January 1995
        Office of the
    Inspector General
    Report to Congress
J~L
IG
rui
n
    Fiscal 1994

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i he Inspector General Act of 1978, as amended, created Offices of
nspector General (OIG) to consolidate existing  investigative and
iudit resources in independent organizations headed by Inspectors
General. For fiscal 1994, the EPA OIG received $44.6 million and a
unded  staffing level of 449 FTE.  The Inspector General (IG) is
Appointed  by,  and can  be removed  only by,  the President.   The
mission of the OIG, as stated in the Act, is to:
  •  Conduct and supervise  independent and objective audits and
     investigations relating to agency programs and operations.
  •  Promote  economy, effectiveness,  and efficiency within  the
     agency.
  •  Prevent  and detect  fraud, waste,  and abuse  in  agency
     programs.
  •  Review and make  recommendations regarding existing and
     proposed  legislation   and  regulations  relating  to  agency
     programs and operations.
  •  Keep the agency head and the  Congress fully and currently
     informed of problems in agency programs.

To ensure objectivity, the Act provides the IGs:
• •  Independence to determine  what reviews to perform.
  •  Access to all information necessary for the reviews.
  •  Authority to publish findings and recommendations based on the
     reviews.
               Office of Inspector General
                       Inspector General
                       John C. Martin

                       Deputy Inspector General
     Jffice of Audit
     (enneth A. Konz
     Assistant Inspector General

     James 0. Ranch
     Deputy
Office of Management
John C. Jones
Assistant Inspector General
Office of Investigations
Michael J. Fitzsimmons
Assistant Inspector General


Deputy
     Acquisition and
      Assistance Audits
     Elissa R. Karpf

     Internal and
      Performance Audits
     Michael D. Simmons

     ADP Audits
     Craig Silverthorne

     Planning and Resources
       Management
     Kenneth D. Hockman

     Engineering and Science
 Program Mamagement
  Division
 John T. Walsh
 Director

 Resources Management
  Division
 Michael J. Binder
 Director

 ADP Support
  OIG Divisional Inspectors General are listed on the inside back panel.

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   JIG  Streamlining and Management
   Improvements
Our relationship with Agency managers has been strengthened
by our work in support of the Agency's strategic themes, and
by focusing more attention on underlying causes of some of the
most  severe problems which  have affected the Agency for
years.  In particular, we have worked on cooperative projects
with Agency managers to improve the integrity of scientific and
financial information and Superfund accounting.  We are also
identifying effective corrective  actions  taken by Agency
management and  examples of good management  practices,
when  possible.

We have ambitiously applied the concepts of reinvention in the
DIG by restructuring our organization and work  processes for
greater staff empowerment, operational efficiency and diversity.
In  fiscal 1994, the EPA OIG implemented a policy supporting
our affirmative action plan resulting in minorities and  women
accounting  for  75 percent of all new hires and promotions. We
have begun a streamlining  process within OIG that has  three
themes:  (1) increased delegation and decentralization  of
authority;  (2)  increased  empowerment of  employees   with
appropriate accountability; and (3)  improvement of  work
processes and  systems.

  • The  Office of Investigations restructured its organization
    by consolidating 7 divisional offices into 3 and reducing
    the number of  supervisory  agents from  11 to 7.   This
    increased the span of control and employee empowerment
    for  more investigative direction and  case  development
    activities by team leaders  in local offices.

  • We  have  undertaken a  comprehensive review  of our
    policies and procedures to ensure that each requirement in
    the audit process adds value to our products.

  • We conducted a management study to identify duplicative
    and inefficient administrative and oversight  functions and
    we are developing  performance measures which include
    customer  surveys.

  • Senior OIG officials conducted outreach activities  with
    senior  Agency officials to increase Agency involvement in
    OIG planning.

