United States Office of the Inspector General ApH1995
Environmental Protection 401 M Street. S.W. (24211
Agency Washington, D.C. 20460
EPA's Office of the
Inspector General
Annual
Superfund Report
to the Congress
for Fiscal 1994
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EPA Office of the Inspector General Annual Superfund Report to the Congress for Fiscal 1994
FOREWORD
This report covers fiscal 1994 activities, and is our eighth Annual Superfund Report
to the Congress. The Superfund Amendments and Reauthorization Act of 1986
(SARA) requires the Office of the Inspector General (DIG) to audit the Superfund
program annually and to report to Congress annually on these audits.
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In addition to reviewing Agency performance, we also take a proactive role to help
the Environmental Protection Agency (EPA) management prevent future problems.
During fiscal 1994, we assisted EPA management in a number of ways. After we
issued our audit report on the Agency's fiscal 1993 financial statements which
found a significant weakness in recording and reconciling Superfund accounts
receivable, the Agency requested our assistance in identifying unrecorded
receivables. In response, we had the independent accounting firm which
performed the audit perform a special analysis to identify these unrecorded
receivables. This helped the Agency to reduce the number of unrecorded accounts
receivable.
In three EPA regions, we worked with EPA regional staff to improve management
and oversight of assistance agreements. In Region 5, we worked with regional
staff to develop our plans for reviewing Superfund cooperative agreements in a
way that would identify systemic problems and help the Region prepare States for
possible enhanced responsibilities. In Region 7, we participated in a work group on
streamlining the Region's grants process and assisted in training staff of a State
agency performing Superfund responses. In Region 8, we alerted management to
possible problems in management of an interagency agreement that we found
while performing a review of other issues.
We have worked closely with the Agency on matters related to Superfund
reauthorization. We reviewed EPA pilots in progress on Superfund administrative
improvements and met frequently with Agency officials to discuss the results of
our reviews and possible implications for reauthorization. In support of the
Administration's efforts to streamline reporting, we worked with the Agency to
identify ways its annual Superfund progress report to Congress could be
streamlined. We also identified our own annual Superfund report to Congress, this
report, as one that was largely duplicative and could be eliminated.
The beginning of the Superfund program created new and unique cost accounting
requirements. Although EPA has continued to improve its site-specific accounting
and documentation of Superfund costs, significant weaknesses remained to be
corrected. In our third review of the Hazardous Substance Superfund under the
new Chief Financial Officers (CFO) Act requirements, we again disclaimed an
opinion on the financial statements because of material weaknesses in EPA's
financial management system and accounting controls. The primary reasons we
could not determine whether the statements were fairly presented were
weaknesses concerning accounting for property, accounts payable and accrued
liabilities, grants funded from multiple appropriations, and State cost share credits.
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EPA Office of the Inspector General Annual Superfund Report to the Congress for Fiscal 1994 ii
Our reviews of the Agency's performance in managing the Superfund program
indicated that the Agency has made significant improvements in some areas we
have been reviewing for several years, but that continued effort is needed to rectify
longstanding problems. In the area of contract management, we found that the
Agency had improved procurement procedures to achieve full and open competition
for Superfund contracts. However, we found limited competition for some major
contracts with one major contractor, and little evidence of competition in this
contractor's award of subcontracts. We also found that the Agency's Emergency
Response Cleanup Services (ERCS) contractors' accounting and billing systems still
did not meet Federal requirements, a longstanding problem. In addition, we found
the Agency failed to close inactive contracts and deobligate unneeded funds in a
timely manner.
We worked with the Agency on two major reviews of the Agency requested by a
Senate Subcommittee. Our review of the Agency's information resources
management program found significant problems with the quality, integrity and
completeness of data, and its usefulness in addressing cross-media pollution. The
Agency's management, organizational structure, and planning functions in this area
needed considerable improvement. Our review of the Agency's financial
management found inconsistency in the priority Agency managers gave to this
function. The Agency needed to improve its financial policies and procedures, and
provide more regular training of financial management personnel. A separate
review of the handling of Superfund bankruptcy settlements found problems which
were partly a result of current bankruptcy laws and partly a lack of adequate
controls to safeguard marketable securities.
Our review of the Agency's site assessment process found EPA regions
inconsistently implemented the Superfund Site Inspection Prioritization (SIP)
program. EPA had not met the statutory goal for completion of site assessment
and listing on the National Priorities List (NPL) within four years of site discovery.
At its current rate, it would take EPA 27 years to reach NPL decisions on the 3,100
SIP sites expected to qualify for the NPL.
Our major investigative effort into the Contract Laboratory Program (CLP) begun
several years ago resulted in additional convictions and debarments from Federal
contracts in fiscal 1994. In other Superfund investigative activity, a company was
fined $1 million for offering a bribe to an EPA official. An owner of a company
pleaded guilty to concealing assets from EPA in connection with his potential
liability for a Superfund cleanup. A former EPA on-scene coordinator for Superfund
removal actions who had repeatedly falsely represented his educational
qualifications was debarred from Federal contracting for three years.
We will continue to help Agency management deliver the most effective and
efficient Superfund program through a comprehensive program of audits,
investigations, fraud prevention, and cooperative efforts with Agency management.
£
John C. Martin
Inspector General
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EPA Office of the Inspector General Annual Superfund Report to the Congress for Fiscal 1994 iii
TABLE OF CONTENTS
PURPOSE 1
BACKGROUND 2
ASSISTANCE TO EPA MANAGEMENT 4
HAZARDOUS SUBSTANCE SUPERFUND 7
RESPONSE CLAIMS 10
Agency Needs to Improve Efforts in Administering Response Claims
Against the Superfund 10
More Than $1 Million of Marion Bragg Superfund Claim Questioned 12
COOPERATIVE AGREEMENTS 14
More Than $278,000 of Questioned Claims for Georgia Superfund
Activities 14
More Than $227,000 of Ineligible Claims for Minnesota Superfund Site . . 16
REMEDIAL INVESTIGATIONS AND FEASIBILITY STUDIES 18
Lightning ROD Approach Speeded Site Response 18
Generally Thorough Remedial Planning Marred by Technical Deficiencies at
Washington Site 19
Inadequate Site Characterization and Administrative Record Documentation
at Pennsylvania Site 19
Remedial Planning Thorough at California Site 20
Site Characterization Needed Improvement at New Jersey Site 21
CONTRACTS 22
More Than $200 Million in Unliquidated and Excess Contract Obligations
Including $143 Million in Superfund Obligations 23
Agency Strives to Achieve Full and Open Competition When Awarding
Superfund Contracts 24
Most Large Contracts Awarded to ICF Had Limited Competition 25
Contractors Still Lack Adequate Accounting Systems . : 27
Conflict of Interest in EPA Region 9 Sample Analysis and Data Validation
Activities 29
EPA's Conflict of Interest Policies and Procedures Needed Further
Strengthening 30
Superfund Contractor Destroyed Source Documentation 31
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EPA Office of the Inspector General Annual Superfund Report to the Congress for Fiscal 1994 iv
INTERNAL AUDITS AND SPECIAL REVIEWS 33
EPA's Information Resources Management (IRM) Program Needed Top
Management Attention 33
Importance of Financial Management Viewed Inconsistently at EPA 35
Better Controls Needed to Protect Securities Received in Bankruptcy Cases 37
Greater Emphasis Needed by OSWER on Implementing the Financial
Integrity Act 39
Superfund Initiatives Reduce Time and Save Money 41
Agreed Upon Improvements Could Accelerate Superfund Site Assessment
and Cleanup 43
Further Steps Needed to Complete Improvements in Contract Laboratory
Program 45
Laboratory Consolidation Would Improve Efficiency and Reduce Costs ... 47
INTERAGENCY AGREEMENTS 49
Agency for Toxic Substances and Disease Registry 49
U.S. Army Corps of Engineers 49
Coast Guard . . 50
Federal Emergency Management Agency 50
Department of the Interior Bureau of Reclamation 50
Department of the Interior U.S. Fish and Wildlife Service 50
Department of Justice 51
National Institute of Environmental Health Sciences 51
REVIEW OF AGENCY'S SUPERFUND PROGRESS REPORT 52
INVESTIGATIVE ACTIVITY 55
EXHIBIT 1: SUPERFUND REVIEW REPORTS ISSUED DURING FISCAL 1994 . . 58
APPENDIX: ACRONYMS AND ABBREVIATIONS 65
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EPA Office of the Inspector General Annual Superfund Report to the Congress for Fiscal 1994
PURPOSE
We provide this report pursuant to section 111(k) of the Comprehensive
Environmental Response, Compensation, and Liability Act (CERCLA) of 1980, as
amended. The Superfund Amendments and Reauthorization Act (SARA) of 1986
amended that section of CERCLA to add several annual requirements for the
Inspector General of each Federal agency carrying out CERCLA authorities. These
requirements include four audit areas and an annual report to Congress about the
required audit work. This report covers fiscal 1994 audits of Superfund activities.
We discuss the required four audit areas below.
This report contains chapters on the mandated audit areas, except claims. We
also summarize other Superfund audit work, assistance to EPA management and
Superfund investigative work performed during fiscal 1994. We exceed the
statutory requirements by providing Congress with the significant results of all of
our Superfund work.
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Trust Fund
CERCLA requires "... an annual audit of all payments, obligations,
reimbursements, or other uses of the Fund in the prior fiscal year . . .." We now
meet this requirement through the financial statement audit required by the Chief
Financial Officers Act of 1990.
Claims
CERCLA requires an annual audit to assure "... that claims are being
appropriately and expeditio'usly considered ..." Since SARA did not include
natural resource damage claims as allowable Fund expenditures, the only claims
provided in CERCLA, as amended, are response claims.
Cooperative Agreements
CERCLA requires audits "... of a sample of agreements with States (in
accordance with the provisions of the Single Audit Act) carrying out response
actions under this title ..." We perform financial and compliance audits of
cooperative agreements with States and political subdivisions. Some of our audits
also review program performance. In addition, we sometimes review EPA regional
management of the cooperative agreement program.
Remedial Investigations/Feasibility Studies (RI/FS)
CERCLA requires our "... examination of remedial investigations and
feasibility studies prepared for remedial actions ..." Our RI/FS examinations
review the adequacy of the studies to provide a sound technical basis for remedial
action decisions. These examinations may be done as part of audits of EPA
management or as special reviews by our technical staff.
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EPA Office of the Inspector General Annual Superfund Report to the Congress for Fiscal 1994
BACKGROUND
The Comprehensive Environmental Response, Compensation, and Liability Act
of 1980 (CERCLA), Public Law 96-510, enacted on December 11, 1980,
established the "Superfund" program. The purpose of the Superfund program is to
protect public health and the environment from the release, or threat of release, of
hazardous substances from abandoned hazardous waste sites and other sources
where other Federal laws do not require response. CERCLA established a
Hazardous Substance Response Trust Fund to provide funding for responses
ranging from control of emergencies to permanent remedies at uncontrolled sites.
CERCLA authorized a $1.6 billion program financed by a five-year environmental
tax on industry and some general revenues. CERCLA requires EPA to seek
response, or payment for response, from those responsible for the problem,
including property owners, generators, and transporters.
The Superfund Amendments and Reauthorization Act of 1 986 (SARA), Public
Law 99-499, enacted October 17, 1986, revised and expanded CERCLA. SARA
reinstituted the environmental tax and expanded the taxing mechanism available for
a five-year period. It authorized an $8.5 billion program for the 1987-1991 period.
It renamed the Trust Fund the Hazardous Substance Superfund. The'Budget
Reconciliation Act of 1990 reauthorized the program for three additional years and
extended the taxing mechanism for four additional years.
The basic regulatory blueprint for the Superfund program is the National Oil and
Hazardous Substances Contingency Plan (NCP), 40 CFR Part 300. The NCP was
first published in 1968 as part of the Federal Water Pollution Control Plan, and EPA
has substantially revised it three times to meet CERCLA requirements. The NCP
lays out two broad categories of response: removals and remedial response.
Removals are relatively short-term responses and modify an earlier program under
the Clean Water Act. Remedial response is long-term planning and action to
provide permanent remedies for serious abandoned or uncontrolled hazardous
waste sites.
CERCLA recognized that the Federal Government can only assume
responsibility for remedial response at a limited number of sites representing the
greatest public threat. Therefore, EPA must maintain a National Priorities List
(NPL), and must update it at least annually. The NPL consists primarily of sites
ranked based on a standard scoring system, which evaluates their threat to public
health and the environment. In addition, CERCLA allowed each State to designate
its highest priority site, without regard to the ranking system.
CERCLA section 104(c)(3) does not allow EPA to fund remedial actions unless
the State in which the release occurs enters into a contract or cooperative
agreement with EPA to provide certain assurances, including cost sharing. At most
sites, the State must pay 10 percent of the costs of remedial action. EPA may
fund 100 percent of site assessment activities (preliminary assessments, site
inspections), remedial planning (remedial investigations, feasibility studies, remedial
designs), and removals. For facilities operated by a State or political subdivision at
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EPA Office of the Inspector General Annual Superfund Report to the Congress for Fiscal 1994
the time of disposal of hazardous substances, the State must pay 50 percent of all
response costs, including removals and remedial planning previously conducted.
CERCLA sections 104(c)(3) and 104(d) authorize EPA to enter into cooperative
agreements with States or political subdivisions to take, or to participate in, any
necessary actions provided under CERCLA. A cooperative agreement serves to
delineate EPA and State responsibilities for actions to be taken at the site, obtains
required assurances, and commits Federal funds. EPA uses cooperative
agreements to encourage State participation in the full range of Superfund activities
- site assessment, remedial, removal and enforcement.
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EPA Office of the Inspector General Annual Superfund Report to the Congress for Fiscal 1994
ASSISTANCE TO EPA MANAGEMENT
Besides performing audits and investigations, the OIG responds to EPA
management requests for OIG input in the development of regulations, manuals,
directives, guidance and procurements. These are proactive efforts to prevent
problems that might later result in negative audit findings or investigative results.
The OIG reviews and comments on draft documents prepared by Agency offices.
Sometimes an OIG staff person attends meetings of an EPA work group to provide
input. Fiscal 1994 was an active year for OIG preventive assistance to EPA
management in the Superfund area. Besides helping EPA management, we
coordinate with other Federal agencies. We also seek to improve Superfund audit
and investigative capabilities of our OIG and of other Federal OIGs. We summarize
below some of the major activities in these areas. We also responded to numerous
requests for assistance from the Agency which did not develop into major projects.
Streamlining of Reporting to Congress
We share the Administration's concern to reduce resources devoted to duplicative,
excessive or unneeded reporting requirements. EPA is required to report annually
to Congress on its progress in implementing Superfund. The reporting requirement
is extensive, and EPA has never been able to provide the report to Congress as
soon as the law requires. We are required to review this report for reasonableness
and accuracy, and the Agency is required to include our report on this review in its
report. During fiscal 1994, OIG staff worked closely with Superfund program staff
on possibilities during Superfund reauthorization to streamlining this report to save
staff resources, while providing the Congress with needed information on a more
timely basis.
We also have identified our own annual Superfund report to Cpngress as one that
could be eliminated. Virtually all of the information of value to Congress in this
report is duplicative of information already provided in our Semiannual Reports to
Congress.
Financial Management
Our audits of EPA's financial statements found a significant weakness in recording
and reconciling Superfund accounts receivable. The Agency reported this to the
President as a material weakness. EPA requested the OIG to perform additional
audit work to identify Superfund accounts receivable that were unrecorded as of
September 30, 1993. In response, we had the independent accounting firm with
which we contracted to perform the fiscal 1993 financial statements audit perform
a special analysis to identify unrecorded receivables. We concluded that all of
these receivables would have been identified and recorded if existing procedures to
reconcile between the Department of Justice and EPA's Integrated Financial
Management System (IFMS) had been performed. We therefore planned to request
management representation letters from Financial Management Officers and
Regional Counsels attesting to their compliance with the procedures to support
future audit opinions on EPA's financial statements. The Agency's Comptroller
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EPA Office of the Inspector General Annual Superfund Report to the Congress for Fiscal 1994 5
requested all EPA Regions to perform the necessary accounts receivable
reconciliations and to follow up on unreconciled items.
