal
Government.   The current  agreements with  EPA do not  recognize
that Superfund work  1s ultimately charged to organizations
outside the  Federal  Government.   If full  cost pricing were
used,  an additional  23 percent ($214,099)  of the claimed
costs  ($930,867) would have  been collected during FY 1987 at
the three locations  we audited.

In passing legislation authorizing  Superfund, the Congress
Intended that all Superfund expenditures be recovered
whenever possible from the non-Federal Government
organization responsible  for the environmental pollution.
When the EPA conducts the clean-up  operation, 1t collects all
the costs of cleaning up  the pollution from the responsible
non-Federal  Government organization.  Those organizations, not
EPA, benefit from and are liable for the costs of services
and materials provided.  The operations offices should  comply
with DOE's order by  charging the full  costs for Superfund
work.

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The operations  offices  are not recognizing that Superfund
work Is different from  other EPA work because the current
Interagency agreements  do not indicate that these costs are
going to be passed on to non-Federal  Government
organizations.  Audit  reports issued to the individual  DOE
operations office managers discussed  the need to charge full
costs for Superfund work on EPA's Interagency agreements.
This issue is being addressed through the Department's audit
resolution process.

The-results of  our review were discussed with the Deputy
Controller on October 6, 1988.  If you wish additional
details on the  audit, please contact  David Broadwell,
Assistant Manager, Capital Regional Office, at 586-8937.
                             ni i i i a in u w i 11 d u v * i
                             Manager, Capital  Regional Office
                             Office of Inspector General
Attachments

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                                              Attachment 1
                     Department of Energy
                 Inspector General Reports On
              Superfund Costs  - Fiscal  Year 1987

ER-CC-88-30, Interim Audit of  Costs Claimed by the Department
of Energy Under Interagency Agreements No. DW8993024601 and
DW8993173901 for Work Performed by Argonne National
Laboratory, dated June 24, 1988.

ER-CC-88-31, Interim Audit of  Costs Claimed by the Oak Ridge
Operations Office on Selected  Interagency Agreements with the
Environmental  Protection Agency for Work Performed by Martin
Marietta Energy Systems, dated July 12, 1988.

WR-0-88-6, Audit of Costs Incurred on EPA Superfund
Interagency Agreements With The U. S. Department of Energy
Richland Operations Office - October 1, 1986 through
September 30,  1987, dated September 1, 1988.

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                                                       Attachment 2

           Summary  of  Superfund  Obligations,  Claimed  Costs
and
Laboratory*
Agreement Number
*DW8993034101
*DH8993079301
*DW8993147501
*DW8993200201
*DW8993214701
IDW8993024601
#DW8993173901
+DW8993055001
+DW8993070901
+DW8993090101
+DW8993104301
+DW8993137701
Total
Results of Audit
Available
Fundl ng
$ 40,000
19.000
19.980
450,000
315,000
44,000
205,880
55,860
5,701
955
72,894
960,956
$2,190,226
for Fiscal

Claimed
$ 8,152
0
19,639
107.226
0
8,427
133,052
30,919
5.562
0
23.859
594,183
$930,019
Year 1987
Costs
Unresol ved
$







5.562(3)


121,692(4)
$127,254


Questlone
$ 8,15211
(1
14,541(3
97.498C
C

2.035C




0
$122.226
* ORNL -  Oak  Ridge  National  Laboratory
# ANL - Argonne  National  Laboratory
+ PNL - Pacific  Northwest Laboratories
  (1)  The  interagency  agreements  at Oak  Ridge National
  Laboratory  used an  arbitrary  process of charging the  oldest
  funds  first.  Consequently,  we were unable to determine the
  correct  amount of  claimed costs for agreements with multiple
  sources  of  funds.

  (2)  Travel  costs were  Incorrectly posted and claimed  by
  Argonne  National Laboratory.

  (3)  Costs were Incurred by  Pacific Northwest Laboratory after
  the  interagency agreement expired.

  (4)  The  subcontract  costs of  Pacific Northwest Laboratory
  will  be  audited In  the future.

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REPORT NUMBER:   ER-CC-88-31
                    U.S.  DEPARTMENT OF  ENERGY
                   OFFICE OF INSPECTOR  GENERAL
                        OFFICE OF AUDITS
                     EASTERN REGIONAL OFFICE
                   Oak Ridge,  Tennessee 37830
                 Interim Audit of Costs Claimed

               by the Oak Ridge Operations Office

              Under Selected Interagency Agreements

            With the Environmental Protection Agency

                      for Work Performed by

              Martin Marietta Energy Systems, Inc.

              October 1, 1986 to September 30, 1987
Contractor  information contained  in  this  audit  report nay  be
confidential.   The  restrictions  of  18  USC  1905  should  be
considered before this information is  released to the public.

This  report  may  not be  released to anyone outside the Department
of  Energy without the  approval  of  Headquarters Office of Audits,
except  to an Agency involved in negotiating or administering the
contract.  Furthermore, the  information contained in this report
should  not be used for purposes  other  than those intended without
prior consultation with  the  Department of  Energy's Office  of
Inspector General regarding  its  applicability.


                    Prepared By:   Irving Burton Associates, Inc.

                       Date:  July 12. 1988

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REPORT NUMBER:  ER-CC-88-31
                 INTERIM AUDIT OF COSTS CLAIMED
               BY THE OAK RIDGE OPERATIONS OFFICE
              UNDER SELECTED INTERAGENCY AGREEMENTS
            WITH THE ENVIRONMENTAL PROTECTION AGENCY
                      FOR WORK PERFORMED BY
              MARTIN MARIETTA ENERGY SYSTEMS, INC.
              OCTOBER 1, 1986 TO SEPTEMBER 30, 1987
                        TABLE OF CONTENTS


                                                              Page

Purpose and Scope	1

Circur.stances Affecting the Audit	2

Audit Results	2

Recorjr.endat ions	4

Management Reaction	4

Auditor Comments	5

Statement of  Amounts Obligated,  Costs Claimed,
  and Audit Results - Exhibit A	6