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    Profile of  Activities and Results
                                             Fiscal 1994
                                          (dollars in millions)
Audit Operations	

• Questioned Costs (Ineligible, Unsupported and
   Unnecessary/Unreasonable)
   -Total*                                         $165.1
   - Federal Share                                  $123.2

• Recommended Efficiencies
   (Funds be Put to Better Use)
   -Total*                                           $17.8
   - Federal Share                                    $17.8

• Costs Disallowed to be Recovered
   - Federal Share                                    $80.1
    (costs which EPA management
    agrees are unallowable and
    is committed to recover or
    offset against future payments)

• Costs Disallowed as Cost Efficiency
   - Federal Share                                     $3.8
    (funds made available by EPA
    management's commitment to
    implement DIG recommendations)

• Recoveries from Audit                              $67.2
   Resolutions of Current and Prior
   Periods (cash collections or offsets
   to future payments)**

• EPA Reviews Performed/Issued by DIG                 1,526

Investigative Operations
  Fines and Recoveries (including civil)                    $1.8
  Investigations Opened                                 233
  Investigations Closed                                 272
  Indictments of Persons or Firms                         1 9
  Convictions of Persons or Firms                         14
  Administrative Actions Taken against
  EPA Employees                                       27

Fraud Detection and Prevention Operations	
• Debarments, Suspensions, and
  Compliance Agreements                                81
  (actions to deny persons or firms from
  participating in EPA programs or
  activities because of misconduct or poor
  performance)
• Hotline Cases Opened                                  45
• Hotline Cases Processed and Closed                     61
• Legislative and Regulatory Items Reviewed               1 24
• Personnel Security Investigations Adjudicated          1,676

 * Questioned Costs and Recommended Efficiencies are subject To
  change in the  audit resolution process.
** Information on recoveries is provided by the EPA Financial
  Management Division and is unaudited.

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   Audit  Activities
The following represents some of our most significant findings
which resulted from audits and reviews performed by or for the
Office of Audit.

Leaking Underground Storage  Tank (LUST) Program on
American Indian Lands Needs Improvements
EPA has not effectively implemented  a nationwide program to
clean up leaking underground storage tanks on American Indian
lands, some of which are  contaminating drinking water.  The
Agency had not established many of the management controls
needed to operate the LUST program, and had not devoted the
resources  necessary to  fully implement the program  on
American  Indian  lands.   In  addition,  the  Agency had  not
developed a reliable  national inventory of underground tanks or
leaking tanks  on American  Indian  lands,  even  though  an
accurate inventory  is a critical first  step for  controlling  the
problem. Slow progress had been made in cleanup efforts, and
at least 75%  of  the leaking underground  storage  tanks  on
American Indian lands had not been cleaned up, including those
contaminating  drinking  water.    Also,  EPA's  enforcement
program for LUST  sites  on American Indian lands  was
insufficient to foster full compliance with laws and resulted in
only two administrative complaints  for leaking tank sites since
the program's inception in  1988.  The Agency  agreed to  take
appropriate actions to resolve the audit issues.

Over $200 Million in Unliquidated and Excess  Contract
Obligations Not Used or Returned
The  Agency did not close  or obtain refunds on almost  2,000
inactive contracts or deobligate $7 million in excess  funds on
over  100  closed  contracts.   Closing inactive contracts  in a
timely manner could have allowed EPA to deobligate over $200
million, over one-half of which is Superfund money.  Some of
the funds could have been deobligated almost 1 2 years ago and
returned to the  Treasury or used  for  other Government
programs or EPA  projects.  The Agency had  not  requested
refunds from contractors which could  potentially amount to $2
million because the contract closeout process was a low priority
and not consistently  accomplished.  We also identified over 1 00
contracts,  some closed  as many  as 11 years ago, with $7
million still obligated  on them because Agency personnel did not
prepare the necessary documentation. The Agency provided  an
acceptable  action plan to  correct the weaknesses,  including
setting  annual  goals for  closing  contracts and  dedicating
personnel to this function to the greatest extent possible.