Administrative Improvements
We reviewed the Agency's Superfund Administrative Improvements pilots as they
were being performed to assist the Agency in improving the Superfund process and
to coordinate with the program regarding Superfund reauthorization issues. We
performed these reviews as special reviews rather than full audits in order to
provide the Agency with quicker feedback. During the course of this effort, we
met frequently with Agency officials to brief them on what we were finding and to
discuss with them ways to enhance their improvement efforts.
Contract Management
We actively participate in the Agency's Superfund Senior Regional Management
Acquisition Council (SRMAC), which includes senior representatives of EPA
Headquarters and regional program and contract management staff. SRMAC
meetings provide a forum for participants to learn from each other, and to share
success stories and good ideas. Discussions cover such issues as standardization
of user guides, evaluation of future contract needs, and Agencywide issues. We
discuss reports we have recently issued and their effect on Superfund procurement
and contract management. We review the recommendations and programmatic
impacts of their implementation. We encourage EPA officials to give us feedback
on the impact our recommendations have on their day-to-da'y operations.
Regional Management of Assistance Agreements
In several EPA regions, our field offices worked with regional staff to improve
management and oversight of assistance agreements. We worked with Region 5
Superfund staff to develop an overall plan for reviewing its Superfund cooperative
agreements that would identify common systemic problems and help the Region
prepare States for possible enhanced responsibilities as a result of Superfund
reauthorization. We participated in a Region 7 work group devoted to improving
and streamlining the Region's grants process while maintaining adequate controls.
We also participated with Region 7 grants administration personnel in training
program and accounting personnel of the Missouri Department of Natural
Resources. We alerted Region 8 management to indicators of possible problems in
Superfund site management under an interagency agreement with another Federal
agency. As a result, the Region began a review of controls under the agreement to
ensure accountability, responsibility, and trackability.
Coordination with Other Agencies
>
Since EPA manages the Hazardous Substance Superfund (Trust Fund), the EPA OIG
took on the task of informing the Federal OIG community (and other appropriate
audit organizations) of the mandated audit requirements. The Superfund
Amendments and Reauthorization Act of 1986 (SARA) requires "... the
Inspector General of each department, agency or instrumentality of the United
States which is carrying out any authority ..." under SARA to conduct an annual
audit of uses of the Superfund. In July 1987, we formed a work group of
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EPA Office of the Inspector General Annual Superfund Report to the Congress for Fiscal 1994 6
representatives from several OIGs and other audit organizations of those Federal
departments or agencies with significant Fund-financed responsibilities under
CERCLA or Executive Order 12580. The objectives of our work group are to:
• Clarify the statutory requirement;
• Coordinate schedules and reports under the mandatory annual audit
requirement;
• Discuss funding mechanisms for the mandatory audit work; and
• Discuss program areas of concerns or audit findings.
There was no need for a formal meeting of the work group in fiscal 1 994 due to
anticipated reauthorization. However, we did assist other OIGs and audit agencies
upon request. For example, we provided the Department of Defense DIG with
information to assist in their audit planning.
We also have considerable contact with the General Accounting Office to
coordinate Superfund audit work. In fiscal 1994, this included a major meeting to
discuss audit priorities and reviews in progress, and numerous telephone contacts.
Superfund Orientation Course
As the Superfund program has expanded and developed, the OIG has recognized a
need to be sure that its auditors and investigators who review Superfund have a
good understanding of the program. Therefore, we developed a special orientation
course explaining the key aspects of the Superfund program, including:
• Superfund and related legislation and regulations;
• The removal, remedial and enforcement parts of the Superfund program;
• Organizational structure and functions of EPA offices delegated specific
Superfund responsibilities; and
• The OIG's role and responsibilities concerning Superfund and the type of
Superfund audits the OIG performs.
We require all OIG employees and OIG audit services contractor employees
performing Superfund audits to take this course. We also offer the course to other
Federal OIGs and audit organizations who perform audits, in their own agencies.
We include the course in the OIG Training and Development Sourc'es course
catalog. In fiscal 1994, we updated the course and presented it twice.
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EPA Office of the Inspector General Annual Superfund Report to the Congress for Fiscal 1994
HAZARDOUS SUBSTANCE SUPERFUND
The Chief, Financial Officers (CFO) Act of 1990 requires Federal agencies to prepare
annual financial statements covering their trust funds, revolving funds and
commercial activities. Fiscal 1994 was the third year EPA was required to prepare
audited financial statements. For EPA, the largest activity requiring an annual
financial statement is the Hazardous Substance Superfund. The CFO Act also
requires audits of the financial statements by the OIG or an independent public
accounting (IPA) firm selected by the OIG. The EPA OIG's requirement to audit
EPA's financial statements also meets our CERCLA requirement to audit annually
the Superfund, which we previously called our Trust Fund audit. The summary
below of our fiscal 1994 financial statement audit concentrates on. findings related
to the financial statements of the Hazardous Substance Superfund.
FURTHER IMPROVEMENTS IN FINANCIAL REPORTING NEEDED
Findings in Brief
During fiscal 1994, the Agency continued to make improvements in its financial
systems and processes. However, additional improvements are needed before an
opinion can be rendered on the Agency's Superfund financial statements.
We Found That
We could not determine if the Superfund financial statements were fairly presented
primarily because of weaknesses in accounting for property, accounts payable and .
accrued liabilities, grants funded from multiple appropriations, and Superfund State
cost share credits. We summarize below our findings on internal controls.
Financial Reporting. The Agency's financial activities could be more effectively
managed if additional information was available, and if available information was
provided in more useful formats and was better used to analyze the Agency's
financial activity. Lack of adequate information and reports resulted in Agency
officials being unable to effectively monitor some asset and liability accounts. In
some cases, to obtain information needed in a timely manner, Agency officials
operated systems that required them to enter information already in the Agency's
Integrated Financial Management System (IFMS).
Property. The procedures used to capitalize property did not identify all property
that should have been capitalized and when property was taken out of service it
was not deleted from the accounting records. Therefore, we were unable to
determine if the Agency's property balances reported in the financial statements
($11.7 million for Superfund) were fairly presented.
Accounts Payable and Accrued Liabilities. We identified a net understatement of
$219,763 in accounts payable and accrued liabilities that affected the Superfund.
This misstatement was caused in part by problems with the accuracy and
timeliness of data from a tracking system used by two of the Agency's finance
offices. In addition, we found that 17 out of 56 Superfund accounts payable/
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EPA Office of the Inspector General Annual Superfund Report to the Congress for Fiscal 1994 8
accrued liability accounts had a debit balance when they should have had a credit
or zero balance.
Grant Payments. The Agency processed disbursements for multi-funded assistance
agreements using a first-in/first-out method, i.e., the oldest available funding was
used first. This method could result in a misstatement of expenses during the
fiscal year among the Agency's appropriations.
Accounts Receivable. Emphasis by Agency management on recording receivables,
and work performed by the independent public accounting firm under contract to
the OIG, succeeded in reducing the number of unrecorded accounts receivable.
We did identify: (1) two receivables totaling $4.7 million that were not initially
recorded in the fiscal 1994 financial statements, (2) an understatement of
$346,701 in the allowance for doubtful accounts, and (3) $4.7 million of
marketable securities accepted in settlement of existing accounts receivable that
had not been recorded.
Superfund State Cost Share Credits. When EPA takes the lead in cleaning up a
site, it enters into a contract with the State for the State to share in the cost of the
cleanup. Rather than make payments to EPA for their share of cleanup costs,
States can receive credits for amounts they incurred for remedial actions prior to
entering into a contract with EPA. These credits were not being recorded in IFMS.
We identified $1.4 million in such credits that were not recorded.
Tests of compliance with laws and regulations. We did not identify any instances
of noncompliance with laws and regulations that would materially affect the
financial statements. However, as we have reported in previous audit reports, the
Agency had not allocated certain support costs to the Superfund Trust Fund
because budgetary ceilings had been reached. The Agency has requested the
Office of General Counsel provide an opinion on whether this is proper.
We Recommended That
The Chief Financial Officer:
• Provide finance offices with general ledger reports by office and hold them
accountable for the accuracy of their account balances.
• Revise the Agency's capitalization polices and procedures to assure that
disbursements necessitating capitalization are being identified and properly
capitalized.
• Determine why liability accounts had debit balances and make any necessary
adjustments to the account balances.
• Require a clause in assistance agreements funded from more than one
appropriation that specifies how the payments should be charged to the
various appropriations. If certain work can only be paid for from a specific
appropriation, the clause should require the grant recipient to include
accounting information with each payment request.
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EPA Office of the Inspector General Annual Superfund Report to the Congress for Fiscal 1994
• Provide guidance to finance offices on the need to: (1) notify Headquarters
finance officials if receivables are identified after the close of the year, so
adjustments can be made to the financial statements; and (2) identify
potentially uncollectible receivables and include these receivables in the
calculation of the allowance for doubtful accounts.
• Develop procedures for recording Superfund State cost share credits in IFMS
and assure that credits are properly recorded.
What Action Was Taken
In responding to our draft report, the CFO indicated:
• EPA would provide general ledger reports by accounting point to enable
resolution of errors in account balances.
• EPA had formed a Quality Action Team to review current policies and
procedures, and develop a plan to resolve reconciliation problems between the
Agency's financial accounting and property accountability systems. Also, the
Agency would issue revised property policies and procedures.
• One of the two finance offices with problems with its accruals would not use
its fiscal 1994 process again, and the other was conducting a revieyv of the
issue.
• EPA had analyzed the problems with debit balances in liability accounts and
would make needed corrections.
• EPA would prepare a policy on how payments are to be charged to grants
funded from multiple appropriations.
• EPA would include special steps in the fiscal 1995 year-end instructions to
improve accounting for receivables.
• EPA would identify existing State credits and determine whether additional
guidance on State credits is needed.
The final report (5100192) was issued to the CFO on February 28, 1995. A
response to the final report is due by May 30, 1995.
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EPA Office of the Inspector General Annual Superfund Report to the Congress for Fiscal 1994 10
RESPONSE CLAIMS
Section 111(a)(2) of CERCLA, as amended by SARA, authorizes EPA to pay any
claim for response costs incurred by "any other person" as a result of carrying out
the NCR. Additionally, section 122(b)(1) of CERCLA, as amended by SARA,
authorizes the President to reimburse Potentially Responsible Parties (PRPs) for
"certain costs of actions under the agreement that the parties have agreed to
perform but which the President has agreed to finance." This authority was
delegated to the EPA under Executive Order 12580, January 26, 1987, and further
delegated to EPA's Office of Solid Waste and Emergency Response (OSWER).
Authority for decisions regarding claims against the Fund is currently delegated to
the Director, Office of Emergency and Remedial Response.
During fiscal 1994, we issued a follow-up report on our September 1992 review of
the response claims process and a report on a claim for the Marion Bragg Dump
site. We summarize these reports below.
AGENCY NEEDS TO IMPROVE EFFORTS IN ADMINISTERING RESPONSE
CLAIMS AGAINST THE SUPERFUND
Findings in Brief
While EPA had made efforts to implement some of the recommendations in our
1992 report, some corrective actions had not been implemented or had not
corrected the deficiencies we noted in 1992. All six EPA regions with
preauthorized mixed funding sites had been late in billing potentially responsible
parties (PRPs) for oversight costs. Commitment and obligation information for two
sites was still missing from the Integrated Financial Management System (IFMS).
Two needed guidance documents had still not been finalized.
Previous Problems and Findings
Our September 1992 report concluded that there were serious problems in EPA's
handling of response claims against the Superfund. We reported that significant
internal control weaknesses resulted in about $35 million of commitments and
obligations not being properly recorded, or not being recorded. Also, EPA paid
$2.8.million for the first preauthorized response claim (for the MOTCO site in
Texas) without adequate-assurance that all reimbursed costs were eligible and that
the PRP complied with the settlement agreement. Finally, EPA did not bill PRPs for
costs associated with the MOTCO site in accordance with the Consent Decree, so
EPA did not collect about $1.1 million for oversight work performed by EPA and its
contractors.
Follow-up Findings
While EPA had made efforts to implement some of our previous recommendations,
some corrective actions agreed to in the Agency's action plan had either not been
implemented or had not corrected the deficiencies noted in our 1 992 report.
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EPA Office of the Inspector General Annual Superfund Report to the Congress for Fiscal 1994 11
All six EPA regions with preauthorized mixed funding sites were from one month to
two years late in their billings for oversight costs. Four of the regions made their
billings current before we began our review, but Regions 3 and 6 were still not
current at the time of our review.
The Agency continued to experience difficulties in ensuring that commitment and
obligation information for these sites was entered into IFMS. The responsible
officials did not notice that two sites were missing from IFMS because periodic
reviews of preauthorized mixed funding site information covered only information
from the prior month, rather than all prior information.
Finally, two separate guidance documents on the commitment and obligation of
funds that the Agency had agreed to finalize by December 31, 1993, continued to
be in draft. The Agency advised us that both would be finalized by December 31,
1994, a year later than the original plan.
Follow-up Recommendations
We recommended that the Assistant Administrator for Solid Waste and Emergency
Response direct the Office of Emergency and Remedial Response to:
• Continue its efforts to finalize and issue procedures for the timely commitment
and obligation of funds.
• Ensure that the missing obligations for the two preauthorized mixed funding
sites are recorded in IFMS, and review financial reports for past as well as
present status of obligations.
• Modify the Office of Regional Counsel perfection form to ensure that PRP
compliance with the Consent Decree includes timely payment of any billed
oversight costs.
• Work with the Office of Enforcement and Compliance Assurance to provide for
an offset provision (reimbursements to PRPs against monies owed to the
Agency) in the consent decrees for preauthorized mixed funding sites.
We also recommended that the Assistant Administrator for Administration and
Resources Management direct the Office of the Comptroller to continue its efforts
to finalize and issue Resources Management Directive System Chapter 11 on
response claims.
We further recommended that the Assistant Administrators for Administration and
Resources Management, Enforcement and Compliance Assurance, and Solid Waste
and Emergency Response direct all regions to ensure PRPs are sent current and
accurate oversight cost billings before any PRP claims are paid at preauthorized
mixed funding sites.
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EPA Office of the Inspector General Annual Superfund Report to the Congress for Fiscal 1994 12
What Action Was Taken
The final report (4400091) was issued to the Assistant Administrator for Solid
Waste and Emergency Response and the Assistant Administrator for Administration
and Resources Management on July 29, 1994. The Office of Solid Waste and
Emergency Response (OSWER) responded on behalf of all involved Offices on
November 21, 1994. The Agency indicated it would:
• Issue final guidance on procedures for the timely commitment and obligations
of funds.
• Would provide account information for the two missing sites for IFMS.
• Modify the Office of Regional Counsel perfection form to specify that
compliance with the Consent Decree includes the payment of EPA's billed
oversight costs.
• Include a provision suggesting an offset in the payment of eligible claims based
on outstanding, billed oversight costs in OSWER guidance, and consider
including such a provision in Office of Enforcement and Compliance Assurance
guidance.
• Finalize and issue Resources Management Directive System Chapter 11 on
response claims.
• Issue a memorandum encouraging the regions to ensure current and accurate
oversight cost billings before any PRP claims are paid at preauthorized mixed
funding sites.
MORE THAN $1 MILLION OF MARION BRAGG SUPERFUND CLAIM
QUESTIONED
Findings in Brief
The Marion Bragg Potentially Responsible Party (PRP) Group claimed $1,079,410 of
ineligible, unsupported, and unreasonable costs related to its hazardous waste
cleanup. Through the combined effort of Agency officials and the OIG, EPA
adjusted the claim and authorized payment to the PRPs.
Background
On September 30, 1987, the Regional Administrator, Region 5, signed a Record of
Decision for the Marion Bragg Dump site, determining that the site was in need of
remediation. EPA then reached agreement with the principal PRPs to fund the
remediation of the site, with EPA reimbursing the PRPs 25% of the costs at the
completion of remediation, with a maximum reimbursement ceiling of $1,775,000.
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EPA Office of the Inspector General Annual Superfund Report to the Congress for Fiscal 1994 13
We Found That
The PRPs submitted a claim for $7,563,838, and requested reimbursement for the
maximum allowable amount of $1,775,000. We audited the claim and questioned
costs of $1,079,410, including:
'• $607,820 of unsupported project management costs because the PRPs did not
procure the services using competitive bid procedures.