Statement of  Superfund Costs Claimed and
  Audit Results  -  Exhibit  B	7

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                   U.S. DEPARTMENT OF ENERGY
                  OFFICE OF INSPECTOR GENERAL
                       OFFICE OF AUDITS
                    EASTERN REGIONAL OFFICE
                  Oak Ridge, Tennessee 37630
                 INTERIM AUDIT OF COSTS CLAIMED
               BY THE OAK RIDGE OPERATIONS OFFICE
              UNDER SELECTED INTERAGENCY AGREEMENTS
            WITH  THE ENVIRONMENTAL PROTECTION AGENCY
                     FOR WORK PERFORMED BY
              MARTIN MARIETTA ENERGY SYSTEMS, INC.
              OCTOBER 1, 1986 TO SEPTEMBER 30, 1987
REPORT NO:  En-CC-88-31                                 JulV 12» 198B
FVF.FOSE AND SCOPE


     As required by the Superfund Amendments and Reauthorization
Act cf 1986, we have performed  an  interim audit of costs incurred
under  five interagency agreements betveen the Department of
Energy's   (DOE)  Oak  Ridge  Operations  Office (ORO)  and  the
Environmental  Protection Agency  (EPA).    Martin Marietta Energy
Syster.s  (Energy  Systems)  performs  the  work  requested  in these
agreements under  the  existing  contract with ORO.  The  five
anteragency agreements and  related work  descriptions  are:
Aareerent                Description

DW8993034101        Assistance  in  genetic  toxicology  studies.

DW8993079301        Technical assistance  in  implementing  a  new
                    analytical   methodology  for  health  risk
                    assessments.                      • .
                                                 *  . •
DW8993147501        Information support to  EPA's  Office  of  Waste
                    Programs Enforcement.        ^ r

DW8993200201        Establishment of  preanalytical holding  tines
                    for environmental samples.

DWB993214701        Assist  EPA  in risk  assessment activities
                    under the Toxic Substances Control Act.

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     The purpose of the audit was  to determine the allowability
of costs that were allocated to  the superfund obligation within
these agreements and claimed for the period October  1,  1986  to
September 30,  1987.  Allowable  costs are costs incurred that are
reasonable,  allocable,  and  in  accordance with the  terms of the
interagency  agreements,  applicable  cost  principles,  lavs and
regulations,  and  generally  accepted accounting  principles and
practices appropriate to  the particular  circumstances.

     The audit  scope was  limited  to reviewing  the accounting
records  and other documentation  supporting  Energy  Systems'
claimed  costs.   Specific  transactions  were  tested.    However,
Energy Systems'  entire  cost control system and technical aspects
of Energy Systems'  performance were not  evaluated.

     As  defined in  the  above  scope,  the audit  was  conducted
according to the  sections of the  generally accepted Government
auditing standards  that  applied and  included  tests of the
contractor's data  and  records  and  other  audit  procedures
considered necessary in the circumstances.   The contract between
OHO and  Energy  Systems, the DOE  Acquisition Regulations, and the
terns and conditions of  the agreements  were used as criteria to
evaluate costs.

CIRCUMSTANCES AFFECTING THE AUDIT

     Four of  the  five  interagency  agreements audited  included
superfund  and  other EPA program  obligations within  the same
agreement.   Energy Systems  accumulated  and billed costs for the
total  interagency  agreement rather  than the  individual program
obligations.   Billed costs  were applied  to  the individual EPA
prograr.  obligations on a first-in,  first-out  basis.  For example,
the earliest EPA  program obligation  received must  be  completely
exhausted before costs are  applied to the next obligation.  EPA
did not  require ORO  and  Energy Systems  to  account separately for
superfund costs incurred.   Consequently, Energy  Systems' records
do not  show  the actual  cost of  superfund  activities for four  of
the five agreements audited.

     We  did not  perform technical  reviews  of  the  interagency
agreements.  Accordingly,   our recommendations for acceptance  of
cost  are qualified  pending  the  contracting  officer's  technical
review of Energy Systems' performance.

AUDIT RESULTS

     We  determined that Energy Systems' records reflect superfund
obligations received and  costs claimed  against these obligations
that  either  agreed with or  could  be reconciled  to  EPA records.
Exhibit  A contains detailed information by interagency agreement.

     As  the  result of  the  failure  to accumulate  superfund costs
separately,  as  discussed in the  special circumstances  affecting
the audit,  we were unable to determine  or audit  the actual cost

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incurred  for  four  of  the  five  agreements  with  superfund
activities.  Instead we  elected to  audit the  $135,017 reported as
incurred and  disclose  that this  amount  was  based  on applying
total interagency agreement costs to the  individual EPA program
obligations on a first-in,  first-out basis.  Costs totaling
$120,191 are questioned because:

     o ,  Employee internal time distribution cards were not
          available to  support labor costs.  Although  we did not
          evaluate  the  entire cost  system at  Oak Ridge National
          Laboratory  we noted  that a January 1988 Internal  Audit
          report disclosed  significant weaknesses  in the  labor
          distribution  system  in effect during Fiscal Year  1987.

     o    A portion of  indirect costs is based on direct labor.

     o    Costs charged to interagency agreement No.  DW8993034101
          could not  be identified by cost elements.  All  costs
          billed  against  the EPA  superfund obligation were
          incurred  in  September  1987.   Total costs for this
          agreement  in  September 1987 were $23,662 and were split
          between  a  non-superfund  and  superfund  EPA program
          obligation.  This split  was done in total,  not by cost
          element.

     The $14,826 balance  of costs  for the  remaining  agreements
are  recommended for acceptance.    Exhibit  B  contains  detailed
inforration by interagency agreement.

     On a test  basis we  examined  payroll  attendance records  for
er.ployees   included  in   costs  billed to  the EPA  superfund
obligation.  These records  were not considered a substitute  for
time  distribution source  documents  because they only show that
the employee was present,  not how  time was spent.

     DOE  Order  2110.1,  Pricing   of Departmental Materials  and
Services,   establishes DOE  policy  for  pricing  materials  and
services provided to organizations  outside DOE.   Other  Federal
agencies  (OFA)  are   charged at  the  Department's full cost less
depreciation  and added factor,  except when the OFA  passes  the
cost  to  an  organization  outside  the   Federal  Government.
Superfund  expenditures related  to  cleaning  hazardous sites  are
often recovered from the  private  organization responsible for the
environmental problem.   Current  superfund  expenditures incurred
by  Energy  Systems  are  not site  specific;  however,  the  costs
billed  to EPA may be treated as superfund overhead and recovered
from  organizations  outside the Federal Government.   Therefore,
charging EPA  the Department's full  cost  recovery  rate would be
appropriate.    If  EPA recovers   DOE  cost  from  an organization
outside the Federal Government, an additional 7 percent  for
depreciation  and an  additional  16 percent  for  Department
administrative  costs (added factor)  should  be billed.  We found
no  evidence  indicating  that  either  ORO  or  Energy  Systems
recognized  that EPA may not be the ultimate customer.