Top  Management Attention  is Needed to Improve  EPA's
Information Resources Management Program (IRM)
EPA  was  not  maximizing  the usefulness of  information  in
implementing  the Agency's  environmental programs.   The
Agency's IRM problems were basically attributable to EPA not
treating information  as a valuable, strategic resource.  EPA has
had significant IRM  problems concerning the quality, integrity,

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and completeness of its data and its usefulness in addressing
cross-media pollution problems due to weaknesses in four key
areas; (1) IRM Management and Organizational  Structure: EPA
staff perceived upper  management as  not recognizing  the
criticality  of  or  being accountable  for IRM.   Also,  the
organizational placement, numbers, and apparent qualifications
of the EPA employees with  significant IRM responsibilities were
inconsistent among Headquarters program offices; (2) Resource
Planning  and  Performance Measurement: The Agency  has
neither an  Agency-wide IRM  strategic  plan  nor a  "business
plan," although  both  are  currently being developed.   EPA's
information  systems do not have the capability to  measure
environmental successes,  accomplishments, and  economic
benefits; (3) Information Systems Development: Developers of
EPA's systems do  not always  work  effectively with  EPA
program officials, Congress, and the States to understand the
programs  and define  their information needs; and  (4)  Data
Management: EPA does not have the IRM "structure" to link or
share data Agency-wide. The Agency agreed to  take corrective
actions to include designating a Chief Information Officer and
a Data Administrator,  creating  a strong- Executive  Steering
Committee, establishing key data standards, upgrading its IRM
training program, and establishing performance measure criteria.

Contractors Still Lack Adequate Accounting Systems
Emergency  Response  Cleanup  Services  (ERGS)  contractor
accounting system deficiencies noted in  past OIG reports still
exist because of inadequate enforcement by EPA personnel.
EPA  continued  to allow contractor non-compliance  with the
Federal Acquisition Regulation and contract accounting system
requirements  clauses  because of  a belief that  complete
enforcement would drive away ERCS contractors.  The Office
of Acquisition Management and regional procurement personnel
also  allowed some  ERCS  contractors to  use  EPA's  internal
Removal Cost Management System as a  billing mechanism,
despite requirements for contractors to generate invoices from,
and  reconcile them to, their  internal  accounting  systems.
Without adequate independent contractor accounting system
support, there  was no assurance  that  billed  charges were
actually incurred  and  paid  by  the  contractor.   With  one
exception, sanctions for contractor non-compliance were not
exercised.   The Agency proposed several corrective actions to
include providing guidance for requiring  contractors to invoice
EPA from their accounting systems and modifying certification
language.

EPA is Taking Actions to  Improve Critical Superfund Data
Quality
EPA  Headquarters and  regions  are implementing actions that
could effectively correct persistent problems with the accuracy
and  reliability  of data  in  the Comprehensive  Environmental
Response,  Compensation,  and  Liability  Information  System
(CERCLIS)  critical to  the  implementation of the  Superfund
program.    Eighty-six percent  of our sample of fiscal  1993
Superfund accomplishments and settlements recorded in
CERCLIS  by  EPA  Regions  1,  5, 6  and 7  were correct.
Subsequent actions  by Agency program officials increased the
percentage of correct entries in that sample to 90 percent and
actions were taken to prevent similar errors from recurring.  Our

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review of internal controls over CERCLIS data'entry a'nd quality
in these regions showed the risk of material data errors, which
would not be promptly detected, varied from low to moderate.
The Agency  is  implementing corrective actions  which include
guidance to the regions  to improve CERCLIS data quality, visits
from Headquarters staff, improved training in the  regions, an
on-line help facility for the entry of accomplishment data, and
increased regional participation  in developing accomplishment
definitions.

Better  Controls  Needed to Protect Over $22 million in
Securities in Bankruptcy Cases
The  Agency had limited controls  in  place  to safeguard
marketable securities received as a result of Superfund cost
recovery efforts.   During fiscal 1 992 and 1 993, EPA received
$22.4 million  worth of  marketable  securities  but  had not
established   central  receiving points, restricted   access,  or
assigned custodial responsibility  for them. The Agency could
not be assured  securities were adequately safeguarded against
theft and forwarded timely to the Department of the Treasury,
and  there were no procedures  to  follow up  with bankrupt
responsible  parties or their trustees to ensure receipt of all
securities.   Bankruptcy cases  handled  by  Headquarters
attorneys were not always entered  into the Comprehensive
Environmental Response,  Compensation,   and  Liability
Information System,  and EPA  was  not  tracking  marketable
securities transferred to the Agency,  the amount of securities
received,  and the  total proceeds from their sale. The Agency
agreed to take  corrective actions.