• $224,250 of ineligible weather delay claims not allowable under the
construction contractor's contract.
• $117,148 of unreasonable project costs related to excessive markups.
As a result, we recommended that the PRPs be reimbursed $1,621,107 of the
claimed amount, $153,893 less than originally sought.
We Recommended That
The Director, Office of Emergency and Remedial Response, adjust the claim
downward for the ineligible costs of $251,967 ($62,992 Federal share) and for the
unreasonable costs of $201,855 ($50,464 Federal share). We also recommended
that the Director require the PRPs to provide sufficient documentation to support
the $625,588 ($156,397 Federal share) questioned as unsupported or recover
these costs.
What Action Was Taken
The final report (4400065) was issued to the Director, Office of Emergency and
Remedial Response, Office of Solid Waste and Emergency Response on May 24,
1994. On June 28, 1994, the Director authorized payment of the claim in the
amount of $1,671,857. We concurred with EPA's action, and closed this report in
our audit tracking system on September 19, 1994.
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EPA Office of the Inspector General Annual Superfund Report to the Congress for Fiscal 1994 14
COOPERATIVE AGREEMENTS
In fiscal 1994, we issued 12 audit and special review reports on Superfund
cooperative agreements, and also a report on regional management of Superfund
cooperative agreements. The combined financial results of the reviews of
Superfund cooperative agreements were as follows:
FINANCIAL RESULTS OF Fl
COOPERATIVE AGREEME
.
Amount audited
Ineligible costs1
Unsupported costs2
Unnecessary/unreasonable costs3
SCAL 1994 SUPERFUND
[NT REVIEW REPORTS
_ ^^== ^^_— — j^—^-^— -—
Federal Share
$93,613,295
588,946
123,309
0
i^^^^HM^HW^^^HH^HHHi^^^^B^BH^^^^^B
Total Costs
$97,261,300
606,817
127,730
0
1 . Costs questioned because of an alleged violation of a provision of a law, regulation,
contract, grant, cooperative agreement or other agreement or document governing the
expenditure of funds.
2. Costs questioned because, at the time of the audit, they were not supported by ade-
quate documentation and/or had not been approved by responsible program officials.
3. Costs questioned because they were not necessary or not reasonable.
We summarize two significant Superfund cooperative agreements audits below.
MORE THAN $278,000 OF QUESTIONED CLAIMS FOR GEORGIA
SUPERFUND ACTIVITIES
Findings in Brief
The Georgia Department of Natural Resources (GDNR) did not properly account for
labor costs or track costs by site as required by EPA regulations. We questioned
$278,756 of the costs claimed for three Superfund Cooperative Agreements.
Background
EPA awarded GDNR three Superfund cooperative agreements with potential costs
of more than $2.1 million to develop and implement management and
administration activities needed for a Superfund core program, to participate in site
inspection activities, and to provide technical review of documents associated with
Superfund remedial activities. Each of the cooperative agreements had been
amended to extend the project period and increase EPA funds.
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EPA Office of the Inspector General Annual Superfund Report to the Congress for Fiscal 1994 15
We Found That
GDNR had major weaknesses in internal controls and did not comply with EPA
regulations and cooperative agreement conditions in the areas of labor charging,
timekeeping, record retention, and site-specific accounting. Labor costs were
frequently charged to the wrong cooperative agreement and supervisory reviews of
time sheets were inconsistent. GDNR destroyed supporting cost records even
though the State had been cautioned in a 1990 audit that Superfund regulations
require such records to be retained for 10 years. GDNR was not tracking costs or
making letter-of-credit drawdowns by site as required because they were not
maintaining a recordkeeping system that enabled site-specific costs to be tracked.
In total, GDNR claimed $251,876 of ineligible costs under the cooperative
agreements, including personnel and fringe benefit costs associated with
mischarged labor, and training and vehicle costs which were not related to the
cooperative agreement.
An additional $26,880 of costs were questioned as unsupported due to the
premature destruction of supporting documentation on personnel, fringe benefit,
travel and equipment costs.
We Recommended That
The Acting Assistant Regional Administrator for Policy and Management, Region 4,
disallow the questioned costs and require GDNR to:
• Develop and implement specific policies, procedures and controls to make sure
all personnel costs are fully documented and properly allocated;
• Establish formal written timekeeping policies and maintain time sheet
documentation in accordance with applicable regulations; and
• Provide written assurance that it will comply with regulatory requirements on
record retention.
What Action Was Taken
The final report (4100496) was issued to the Acting Assistant Regional
Administrator for Policy and Management, Region 4, on August 22, 1994. In
response to our draft report, GDNR generally agreed with our findings and
recommendations and provided substantive planned or already initiated actions to
correct the identified weaknesses. Region 4 issued a Final Determination Letter to
GDNR on March 27, 1995, disallowing $256,825 ($244,645 Federal share),
including all of the costs we had questioned as ineligible. The Region also required
GDNR to submit their revised procedures for various areas of internal control
weaknesses we had identified.
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EPA Office of the Inspector General Annual Superfund Report to the Congress for Fiscal 1994 16
MORE THAN $227,000 OF INELIGIBLE CLAIMS FOR MINNESOTA
SUPERFUND SITE
Findings in Brief
The Minnesota Pollution Control Agency (MPCA) had weak internal controls over
personnel and contractor costs, and did not comply with procurement laws and
regulations. As a result, we questioned $227,584 of the costs claimed for the
Ritari Post and Pole site under a Superfund cooperative agreement.
Background
MPCA is responsible for managing remedial activities at selected Superfund sites
under EPA's CERCLA authority. In 1987, a Superfund multi-site cooperative
agreement was amended to provide funding of $234,005 for the Ritari Post and
Pole site with two-year budget and project periods. Six additional amendments
increased the award to $942,963 and extended the budget and project periods to
September 30, 1995.
We Found That
MPCA had significant weaknesses in internal controls in the areas of leave
allocation, contractor rate increase approvals, contractor indirect cost rate reviews,
contractor invoice support, and time sheet reviews. We found that leave allocation
procedures did not equitably distribute leave because the distribution was based
upon a percentage of the quarterly budgeted time allocated for Federal and State
projects, and MPCA employees were not consistently following leave allocation
procedures.
Contractor rate increases were approved by MPCA in excess of contract limits and
without a thorough cost analysis or supporting cost documentation. The process
used to review and approve indirect costs and associated rate increases did not
assure that these rates were accurate, allowable, and sufficiently justifiable. Under
a cost reimbursement type contract, MPCA permitted its contractor to submit
supporting documentation for its invoices on an inconsistent basis, and never
examined contractor time sheets to determine whether labor charges were
appropriate.
MPCA did not comply with regulations and cooperative agreement conditions on
contract procurement and site management. MPCA awarded a full scope contract
to a company that submitted only a limited scope proposal. MPCA also improperly
changed the scope of the cooperative agreement by adding more tasks to it
without obtaining approval from the EPA project officer. As a result, we found
$227,584 ineligible out of $942,959 total claimed costs.
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EPA Office of the Inspector General Annual Superfund Report to the Congress for Fiscal 1994 17
We Recommended That
The Regional Administrator, Region 5:
• Ensure MPCA implements its planned corrective actions to improve internal
controls.
• Clarify with MPCA that all work plans and reports are to be submitted to the
EPA project officer.
• Recover the questioned costs of $227,584.
What Action Was Taken
MPCA agreed to take corrective action for all identified weaknesses in internal
controls and disagreed with our conclusions regarding compliance and questioned
costs. The final report (4100488) was issued to the Regional Administrator,
Region 5, on August 15, 1994. In its November 9, 1994, response to the final
report, the Region .indicated it was assisting MPCA to improve its controls and train
its staff. The Region also indicated it would clarify responsibilities of its own staff.
The Region required MPCA to repay $148,587 of the questioned costs. While we
disagreed with the Region's decision not to require repayment of $29,461 of State
costs associated with monitoring work outside the contract scope, we felt the
issue was not significant enough for us to appeal. As a result, we closed this audit
in our tracking system.
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EPA Office of the Inspector General Annual Superfund Report to the Congress for Fiscal 1994 18
REMEDIAL INVESTIGATIONS AND FEASIBILITY STUDIES
In fiscal 1994, we issued five technical reports on remedial investigation/feasibility
study (RI/FS) activities covering six sites. The reports covered the American
Creosote, Louisiana, Popile, Arkansas, Frontier Hard Chrome, Washington,
Palmerton Zinc, Pennsylvania, Purity Oil, California, and Vineland Chemical Co.,
New Jersey sites. The OIG Engineering and Science Branch conducted these
reviews. The reports contained no recommendations, and required no response
from the Agency. We summarize these reviews below.
LIGHTNING ROD APPROACH SPEEDED SITE RESPONSE
Findings in Brief
Use of the Lightning ROD (Record of Decision) approach significantly speeded
remedial planning and the initiation of remedial action at two sites in Region 6. •
Background
The American Creosote site is a former wood treating facility located in central
Louisiana. The Popile site is an inactive wood preserving facility located near El
Dorado, Arkansas. Remedial planning activities for the American Creosote site and
the Popile site were performed as part of a pilot program. Both sites were referred
to as Lightning ROD pilots. The goal of the Lightning ROD approach was to reduce
the time required to complete remedy selection and initiate remedial action. The
Lightning ROD pilot projects were also intended to demonstrate the use of
"presumptive remedies" at wood treating facilities and landfills.
We Found That
Region 6 accomplished streamlining and acceleration of remedial planning and
remedy selection activities for the pilot projects with only minor adverse effects.
Remedial planning and initiation of remedial action at these pilot projects were
achieved significantly faster than was routinely experienced.
Program staff advantageously used information resulting from earlier
characterization efforts and from remedial actions performed at other wood treating
sites. Obtaining performance-related information on bioremediation late in the
selection process lessened its value.
The innovative field analysis techniques used to facilitate rapid collection,
validation, and interpretation of data did not work as expected. Consequently,
some useful information may not have been collected or properly used.
Preplanning efforts were not adequate to fully integrate prior removal actions at
these sites with subsequent remedial planning activities. Better coordination could
have hastened site characterization and assisted in streamlining the RI/FS and
remedial design planning process.
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EPA Office of the Inspector General Annual Superfund Report to the Congress for Fiscal 1994 19
Concurrent, rather than sequential, execution of remedial investigation, feasibility
study, and remedial design activities at wood treating sites can be expected to
improve overall project performance. Ongoing communication among regional
decision team members is an important element in the success of concurrent
activities. In addition, if site activities performed by either the removal or remedial
programs are to serve the needs of the other, the differing objectives and
requirements of each program must be recognized andoaddressed. For example,
inconsistent quality control requirements are an avoidable constraint on the use of
field data.
GENERALLY THOROUGH REMEDIAL PLANNING MARRED BY TECHNICAL
DEFICIENCIES AT WASHINGTON SITE
Findings in Brief
The remedial planning activities at the Frontier Hard Chrome site in Vancouver,
Washington were generally thorough and consistent with requirements of the
National Contingency Plan (NCP). However, there were technical deficiencies in
remedial planning methodology and presentation for both RODs for the site.
We Found That
While remedial planning was generally thorough and consistent with NCP
requirements, we also noted some technical deficiencies, including:
• Several potential contaminant source areas in the vicinity of the site described
in Administrative Record documents were not sufficiently investigated as part
of the Rl. The nature, extent, and significance of contamination at these
potential sources should have been established.
• Presentation in the Rl report of the highest reported chromium levels in
groundwater at the site was based on improperly commingling data from two
wells screened at different hydrostratigraphic zones. Although this deficiency
did not appear to significantly affect the remedy selection process, the method
of data presentation used for one monitoring well could lead to incorrect
conclusions regarding contaminant levels and trends within the alluvial aquifer.
INADEQUATE SITE CHARACTERIZATION AND ADMINISTRATIVE RECORD
DOCUMENTATION AT PENNSYLVANIA SITE
Findings in Brief
Inadequate preplanning, site characterization, and remedial alternatives analyses
resulted in ineffective remedial planning at the Palmerton Zinc site in Palmerton,
Pennsylvania. The public's ability to effectively participate in the remedial planning
process was limited by an inadequate Administrative Record.
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EPA Office of the Inspector General Annual Superfund Report to the Congress for Fiscal 1994 20
We Found That
The Administrative Record contained inadequate documentation to demonstrate
that sufficient preplanning was performed to fully address contamination in the
vicinity of the Town of Palmerton. Remediation boundaries were not specified, and
site activities did not seem to address all impacted areas. This contributed to the
deficiencies in the remedial planning process we observed.
There was inadequate characterization of the Cinder Bank with respect to
contaminants, internal fires, and stability. The remedial alternatives analysis for the
Cinder Bank Operable Unit could not be effectively conducted due to a lack of
sufficient information.
Remedial alternatives analyses did not adequately address implementation and
effectiveness criteria for several remedial alternatives. As a result, the reduction in
risk to human health, the costs for implementing several of the remedial
alternatives, and the technical feasibility of several alternatives were uncertain.
The Administrative Record was missing critical decision documents, and its
usability was diminished because of insufficient indexing of the contents. These
deficiencies limited the public's ability to effectively participate in the remedial
planning process.
REMEDIAL PLANNING THOROUGH AT CALIFORNIA SITE
Findings in Brief
The remedial planning activities at the Purity Oil Sales site in Fresno, California
were generally thorough and consistent with NCR requirements.
We Found That
The remedial planning activities at the site were generally thorough and consistent
with NCR requirements. The following two aspects of the planning process were
particularly commendable:
• The clarity and thoroughness with which the baseline risk assessment report
was written.
• The decision to conduct soil treatability tests prior to issuing a Record of
Decision for soils.
The presentation and documentation of several issues in the RI/FS reports could
have been improved. However, these areas for improvement did not appear to
have impacted the overall remedial alternatives analysis or remedy selection for the
site.
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EPA Office of the Inspector General Annual Superfund Report to the Congress for Fiscal 1994 21
SITE CHARACTERIZATION NEEDED IMPROVEMENT AT NEW JERSEY SITE
Findings in Brief
Shortcomings in site characterization during remedial planning at the Vineland
Chemical Co. site in Vineland, New Jersey resulted in additional activities being
needed after the ROD was signed.
We Found That
Remedial planning at the site was performed in a manner consistent with NCR
requirements. We did, however, identify shortcomings in characterization of the
distribution of arsenic-contaminated sediment and characterization of groundwater
hydrology. While we do not believe that the remedy evaluation and selection were
seriously compromised by these weaknesses, better information would result in
increased confidence in remedial planning for this site. The ROD identified
additional activities to be undertaken prior to final design that could account for the
identified weaknesses. In comments on our draft report, Region 2 stated that
additional information had been gathered.
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EPA Office of the Inspector General Annual Superfund Report to the Congress for Fiscal 1994 22
CONTRACTS
The OIG is responsible for conducting and supervising independent and objective
audits of Superfund programs and operations. To carry out this responsibility, the
OIG performs financial and compliance audits of EPA contractors. Each Public Law
authorizing EPA to award contracts provides the Agency authority to audit and
examine the books and records of the contractors and subcontractors receiving
Federal funds. Each EPA contract also contains audit provisions. Our primary
audit objectives are to determine (1) whether the controls exercised by the
contractors and subcontractors through their accounting, procurement, contract
administration, and property management systems are adequate to account for
costs claimed; and (2) costs claimed are reasonable, allowable, and allocable, in
accordance with applicable laws and regulations, to the sponsored project.
Audits of contracts not only yield financial benefits to the Agency, but also aid in
improving Agency management. We expect to devote increased resources to
auditing EPA contractors and subcontractors given the increased size of the
program and EPA's conduct of more actual cleanups. These audits also play an
integral part in supporting EPA's cost recovery actions.
Of the 177 contract review reports we issued in fiscal 1994, 60 covered incurred
costs under EPA contracts. The financial results of these reviews were as follows:
FINANCIAL RESULTS OF FISCAL 1994 SUPERFUND
INCURRED COST CONTRACT REVIEW REPORTS
Amount audited
Ineligible costs1
Unsupported costs2
Unnecessary/unreasonable costs3
Federal Share
$368,769,174
1,896,146
8,928,974
0
Total Costs
$371,992,126
1,902,057
8,928,974
0
1 . Costs questioned because of an alleged violation of a provision of a law, regulation,
contract, grant, cooperative agreement or other agreement or document governing the
expenditure of funds.