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RECOMMENDATIONS

     1.   We recommend  that  the  Manager,  Oak  Ridge Operations
Office, require Energy Systems  to:

          a.   Accumulate and bill the  cost  of  each EPA program
               obligation,  such as  superfund,  separately within
               the same interagency  agreement.

          b.   Retain  for  3.  years  individual  internal  time
               distribution  cards  signed  by  the employee  to
               support superfund costs claimed.

     2.  We    also  recommend   that  the  Manager,   Oak  Ridge
Operations Office, require appropriate staff members to  evaluate
future superfund  tasks  to  identify  instances where the  ultimate
customer  is  an organization  outside  the  Federal Government  and
arrange with EPA  to recover  depreciation and Departmental  added
factor.

MANAGEMENT REACTION

     The Manager,  Oak Ridge Operations Office (ORO),  responded to
the report.  His comments are summarized below.

Eecor.rendation 1

     Management concurred  in Part A  of the recommendation.  ORO
presently  cannot  determine which program obligations  (superfund
or  nonsuperfund)  are to  be  accounted  for  separately within  an
interagency  agreement.   This  determination  must be made by  the
EPA.   Upon accepting  future work,  ORO will  request the EPA  to
segregate  on each  funding  authorization document those  superfund
activities  where  the  cost  will  be  passed  on  to  the  private
sector.   If EPA agrees, ORO will  then direct  Energy Systems  to
accumulate  and bill  the costs  in accordance with the guidelines
on each funding authorization document.

     Management nonconcurred in Part  B of the recommendation  and
stated  that there  is  no requirement  for  signing  and  retaining
time cards in  DOE's contract  with  Energy  Systems,  and  that  the
present systems contains sufficient  internal controls to produce
accurate  and reliable cost  distribution  reports.   Also,  Energy
Systems  is moving to  an electronic  input  system which will  do
away with  all  time cards for labor distribution purposes.

Recommendation 2

     Management stated  that  upon accepting  future work,  the  EPA
will be requested to segregate superfund and non-superfund tasks.
After  this is done,  recovery  factors  for  depreciation  and
Departmental administrative costs can  be added to the other costs
billed.

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AUDITOR COMMENTS

     Management's comments are responsive to recommendations  l.a.
and 2.

     With respect to recommendation l.b., we  believe  that labor
costs billed under  EPA superfund agreements  are  not  adequately
supported under the current  system  without  time  distribution
cards signed  by the employees.   With  respect to  management's
comment  that  the  present  system  contains  sufficient  internal
controls to produce  accurate and  reliable  cost distribution
reports, recent reviews by Energy System's internal auditors  have
disclosed significant weaknesses  in  the  labor distribution
system.   Furthermore,  the planned electronic input system should
have adequate  controls and supervisory review  to assure  the
accuracy of the labor distribution.
                                   Irving  Burton Associates, Inc.


                                   Accepted  Bv:

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                                                                                                Inhibit *
                                          O»k  Ridge Operations Office
                                           C>» Internqency Agreement!

                     Statement  of  Amounts  Obligated,  Cost* Claimed,  snd Audit Results
                                     October 1.  1986  to September 30, 1987
                                                                                      Co* 11 C I • lined
• yfbvr ___

  OW899J034101

  DU899J079J01
  DWB993200201

  OU699S2U701

     TOTAl
  Quest lontd by Audit (1)

     ••I «net
	io«;i_

»  125.500

    64,000

    19.980

   450.000

	630Aogo

•1.289,480
Super f und

 t 40.000

   19.000

   19,980

  450,000

 _3i5Agog

 tB43.9BO
__fot •! _

« 94.016

  11.5JJ

  19.639

 207.226
•653.606
••••*•••
Super fund

 »  8, 152



   19.619

  107,226



 «135,017




  1Z0.191

 » 14.826
 ••••••••
    (1)
Notef:
(1)  Details by agreement are shown  In  exhibit  I.

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 •t»ptr
                  ER-CC-88-3 1
                                                                               Inhibit •
                                                      Oak  tidqe Operations Office
                                         Statement  of  Super fund Co^tS Clulmrd and Audit
                                                 October  1.  19r16  to September 50. 19rU
                                                           Agreement Number
                                     DU89930U101
Direct labor
Materials
Subcontract I
Other Direct
Total Direct
Indirect Cost*
    total Co*tt

Audit.*«sultt
Questioned by Audit:
'•Mure to Identify
  Super fund Cottt Elements (3)
Direct labor (t)
Indirect Cotti (5)
    Total Oueitioned Cotti
    ••lance
18.1)2(1)
 8.152
                   	-0-
                   t  -0-
OW8993HH01

  S11.200
    5.061
      614
  	212
   15.127
  _ 44512
  S19.619
                                                  OUB99J20070I   DUS99S214f'01      tOfAL
                                     11.200
» 5,098
*r»r i=>
                __2A003
                 82.381
                 2tt8O_
                S107.226
                  74.909
                _224589
S  9,728
                    •0-(2)    S135.017
                               8.152
                              86.109
                                              _120t191
                                              < U.B26
Motet:
fll  lh« flrtt-ln. flrtt-out •wthod of •(locating  cottt  to IPA prograM obllgttlons wat applied on a total-cost batlt rathtr than
     by Individual c*tt clcawnta.
(2)  The flrat-ln.  f(rat-out  method of  allocating cotta  to  obllgatlona  resulted In  no  cottt being charged  to  thlt agreement.
(3)  total   coata  for  Agreement  No. OW8993034101  In  September  1987  were  S23.662 and  were  tptlt between  a non- super fund and
     tuperfund (f>*  program obligation on a  total  cott batlt.   A  breakdown of the SB. 152  luperfund  portion by cost  element  la
     unavailable.   We did not* that total coat were primarily labor.
(4)  Direct  labor cotta  art  quettloned  because  employee  Internal  time dlatrlbutlon  cards,  which  are  the  supporting  source.
     documentt. were not retained,  labor houra could not be traced beyond summary report! of  time  distribution.
(5)  Indirect cotta quettloned were bated on direct labor questioned.
                                                                   7

-------
Report Number:  ER-CC-83-30
                    U.S.  DEPARTMENT OF ENERGY
                   OFFICE OF  INSPECTOR GENERAL
                        OFFICE  OF AUDITS
                     EASTERN  REGIONAL OFFICE
                   Oak Ridge, Tennessee   37830
                 Interim Audit of Costs Claimed

                   by the Department of Energy

 Under Interagency Agreements No. DW8993024601 and DW8993173901

            With the Environmental Protection Agency

                      for Work Performed by

                  Argonne National'Laboratory,

                        Chicago, Illinois

              October 1, 1986 to September 30, 1987
Contractor  information contained  in  this  audit  report  may  be
confidential.   The  restrictions  of  18  USC 1905  should  be
considered before this information is released  to the public.