Nearly  $9.4 Million of Vallejo, California, Project Costs
Questioned
EPA  awarded  a grant  totaling  $19,962,958  to  the Vallejo
Sanitation  and   Flood Control District for construction  of a
wastewater treatment plant.  Vallejo  claimed $5,525,458 of
ineligible administration, engineering and construction costs,
primarily consisting of costs  related  to interest earned on an
overpayment of Federal funds, and  costs for the depreciated
value of  abandoned  and replaced  equipment.   We also
questioned  $3,874,497  of  unreasonable  costs  related  to
facilities  and equipment items intended for a biological  plant
which were being used only as a wet weather reserve capacity.

Ann  Arbor  Laboratory  Exercised  Good  Management
Practices Over Extramural Resources
EPA's National Vehicle and Fuel Emissions Laboratory, Office of
Mobile Sources (QMS), Ann  Arbor, Michigan, generally was
following  good  practices  in  managing its contracts, grants,
cooperative agreements, interagency agreements, imprest fund,
and integrity  program to prevent conflicts of interest. In March
1992, the Office  of Air and  Radiation  (OAR) initiated  an
assessment of the effectiveness of management controls over
its  contracting activities  and  identified  a number  of
improvements that could be implemented immediately.  OAR
also formed a quality assessment team to review its contracting
processes which found several contract management practices
that  were working  well and should help safeguard Government
funds.  OMS ensured that all of its staff had filed mandated
confidential  financial disclosure  statements  and carefully

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 reviewed'the statements for conflicts of interest.  In addition,
 the Ann Arbor Laboratory properly administered its imprest fund
 and used blanket purchase agreements to acquire such items as
 cylinder gases and automotive parts.

 EPA  Made Many  Contract'Awards  With  Limited
 Competition
 Most  of EPA's  contracts   were awarded  using  competitive
 procedures.   However, many of the awards were  made when
 only one proposal was within the Agency's acceptable technical
 and cost  range (competitive  range).   The composition  of
 technical evaluation panels (TEP) that evaluate and  score
 contract proposals created an appearance of partiality in scoring
 proposals and the potential for bias in the award of follow-on
•contracts.  The TEP is often  chaired by project officers who
Kiministered the prior contract and is  sometimes composed
l^tirety of  officials from the  program offices  acquiring  the
 services.   Although  the  Agency's  Competition Advocacy
 Program has been successful in limiting the number of sole-
 source awards,  monitoring  was not in place to determine the
 extent of actual competition (number of proposals) for contracts
 awarded under  competitive procedures.  Many firms believed
 that  conditions favored incumbent  contractors and were
 reluctant to submit proposals since they perceived their chance
 of winning  the  award  as remote.  The Agency is  taking
 corrective actions.

 Continued Efforts are Needed to Improve EPA's Pesticide
 Program
 For years EPA's pesticide program has had significant  problems
 in managing  its programs, maintaining information systems, and
 developing and  revising regulations, policies, and  procedures.
 During the 1 980's,  decreases in funding and staffing coupled
 with  increases in responsibilities, led the pesticide program to
 emphasize   short-term  solutions  to  problems  instead  of
 addressing  some fundamental  program activities, making  it
 more difficult and costly to  manage the program over the long
 term.    Pesticide managers were  often  aware  of significant
 problems, but did not always take corrective actions and  target
 dates  were  often  missed  in  areas such  as registration,
 reregistration and development  of regulations.   The  pesticide
 program had many computerized information systems that often
 contained  inaccurate  and  incomplete data, duplicated  other
 systems, and were  not integrated.  Some regulations did  not
 reflect what the  program was actually requiring  registrants to
 include on  pesticide labels  creating confusion  for the
 registrants.    Also,  the absence of policies and  procedures
 contributed to the sale of unregistered pesticides in the United
 States.  Other procedures  did not ensure that statements  on
 some  pesticide  labels adequately  protected humans and  the
 environment from unnecessary  risks.  The Agency agreed to
 correct  the  problems and  developed  a strategy  to  improve
 information management in 1 992 and funded several projects
 under that  strategy, in 1994.  The  pesticide  program also
 committed to reviewing its regulations, policies, and procedures
 to identify and prioritize those needing revision.