2. Costs questioned because, at the time of the audit, they were not supported by ade-
quate documentation and/or had not been approved by responsible program officials.
3. Costs questioned because they were not necessary or not reasonable.
Another 45 of our reviews were initial pricing reviews in which we reviewed costs
proposed by offerers or bidders seeking EPA contract awards. Because these are
only proposed costs, our reviews do not question costs but rather recommend as
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EPA Office of the Inspector General Annual Superfund Report to the Congress for Fiscal 1994 23
efficiencies costs that we believe EPA should not incur. The combined financial
results of the initial pricing reviews were as follows:
Total Costs Audited $ 909,760,488
Total Recommended Efficiencies $ 4,682,680
We also issued 22 reports on proposed indirect cost rates, 47 system survey
reports, and 3 program review reports on EPA contractors.
The OIG can choose to have the reviews performed by in-house staff, independent
public accounting firms or another Federal audit agency. During fiscal 1994, our
Superfund contract reviews were performed as follows:
Reviews Performed by OIG staff 18
Reviews Performed by Independent Public Accountants 31
Reviews Performed by Defense Contract Audit Agency 127
Reviews Performed by another Federal agency 1
Exhibit I contains a listing of all Superfund review reports issued by the OIG during
fiscal 1994.
We also conduct performance reviews of EPA's management of contracts and
procurement. During fiscal 1994, we issued six reports on such performance
reviews. '
We summarize the performance reviews and a particularly significant contract
review report on an EPA Superfund contractor below.
MORE THAN $200 MILLION IN UNLIQUIDATED AND EXCESS CONTRACT
OBLIGATIONS INCLUDING $143 MILLION IN SUPERFUND OBLIGATIONS
Findings in Brief
EPA did not close almost 2,000 inactive contracts (886 were Superfund) or
deobligate $7 million ($4.4 million Superfund) in excess funds on more than 100
closed contracts. This left more than $200 million ($143.4 million Superfund) in
unliquidated obligations that could have been used for other environmental
purposes or returned to the U.S. Treasury.
Background
During the past 23 years, the Agency's total contract obligations have exceeded
$12 billion for work performed under 14,500 contracts. Legislation enacted in
1990 requires payments needed to finalize old contracts to come from current year
funds. This legislation made timely contract closeout, deobligation of unexpended
monies, and receipt of refunds due the Agency even more important in helping the
Agency avoid using current financial resources on old contractual issues.
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EPA Office of the Inspector General Annual Superfund Report to the Congress for Fiscal 1994 24
We Found That
Closing almost 2,000 (886 Superfund) inactive contracts in a timely manner could
have allowed EPA to deobligate more than $200 million, the majority of which is
Superfund money. Some of these funds should have been deobligated almost 12
years ago and then used to either pay for other Government programs or EPA
projects or initiatives.
We also found more than 100 contracts (70 Superfund) were closed as many as
11 years ago, and $7 million was not deobligated because Agency personnel did
not prepare the necessary documentation. The Agency could have reprogrammed
$4.4 million for use in EPA Superfund programs and returned $2.6 million to the
U.S. Treasury.
We Recommended That
The Assistant Administrator for Administration and Resources Management:
• Emphasize the importance of timely contract closeout to all personnel
responsible for this function.
• Close completed contracts in accordance with the time frames specified by the
Federal Acquisition Regulation (FAR) and deobligate excess funds in a timely
manner.
• When closing contracts, direct initial efforts to those contracts with fiscal
1989 appropriations.
• Deobligate excess funds on all closed contracts as required by FAR.
What Act/on Was Taken
The final report (4100462) was issued to the Assistant Administrator for
Administration and Resources Management on July 21, 1994. In responding to our
draft report, the Agency agreed with our recommendations and provided an
acceptable action plan to correct the identified weaknesses, including setting
annual goals for closing contracts and dedicating personnel to this function to the
greatest extent possible. As a result, we closed this audit in our tracking system
and all corrective actions will now be tracked in the Agency's Management Audit
Tracking System.
AGENCY STRIVES TO ACHIEVE FULL AND OPEN COMPETITION WHEN
AWARDING SUPERFUND CONTRACTS
Findings In Brief
We found that the Agency had improved procurement procedures to achieve full
and open competition for Superfund contracts. Nineteen of 26 Superfund
contracts selected for review were competitively awarded amounting to $534.5
million or 99.6 percent of the total value of all contracts. Of the 19 competitively
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EPA Office of the Inspector General Annual Superfund Report to the Congress for Fiscal 1994 25
awarded contracts, 15 went to non-incumbent companies or companies not
previously involved in Superfund contracts.
Background
Prior OIG audits of Agency contracting activities disclosed several conditions that
limited competition in many EPA contracts. One such condition was the issuance
of large umbrella contracts that often allowed one company or a small number of
companies to control all of the activity in a specified program area for an extended
period of time. This and other conditions created a perception that incumbent
contractors were more than likely to be awarded follow-on contracts.
We Found That
The Agency actively sought ways to increase competition for Superfund contracts.
For example, the Agency eliminated many of the restrictive technical requirements
in the statement of work. Multi-tasked jobs for the larger Superfund contracts,
such as Emergency Response Cleanup Services (ERGS) contracts were divided into
separate tasks and awarded as separate contracts. Four of seven ERCS contracts
reviewed were awarded to non-incumbents or companies new to the Superfund
program. The four solicitations that resulted in seven ERCS contracts averaged
nearly four proposals and three companies in the competitive range.
What Action Was Taken
The final report (4100111) was issued to the Assistant Administrators for
Administration and Resources Management and Solid Waste and Emergency
Response on December 7, 1993. Since adequate action had been taken in
response to prior audit reports, we made no recommendations for action in this
report and no response was required from the Agency. The information in the
report was incorporated into our consolidated report on competition in contracting
throughout the Agency (4100232).
MOST LARGE CONTRACTS AWARDED TO ICF HAD LIMITED COMPETITION
Findings in Brief
There was limited competition in EPA's award of over half of the larger contracts to
ICF, Inc., and in ICF's award of subcontracts. In addition, EPA did not evaluate
ICF's performance on cost-plus-award-fee contracts timely. As a result, EPA did
not receive the full benefits of competition.
Background
As of March 1992, ICF, along with its subsidiary, Clement Associates, was the
Agency's second largest contractor and had 25 active contracts potentially worth
$388 million. EPA uses ICF {o support various activities of Agency program
offices.
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EPA Office of the Inspector General Annual Superfund Report to the Congress for Fiscal 1994 26
We Found That
EPA complied with Federal regulations when soliciting competition for contracts
awarded to ICF, and adequate competition existed in the award of most of the
smaller ICF contracts. However, the level of competition lessened as the value of
the contract reached $10 million. In three of the eight contracts exceeding $10
million (one of which was a Superfund contract), ICF was awarded the contract
because its price and technical proposals were more favorable than those of its
competitors. However, in the other five awards (one of which was for a Superfund
contract), ICF was the only firm to either submit a proposal or have its proposal
make the competitive range. On two of the three contract awards (one of which
was a Superfund award) in which only ICF made the competitive range, ICF was
the incumbent contractor or a subcontractor on the predecessor contract. As a
result, EPA did not receive the full benefits of competition in the award of these
contracts.
There was little evidence of competition in the award of subcontracts by ICF under
its three largest EPA prime contracts (one of which was a Superfund contract). ICF
routinely awarded subcontracts on a sole source basis, and EPA contracting
personnel had various interpretations of what constituted competition in the
assignment of work to subcontractors assembled by ICF to work on the contracts.
EPA's management of the award fee process was inadequate. In the four ICF cost-
plus-award-fee contracts (two of which were Superfund contracts) we reviewed,
EPA experienced difficulty and delays, ranging from less than 2 months to more
than 2 years (less than 2 months to 8 months for the Superfund contracts), in
evaluating ICF's performance. However, rather than improve its administration of
the award fee process, EPA converted three (one Superfund) of the contracts into
cost-plus-fixed-fee contracts.
We Recommended That
The Assistant Administrator for Administration and Resources Management have
the Director, Office of Acquisition Management:
• Issue guidance instructing Contracting Officers (COs) to conduct post-award
efforts to determine reasons why only one proposal made the competitive
range.
• Require the CO to review the awards of all significant subcontractors under
EPA prime contracts to ensure selection on a competitive basis.
• Require prime contractors to obtain CO approval of all significant subcontractor
budgets and any subsequent budget revisions.
• Emphasize to the EPA personnel involved in the award fee process that
completing timely evaluations is essential to the objectives of the process.
• Inform COs that the type of contract should be changed only when justifiable,
rather than simply to remedy administrative problems.
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EPA Office of the Inspector General Annual Superfund Report to the Congress for Fiscal 1994 27
What Action Was Taken
The final report (4100233) was issued to the Assistant Administrator for
Administration and Resources Management on March 31, 1994. In responding to
our draft report, the Agency provided responsive action plans and milestone dates
to correct the identified weaknesses. As a result, we closed this audit in our
tracking system and all corrective actions will now be tracked in the Agency's
Management Audit Tracking System.
CONTRACTORS STILL LACK ADEQUATE ACCOUNTING SYSTEMS
Findings in Brief
Emergency Response Cleanup Services (ERGS) contractor accounting system
deficiencies noted in past OIG reports still exist because of inadequate enforcement
by EPA personnel. EPA also rarely exercised sanctions for contractor non-
compliance.
Background
Prior audits of EPA's management of ERCS contracts reported that ERCS
contractors generally did not have adequate accounting systems to provide
accurate cost and equipment utilization data. ERCS contracts awarded after
March 31, 1992, include a new mandatory clause addressing accounting system
requirements.
We Found That
EPA's Office of Acquisition Management (0AM) and its regional contracting
officers (COs) continued to allow contractor non-compliance with the Federal
Acquisition Regulation and contract accounting systems requirements contract
clauses because they believed complete enforcement would drive away ERCS
contractors. Despite a decade of doing business with EPA, the ERCS contractors
reviewed still did not have approved accounting and billing systems needed for
cost reimbursement contracts. Except for one instance, sanctions for contractor
non-compliance were not exercised.
0AM and regional procurement personnel also allowed ERCS contractors to use
EPA's internal Removal Cost Management System (RCMS) as a billing mechanism,
despite requirements for ERCS contractors to generate invoices from, and reconcile
them to, their internal accounting systems. Moreover, EPA's historic reliance on
the RCMS to validate the contractors' claims did not provide the necessary internal
controls to reasonably assure proper accounting for the Agency's contract
expenditures because there was no assurance that billed charges were actually
incurred and paid by the contractor.
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EPA Office of the Inspector General Annual Superfund Report to the Congress for Fiscal 1994 28
We Recommended That
The Assistant Administrator for Administration and Resources Management require:
• 0AM and regional ERCS contracting officers (COs) to enforce FAR and
contract clause accounting system requirements for all current and future
ERCS contacts. Significant remedies should be pursued when contractors are
not making sufficient, timely progress toward clause compliance.
• Contractors to correct inadequate accounting systems before EPA awards the
contract.
• 0AM to provide the needed oversight and assistance to ensure consistent and
uniform regional implementation and enforcement of FAR and contract
accounting system requirements.
• Contractors to generate invoices from, and support invoices by, contractor
accounting systems. The RCMS should not be used as a substitute for
required contractor accounting systems.
The Assistant Administrator for Solid Waste and Emergency Response require that:
• EPA Forms 1900-55 certified by On-Scene Coordinators (OSCs) not be used in
a manner that could be reasonably interpreted to satisfy contract
documentation requirements. To neutralize this possible interpretation, the
historical significance of EPA Form 1900-55 as a cost report should be
de-emphasized and affirmation of its use as a receiving report should be
emphasized.
• The EPA Form 1900-55 be modified by supplementing the OSC certification
language with a clear disclaimer of the authenticity and acceptance of the
costs recorded thereon.
What Action Was Taken
The final audit report (4400112) was issued to the Assistant Administrators for
Administration and Resources Management and Solid Waste and Emergency
Response on September 29, 1994. On February 16, 1995, the Assistant
Administrator for Administration and Resources Management responded, indicating:
• OAM would provide guidance regarding alternative sanctions COs may use to
enforce contract compliance. Regions had used such sanctions as reducing
the award fee for contract management for two contracts and partially
suspending program management costs.
• Cost accounting for equipment charges was the single area where removal
contractors were still not able to demonstrate full cost accounting. The
Agency would pursue a strategy of using time and materials contracts with
fixed rates for labor and equipment to verify that rates will be fair and
reasonable.
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EPA Office of the Inspector General Annual Superfund Report to the Congress for Fiscal 1994 29
• 0AM issued a memorandum to COs reminding them of their fiduciary
responsibilities to manage contracts prudently, and encouraging them to
aggressively pursue remedies permitted under the contract to cure failures or
violations.
• 0AM reminded COs that the use by contractors of RCMS and EPA Form 1900-
55 to invoice the Agency was improper.
CONFLICT OF INTEREST IN EPA REGION 9 SAMPLE ANALYSIS AND DATA
VALIDATION ACTIVITIES
Findings in Brief
Region 9's use of the Environmental Services Assistance Team (ESAT) contract for
both sample analysis and data validation activities created an organizational conflict
of interest and the opportunity for biased data validation that could have improperly
influenced Superfund actions.
Background
EPA's ESAT contract Inc., provided personnel to perform analytical and technical
tasks as directed under specific work assignments for six EPA Regions and
Headquarters. ESAT task areas included hazardous waste chemical analysis,
review and validation of Contract Laboratory Program data, and review of site
specific quality assurance, site investigation and sampling plans.
We Found That
Region 9 had assigned an increasing amount of its sample analyses to the Region 9
Laboratory staffed by ESAT rather than using the Contract Laboratory Program.
The analytical data was sent to the regional office for data review and validation by
ESAT contract personnel. For the 10-month period ended July 1993, about 38
percent of all data reviews conducted by the ESAT contractor were on analyses
performed in the Region 9 Laboratory.
Region 9's practice of using the Regional Laboratory for sample analyses and the
same contractor to conduct data validations for the same samples created an
organizational conflict of interest as described in the Federal Acquisition Regulation.
The situation jeopardized the independence of the data validation portion of the
Region's quality assurance/quality control program. Although our limited review
did not disclose any evidence of bias in the ESAT contractor's data validation
activities, the opportunity existed for'impairment of the contractor's objectivity in
performing sample analysis and data validation activities.
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EPA Office of the Inspector General Annual Superfund Report to the Congress for Fiscal 1994 30
We Recommended That
The Regional Administrator, Region 9, eliminate the organizational conflict of
interest with the ESAT contract, considering the following options:
• Conducting data validations using either Region 9 personnel or another
contractor; and
• Initiating additional quality control reviews of ESAT-conducted data validations
until the conflict of interest is eliminated.
What Action Was Taken
The final report (4400025) was issued to the Regional Administrator, Region 9, on
January 31, 1994. Region 9 responded to the final report on May 2, 1994. The
Region indicated that the ESAT contract task providing for data validation on data
generated by ESAT chemists had been discontinued, eliminating the conflict of
interest. The Region proposed alternative data validation measures relying upon
EPA staff.
ERA'S CONFLICT OF INTEREST POLICIES AND PROCEDURES NEEDED
FURTHER STRENGTHENING
Findings in Brief
EPA did not have a formal process for identifying and prioritizing contracts most
vulnerable to conflict of interest (COI) problems, or for planning and conducting
reviews of contractors' COI prevention systems. EPA had not performed an on-site
review of the COI identification system of a contractor performing sensitive site
ranking work.
Background
A government contractor has a COI when the nature of the work to be performed
under a contract may result in an unfair competitive advantage to the contractor or
may impair the contractor's objectivity in performing the work. EPA's Contracting
Officers handle COI issues under Agency contracts.
The Office of Solid Waste and Emergency Response (OSWER) lists and ranks the
Nation's worst hazardous waste sites on the National Priorities List (NPL). Sites
proposed to the NPL are evaluated using the Hazard Ranking System (MRS), a
mathematical model which serves as the primary tool for determining which sites
are placed on the NPL. Under a contract with EPA, Dyncorp Viar, Inc. provides
technical assistance with quality assurance reviews of the analyses supporting MRS
scores.