This  report may  not be  released to anyone outside the Department
of  Energy without the  approval  of  Headquarters Office of  Audits,
except to an  Agency involved  in negotiating or administering the
contract.  Furthermore, the  information contained in this  report
should not be used for purposes other than  those intended  without
prior consultation with  the  Department of  Energy's  Office  of
Inspector General regarding its applicability.


                    Prepared  By:   Irving Burton Associates,  Inc.


                                         Date: June 24, 1988

-------
Report Number:  ER-CC-88-30
                 INTERIM AUDIT Of COSTS CLAIMED
                   BY THE DEPARTMENT OF ENERGY
 UNDER INTERAGENCY AGREEMENTS NO. DW8993024601 AND DW8993173901
            WITH THE ENVIRONMENTAL PROTECTION AGENCY
                      FOR WORK PERFORMED BY
                  ARGONNE NATIONAL LABORATORY,
                        CHICAGO, ILLINOIS
              OCTOBER 1, 1986 TO SEPTEMBER 30, 1987
                        TABLE OF CONTENTS
                                                        Paae
Purpose and Scope  	1

Audit Results  	2

Management Reaction	2

Statement of Amounts Obligated,  Costs  Claimed,
  and Audit Results  -  Exhibit  A  	3

-------
                   U.S. DEPARTMENT OF ENERGY
                  OFFICE OF INSPECTOR GENERAL
                       OFFICE OF AUDITS
                    EASTERN REGIONAL OFFICE
                  Oak Ridge, Tennessee   37830
                INTERIM AUDIT Of COSTS CLAIMED
                  BY THE DEPARTMENT OF ENERGY
 UNDER INTERAGENCY AGREEMENTS NO. DW8993024601 AND  DW8993173901
            WITH THE ENVIRONMENTAL PROTECTION AGENCY
                     FOR WORK PERFORMED BY
                 ARGONNE NATIONAL LABORATORY,
                       CHICAGO, ILLINOIS
              OCTOBER 1, 1986 TO SEPTEMBER 30, 1987
REPORT NO:  ER-CC-88-30                                June 24,  1988
PURPOSE AND SCOPE

     As required   by the Superfund Amendments and Reauthorization
Act of 1986,  we have performed an interim audit of costs incurred
under  interagency  agreements  DW8993024601  and  DW8993173901
between   DOE's   Chicago   Operations   Office   (CH)   and   the
Environmental Protection Agency  (EPA).   The  Argonne   National
Laboratory (ANL)  performed  the work projects set  forth in  these
agreements under its  cost-type contract  with  CH.    Agreement
nur.ber   DW8993024601   requested   that  certain   samples   of
contaminated materials  that EPA  sent  to  ANL be  tested at  an
outside lab  and/or maintained in protective storage.   Agreement
number  DW8993173901  requested  that  DOE  direct  and  monitor
decontamination of  a  site  in Lansdowne,  Pennsylvania,  provide
certification  required  for the disposal of  the contaminated
material,   and  conduct   a  radiological  assessment  and/or
decontamination certification.

     The purpose of the audit was  to  determine the allowability
of S141,479  of costs claimed  for the period October  1, 1986, to
September 30, 1987.   Allowable costs are cost  incurred which are
reasonable,  allocable,  and  in accordance with the terms of the
interagency agreements, applicable cost  principles,  laws and
regulations, and  generally  accepted  accounting  principles  and
practices appropriate to the particular  circumstances.

     The   audit  scope was  limited to  reviewing  the  accounting
books  and records  and  other documents supporting  the  ANL's
claimed  costs.    Specific  transactions  were  tested.    However,
ANL's total  internal control system and technical aspects of the
ANL's performance were  not  evaluated.

-------
     As  defined  in  the  above  scope,  the  audit was  conducted
according to the  sections  of  the generally  accepted Government
auditing standards  that  applied  and included tests  of  the
contractor's  data  and  records  and  other  audit procedures
considered necessary  in the circumstances.   The contract between
CH and ANLf the  DOE  Acquisition Regulations,  and the  terns  and
conditions of  the interagency  agreements were used as criteria to
evaluate costs.

AUDIT RESULTS

     The audit results are summarized below.   Details of claimed
costs and audit results are contained in exhibit A.


               Questioned Costs         $2,035


     The audit results were discussed  with  Al  Nisius,  ANL Chief
of Accounting,  who agreed with our findings.

MANAGEMENT REACTION

     Management concurred  with  the  questioned  costs and  stated
that a correcting entry has been made.
                                   Irving Burton Associates,  Inc
                                   Accepted Bv;


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REPORT NUMBER:ER-CC-88-30
                                Exhibit A
                                Page 1 of 3
     Environmental  Protection Agency Interagency Agreements
               Amounts Obligated and Costs Claimed
                       Fiscal Year 1987
Agreement
Number

DW8993024601

DK8993173901

     Total
  Amount   Responsible   Cost Claimed
Obligated  DOE Office       by  DOE
Results of Audit


               Notes
S 44,000   CH Operations   $   8,427

 205,880   CH Operations    133,052

$249,880                  $141,479
Note 1 -  This agreement  requested the performance of a number of
          different  projects.     Only  the  work   related  to
          protective  storage  of  hazardous  waste  samples  or
          certain lab fees was  chargeable to the  EPA Superfund
          appropriation.    However,  the  monthly   interagency
          billing to  the  EPA's   Cincinnati  Finance Office shows a
          total  charge  for  all projects  in  the  agreement.
          Detailed monthly reports submitted by  ANL are used by
          the  EPA  Project Officer  to  track  costs  on specific
          projects,  but  these amounts could not be reconciled to
          amounts allocated to  the  Superfund appropriation from
          the  monthly billing.    Our review indicated  that the
          costs  amounts  in the  monthly reports  were generally
          valid.