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iot|
4
 Agreed Upon Improvements Could Accelerate Superfund
 Site Assessment and Cleanup
 While final program guidance for the Superfund Site Inspection
 Prioritization  (SIP)  program  was  delayed,  some regions
 implemented  the draft guidance inconsistently  and did not
 always  ensure that the worst  sites  were given priority  for
 cleanup. EPA uses the site assessment process to identify the
 highest priority sites posing threats to human health and the
 environment for listing on the National Priorities List (NPL). EPA
 did not issue  SIP program guidance until 1 993, almost two
 years  after  implementation  of the program  was  begun.
 Information about program results input into the Comprehensive
 Environmental  Response,  Compensation, and  Liability
 Information System was incomplete and could not be relied
 upon to assess national accomplishments. The Agency had
 met the legislative goal to list sites on the NPL within four year
 of site discovery and will likely be unable to  meet this goal
 the near future.  Estimated cost of  cleaning  up potential NPL
 sites is not included in the annual  Superfund report to Congress,
 even though cleanup of backlog  NPL sites will cost billions of
 dollars,  and EPA may have to reevaluate sites that remain in the
 backlog for an extended period of time. The Agency agreed to
 recommended improvements to the SIP  program  and to more
 fully disclose the cost of Superfund  to Congress. An analysis
 of why legislative timeliness goals are not met will be provided,
 and EPA will pursue deferral of sites to States and responsible
 parties.

 Further Actions are needed on EPA's Integrated Financial
 Management System (IFMS)
 After years of problems and cost overruns, continued Agency
 top management attention is required to make the IFMS reliable,
 usable,  and cost  effective.  Since the mid-1980's, EPA has
 been developing a major system, IFMS,  to integrate all of  its
 financial systems which track and  control over $6.9  billion
 annually.   EPA has taken  a number  of  significant steps  to
 implement IFMS and  to overcome  previous management
 problems including (1) implementing a single general ledger; (2)
 appointing  a Chief Financial Officer (CFO), a Deputy CFO, and
 a Director, IFMS Project Management Staff; (3) completing the
 IFMS  Strategy and  Master Work Plan; (4) implementing the
 newest  off-the-shelf software  version which  upgraded IFMS
 capabilities;  and (5)  completing an  updated  cost study,
 requirements analysis,  and  charter.   Despite  these
 accomplishments,  the  Agency  still needs  to take further
significant actions  to fully  implement  an  integrated,
 comprehensive financial management system.  Target dates for
 completing IFMS implementation have slipped more than 6.5
years, to at least fiscal  1995.  Until full implementation is
attained, the return  on  the planned IFMS investment over the
remaining system life will be limited.  Specifically,  EPA has not
implemented  critical modules; eliminated dependency on the
existing  financial  systems which,  in  part,   duplicate  IFMS
functions and capabilities; and fully interfaced IFMS to financial
subsystems and other administrative systems.  As  a result, EPA
has incurred cost overruns  and  other  unexpected operational
costs.   The Agency has completed action  on 5 of our 16
recommendations and has initiated or plans to initiate action on
the remaining  1 1.

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Over $44.4  IVJillion  in  Questioned  Costs  Claimed  by
Philadelphia,  Pennsylvania
EPA awarded eight grants totaling $291,81 7,947 to the City of
Philadelphia  to upgrade  and expand the Southwest  Water
Pollution  Control Plant.  We questioned  $10,959,010 of the
costs claimed by the City as ineligible, including force account,
engineering, construction, and indirect costs for the expansion
of an existing wastewater treatment plant. We also questioned
$32,663,495  of  unsupported  costs,  including  supplemental
funding  for projects not  complying  with  special  grant
conditions, unapproved contracts, unused or inoperable  plant
equipment, and change  orders which had not been reviewed.
Additionally, we questioned $794,684  of claimed costs as
unnecessary primarily  because  the grantee did not hold
contractors  to their scheduled  completion  dates for sludge
facilities, resulting in the bid opening for a transfer station being
delayed and  its construction costs escalating, and because the
grantee approved a change order that significantly increased the
cost of backfill without conducting a cost  or benefit pricing
analysis.