This special review was the result of a request from the Chairman, Committee on
Governmental Affairs, United States Senate.
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EPA Office of the Inspector General Annual Superfund Report to the Congress for Fiscal 1994 31
We Found That
0AM has no formal process for planning or conducting reviews of contractors' COI
prevention systems, although EPA officials stated in response to a 1989 General
Accounting Office report that such checks would be appropriate and could be done
as part of existing contractor performance reviews.
Although NPL listings are extremely sensitive, 0AM had not performed an on-site
review of the COI prevention system of Dyncorp Viar, Inc. (Viar) or Dyncorp (Viar's
parent company). Although Viar's COI procedures appeared to meet regulatory
requirements, we believed that the Agency should verify that Viar was following
those procedures.
We Recommended That
The Assistant Administrator for Administration and Resources Management direct
0AM to:
• Develop a process to assure annual testing of contractors' COI identification
systems.
• Review Viar's and Dyncorp's COI identification systems.
What Action Was Taken
The final report (4400076) was issued to the Assistant Administrator for
Administration and Resources Management on June 27, 1994. He responded to
the report on September 29, 1994, indicating that 0AM:
• Would establish a method for prioritizing contracts most vulnerable to COI
concerns and develop procedures for conducting on-site COI compliance
reviews at contractors' facilities.
• Had conducted an on-site review of Viar's and Dyncorp's COI identification
systems and their compliance with EPA requirements, which uncovered no
COIs pertaining to the HRS contract.
SUPERFUND CONTRACTOR DESTROYED SOURCE DOCUMENTATION
Findings in Brief
OHM Remediation Services Corp., an EPA Emergency Response Cleanup Services
(ERCS) contractor, was destroying original source documentation. EPA's ERCS
contracts specifically stated that source documentation was to be maintained in
order to support cost recovery actions by EPA.
Background
OHM Remediation Services Corp. held several ERCS contracts during the period of
1987 to 1991. Section H of these contracts specifically stated that the contractor
shall not destroy original records relating to the contract until: (1) ten years have
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EPA Office of the Inspector General Annual Superfund Report to the Congress for Fiscal 1994 32
passed from the date of final payment, (2) litigation involving the records has been
instituted, and (3) approval of the contracting officer is obtained.
We Found That
The contractor had not been complying with this contract provision. The
contractor had been destroying original source documentation for a period prior to
1987 though March 1992. Additionally, the contractor did not have written,
formal procedures for record retention and storage. These conditions were
disclosed during our review of direct costs billed under these contracts for fiscal
years 1987 through 1991.
The lack of compliance with this contract term significantly impeded the extent to
which an audit could be conducted because the original invoices, stamped with the
applicable delivery order number, are the auditor's principal means of testing the
allocability of costs to the delivery order under which the costs were billed. This
could prolong resolution and definitization of delivery orders by EPA. In addition,
cost recovery could be severely hampered should Potential Responsible Parties
request original source documentation in order to determine their liability at a
Superfund site.
We Recommended That
EPA's Financial Administrative Contracting Officer (FACO) take action to formally
notify OHM that it was in noncompliance with contract terms on record retention.
We also recommended that if the contractor failed to come into compliance, the
FACO should pursue administrative action against OHM.
What Action Was Taken
The final report (4400064) was issued to the Chief, Cost Policy and Rate
Negotiations Branch, Cost Advisory and Financial Analysis Division, Office of
Acquisition Management, on May 20, 1994. On June 16, 1994, EPA notified the
contractor that it must comply with its contract terms, or be faced with
administrative action. On June 29, 1994, the contractor responded to EPA, stating
that it no longer destroys original source documentation, and that it uses
microfilming as an additional security measure. We concurred with EPA's action,
and closed this report on September 19, 1994.
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EPA Office of the Inspector General Annual Superfund Report to the Congress for Fiscal 1994 33
INTERNAL AUDITS AND SPECIAL REVIEWS
In addition to reviews required by CERCLA, as amended, we conducted other
reviews of EPA's management of the Superfund program. We summarize below
internal audits and special reviews completed in fiscal 1994 not summarized
elsewhere in this Report.
EPA'S INFORMATION RESOURCES MANAGEMENT (IRM) PROGRAM
NEEDED TOP MANAGEMENT ATTENTION
Findings in Brief
EPA had systemic deficiencies in IRM management and organizational structure,
resource planning and performance measurement, information systems
development, and data management. EPA did not treat information as a valuable,
strategic resource.
Background
Sound, efficient, and responsive information systems are critical to EPA's
achievement of its mission. For example, EPA's information systems must provide
accurate and reliable data on management and oversight of the Superfund program
and on nationwide air and water quality. On September 27, 1993, the Chairman
and Ranking Minority Member of the Senate Subcommittee on Superfund,
Recycling, and Solid Waste Management, Committee on Environment and Public
Works, requested the Inspector General to perform a comprehensive management
review of EPA's information systems. At the Inspector General's request, EPA
agreed to participate in this review which was performed by a joint OIG/Agency
team working cooperatively to identify the root causes of EPA's IRM problems.
We Found That
EPA had significant IRM problems concerning the quality, integrity, and
completeness of its data and its usefulness in addressing cross-media pollution
problems due to weaknesses in four key areas.
IRM Management and Organizational Structure. EPA staff perceived upper
management as not recognizing the criticality of or being accountable for IRM. The
IRM Steering Committee had not fulfilled its important role as an executive-level
decision-making body, and EPA's formal lines of authority and communication for
IRM matters were confused. Also, the organizational placement, numbers, and
apparent qualifications of the EPA employees with significant IRM responsibilities
were inconsistent among Headquarters program offices.
Resource Planning and Performance Measurement. The Agency had neither an
Agency-wide IRM Strategic Plan nor a "Business Plan," although both were being
developed. Not integrating its long-term IRM planning with its single-year
budgeting process had historically contributed to funding shortages for systems
development projects. IRM planning was greatly complicated by EPA's unbalanced
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EPA Office of the Inspector General Annual Superfund Report to the Congress for Fiscal 1994 34
emphasis on short-term vs. Jong-term results. EPA's IRM was generally reactive as
a result of continually changing Congressional information needs, new and
changing environmental regulations, and poor communications with Congressional
staff. Also, EPA's information systems did not have sufficient capability to
measure environmental successes, accomplishments, and economic benefits.
Further, EPA could not account for its IRM expenditures on a system by system
basis.
Information System Development. Developers of EPA's systems did not always
work effectively with EPA program officials, Congress, and the States (their users
and customers) to understand the programs and define their information needs.
Most national systems appeared designed to meet Headquarters needs, but were
not very useful and "friendly" to the regions and the States and could not answer
some valid questions by the Congress about Agency accomplishments. In addition,
EPA offices usually did not use a standard software development approach,
primarily due to the extensive use of many contractors with widely varying
methodologies which did not always meet Federal requirements.
Data Management. Data sharing was crucial to the Administrator's four top
priorities: ecosystems protection, pollution prevention, environmental justice/equity,
and partnership development. Yet EPA did not have the IRM "structure" to link or
share data Agency-wide, due partly to insufficient resources and EPA's media-
based organizational structure. Data quality problems in many EPA information
systems were often due to frequently changing definitions of data and lack of data
"ownership" by those who input it.
We Recommended That
The Administrator:
• Establish a separate Chief Information Officer at the Assistant Administrator
level with authority and responsibility for the Agency's IRM program .and
strengthen a number of components of the IRM program.
• Closely link the IRM planning process with EPA's Business Plan and integrate it
with the Agency's budget process.
• Strengthen EPA's process for developing information systems and increasing
user involvement during the development process.
• Develop an Agency-wide data architecture and data standards and establish a
centralized data administration function.
What Action Was Taken
The final report was issued to the Administrator on March 24, 1994. The Office of
Administration and Resources Management (OARM) responded to the report on
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EPA Office of the Inspector General Annual Superfund Report to the Congress for Fiscal 1994 35
July 21, 1994, and supplemented that response with further information on
September 29, 1994. Among the actions taken or planned by OARM were:
• Asking the Administrator to name the Assistant Administrator of OARM as the
Agency's Chief Information Officer.
• Linking the IRM Strategic Plan with the Agency Strategic Plan and the IRM
budget process.
• During development of the Agency's new life cycle management policy,
addressing identification and involvement of primary and secondary users,
detailed needs analyses including the needs of primary and secondary users,
and cost-benefit analyses.
• Undertaking an initiative in fiscal years 1995 and 1996 on Agency data
requirements and a data architecture study.
IMPORTANCE OF FINANCIAL MANAGEMENT VIEWED INCONSISTENTLY
AT EPA
Findings In Brief
Some EPA staff viewed financial management as subservient to program
management, while others believed these functions were mutually supportive.
These differing viewpoints and perceptions made it difficult for EPA to effectively
manage and improve its financial management activities.
Background
On September 27, 1993, the United States Senate Committee on Environment and
Public Works, Subcommittee on Superfund, Recycling, and Solid Waste
Management requested a comprehensive review of EPA's financial management
program, with as much attention as possible to the Superfund program. Working
cooperatively with EPA's Financial Management Division (FMD), we highlighted
current issues and developed solutions based on input from representative EPA
managers and staff through a series of focus group meetings and extensive
interviews. We also analyzed over 130 OIG reports and over 60 General
Accounting Office reports to identify financial management concerns.
We Found That
Although the Chief Financial Officer position was created to raise the visibility of
financial management throughout the Agency, this had not yet been fully realized.
EPA financial management in the program offices suffered from: (1) an overall lack
of understanding of the importance of financial management, (2) lack of the data
and reporting tools that managers needed to effectively manage their programs, (3)
a weak link between budgeting and planning, and (4) too many financial codes
with interpretations that were confusing to program staff.
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EPA Office of the Inspector General Annual Superfund Report to the Congress for Fiscal 1994 36
Agency personnel were concerned about the principal EPA finance and reporting
systems. The Agency's Integrated Financial Management System (IFMS) could not
always be relied on to effectively meet their financial management requirements.
Overall, there was a lack of integration and incompatibility of financial and
reporting systems. Duplicate or alternate personal computer based systems were
developed locally to meet regional financial management needs not provided by the
Agency's systems.
EPA financial policies and procedures were often difficult to locate, out of date,
incomplete, and confusing; and therefore difficult to use. EPA staff did not believe
the Agency's policies and procedures were effective.
With respect to Superfund activities, cost recovery from responsible parties for the
cleanup of hazardous waste sites was not always given the support or resources
needed and was viewed as secondary to the mission of cleaning up hazardous
waste sites. The Agency did not have information readily available to determine a
feasible target or amount for cost recovery. Further, the Agency did not routinely
analyze results to compare recoveries against established targets. Some costs
were not allocated to their specific sites, preventing the Agency from tracking and
recovering the costs later from responsible parties. These costs were often
recorded differently in IFMS and the Comprehensive Environmental Response
Compensation and Liability Information System (CERCLIS), leading headquarters to
sometimes ask the regions to manually collect data for external reports.
EPA did not regularly offer courses essential for training Agency employees to
effectively accomplish their financial management responsibilities. This resulted in
inexperienced and untrained personnel performing financial management duties.
We Recommended That
The Administrator, EPA:
• Identify and implement best or bench mark practices for financial management
operations Agency-wide to help set standards of service and performance.
• Establish a joint effort between FMD and the program offices with
client/customer teams to work out the interface problems associated with
IFMS and other Agency finance and reporting systems.
• Review, update and consolidate EPA's financial management policies and
procedures electronically and make them more user friendly.
• Ensure that clear and consistent EPA cost recovery goals and targets are
established and assign a higher priority to Superfund financial management,
specifically cost recovery.
• Have FMD establish an Agency-wide core of training courses that are
mandatory for Agency employees involved in financial management activities.
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EPA Office of the Inspector General Annual Superfund Report to the Congress for Fiscal 1994 37
What Action Was Taken
The special review report (4400042) was issued to the EPA Administrator on
March 31, 1994. The Agency responded to the report on August 10, 1994. The
Agency's response outlined a comprehensive series of actions taken or planned to
implement report recommendations. These actions included:
• Upgrading the Financial Managers Quality Assurance (QA) Program for
financial operations Agencywide. This includes periodic QA reviews by FMD
of the finance offices. The QA Program will identify best practices and share
them among all finance offices.
• FMD working with its clients through several management and user groups to
identify and address interface problems and needs.
• Establishing a schedule for addressing the Agency's most pressing needs for
Resources Management Directives, and providing accounting and financial
management policies on an electronic bulletin board.
• Increasing focus on setting goals and communicating the successes of the cost
recovery program.
• Establishing the Financial Management Career Development Committee to
review current financial management training programs and develop options for
ensuring that the workforce receives needed education and training.
BETTER CONTROLS NEEDED TO PROTECT SECURITIES RECEIVED IN
BANKRUPTCY CASES
Findings In Brief
EPA had limited controls in place to safeguard marketable securities received as a
result of Superfund cost recovery efforts. Also, current bankruptcy laws hinder
EPA's cost recovery efforts.
Background
Some responsible parties from whom EPA has sought to recover Superfund Trust
monies filed for bankruptcy protection. In such cases, EPA may receive marketable
securities in the reorganized companies as payment of debts. During fiscal years
1992 and 1993, EPA received 2.4 million shares of marketable securities worth
$22.4 million which were transfered to the Treasury Department to be sold and
proceeds returned to the Superfund Trust Fund.
We Found That
EPA had not established central receiving points, restricted access, maintained
records, or assigned custodial responsibility for securities. The Agency could not
be assured securities were adequately safeguarded against theft and forwarded
timely to Treasury, and there were no procedures to follow up with bankrupt
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EPA Office of the Inspector General Annual Superfund Report to the Congress for Fiscal 1994 38
responsible parties or their trustees to ensure receipt of all securities. In the two
regions we visited, accounts receivable for Superfund bankruptcy settlements were
recorded an average of seven months after agreements were reached with
responsible parties, and securities received were not recorded in the Agency's
accounting system until Treasury sold the securities.
Bankruptcy cases handled by Headquarters attorneys were not always entered into
the Comprehensive Environmental Response, Compensation and Liability
Information System (CERCLIS), the Agency's main Superfund tracking system. We
identified six bankruptcy cases valued at over $96.6 million that were settled
during fiscal years 1992 and 1993, but were not recorded in CERCLIS. Further,
EPA was not tracking marketable securities transferred to the Agency, the amount
of securities received, and the total proceeds from their sale.
Two key issues involving bankruptcy law need to be resolved to improve the
Agency's ability to recover Superfund cleanup costs. First, some reorganizing
companies have argued that EPA's claim should include all environmental liability,
even future cleanup costs EPA might incur, and that the bankruptcy settlement
should discharge all of their environmental liability. Second, it is unclear how much
information responsible parties should include in their bankruptcy notices to
creditors, and where the notices should be filed, which could cause the Agency to
miss its opportunity to participate in bankruptcy proceedings.
We Recommended That
The Chief Financial Officer establish central receiving points for marketable
securities, designate employees to be responsible for securities, and develop
procedures for properly handling and recording marketable securities.
The Assistant Administrator for Enforcement and Compliance Assurance:
• Assign responsibility for following up with reorganized companies to help
ensure EPA receives all of the securities it is entitled to receive, and develop
procedures to ensure Superfund bankruptcy settlements are recorded in
CERCLIS.
• Include provisions in the Agency's bankruptcy guidance to follow up with the
Department of Justice when final bankruptcy orders are not forwarded timely
to EPA; and forward bankruptcy orders timely to the appropriate financial
management office so an account receivable can be established.
• Develop procedures to track collections, including form of payment for
bankruptcy settlements; and revise,the Superfund enforcement performance
measurement reporting to reflect the impact bankruptcies have on the
Superfund cost recovery program.
What Action Was Taken
The final report (4100579) was issued to the Chief Financial Officer and the
Assistant Administrator for Enforcement and Compliance Assurance on
September 30, 1994. The Chief Financial Officer responded to the draft report on
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EPA Office of the Inspector General Annual Superfund Report to the Congress for Fiscal 1994 39
October 5, 1994 (after the final report was issued) and to the final report on
January 25, 1995. He indicated EPA would:
• Issue instructions on the central receiving point for securities, assign custodial
responsibilities for handling and safeguarding marketable securities, and
incorporate securities handling procedures into a revision of Resources
Management Directive 2550D.