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REPORT NUMBER: ER-CC-88-30                          Exhibit A
                                                  Page 2 of 3


      Statement of The Department of Energy's Claimed Costs
                        and Audit Results
            Interagency Agreement Number DW8993024601
                        Fiscal Year 1987
       .-,

                                     Audit Results 	
                   DOE's        Questioned    Unresolved
               Claimed Costs       Costs          Costs
Direct Labor   $  1,188

Other Direct      5,702

Total Direct   $  6,890

Indirect Costs    1,537
Total Costs    $  8,427          $    -0-       §   -0-

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REPORT NUMBER:  ER-CC-88-30
                 Exhibit A
                 Page 3 of 3
      Statement of The Department  of  Energy's  Claimed Costs
                        and Audit  Results
            Interagency Agreement  Number DW8993173901
                        Fiscal Year 1987

                                        Audit Results
Direct Labor

Material

Other Direct

Total Direct

Indirect Costs

Total Costs    $133,052
DOE's Questioned Unresolved
Claimed Costs Costs Costs Notes
$ 38
5
65
$108
24
,307
,056
,411 $1,664
,774 1,664
,278 371
1

2

3
$2,035
-0-
Note 1 -  Effort  distribution  reports prepared  by nonscientific
          personnel in two cost centers had not been retained and
          were not available for audit.  Total direct labor costs
          charged  to  the  interagency  agreement  by these  cost
          centers were $20,199  in  Fiscal  Year 1987.  Alternative
          procedures were used to determine the reasonableness of
          the charges.

Note 2 -  Travel  costs were  posted incorrectly.   The interagency
          agreement  account  number  was very  similar to  the
          correct account number.

Note 3 -  Indirect  cost  applicable to  questioned  travel  costs
          ($1,664 X 22.32 percent).

-------
ORT NO.

0-88-6
U.S. Department of Energy
Office of Inspector General
     Release Date:

September  1, 1988
                   ADDIT OP COSTS INCURRED ON EPA

                  SDPERFUND INTERAGENCY AGREEMENTS

                 WITH THE D.S. DEPARTMENT OF ENERGY

                    RICHLAND OPERATIONS OFFICE

             OCTOBER 1, 1986 THROUGH SEPTEMBER 30, 1987

-------
REPORT NO: WR-0-88-6
                    0.S.  DEPARTMENT.OF ENERGY
                   OFFICE OF  INSPECTOR GENERAL
                       OFFICE OF AUDITS
                         WESTERN REGION
                     ALBUQUERQUE, NEW MEXICO
                 AUDIT OF  COSTS INCURRED ON EPA

                SUPERFUND  INTERAGENCY AGREEMENTS

               WITH THE U.S.  DEPARTMENT OF ENERGY

                   RICHLAND OPERATIONS OFFICE

           OCTOBER 1,  1986 THROUGH SEPTEMBER 30, 1987

-------
REPORT NO: WR-0-88-6
                 AUDIT OF  COSTS  INCURRED ON EPA
                SDPERFDND  INTERAGENCY AGREEMENTS
               WITH THE U.S. DEPARTMENT OF  ENERGY
                   RICHLAND OPERATIONS OFFICE
           OCTOBER 1,  1986 THROUGH  SEPTEMBER 30, 1987

                        TABLE  OF CONTENTS
PURPOSE AND SCOPE 	  1

RESULTS OF AUDIT	2

     Full Cost Recovery	2

     Expired Agreement	3

     Subcontract Costs Claimed	3

RECOMMENDATIONS 	  3

MANAGEMENT REACTION  	  4
Exhibit A

Exhibit B



Exhibit C


Exhibit D


Exhibit E


Exhibit F
Exhibit G
  Page 1

  Page 2
Amounts Obligated and Costs Claimed

Statement of Claimed Costs and Audit Results
EPA Interagency Agreements with the Richland
Operations Office

Statement of Claimed Costs and Audit Results
EPA Interagency Agreement Number DW8993055001

Statement of Claimed Costs and Audit Results
EPA Interagency Agreement Number DW8993070901

Statement of Claimed Costs and Audit Results
EPA Interagency Agreement Number DW8993090101

Statement of Claimed Costs and Audit Results
EPA Interagency Agreement Number DW8993104301

Statement of Claimed Costs and Audit Results
  EPA Interagency Agreement  Number  DW8993137701

  Statement of Subcontracts  EPA Interagency
  Agreement Number SW8993137701

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                   U.S. DEPARTMENT OF ENERGY
                   OFFICE OF INSPECTOR GENERAL
                       OFFICE OF AUDITS
                        WESTERN REGION
                    ALBUQUERQUE, NEW MEXICO
                 AUDIT OF COSTS INCURRED ON EPA
                SUPERFUND INTERAGENCY AGREEMENTS
               WITH  THE U.S. DEPARTMENT OF ENERGY
                  RICHLAND OPERATIONS OFFICE
           OCTOBER 1, 1986 THROUGH SEPTEMBER 30, 1987
Report No:  WR-0-88-6                        September 1, 1988
     Section  III  or  cne  superrund  Amendments and Reauthorization
Act of 1986  requires annual  audits of payments, obligations,
reimbursements,  and other  uses  of the  Environmental  Protection
Agency (EPA)  Superfund   appropriations to assure that the fund is
being properly  administered.   The Department of Energy  (DOE)
expends  Superfund monies through  a  series of interagency
agreements  with EPA.

     DOE  Richland Operations Office (RL)  had five open agreements
with EPA during Fiscal  Year  (FY)  1987.  Exhibit A contains data
relating  to amounts  obligated and claimed during the year.

     Work performed on  the  open agreements was  accomplished  by
Battelle  Memorial  Institute  through  RL's  prime  contract Number
DE-AC06-76RL01830. Under  that  contract,  Battelle manages  and
operates  DOE's Pacific   Northwest   Laboratory  (PNL) .

     The  purpose of the audit was  to  determine the allowability
of costs that were  allocated  to the  superfund obligation within
these agreements and claimed  for  the  period October  1,  1986  to
September 30, 1987. Allowable costs are  costs incurred that are
reasonable, allocable,   and  in  accordance  with the terms of the
interagency  agreements,  applicable  cost  principles,  laws and
regulations,   and  generally accepted  accounting  principles  and
practices appropriate  to the particular  circumstances.