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   Investigative Activities
 During this fiscal year, our investigative efforts resulted in 1 9
 indictments,  14  convictions  and  $1.8 million  of fines  and
 recoveries from persons or firms who defrauded the Agency.

 Firm and President Convicted of Making False Claims
 T. Head and  Company, Inc., known as THI, and  Toney Head,
 Jr., the firm's owner,  president, and  chief executive  officer,
 were convicted in August 1 994 of filing 41 false claims. Head
 personally directed four former THI employees to falsify records
 which showed the number of hours  that these  employees
 worked on the EPA contract, and used the false information to
 inflate numerous THI invoices submitted to EPA.

 Former Maryland Chief Fiscal Officer Pleads Guilty to
 Money Laundering
 Rufus  0. Ukaegbu, former chief fiscal officer for the State of
 Maryland  Department of  the  Environment, Water  Quality
 Financing  Administration (WQFA), pleaded guilty in July 1994
 to money laundering and to a State theft statute.  Through the
 use  of wire transfers and  monetary instruments,  the stolen
 funds were used to purchase: numerous automobiles, shipped
 to Nigeria;  sizeable security investments; penicillin and other
 pharmaceutical supplies shipped to Nigeria  for  resale;  home
 remodeling;  and  to reduce  personal  debt.   This case was
 investigated jointly by the DIG, the FBI, and the Maryland State
 Police.

 North Carolina  Man  Sentenced in Insurance Case
 After pleading guilty to wire fraud  and mail fraud, Warren H.
 Berkle, Jr.,  of Elon College, North Carolina,  was sentenced to
 5 years probation and ordered to pay restitution of $203,195
 and  $150 in  special  assessments  in February 1994.  Berkle
 used an insurance scheme involving the construction of an EPA-
 funded  wastewater treatment  plant in Florham  Park, New
 Jersey.  He conspired to illegally write  insurance contracts for
 asbestos and  other high risk liabilities for FJorham Park without
 adequate reserves to pay claims  and without approval from the
 State of New Jersey.

 Region 4  Employee Sentenced in Fraud Case
Angela  Fields, a  former supervisory accountant  in the EPA
 Region 4 office in Atlanta, pleaded guilty in  March 1994 to
defrauding EPA of $28,000 in 1 991  and 1 992. Fields admitted
that she  entered false  information  into  EPA's Integrated
 Financial Management  System and  received 23 U.S Treasury
 checks.  Fields was  sentenced in  June 1994 to 5  months
 prison, 5 months home confinement,  3 years probation,  and
ordered to  pay restitution of $28,049 and  a $750 special
assessment.

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Two Sentenced  in  False Asbestos Removal Claims;
Another Pleads Guilty
Russell Curtis and  Dean  Curtis pleaded guilty to causing-the
Fairbury,  Nebraska public schools to  submit false asbestos
removal claims to EPA and were each sentenced to 6 months
home confinement, 5 years probation, restitution of $1 53,476
to EPA, and a special assessment of $50. Stanley Peters, also
charged  in this  case,  was  found  guilty  of one  count of
conspiracy, three counts of making a false and fraudulent claim,
and one count of theft of Government money on December 21,
1993.  A joint investigation by the OIG and  the FBI revealed
that  the  three used an  EPA  grant and loan  awarded to the
school system for asbestos removal to pay for services outside
the scope of the  grant and loan, i.e., renovation of the Fairbury
Central Elementary School and related fees.

Environmental  Engineer Sentenced  for Role  in  NPDES
Violation
After pleading guilty to  negligently discharging  pollutants in
violation  of National Pollutant Discharge Elimination System
(NPDES)  permit  limitations and filing  false  statements, Harry
Kring was sentenced to serve  6 months home detention,  3
years probation,  and  was fined  $5,000 and  a special
assessment.  Kring, an AT&T environmental  engineer, allegedly
conspired with  AT&T to  falsify laboratory  test  results  on
samples he collected frorn^a wastewater treatment system at
an AT&T facility and to  report the falsified results as  part of
AT&T's NPDES permit. In January 1 994, AT&T pleaded guilty
to the same NPDES violation and was fined  $175,000.  The
case was investigated jointly by the OIG and the EPA Criminal
Investigations Division.