• Create bankruptcy policy and procedure revisions to settle EPA claims.
• Conduct a needs analysis of CERCLIS which would include tracking
information on bankruptcy cases.
GREATER EMPHASIS NEEDED BY OSWER ON IMPLEMENTING THE
FINANCIAL INTEGRITY ACT
Findings in Brief
The Office of Solid Waste and Emergency Response (OSWER) had not ensured that
managers scheduled and conducted evaluations necessary for properly assessing
and improving management controls over resources available for accomplishing
their missions.
Background
The Federal Managers' Financial Integrity Act (FMFIA) requires agencies to evaluate
the adequacy of their accounting and administrative control systems and report
their conclusions annually to the President and Congress. OSWER is among the 22
major organizational components responsible for administering FMFIA at EPA.
We Found That
OSWER trained managers and properly included management control
responsibilities in their performance standards, making them aware of FMFIA's
requirements. Several managers properly used strategic plans, work plans, and
priorities to identify vulnerabilities and schedule control evaluations. Also, OSWER
managers planned and tracked corrective actions for weaknesses reported in
annual assurance letters and established validation strategies to ensure reported
weaknesses were corrected.
However, OSWER had not organized control evaluation efforts so that managers
assessed vulnerabilities for all programs and functions and then scheduled control
evaluations based on vulnerabilities. Some managers did not know how
vulnerability assessments, management control plans, and control evaluations
related. As a result, managers did not properly plan and conduct control
evaluations.
In addition, OSWER did not properly evaluate interactions with the regions to
ensure overall mission accomplishment. OSWER needed to work with the regions
to develop model management principles to ensure that the regions are fulfilling
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EPA Office of the Inspector General Annual Superfund Report to the Congress for Fiscal 1994 40
OSWER strategic plans and program goals. OSWER also needed to use the
regions' management control evaluation results as early warnings of potential
program-wide problems and weaknesses that could affect successful mission
accomplishment.
We Recommended That
The Assistant Administrator for OSWER:
• Establish procedures to ensure that all managers integrate Integrity Act
requirements into management activities, identify best practices and encourage
managers to share them.
• Require managers to assess annually the effectiveness of their management
control systems and document the results. Advise managers to consider all
programs and functions when assessing controls.
• Share model management practices with regional program offices for their use
in developing management controls consistent with the OSWER mission and
goals.
• Obtain the results of regional management control assessments to identify
potential Agency-wide weaknesses and advise regions and other program
offices when appropriate. For potential Agency-wide weaknesses, strengthen
controls in written policies and procedures.
What Action Was Taken
The final audit report (4100224) was issued to the Assistant Administrator,
OSWER on March 28, 1994. OSWER responded to the report on July 1, 1994.
OSWER indicated it:
• Had issued integrity guidance and OSWER implementation strategy to the
OSWER Office Directors.
• Would develop and implement a systematic review strategy for assessing how
well its program guidance and procedures protect its programs and resources
from fraud and mismanagement, and support the achievement of mission
goals.
• Would develop program-specific integrity principles for program areas that are
most visible, vulnerable, or susceptible to mismanagement; and share those
principles with regional program offices and throughout OSWER.
• Would request from the regions lists of reviews conducted in areas program-
specific to OSWER. [This was completed on August 4, 1994.]
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EPA Office of the Inspector General Annual Superfund Report to the Congress for Fiscal 1994 41
SUPERFUND INITIATIVES REDUCE TIME AND SAVE MONEY
Findings in Brief
EPA conducted a variety of successful initiatives which demonstrated the potential
for reducing the time and cost of cleanups, and for making the process more
equitable. However, improvements were needed in analyzing, measuring, and
publicizing the results of pilot projects to replicate successful techniques
nationwide.
Background
In July 1993, the Deputy Administrator announced the Agency's plan to improve
the Superfund program within the current statutory authority. This plan, known as
the "Superfund Administrative Improvements" (SAI), focused on enhancing four
areas of most concern to the Administration, Congress, and the public:
• Enforcement fairness and reduced transaction costs.
• Cleanup effectiveness and consistency.
• Meaningful public involvement.
• The States' role in the Superfund program.
The Superfund Revitalization Office (SRO) in the Office of Solid Waste and
Emergency Response (OSWER) provided overall coordination of the SAI effort. The
OIG initiated a number of reviews of SAI pilot projects. We summarize below nine
SAI review reports we issued during this reporting period.
We Found That
Regions 1 and 8 conducted enforcement pilot projects which showed potential to
accelerate the Superfund process and reduce costs. However, SRO needed to
improve the transfer of knowledge gained from pilots. In addition, the Regions did
not always adequately plan for using available funds or report important project
activities to Headquarters.
Region 3 conducted an "Innovative Data Validation Approach" to reduce the cost
and turnaround time associated with validating analytical results of samples taken
at Superfund sites. The initiative proved to be a worthwhile concept which
deserved more emphasis by Regional management.
Region 5 successfully completed three pilot projects focusing on accelerating the
Superfund cleanup process. The pilots streamlined the traditional Superfund
process by accelerating cleanup actions and integrating site assessments.
However, summary reports providing Headquarters quantitative and qualitative
results of the pilots were not completed.
Region 5 also introduced pilot projects under the Allocation Tools and Mixed
Funding initiatives to promote fairer settlements. Limited progress was achieved
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EPA Office of the Inspector General Annual Superfund Report to the Congress for Fiscal 1994 42
using allocation tools due to contract delays, and the Region had not developed
measures of success for the mixed funding initiative.
Region 6 used a Regional Decision Team at the National Zinc site to effectively
coordinate the simultaneous collection and use of data for multiple purposes. It
appeared that this pilot would be successful in achieving its objectives of
accelerating cleanup and increasing efficiency in the Superfund process.
Region 7 initiated 12 pilot projects for six different initiatives. Although the Region
completed three projects and started work on nine others, it could not measure the
projects' success because measurable performance objectives had not been
established.
Region 10 demonstrated the use of removal authorities at two sites to accelerate
site cleanups. The removal actions achieved permanent site remedies which saved
time and, at least for one of the sites, costs by eliminating the need to perform
longer term remedial actions.
We Recommended That
• The Acting Regional Administrator, Region 1, direct program staff to prepare
cost estimates prior to requesting funds from Headquarters, direct program
staff to discuss with the SRO the guidelines for reporting on innovative pilot
activities, and include expenditure of extramural funds in pilot report sheets.
• The Acting Regional Administrator, Region 8, contact SRO on pilot report
content and format, documentation of cost/time savings, potential pilot sites,
the expenditure of pilot funds, and significant changes in pilot status.
• The Assistant Administrator for Solid Waste and Emergency Response request
SRO to coordinate with division directors to determine the best way to
disseminate pilot results and coordinate presentations by regional personnel at
Agency professional conferences on successful pilot approaches; re-evaluate
the system for regional goal setting to provide comparable credit for successful
innovative approaches; and request the regions to document cost estimates,
report the status of extramural funds, consult with SRO before reprogramming
pilot funds, report significant pilot activity, and consult with SRO on
documentation of time/cost savings.
• The Regional Administrator, Region 5, complete final pilot reports and
coordinate with Headquarters to develop performance measures for the mixed
funding initiative.
• The Regional Administrator, Region 7 establish measurable performance
objectives for each of the pilot projects.
What Action Was Taken
• Region 1 agreed to consult with Headquarters regarding funding and reporting
issues, and to report the status of extramural funds in progress reports to
Headquarters.
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EPA Office of the Inspector General Annual Superfund Report to the Congress for Fiscal 1994 43
• Region 8 agreed to consult with SRO on report format and content, and on
documentation of cost/time savings, respond to SRO requests for accounting
of pilot funding expenditures, and advise SRO of significant changes in pilot
status. ^
• OSWER indicated it had taken several steps to disseminate pilot results, would
clarify performance measures to be reported, and would provide guidance to
the regions on monitoring pilot funding and results.
• Region 5 agreed to complete final project reports and work with Headquarters
to develop measures of success for the mixed funding initiative.
• Region 7 obtained specific guidance and direction from EPA Headquarters on
performance objectives, and compared its regional project results against thosev
objectives.
AGREED UPON IMPROVEMENTS COULD ACCELERATE SUPERFUND SITE
ASSESSMENT AND CLEANUP
Findings in Brief
Without program guidance from EPA Headquarters, regions implemented the
Superfund Site Inspection Prioritization (SIP) program inconsistently, performed
SIPs on some sites unnecessarily, and did not ensure that the worst sites were
given priority in assessment.
Background
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) and to ensure accomplishment of EPA's policy to cleanup "worst sites
first". The process consists of investigations of the threats posed by a site and
whether the site qualifies for Federal funding. The SIP program is one step in the
site assessment process and involves reevaluating nearly 6,500 hazardous waste
sites for possible inclusion on the NPL. These sites were initially evaluated prior to
the implementation of the revised Hazard Ranking System.
We Found That
EPA did not issue SIP program guidance until August 1993, almost two years after
implementation of the program. Although the August 1993 guidance reiterates
EPA's policy to propose worst sites first for listing on the NPL, the guidance does
not provide a planned implementation approach with measurable goals.
Information about SIP program results input into Comprehensive Environmental
Response, Compensation and Liability Information System, the Superfund
program's automated information system, was inconsistent and inaccurate,
hindering effective program management. The program's management control
documentation did not include adequate control techniques to ensure national
consistency in program implementation.
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EPA Office of the Inspector General Annual Superfund Report to the Congress for Fiscal 1994 44
Despite its efforts to accelerate site assessment and cleanup, EPA had not met the
CERCLA goal to list sites on the NPL within four years of site discovery and will
likely be unable to meet this goal in the near future. Further, the SIP program is
expected to identify over 3,100 sites that qualify for inclusion on the NPL, which
presents significant funding problems.
At EPA's current budget rate, it will take over 27 years and about $105 million to
make NPL decisions on these 3,100 sites. EPA may have to reevaluate sites that
remain in the backlog for an extended time period. Based on past EPA cleanup
costs per site, it will cost $74.5 billion to clean up these 3,100 sites. Although
extremely important to the public, Congress, and responsible parties, EPA does not
include information on the cost of cleaning up potential NPL sites in its annual
Superfund report to Congress.
As one possible solution, EPA initiated a State deferral pilot program that may
reduce the NPL backlog, conserve site assessment resources, accelerate site
cleanups, and help EPA meet CERCLA site assessment goals. States would be
allowed to clean up sites that otherwise would be candidates for listing on the NPL.
An even broader deferral policy could permit other Federal authorities and
responsible parties to clean up sites awaiting NPL listing. EPA had previously
proposed a deferral policy but still needed to consider and respond to comments on
the proposal.
We Recommended That
The Assistant Administrator for Solid Waste and Emergency Response:
• Ensure that regions conduct SIPs on high priority sites and account for SIPs
consistently.
• Analyze the resources required to meet CERCLA's site assessment goals and
report to Congress the estimated cost of cleaning up those sites that, upon
completion of the SIP program, will likely be listed on the NPL.
• Consider elements identified by EPA and State officials as essential to a
successful deferral policy and determine the proper Federal role when
establishing oversight responsibilities before implementing a broader deferral
policy.
What Action Was Taken
Our final audit report (4100180) was issued to the Assistant Administrator for
Solid Waste and Emergency Response on January 31, 1994. The Office of Solid
Waste and Emergency Response (OSWER) responded on May 16 and June 20,
1994. OSWER agreed to implement recommended improvements to the SIP
program concerning high priority sites, provide an analysis of the resources needed
to meet CERCLA timeliness goals, and pursue deferral of sites to States.
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EPA Office of the Inspector General Annual Superfund Report to the Congress for Fiscal 1994 45
FURTHER STEPS NEEDED TO COMPLETE IMPROVEMENTS IN CONTRACT
LABORATORY PROGRAM
Findings in Brief
EPA initiated significant actions to address weaknesses in the Contract Laboratory
Program (CLP) in response to prior audits and an Agency task force review.
However, EPA would benefit from additional management attention to contract
actions against poorly performing laboratories and a re-evaluation of its policy on
applying the contractual Warranty of Services clause.
Background
Under the CLP, EPA awards contracts to private laboratories to provide analytical
services to support Superfund site investigations and cleanups. During the period
of our review, EPA contracted with more than 100 laboratories which analyzed
over 100,000 samples a year. The National Program Office directing the CLP is
located in the Office of Solid Waste and Emergency Response (OSWER).
We Found That
The Agency initiated significant actions to address weaknesses in the CLP. These
actions responded to previous OIG reports on the CLP and an internal Federal
Managers' Financial Integrity Act task force review of the CLP. For example, data
acquired during this review indicates that the program was now very conscientious
about performing pre-award evaluations prior to the award of new CLP contracts.
When fully implemented, OSWER's new and revised policies, procedures and
tracking system should significantly improve program management and controls.
We found two areas, however, which we believe would benefit from some
additional management attention. In our opinion, the program should (1) increase
its use of contract actions against poorly performing laboratories, and (2) re-
evaluate its policy on applying the Warranty of Services clause in the CLP
contracts.
Additional emphasis on the use of contract actions in cases of poor performance
could improve program effectiveness in assuring receipt of high quality data
analyses. We found a few instances of sanctions imposed on contractors with
indications of poor performance during the period of our review. The review did
show, however, that the CLP consistently withheld payments for incomplete or late
submissions identified during the contract compliance screening activities
conducted by the Sample Management Office.
The Agency issued a CLP procedure which appears to provide only 90 days for the
Agency to apply the Warranty of Services provision in the CLP contracts. This
provision allows EPA to revoke acceptance of data if it finds latent defects, fraud
or gross mistakes. Past experience indicates these conditions are often not
discovered within 90 days. Neither the Federal Acquisition Regulations nor EPA's
Contract Administration Manual required a time limitation for application of the
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EPA Office of the Inspector General Annual Superfund Report to the Congress for Fiscal 1994 46
Warranty of Services. The Agency procedures could limit the Government's ability
to recover for defective or fraudulent data.
We Recommended That
The Assistant Administrator for Solid Waste and Emergency Response:
• Remind Administrative Project Officers (APOs) of their responsibilities to initiate
timely and sufficient actions against poorly performing CLP laboratories as
delineated in OSWER program guidance documents.
• Remind APOs of the need to fully document contract related actions and
corrective actions in order to protect the Agency's interests.
• Remind the regions of the importance of accepting only analytical data which
fully complies with contract requirements and their responsibilities for
recommending actions when CLP contractors submit unacceptable data
analyses.
• Review, in consultation with the Office of Administration and Resources
Management and the Office of General Counsel, the 90-day revocation period
specified in OSWER Directive 9200.9-02 to assure that Agency rights are not
unduly limited; and revise the Directive as appropriate.
What Action Was Taken
The final report (4400115) was issued to the Assistant Administrator for Solid
Waste and Emergency Response on September 29, 1994. OSWER responded to
the report on January 17, 1995, indicating it would:
• Annually send a memorandum to APOs reminding them of their responsibilities
in initiating actions against poorly performing laboratories.
• Send a memorandum to APOs reminding them of the need to fully document
contract actions and corrective actions.
• Annually send a memorandum to APOs reminding them of the importance of
accepting data which fully comply with contract requirements, and of their
responsibilities for recommending actions when CLP laboratories submit
unacceptable data.
• Work with the Office of Administration and Resources Management and the
Office of General Counsel to determine if the Agency's Warranty of Services
policy unduly limits the Agency's rights to revoke acceptance of data, and
revise the policy if needed.
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EPA Office of the Inspector General Annual Superfund Report to the Congress for Fiscal 1994 47
LABORATORY CONSOLIDATION WOULD IMPROVE EFFICIENCY AND
REDUCE COSTS
Findings in Brief
The Office of Research and Development (ORD) could improve efficiency and
reduce costs by relocating personnel and consolidating functions of its Risk
Reduction Engineering Laboratory-Releases Control Branch (RREL-RCB) in Edison,
New Jersey with the Cincinnati, Ohio, Risk Reduction Engineering Laboratory
(RREL).