     The  scope of the  audit included evaluating PNL's accounting
books and records and  other supporting documentation on which the
claimed costs were  based.   A study  and evaluation  of PNL  internal
accounting control  was not made because internal  accounting con-

-------
trol is studied and evaluated as a part of other  audits  of  PNL.
The  results of prior internal  accounting  control  study  anc
evaluation established a  basis  for reliance thereon and  for  the
determination of the  extent  to  which  auditing  procedures  were tc
be  restricted.   Technical aspects  of  the  effort  were  not
evaluated.  We  also reviewed RL's application of the added factoi
to the work performed  under the interagency agreements.

     The  audit  was   completed according  to  generally accepted
government auditing  standards and included  such tests of  the
contractor's data  and  records and  such  other  auditing  procedures
as were considered necessary.

     This  report may  not  be  released  to anyone  outside  of DOE 01
EPA without  the  approval   of DOE Inspector  General,  Office oi
Audits, except  to  an agency involved  in  negotiating    01
administering the  contract.

RESULTS OF AUDIT

     The Richland  Operations  Office did not follow the  DOE  regu-
lations requiring  full cost  recovery for  services and materials
provided to non-DOE  organizations.   As  a  result,  RL underrecov-
ered $130,250 on its EPA  agreements during FY 1987.  In addition,
PNL procedures were not followed, resulting  in PNL  incurring
$5,562  of unresolved  cost  on an  agreement  that had expired.
Unaudited  subcontract  costs  of  $101,735 and related PNL costs of
$19,957 have been  classified  as unresolved.  We consider $527,269
of the $654,523 claimed cost acceptable.
                 a
     Cust  Rcoove-E
          eider  2T10.1,  Pricing of  Departmental  Material  and
Services, dated  February 16, 1984 establishes  DOE   policy  for
pricing materials  and  services  provided to non-DOE organizations
either  directly or through operating contractors. The  Order
requires that other  Federal  agencies  be charged the Department's
full cost less depreciation and  added  factor, except   when the
other agency passes costs  to  organizations outside  the Federal
Government.  Under  those circumstances,  the  charge for materials
and services shall be  the Government's  full cost.

     Based upon  the principle that "the polluter should pay", the
Superfund Act authorizes  enforcement  action  and  cost  recovery
from those  responsible  for a hazardous waste  problem.  These
recoveries,  plus tax revenues,  are the main  source  of funds for
cleaning up  hazardous waste sites.  Recoveries may play  a  major
role in replenishing the Supjerfund.

    "We  found "that  RL was  not  recovering the full 'c6st incurred
for the EPA  agreements as required by  DOE Order 2110.1. Current

-------
superfund expenditures incurred by^PNL generally do not relate to
a  specific contaminated site.  However,  the costs billed to EPA
are treated  as   superfund overhead and may be recovered from
organizations outside  the   Federal  Government. Under  those
circumstances,   charging EPA the Department's  full cost recovery
rate would be   appropriate. For  FY 1987 the full  cost recovery
rates  for  work  performed  at  PNL were 2.9  percent   for
depreciation  and  17  percent  for  the Department's  added  factor
(administrative  costs) . Thus,  the  underrecovered amount based on  ]
FY 1987 costs ($654,523) was $130,250.                       O—^

Expired Agreement

     The  period  of performance for agreement  DW8993070901 was
from  March  1,  1984  through  September 30,  1985.  Although the
agreement  was  never  extended,  PNL  incurred  costs  and   was
reimbursed $49,531 in FY 1986  and  $5,562 in FY 1987.
                                                              _
     We sampled  the costs incurred  during FY 1987  and found them
to  be  adequately supported and incurred  for purposes of
accomplishing the  work scope.  In addition we noted  that  EPA has
obligated sufficient  funds to  cover expenditures. Nevertheless,
we believe the  agreement should  be modified to  assure contract
compliance.
                                             . .  --.    'TV-'
Subcontract Costs  Claimed
                                                                          ~C(_
                                                                          '
             A-6-Ghown-—tn  tixniort—&,  we  are  classifying $121,692  in
         subcontract  related costs  as  unresolved.  PNL  entered  into
         subcontract agreements with several firms to accomplish the work
         scope  of  agreement  number  DW899313.7701.  We have not audited the
         costs  incurred ($101,735)  by  the  subcontractors  listed  on Exhibit
         G  page two.  Our tests  did,  however,  include PNL's indirect
         ($10,651)   and  service charge  ($9,306)  costs    related to those
         subcontracts. Those tests  indicated that PNL applied appropriate
         indirect  and  service  charge  rates and  we  would recommend those
         costs  for  acceptance  if the  base cost  is  determined  to  be
         allowable.
                	9-^
         RECOMMENDATIONS^
I\\J«L. Cf^fe- cfa	 v
          f ' t*e recommendxthat the Manager,  Richland Operations  Office:
         A^JX*—
         Ofr                                                          "* -—
             -Evaluate  each existing  and future Superfund  task to
         identify instances where the ultimate customer is an organization
         outside the  Federal  Government and  arrange  with EPA to  recover
         Departmental depreciation and added  factor.
                                                                       ..^
             -Monitor agreements  more  closely to  assure that costs  are
         not incurred on agreements which have expired.

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                           /I
     RL' agreed with our finding that costs  were  incurred  on an
interagency agreement whose period of performance  had  expired and
agreed that interagency agreements should be monitored to assure
that costs are not  incurred on expired agreements.            	•

     RL stated that they were  unable  to  determine why the
agreement  was not formally  extended.  They stated  that  PNL's
practices  and procedures  are designed to  identify,  in a timely
manner, work orders with  periods  of performance about to expire
or budgets nearly  expended. As the  work orders are  identified,
actions are taken to extend the time period or  request additional
funding
                                                            £. •
                                                          fc;
        did  not agree  with otrr finding  and  recommendations
concerning full  cost  recovery for the following reasons.

—  Full cost recovery policy does  not  apply to work performed
    under  an  interagency agreement.  Further,  they  contend that
    work performed  under these  agreements  is not  for  a non-
    federal  third party.