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   Fraud  Prevention  Activities
Suspension and Debarment Activities
EPA's policy  is  to  do business  only  with contractors  and
grantees who  are honest and responsible.  EPA enforces  this
policy by suspending or debarring contractors or grantees, or
individuals within those organizations, from further contracts or
assistance  for  acting  improperly,  having  a  history of
substandard work, or willfully failing to perform on EPA or other
federally-funded  activities.   Both  procurement and
nonprocurement debarments or suspensions  by one agency are
effective in all  agencies.

In  fiscal 1994,  81  debarment,  suspension, or  compliance
agreement actions were taken, including the following:

 •   EPA debarred Robert  E. Caron for  3 years  based on his
     conviction of making false declarations for purposes of
     Federal employment  and security  clearances.  Over an
     eight-year period, Caron falsely represented his educational
     qualifications on numerous occasions.

 •   EPA debarred National Environmental Testing  (NET)  Gulf
     Coast Inc., (except its Baton Rouge, Louisiana, laboratory)
     for  25 years and two of its  managers, Joan  Lutkenhaus
     and Cynthia Placko-Moore, for 50 years. NET Gulf Coast
     Inc.,  pleaded   guilty to making  false,  fictitious,   and
     fraudulent claims under an  EPA contract  for laboratory
     analyses  of  inorganic  compounds.   The two managers
     accepted responsibility for knowing of and participating in
     the crime, which involved fraudulently  manipulating  data
     and instructing  subordinates to  "cut and paste"  data on
     Contract  Laboratory Program (CLP)  sample analyses.

 •   EPA debarred Robert Olcerst, owner and  operator of Brujos
     Scientific  Inc.,  and Kenneth  Charles  and Michael  Harris,
     employees of Sandag Engineering  Inc., for  3 years.  All
     were  involved  in a  scheme to  defraud the  School
     Construction Authority of New York and the public through
     schemes in obtaining  and performing asbestos  testing and
     monitoring.

 •   EPA debarred Rex Wilson Robinson for 3 years. Robinson
    pleaded guilty to falsely impersonating  an  officer and/or
    employee of EPA.  While identifying  himself as an agent of
     EPA, Robinson  made several telephone  calls to and met
     with officials of Corporate Services Inc., a  subsidiary of
    the  Michigan Farm Bureau of Lansing, Michigan.

 •  EPA suspended  Ricards  International,  Inc. (RID,  its
    President,  Richard Salvatierra, and two top officials, Sonny
    Bloom and Edsel Billingy, along with an affiliated company,
    Potomac Leasing, Inc., based  on evidence that  Rll officials
    repeatedly directed employees  to  charge  time  to  EPA
    contracts fraudulently.

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Personnel  Security Program
The Personnel Security Program is one of the  Agency's first
lines of defense against fraud, using background investigations
to review the integrity  of  EPA employees and  contractors.
During fiscal  1994,  1,676  investigations  were  reviewed,
adjudicated, and appropriate actions were taken.

Hotline Activities
The OIG Hotline  Center opened 45 new cases and completed
and closed 61  cases  during fiscal 1994.  Of  the  61 cases
closed,  1 1  resulted  in  environmental, administrative,  or
prosecutive action.   We also  referred  4,828  callers to the
appropriate program office, State  agency,  or  other  Federal
agency  for assistance.   The  following are  examples  of
corrective action resulting from calls to the OIG Hotline Center:

    • A complainant alleged that a manufacturing company in
      Troutdale, Oregon, was polluting  a nearby river with
      toxic material from a  smelter.  EPA officials in Region 1 0
      determined that the  site was a high-priority  candidate
      for the National Priorities List. As a result,  Region 10's
      Superfund Regional  Decision Team sent a Hazardous
      Ranking  System package  to EPA Headquarters  for
      expedited review.