Background
The Edison, New Jersey, RGB staff performed basic small scale research operations
until fiscal years 1987 and 1988, when Congress approved funding for a research
facility at Edison to develop and evaluate commercial-scale innovative technologies.
However, local objections during 1991 and 1992 resulted in Congress canceling
the project and RGB's principal research facility was closed due to a lack of funds.
We Found That
The RGB function could be consolidated into RREL, Cincinnati, Ohio, which would
provide an improved management structure where the laboratory director could
have greater direct knowledge and control of daily operations, planning, and
administrative matters. In addition, cost savings would be achieved in areas such
as payroll, equipment and supplies, and time and money spent on travel from RGB
to Cincinnati, and RREL to Edison, for meetings or conferences.
Rather than conducting hands-on research, RGB scientists were primarily writing
and publishing technical papers, making presentations at meetings and
conferences, and monitoring extramural activities as Project Officers or Work
Assignment Managers. Consolidation would provide RGB personnel with the
opportunity to conduct hands-on research as RREL would have more flexibility in
assigning administrative work.
We Recommended That
We recommended that the Acting Assistant Administrator for Research and
Development:
• Formulate a plan to relocate the RGB and two other RREL functions from
Edison, New Jersey to the RREL in Cincinnati, Ohio in phases and in
coordination with recommendations made by an external study of EPA
laboratories and facilities.
• Gradually phase out functions instead of relocating the entire office at one
time, allowing some individuals to temporarily remain at Edison to complete a
specific project.
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EPA Office of the Inspector General Annual Superfund Report to the Congress for Fiscal 1994 48
What Action Was Taken
The final report (4400100) was issued to the Acting Assistant Administrator for
Research and Development on August 25, 1994. ORD responded to our report on
December 6, 1994. The response indicated our recommendations would be
implemented in conjunction with the recommendations in an Agency study of the
ORD laboratory structure to respond to current and future roles and missions. The
Administrator accepted the study's recommendation to functionally consolidate
EPA's 12 research laboratories into 4 national laboratories. The research and
development functions in Edison, New Jersey, are to be functionally incorporated
into one of these laboratories, centered in Cincinnati. However, the Administrator
decided to postpone consideration of physical consolidation of laboratories until at
least June 1996 due to the attendant human and financial costs. RGB's physical
location and mission will be evaluated as part of the detailed implementation of the
study recommendations.
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EPA Office of the Inspector General Annual Superfund Report to the Conqress for Fiscal 1994 49
INTERAGENCY AGREEMENTS
EPA enters into interagency agreements (lAGs) with several other Federal agencies
to perform Superfund tasks. The Offices of Inspector General or other audit
organizations of the receiving agencies audit the cost records for these agreements
and/or their agency's performance. The EPA DIG also issues these audit reports to
EPA with a cover letter, which includes recommendations for EPA action if
appropriate. In fiscal 1994, we issued nine of these reports to EPA management,
including one that was a reissue of a defective copy of a report. We summarize
the audits below by agency audited. We did not recommend EPA action on any of
these audits. CERCLA requires other Inspectors General, like EPA's, annually to
audit their agency's use of the Superfund and report on that audit to the Congress.
AGENCY FOR TOXIC SUBSTANCES AND DISEASE REGISTRY
The Department of Health and Human Services (HHS) OIG performed an audit
of the fiscal 1992 Superfund financial activities of the Agency for Toxic
Substances and Disease Registry (ATSDR), which is part of the Public Health
Service (PHS). For fiscal 1992, the HHS OIG found that, in general, ATSDR
administered the fund in accordance with CERCLA, as amended. However, the
HHS OIG determined that the Centers for Disease Control and Prevention (CDC),
which provides administrative services to ATSDR, and ATSDR did not have
procedures in place to ensure that all Superfund grantees had obtained independent
audits. As a result, CDC and ATSDR were not aware whether audit requirements
were being met. They also were not aware whether some grantees who did not
submit the required audit reports should have been sanctioned.
/
In its response to the audit report, the PHS agreed that procedures should be
established to ensure that the appropriate audit reports are submitted by grantees.
However, it did not believe it was responsible for ensuring they were received. It
did agree to ask CDC to ensure that audit reports are submitted for Superfund
grantees and to take appropriate action should any grantee refuse to submit a
required audit report.
U.S. ARMY CORPS OF ENGINEERS
The U.S. Army Audit Agency audited the fiscal 1992 Superfund financial
transactions of the U.S. Army Corps of Engineers. The Corps is responsible for
managing the design and construction of Federal cleanup sites. It found that
financial transactions were properly supported and accurately recorded. However,
the New York District did not promptly record obligations for contracts and
contract modifications. It also found that the Corps submitted its Superfund
minority contractors utilization report on time, and the report was properly
supported by feeder reports from the districts and divisions. However, the feeder
reports did not include all Superfund obligations and, in one case, did not include
all obligations to business concerns or other organizations owned or controlled by
socially and economically disadvantaged individuals, including women (small
disadvantaged businesses).
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EPA Office of the Inspector General Annual Superfund Report to the Congress for Fiscal 1994 50
COAST GUARD
The Department of Transportation (DOT) OIG performed an audit of fiscal 1992
Superfund costs incurred by the Coast Guard. The DOT OIG found that the Coast
Guard had improved its administration of Superfund activities, encouraged minority
firms to participate in Superfund-related contracts, and submitted the required
annual report on minority contractor participation to EPA. However, the DOT OIG
identified $491,226.29 of costs billed to EPA but not supported by required
documentation, overbilled EPA a net of $128,640.44, and did not bill EPA for
$355,202.92 of valid incurred Superfund reimbursable costs. The Coast Guard
generally concurred with the findings and recommendations, and took or planned
actions meeting the intent of the recommendations.
The EPA OIG noted that the Coast Guard reported that the unsupported costs
were supported by imaged documentation. The unsupported costs would be
resolved by a Memorandum of Understanding being finalized between the Coast
Guard and EPA authorizing the use of imaged documents as support for Superfund
costs.
FEDERAL EMERGENCY MANAGEMENT AGENCY
The Federal Emergency Management Agency (FEMA) OIG audited FEMA's
administration of the permanent and temporary relocation components of the
Superfund program for fiscal 1992. The FEMA OIG found that FEMA had
effectively administered the permanent and temporary relocation program.
Generally, FEMA spent funds for eligible purposes and supported expenditures with
documentation. The FEMA OIG questioned only $72,690 of the $2.3 million in
expenses incurred. In addition, FEMA recorded $15,749 in the wrong Superfund
account. FEMA management agreed with the findings and recommendations for
corrective actions.
DEPARTMENT OF THE INTERIOR BUREAU OF RECLAMATION
The DOI OIG audited the Bureau of Reclamation's accounting for fiscal 1992
Superfund expenditures. The Bureau provides technical assistance to EPA in
responding to releases of hazardous substances into the environment. The
technical assistance included managing remedial investigations and feasibility
studies, preparing specifications, and managing and overseeing construction. The
DOI OIG selected 25 of the 53 lAGs under which the Bureau had incurred a total of
$21,144,134 in costs. The audit reviewed $18,353,947 of the $20,846,656 in
costs incurred under these 25 lAGs. The DOI OIG questioned a total of $121,197:
$27,461 of unsupported direct costs and $93,736 of costs in excess of amounts
authorized by the lAGs. The Bureau also submitted its fiscal 1992 Minority
Business Utilization Report late and was inconsistent in meeting the required level
of spending for contracts with minority businesses. The Bureau resolved all
recommendations made by the DOI OIG.
DEPARTMENT OF THE INTERIOR U.S. FISH AND WILDLIFE SERVICE
The DOI OIG audited the U.S. Fish and Wildlife Service's accounting for fiscal
1991 and 1992 reimbursable Superfund expenditures. The Service provides
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EPA Office of the Inspector General Annual Superfund Report to the Congress for Fiscal 1994 51
technical assistance to survey damages to natural resources from releases of
hazardous substances, pollutants, and contaminants into the environment. The
DOI DIG judgmentally selected 20 lAGs for review and audited $80,762 of the
$356,071 in costs claimed for fiscal 1991, and $124,657 of the $529,058 claimed
for fiscal 1992. The Service could not support costs totaling $3,251. The Service
timely reported negative Minority Business Utilization Reports to EPA. The DOI DIG
resolved its recommendations with the Service.
DEPARTMENT OF JUSTICE
The Department of Justice (DOJ) OIG conducted an audit of the DOJ
Environment and Natural Resources Division's (ENRD) implementation of its IAG
with EPA for fiscal 1992. The DOJ conducts all Superfund litigation. The direct
and indirect costs charged to the IAG were allowable, allocable, and reasonable;
and the accounting procedures and controls applied were consistent with IAG
requirements and DOJ standards. However, the ENRD incurred costs which
exceeded the IAG by $808,252 because of untimely reporting and accounting of
expenses. In addition, the Minority Business Utilization Report was incomplete and
inaccurate. ENRD included in the Report five businesses with subcontracts totaling
over $215,000 which did not qualify as disadvantaged business enterprises and
estimated the subcontract amounts for two prime contractors. In response to the
draft audit report, ENRD concurred with the recommendations of the DOJ OIG and
was taking steps to implement them.
NATIONAL INSTITUTE OF ENVIRONMENTAL HEALTH SCIENCES
The HHS OIG performed an audit of the fiscal 1992 Superfund financial
activities of the National Institute of Environmental Health Sciences (NIEHS). The
NIEHS carries out training activities and studies of chemical exposure effects
mandated by CERCLA, as amended, through funding provided by lAGs with EPA.
The NIEHS is a component of the National Institutes of Health (NIH), an agency of
the PHS. The HHS OIG found that NIEHS generally administered the fund
according to Superfund legislation. However, NIH and NIEHS had not implemented
recommendations in the prior year's audit report to establish procedures to ensure
that all Superfund grantees submit audit reports and sanction grantees unwilling to
have a proper audit conducted and submitted. PHS agreed that such procedures
should be established, but did not believe it was PHS' responsibility. It agreed to
ask NIH to ensure that audit reports are submitted. It also agreed to take
appropriate action should any grantee refuse to submit a required audit report.
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EPA Office of the Inspector General Annual Superfund Report to the Congress for Fiscal 1994 52
REVIEW OF AGENCY'S SUPERFUND PROGRESS REPORT
Section 301 (h) of CERCLA, as amended by SARA, requires that, "On January 1 of
each year the Administrator of the Environmental Protection Agency shall submit
an annual report to Congress of such Agency on the progress achieved in
implementing this Act during the preceding fiscal year." The provision also requires
the inclusion of seven specific areas in the report. CERCLA requires the Inspector
General to review this report ". . . for reasonableness and accuracy and submit to
Congress, as a part of such report a report on the results of such review."
The sixth Annual Report was due to Congress on January 1, 1993, covering fiscal
1992 activities. This report was ready for final signature as of April 11, 1995.
Our reviews of data integrity for the accomplishments to be included in the
Agency's fiscal 1992 report were summarized in the OIG Annual Report for fiscal
1993. The Agency's seventh Annual Report was due to Congress on January 1,
1994, covering fiscal 1993 activities. It was at the Office of Management and
Budget for review as of April 11, 1995.
During fiscal 1994, we issued several reports on the Agency's claimed
accomplishments to be reported in its fiscal 1993 Annual Report. These review
reports are summarized below.
EPA TAKING ACTIONS TO IMPROVE CRITICAL SUPERFUND DATA
QUALITY
Findings in Brief
EPA Headquarters and regions are implementing actions that could effectively
correct 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.
Background
CERCLIS maintains information about activity at Superfund sites. Information is
usually entered by regional staff, using a regional data base system called
WasteLAN. The Agency uses CERCLIS data in its financial statements and its
Superfund Annual Report to Congress. CERCLIS should contain complete, current,
and accurate information.
We Found That
Eighty-six percent of pur sample of fiscal 1993 Superfund accomplishments and
settlements recorded in CERCLIS by EPA Regions 1, 5, 6 and 7 were correct.
Subsequent Agency actions increased the percentage of correct entries in that
sample to 91 percent, and actions were taken to prevent similar errors from
recurring. The questioned accomplishments and settlements in our sample either
were not in compliance with criteria in the program office manual, duplicated other
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EPA Office of the Inspector General Annual Superfund Report to the Congress for Fiscal 1994 53
reported accomplishments, were not supported by settlement documents, or lacked
compliance by responsible parties.
Our review of internal controls over CERCLIS data entry and quality in EPA Regions
1, 5, 6 and 7 showed the risk of material data errors, which would not be promptly
detected, varied from low,to moderate. The location with the weakest controls,
Lexington laboratory in Region 1, had the largest number of significant problems in
its CERCLIS data. Region 5 had improved its internal controls, after our review of
CERCLIS data entry and Superfund accomplishments recorded for fiscal 1992, and
had a low rate of questioned accomplishments for fiscal 1993. In Region 6, we
found that some required management letters accepting actions has not been
prepared. Region 7 officials took corrective action on problems during our review
of fiscal 1993 data.
At the national level, WasteLAN programming still allowed individuals to attempt
entry into the system an unlimited number of times, which created a risk of
alteration of data by unauthorized persons. The Agency began the process of
instituting an intruder lockout system to correct this problem before we issued our
final report.
We also found that settlements amounts recorded in CERCLIS were sometimes not
documented or did not agree with the documentation. Headquarters had not
provided the regions with guidance on estimating the cost of future work to be
performed by responsible parties.
We Recommended That
The Assistant Administrator for Solid Waste and Emergency Response provide final
guidance on preparing and documenting the estimated settlement amounts for
responsible parties!!
The Regional Administrator, Region 1, continue to improve administration of
controls and correct erroneous information in CERCLIS.
The Assistant Regional Administrator for Management, Region 6, strengthen
internal controls.
What Action Was Taken
We issued final audit reports to each of the four Regions we reviewed: Region 1
(4100212, March 18, 1994), Region 5 (4100196, March 3, 1994), Region 6
(4100213, March 21, 1994), and Region 7 (4100201, March 4, 1994). We issued
our final consolidated audit report (4100229) to the Assistant Administrator for
Solid Waste and Emergency Response on March 30, 1994. The Office of Solid
Waste and Emergency Response (OSWER) responded on July 18, 1994, reporting
that supplemental guidance to the Superfund Program Implementation Manual
(OSWER Directive 9200.3-14-1 a) was issued on April 11, 1994. This guidance
outlined the sources for estimated settlement amounts, and required that the basis
for estimated settlement amounts be documented in the site/case files.
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EPA Office of the Inspector General Annual Superfund Report to the Congress for Fiscal 1994 54
Region 1 responded to our final audit report on May 11, 1994. The Region
reported that it had corrected data entry errors. It also reported it had drafted
internal control procedures and had taken other steps to improve internal controls.
Region 6 responded to our final audit report on May 11, 1994. The Region had
formed a CERCLIS data quality work group to address audit recommendations.
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EPA Office of the Inspector General Annual Superfund Report to the Congress for Fiscal 1994 55
INVESTIGATIVE ACTIVITY
During fiscal 1994, our Superfund investigative efforts resulted in eight indictments
and four convictions. In addition, OIG investigations led to 11 administrative
actions, including the debarment of companies and their personnel. At the end of
fiscal 1994, we had 46 active Superfund investigations, 29 percent of all active
OIG investigations at EPA.
The OIG Office of Investigations (Ol) has undertaken a major proactive investigative
effort with respect to the Superfund program. As part of this initiative, Ol held a
conference in Chicago bringing together Ol managers and investigators from
various locations nationwide. The group met to develop proactive investigative
plans based on a review of Superfund program vulnerabilities identified at a
previous task force meeting. The plans developed focus on all stages of Superfund
activities including contracting, removals, and remediation. As a result of this
conference, several of the plans developed have been initiated nationwide as open
proactive investigations.
Ol also has had a major investigative initiative directed at fraud in the Contract
Laboratory Program (CLP). Laboratory analyses under the CLP are the empirical
basis for the entire Superfund program. Based on testing for the presence of
hazardous chemicals by these laboratories, the Superfund program decides which
cleanups to initiate and how to carry them out. Fraudulent analyses could result in
a danger to the public health and safety as well as the unnecessary expenditure of
cleanup funds. In addition, fraudulent analyses could hinder the Department of
Justice's efforts to collect the cost of cleanups from the responsible parties. Three
contract laboratory investigative cases are described below.