—  Full  cost recovery may  be charged  when  the Statutor;
    authority for an agreement with another federal agency i:
    other  than the Economy  Act  of  1932. The agreements  in thj
    report are authorized under the Economy  Act.
                                                 use  full cost
                                                 Federal  agency
                                            cost recovery  rules
                                             or services  to be
                                        Federal government. The
                                         establish  standards and
                                                         to EPA
                                       Financial  Management and
                                             these  costs will be
                                       on to responsible parties
     W« agreej that it  is  DOE's policy not  to
recovery when the  work  performed  is for another
only. However,  it is DOE policy to use  full
when  the  charges  become  part of  the  cost
provided to  organizations  outside  the
primary work  under  these agreements is __ 	 	
criteria  which relate  to future  projects.  According
officials  and  their  draft "Superfund  Fin	•-1  "	
Recordkeeping Guidance for Federal Agencies ,
i-r*»ai-pd as overhead and  will  be passed  on to
treated
outside
as
of
           EPA.
     DOE Order 2110.1,  which contains the full  cost recovery
policy,  relates  to  interagency  agreements  funded  under the
Economy Act.  The policy also states that full cost  recovery  rules
can apply to  agreements funded under other authorities.

     At the exit conference,  RL officials informed us that  they!
would submit  a decision paper to the DOE Controller on the  full'
cost recovery issue.

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                                                  Exhibit A
  Agreement
   Number

DW8993055001

DW8993070901

DW8993090101

DW8993104301

DW8993137701
               EPA and Richland Operations Office
                     Interagency Agreements
               Amounts Obligated and Costs Claimed
Amount Obligated
Costs Claimed
FY 1987
$ 25,000
-0-
-0-
60,000
250,000
Cumulative
$ 546,700
130,900
228,800
110,000
1,164,100
FY 1987
$ 30,919
5,562
-0-
23,859
594,183
Cumulative
$ 521,759
130,761
227,845
60,965
797,327
                   $335,000  $2,180,500   $654,523   $1,738,657
NOTE
PNL carries unobligated amounts to subsequent  fiscal  years,

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                                                 Exhibit B

          Statement of Claimed Costs and Audit Results
                 EPA  Interagency Agreements with
                 the  Richland Operations Office
                       Fiscal Year 1987

                     Claimed   Recommended For   Unresolved
   Cost Element       Costs      Acceptance        Costs    Notes

Salaries & Fringe
  Benefits         $169,209      $166,678       $  2,531     1

Overhead             113,516       112,158          1,358     1

Materials        .    33,889        33,865             24     1

Subcontracts          101,735         -0-          101,735     2

Other Direct          72,022        62.714          9,308    1&2

Total Direct        $490,371      $375,415       $114,956

Indirect             164,152       151,854         12,298     3

Total Costs        $654,523      $527,269       $127,254

NOTES

1.  These costs  were incurred after  the agreement  had expired.
    The agreement had not been extended by modification; however,
    sufficient  funds  had been obligated  to  cover  claimed costs.
    (See Exhibit  D)

2.  PNL  entered  into  subcontracts  with several  firms to
    accomplish the  work scope on  one  agreement.   None of  the
    subcontracts  have been  audited  by  us.   The  service  charge
    costs related to administrating those  subcontracts are also
    classified as being unresolved.  (See Exhibit G)

3.  Indirect  costs are comprised of service assessment costs and
    General  Administrative (G&A)  costs  for  PNL  operations.
    Service Assessments  are Hanford-wide costs,  such as Hanford
    security  forces,  which  are assessed by DOE to each  contractor
    on the reservation.  These costs  are assessed  on total cost
    including G&A. The service assessment rate was 4.7 % through
    March 29, 1987 and 7.0%  thereafter. The G&A  rate was 35.9% of
    the "value  added" base. Cost elements  included in the  value
    added  base  are  generally  all costs  except  materials,
    subcontracts,  and indirect costs.  Unresolved indirect  costs
    were calculated  by  applying  the  appropriate rates to  the
    unresolved direct costs.

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                                                  Exhibit C
          Statement of Claimed Costs and Audit Results
          EPA Interagency Agreement Number DW8993055001
               With The Richland Operations Office
                        Fiscal Year 1987
  Cost Element
         .-.
Salaries & Fringe
     Benefits

Overhead

Materials

Subcontracts

Other Direct

Total Direct

Indirect

Total Costs
Claimed
Costs
$ 8,611
6,599
379
-0-
6,269
$21,858
9,061
$30,919
Recommended For
Acceptance
$ 8,611
6,599
379
-0-
6,269
$21,858
9,061
$30,919

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                                                 Exhibit D
          Statement of Claimed Costs and Audit Results
          EPA Interagency Agreement Number DW8993070901
               With The Richland Operations Office
                       Fiscal Year 1987
                    Claimed
   Cost Element       Costs

Salaries &  Fringe
     Benefits        $ 2,531

Overhead             1,358

Materials               24

Subcontracts            -0-

Other Direct          	2.

Total Direct         $3,915

Indirect             1,647

Total Costs         $5,562
NOTES
Recommended For
  Acceptance
    $ -0-

      -0-

      -0-

      -0-

      -0-

      -0-
Unresolved
  Costs    Notes
    $ -0-
 $ 2,531

   1,358

      24

     -0-

   	2.

  $3,915

   1.647

  $5,562
1

1

1
    These  costs were incurred  after  the agreement  had  expired.
    The agreement  had not been  extended  by modification; however,
    sufficient  funds had been obligated  to cover claimed costs.

    Indirect costs are comprised of service assessment costs and
    General  Administrative (G&A)  costs  for  PNL  operations.
    Assessments are  Hanford-wide  costs,  such as Hanford security
    forces, which are assessed by DOE to  each contractor  on the
    reservation.   These  costs  are assessed on  total  cost
    including G&A.   The service assessment rate  was 4.7 % through
    March  29, 1987 and 7.0% thereafter.  The  G&A  rate was 35.9%
    of the  "value  added" base.  Cost elements included  in the
    value  added base are  generally  all costs except materials,
    subcontracts,  and indirect costs.  Unresolved  indirect costs
    were calculated  by applying  the appropriate rates  to the
    unresolved  direct costs.