    • A complainant  alleged that EPA funds were  wasted in
      the  procurement and  disposal  of office  furniture  in
      Region 6.  A review  of the complaint  disclosed that a
      breakdown in communications  precluded  information
      regarding excess systems  furniture inventory  from
      reaching the  Competition Advocate.  Funds were used
      to buy out  leased systems furniture  rather  than use
      furniture in inventory, causing unnecessary expenditures
      of $627,600. Several internal control  procedures were
      implemented to ensure proper coordination  and
      communication in major procurements.

    • A complainant  alleged that Region 9 employees had
      backdated site  inspection  reports,  misrepresented site
      assessment  records,  and made  false entries  in a
      Superfund database,  the Comprehensive  Environmental
      Response, Compensation, and  Liability  Information
      System (CERCLIS). A review of the complaint disclosed
      that between 1988 and 1991, 212 invalid preliminary
      assessments (PAs) and 63 invalid site inspections (Sis)
      were entered  into  CERCLIS and also  claimed  as
      Superfund Comprehensive Accomplishment Plan (SCAP)
      accomplishments.    This  significantly  inflated EPA's
      accomplishments in  its annual report  to Congress  for
      those years.  As a result, the invalid accomplishments
      were removed  from  CERCLIS and a  senior-level  EPA
      employee received a  written reprimand.

    • A complainant  alleged misuse of a government travel
      card by an EPA employee.  An inquiry determined that
      misuse had  occurred.  The employee was required  to
      pay  all outstanding charges on the card  before it was
      canceled and was given a letter of reprimand.

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     '(visional Inspectors General
                 Audit
Headquarters


Regions 1 & 2

Region 3

Regions 4 & 6

Region 5

Regions 7 & 8

Regions 9 & 10
                 Headquarters Audit Division
                 Financial Audit Division

                 Eastern Audit Division

                 Mid-Atlantic Audit Division

                 Southern Audit Division

                 Northern Audit Division

                 Central Audit Division

                 Western Audit Division
(703) 308-8222
(202)260-1497

(617)565-3160

(215)597-0497

(404) 347-3623

(312)353-2486

(913)551-7824

(415} 744-2445
               Investigations
Headquarters     Procurement Fraud Division  (703)308-8813

                                           (617)565-3925
Regions 1, 2 & 3  Eastern Investigations
                 Division

Regions 4, 5, 6,   Western  Investigations
        7, 8, 9    Division
        & 10
                                           (312)353-2507
If you  are aware of any fraud, waste, or mismanagement,
please  contact  the EPA Inspector General Hotline  or the
appropriate Divisional Inspector General.

 •  Information is confidential.

 •  Calls can be made toll free on (800) 424-4000. Callers in
    area code 202 should use 260-4977.

                    Remember:
        Act Like It's Your Money-It Is!

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             EPA Office of Inspector General

                 Customer Survey
Please take a few minutes to provide the answers to the
following questions, tear off, and place in the mail.
Thank you.  Circle all that apply.

1.  Are you a(n):
   a.  EPA employee-Headquarters or DC area?
   b.  EPA employee-Regional office, lab, or other?
   c.  EPA contractor/grantee?
   d.  Member of the public?

2.  Are you familiar with the  mission or the work of the DIG?

             Yes        No

3.  Do you believe that the OIG helps prevent possible fraud,
   waste,  and mismanagement and promotes economy,
   efficiency, and effectiveness of Agency operations?

             Yes        No

4.  If you have come in contact with any OIG work product
   or  staff member, has  that contact been:

   a.  Positive    b. Negative    c. No contact

5. Are the OIG  staff members generally:

   a.  Helpful   b. Courteous    c. Professional

   d.  Knowledgeable     e. Objective

   f. I don't know any OIG  staffers

   g.  Other, explain	

6. How well do you believe that the OIG is contributing to
   the success  of the  Agency?

   a.  Very well     b. Reasonably well      c. Not at all

7.  Do you know of any fraud, waste,  or mismanagement
   that should be reported to  and reviewed by the OIG?

             Yes         No

8. Comments:  	

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