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                                                  Exhibit  E
          Statement  of  Claimed  Costs  and  Audit  Results
         EPA Interagency  Agreement  Number DW 8993090101
               With  The Richland  Operations Office
                       Fiscal  Year 1987
No costs were obligated,  incurred  or  invoiced during  FY 1987

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                                                  Exhibit F
          Statement of  Claimed  Costs  and  Audit Results
         EPA Interagency Agreement Number DW 8993104301
               With The Richland  Operations Office
                        Fiscal  Year 1987
                     Claimed
   Cost Element        Costs

Salaries & Fringe
     Benefits       $  -0-

Overhead               -0-

Materials             10,861

Subcontracts           -0-

Other Direct           8,272

Total Direct         $19,133

Indirect               4,726

Total Costs          $23,859
Recommended For
  Acceptance
   $  -0-

      -0-

     10,861

      -0-

      8,272

    $19,133

      4,726

    $23,859

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                                                 Exhibit G
                                                 Page 1

          Statement of Claimed Costs and Audit Results
         EPA Interagency Agreement Number DW 8993137701
               With The Richland Operations Office
                       Fiscal Year 1987

                    Claimed   Recommended For   Unresolved
  Cost Element       Costs      Acceptance        Costs    Notes

Salaries & Fringe
     Benefits        $158,067     $158,067         $  -0-

Overhead             105,559      105,559            -0-

Materials             22,625       22,625            -0-

Subcontracts         101,735        -0-            101,735   1

Other Direct          57,479       48,173            9,306   2

Total Direct        $445,465     $334,424         $111,041

Indirect             148,718      138.067           10.651   3

Total Costs         $594,183     $472,491         $121,692


NOTES

1.  None of the subcontract costs have been audited by us.

2.  Other  direct  costs are   service  charge  costs PNL  incurs
    administrating subcontracts.

3.  Indirect costs are comprised of service assessment costs and
    General  Administrative   (G&A)  costs  for  PNL  operations.
    Service Assessments  are Hanford-wide costs,  such as  Hanford
    security forces, which  are assessed  by DOE  to  each contractor
    on  the  reservation. These costs  are assessed  on total cost
    including G&A. The  service assessment rate was 4.7 %  through
    March 29,  1987  and 7.0% thereafter.  The  G&A rate was 35.9%
    of  the  "value added" base.  Cost elements included in the
    value added base are  generally all  costs  except materials,
    subcontracts, and  indirect costs.    Unresolved  indirect costs
    were  calculated  by applying  the appropriate rates to the
    unresolved  direct costs.

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                                                  Exhibit G
                                                  Page 2
                    Statement of Subcontracts
         EPA Interagency Agreement Number DW 8993137701
               With The Richland Operations Office
                        Fiscal Year 1987
 Number      Subcontractor

BQ 1336   Fred Hutchinson Cancer
           Research Center

BQ 1316   Fred Hutchinson Cancer
           Research Center

BQ 1315   R. Craig Schnell

BG 8294   Westjet Air Center

BL 3002   Battelle Conference Center

BQ 8283   James J. Morgan

                                    $101,735
FY 1987
Amount
$ 75,903
30,145
1,817
758
662
(7.5501
Contract
Ceiling Notes
$132,038
30,726
9,060
900
—
7,600




1
2
NOTES

1.  Subcontract sets rates for conference room rental.

2.  Negative figure is reversal of FY 1986 accrual.

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                        Department of Energy
                            Washington, DC 20545

                          November 22,  1988
Mr. Ernest E.  Bradley,  III
Assistant Inspector General  for Audit
Office of the  Inspector General (A-109)
Environmental  Protection  Agency
401 M Street,  S.W.
Washington, D.C.   20460

Dear Mr.  Bradley:

We conducted an  audit  of  the Fiscal Year  (FY)  1987  Superfund costs claimed
by the Department  of Energy  (DOE)  on interagency  agreements. The
Environmental  Protection  Agency (EPA) entered  into  the  agreements with
various DOE field  offices for  the  performance  of  specific  services.  The
agreements were  assigned  to  DOE contractors  for actual  performance.  After
reviewing the  contractors' invoices for work performed, the appropriate DOE
field offices  obtained reimbursement from EPA.

Our audit reviewed 12  agreements with claimed  costs of  $930,019 of which
$680,539 was acceptable,  $122,226  was questioned, and $127,254 was
unresolved. Details are  in  the enclosed  reports.   Please  note that  these
reports may contain proprietary information.

An additional  observation during the audit was that we  could  not  reconcile
FY 1987 DOE and  EPA obligation and cost records for 6 of the  12 interagency
agreements.  (See  Exhibit A.)  The exhibit shows  DOE's  obligation was
approximately  $463,000 more  than EPA records indicate.   Also,  DOE's  cost
records indicate approximately $270,000 more than EPA records.

Our August 24, 1987 letter to  you  suggested that  future interagency
agreements specifically require the accumulation  and reporting of Superfund
costs.  We believe that a better audit trail is needed  for Superfund
interagency agreements.  For example, some current Interagency agreements
include both Superfund work  and non-Superfund  work  in the  same agreement.
As a result, DOE is not always maintaining separate records on the  specific
use of the Superfund funds.

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If you wish additional  details  of the audit,  or have questions about
release of the attached reports,  please contact David Broadwell, Assistant
Manager, Capital  Regional  Office, at 586-8937.

                                      Sincerely,
                                       )Fdon W.  Harvey
                                      Assistant Inspector General
                                        for Audits
                                      Office of Inspector General

4 Enclosures

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                                                  Exhibit  A
                  Unreconciled  EPA  and  DOE  Superfund
Interagency Agreements -
Agreement Number
DW8993055001
DW8993070901
DW8993090101
DW8993104301
DW8993137701
DW8993024601
Total
Agreement Number
DW8993055001
DW8993070901
DW8993090101
DW8993104301
DW8993137701
DW8993024601
ObHgatl
DOE Records
$ 55,860
5,701
955
72,894
960,956
44,000
$1,140,366
Costs
DOE Records
$ 30,918.93
5,561.80
0
23,859.03
594,182.99
8,427.00
Fiscal Year 1987
on Balance
EPA Records
$ 20,056
11,828
894
15,851
561,707
66,604
$676,940
Cl aimed
EPA Records
$ 20,056.61
11,688.96
- 60.28
15,851.57
311,707.28
34,104.14
Difference
$ 35,804
-6,127
61
57,043
399,249
-22,604 (1)
$463,426
Di f ference
$ 10,862.32
- 6,127.16
60.28
8,007.46
282,475.71
- 25,677.14
     Total
$662,949.75
$393,348.28
$269,601.47
(1) This agreement is  with  the  Chicago Operations  Office.   All  the
other agreements are  managed  by the Richland Operations Office.
                                                                    (1)

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