Firm and President Convicted of 41 Counts
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 1994 of filing 41
false claims. THI of Herndon, Virginia, was to establish and monitor national
shipping accounts for the shipment of laboratory samples of hazardous waste and
other materials to certain contract laboratories for analysis. Under the cost plus
fixed fee subcontract, with a value of greater than $2 million/ EPA was to pay THI
for certain percentages of THI's direct and indirect costs. The investigation
revealed that Head personally directed four former THI employees to falsify records
which showed the number of hours that these employees worked on the EPA
contract. Mr. Head used the false information to inflate numerous THI invoices
submitted to EPA.
Louisiana Company Debarred for 25 years; Managers for 50 Years
On March 9, 1994, EPA debarred National Environmental Testing (NET) Gulf Coast,
Inc., (with the exception of its Baton Rouge, Louisiana laboratory) for 25 years.
Also, EPA debarred two of the company's managers, Joan Lutkenhaus and Cynthia
Placko-Moore, for 50 years. As a result of an earlier investigation, NET Gulf Coast,
Inc., pleaded guilty to making false, fictitious, and fraudulent claims under EPA's
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EPA Office of the Inspector General Annual Superfund Report to the Congress for Fiscal 1994 56
contract for laboratory analyses of inorganic compounds. The two managers
accepted responsibility for knowing of and participating in fraudulent manipulation
of data and instructing subordinates to falsify data on CLP sample analyses in order
to meet EPA CLP criteria.
California Lab Indicted
Eureka Laboratories, Inc., of Sacramento, California and 2 of its principal managers
were indicted on 71 counts of making false documents and filing false claims.
Each count carries a maximum penalty of five years imprisonment and a $250,000
fine. An analytical services laboratory, Eureka was hired by government agencies
including EPA, the Army, the Air Force, and the Navy, to test water, soil, and air
samples for environmental pollutants in connection with the remediation of
hazardous waste sites. The government contracts required the tuning, calibration,
and performance testing of laboratory equipment to make sure the data produced
were accurate and reliable.
The indictment alleged that the defendants routinely used sophisticated computer
software commands to falsify its analytical test results so that it falsely appeared
that Eureka properly calibrated and maintained its laboratory equipment. The
indictment also alleged that Eureka concealed its fraudulent manipulations of data
by removing various computer-generated "flags" or identifiers from the documents
it delivered to government clients. The alleged fraudulent practices compromised
the accuracy and reliability of the test results.
The Eureka investigation was conducted by the EPA OIG, the U.S. Army Criminal
Investigation Command, the U.S. Air Force Office of Special Investigations, and the
California Environmental Protection Agency.
OTHER INVESTIGATIVE ACTIVITY
In addition to the CLP activity, EPA OIG investigations related to Superfund
resulted in the prosecutive activity and administrative actions described below.
Battery Company Owner Pleads Guilty
Charles L. Guyton, owner of C&R Battery, Inc., of Richmond, Virginia, pleaded
guilty in November 1993 to making a false statement to EPA. He concealed
personal assets from EPA in connection with his potential liability for the costs of
Superfund cleanup of contamination at the battery company location.
Former Section Chief and On-scene Coordinator Debarred for 3 Years
On January 28, 1994, EPA debarred Robert E. Caron for three years. Mr. Caron
was formerly employed as chief of the EPA Region 3 Emergency Response and
Preparation Section and as an on-scene coordinator at hazardous waste sites for
Superfund removal actions. Over an eight-year period, Mr. Caron falsely
represented his educational qualifications on numerous occasions. In his guilty
plea, Mr. Caron admitted to making false declarations for purposes of Federal
employment and security clearances. On October 2, 1992, the U. S. District Court
for the District of Maryland convicted Mr. Caron on one count of making false
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EPA Office of the Inspector General Annual Superfund Report to the Congress for Fiscal 1994 57
declarations. The Court sentenced Mr. Caron to home confinement for three
months followed by three years probation and a $2000 fine.
Employee Reprimanded for Inflated CERCLIS Accomplishments
The OIG Hotline office received a complaint alleging that Region 9 employees had
backdated site inspection reports, misrepresented site assessment records, and
made false entries in the CERCLIS database. Our review found Region 9 had
claimed 212 invalid preliminary assessments and 63 invalid site inspections within
three Superfund mega-sites between 1988 and 1991 in CERCLIS. The Region also
claimed them as Superfund Comprehensive Accomplishment Plan accomplishments
to be included in EPA's Superfund Annual Report to the Congress. As a result of
the review, the invalid accomplishments were removed from CERCLIS and a senior-
level EPA employee received a written reprimand.
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EPA Office of the Inspector General Annual Superfund Report to the Congress for Fiscal 1994 58
EXHIBIT 1
1 OF 7
SUPERFUND REVIEW REPORTS
ISSUED DURING FISCAL 1994
INTERNAL AND MANAGEMENT AUDITS AND SPECIAL REVIEWS
Final
Report
Number Description
Audit
Control Number
Date
Report
Issued
Reviews Related To Statutory Requirements (other than IG Act)
4100229 AGENCY FY93 RE PORT -CONSOLIDATED CERCLIS DATA
4100212 AGENCY FY93 REPORT-REGION 1 CERCLIS DATA
4100196 AGENCY FY93 REPORT-REGION 5 CERCLIS DATA
4100213 AGENCY FY93 REPORT-REGION 6 CERCLIS DATA
4100201 AGENCY FY93 REPORT-REGION 7 CERCLIS DATA
4100231 FINANCIAL STATEMENTS - FISCAL 1993
4400065 RESPONSE CLAIM - MARION BRAGG LANDFILL, IN
4400094 RI/FS REVIEW - AM. CREOSOTE, LA/POPILE, AR
4400032 RI/FS REVIEW - FRONTIER HARD CHROME, WA
4400070 RI/FS REVIEW - PALMERTON ZINC, PA
4400014 RI/FS REVIEW - PURITY OIL, CA
4400018 RI/FS REVIEW - VINELAND CHEMICAL CO., NJ
Other Performance Audits
4100579 BANKRUPTCY SETTLEMENTS
4100111 COMPETITION IN SUPERFUND CONTRACTING
4100462 CONTRACTS NOT CLOSED
4100522 FMFIA ADMINISTRATION - CAPPING REPORT
4100224 FMFIA ADMINISTRATION - OSWER
4100233 ICF CONTRACTS COMPETITION
4100218 REGION 5 ADMIN. OF MICHIGAN COOP. AGREEMENTS
4100180 SUPERFUND SITE ASSESSMENTS
Follow-Up Review
4400091 RESPONSE CLAIMS FpLLOW-UP
Other Special Reviews
4400092 ALLOCATION TOOLS/MIXED FUNDING PILOTS-REG. 5
4400103 ADMINISTRATIVE IMPROVEMENTS - REGION 7
4400076 CONFLICT OF INTEREST POLICIES /PROCEDURES
4400115 CONTRACT LABORATORY PROGRAM MANAGEMENT
4400017 ENFORCEMENT PILOTS - REGION 1
4400024 ENFORCEMENT PILOTS - REGION 8
4400037 ENFORCEMENT PILOTS - SF REVITALIZATION OFC.
4400112 ERCS CONTRACTS AUDITS ANALYSIS
4400025 ESAT CONTRACT USE - REGION 9
4400042 FINANCIAL MANAGEMENT REVIEW-CONG. REQUEST
4400038 INFORMATION RESOURCES MGMT.-CONG. REQUEST
4400059 INNOVATIVE DATA VALIDATION PILOT-REGION 3
4400100 RISK REDUCTION ENG. LAB. CONSOLIDATION
4400011 SACM PILOT - NATIONAL ZINC, OK
4400080 SACM PILOTS - REGION 5
4400073 SACM PILOTS - REGION 10
4400110 VEHICLE USE BY REG. 3 ON-SCENE COORDINATORS
E1SFF3-11-0029
E1SFL4-01-0032
E1SFL4-05-0017
E1SFL4-06-0033
E1SFL4-07-0015
P1SFL3-20-8003
E9HGP2-23-0369
E1SGG3-14-0015
E1SGG3-14-0009
E1SGG3-14-0013
E1SGG3-14-0008
E1SGGO-14-0010
E1SFF3-20-8004
E1SFF3-11-0020
E1SFF3-03-0162
E1SFE3-07-0101
E1SFE3-07-0101
E1SKF3-03-0161
E1SGF2-05-0269
E1SFF3-08-0021
E1SFG4-11-5015
E1SFG4-05-0175
E1SFG4-07-0047
E1SFG4-13-0063
E1SKG3-09-0021
E1SJG3-01-0138
E1SJG3-01-0138
E1SJG3-01-0138
E1SHG3-18-0045
E1SKG3-09-0258
E1SFG3-11-0026
E1SKG3-15-0098
E1SKG4-03-0122
E1SKF4-02-0059
E1SGG3-06-0097
E1SFG4-05-0129
E1SGG4-06-0056
E6FHG4-03-0266
3/30/94
3/18/94
3/ 3/94
3/21/94
3/ 3/94
3/31/94
5/24/94
8/ 4/94
2/24/94
6/16/94
12/21/93
2/ 4/94
9/30/94
12/ 7/93
7/21/94
9/16/94
3/28/94
3/31/94
3/23/94
1/31/94
7/29/94
7/29/94
9/ 7/94
6/22/94
9/29/94
12/22/93
1/31/94
3/ 9/94
9/29/94
1/31/94
3/31/94
3/15/94
5/10/94
8/25/94
12/10/93
7/ 7/94
6/20/94
9/22/94
-------
EPA Office of the Inspector General Annual Superfund Report to the Congress for Fiscal 1994 59
EXHIBIT 1
2 OF 7
SUPERFUND REVIEW REPORTS
ISSUED DURING FISCAL 1994
Final
Report
Number
Auditee
Audit
Control Number
Date'
Report
Issued
COOPERATIVE AGREEMENTS
4300011
4100530
4300033
4400046
4100167
4100496
4400111
4100488
4400061
4300026
4300006
4100017
AR DEPT. POLL. CONTROL & ECOLOGY-MIDLAND PR.
AZ DEPT. OF ENV. QUAL .- INDIRECT CSTS-FY90-91
CA DEPT. OF HEALTH- INDIRECT COSTS-FY88- 91
CA DEPT. OF HEALTH -ACCT'G & INT. CONTROLS
CO DEPARTMENT OF HEALTH-REMEDIAL/CORE/PA/SI
GA DEPT. OF NAT. RES . -PA/SI/CORE/ENF . SUPP .
IL ENVIRON. PROTECTION AGENCY-CORE PROGRAM
MN POLLUTION CONTROL AGENCY-RITARI POST/POLE
MN POLLUTION CONTROL AGENCY-RITARI PROCUREMT
OK DEPT. OF HEALTH-TAR CREEK & OK REFINING
TX WATER COMMISSION-REMEDIAL ACTIVITIES
TX WATER COMMISSION-SIKES
E5BGN3
E5DGL4
S5DGN2
S5AGP4
P5BGL2
E5BGL4
E5FGS4
E5FGF4
E5FGT4
E5BGN3
E5BGN3
P5BGL2
-06-
-09-
-09-
-09-
-08-
-04-
-05-
-05-
-05-
-06-
-06-
-06-
0182
0202
0047
0147
0089
0097
0261
0138
0138
0090
0083
0193
11/30/93
9/21/94
3/31/94
3/31/94
I/ 4/94
8/22/94
9/23/94
8/15/94
5/13/94
2/ 2/94
11/15/93
10/15/93
INTERAGENCY AGREEMENTS
4100514
41001661
4100188
4100190
4100508
4100165
4100189
4100164
4100509
AGENCY FOR TOXIC SUBST . & DISEASE REG.-FY92
ARMY CORPS OF ENGINEERS -FISCAL 1992
ARMY CORPS OF ENGINEERS -FISCAL 1992
BUREAU OF RECLAMATION- FISCAL 1992
COAST GUARD-FISCAL 1992
FEDERAL EMERGENCY MGMT. AGENCY- FISCAL 1992
FISH & WILDLIFE SERVICE- FISCAL 1991-92
JUSTICE DEPARTMENT- FISCAL 1992
NAT'L INST. OF ENV. HEALTH SCIENCES-FY92
H5BFL4
M5BFL4
M5BFL4
M5BFL4
M5BFL4
M5BFL4
M5BFL4
M5BFL4
H5BFL4
-11-
-11-
-11-
-11-
-11-
-11-
-11-
-11-
-11-
0034
0012
0017
0019
0032
0011
0018
0013
0033
8/31/94
I/ 4/94
2/22/94
2/22/94
8/26/94
I/ 4/94
2/22/94
I/ 4/94
8/26/94
Reissued as 4100188. The original issuance had missing pages.
-------
EPA Office of the Inspector General Annual Superfund Report to the Congress for Fiscal 1994 60
SUPERFUND REVIEW REPORTS
ISSUED DURING FISCAL 1994
EXHIBIT 1
3 OF 7
CONTRACT AUDITS
Final
Report
Number Auditee
Initial Pricing Reviews
4100422 ACUREX, PA
4100506 AE ENVIRONMENTAL SERVICES,
4100410 ARTHUR ANDERSON, IL
4100172 BATTELLE MEMORIAL INSTITUTE,
4100024 BOOZ, ALLEN & HAMILTON,
4100552 BROWN AND ROOT ENVIRONMENTAL
4100447 CACI, INC., VA
4100286 C.C. JOHNSON, MD
4100554 C.C. JOHNSON & MALHOLTRA,
4100273 CDM FEDERAL PROGRAMS CORE
4100038 CF SYSTEMS, ID (MORRISON
4100269 CF SYSTEMS, ID.(MORRISON
4100225 CH2M HILL INC., OR-ARCS I
4100142 CH2M HILL INC., OR-CATALOG
4100500 DESA, INC., SC-ACCOUNTING
4100403 DYNCORP, VA
4100404 DYNCORP, VA
4100364 DYNCORP VIAR, VA-SAMPLE V.
4100013 ENERGY & ENVIRONMENTAL RE
4100310 FOSTER WHEELER U.S. CORP.
4100515 FOSTER WHEELER U.S. CORP.
4100064 HYDROGEOLOGIC, INC., VA
4300008 INDUSTRIAL ECONOMICS, INC.
4100040 INTERNATIONAL TECHNOLOGY
4100011 KIBER ENVIRONMENTAL, GA
4100049 LOCKHEED ENVIRONMENTAL S
4100220 LOCKHEED ENVIRONMENTAL S
4100264 LOCKHEED ENVIRONMENTAL S'
4100235 MANTECH RESEARCH, NC
4400001 OHM REMEDIATION, -OH-ERCS
4400002 OHM REMEDIATION, OH-ERCS
4400004 OHM REMEDIATION, OH-RISK
4100028 PEER CONSULTANTS, MD-SUB
4400117 PRC ENVIRONMENTAL MGMT.,
4400074 PRC ENVIRONMENTAL MGMT.,
4100009 PSARA TECH, OH
4100010 RE WARNER, OH
4100279 RESOURCE TECHNOLOGY CORP
4100288 ROY F. WESTON, PA
4100536 ROY F. WESTON, PA
4100014 SCIENCE APPLICATIONS INT
4100296 SCIENCE APPLICATIONS INT
4100027 SCICOMM, INC., MD
4100283 SYSTEMS RESEARCH & SYSTEMS,
4300036 UNIVERSITY OF IDAHO, ID
; , INC . , wv
ITE , OH
CD
rTAL, MD- SUBCONTRACT
MD
'ORATION, VA
KNUDSEN SUBSIDIARY)
KNUDSEN SUBSIDIARY)
V TERM. SETTLEMENT
)G PRICING
! SYSTEM SURVEY
[GMT OFFICE MOD.
ISEARCH, CA
, NJ-SUB.-DYNAMAC
, NJ-SUB. -WESTON
:. , MA
CORP . , CA
'STEMS , TX
'STEMS , TX
'STEMS , TX
2 Z2 FY90 EQUIP.
2 21 FY90 EQUIP.
REDUCT. ENG. LAB.
TO SAIC
IL-SUB TO WESTON
IL-TECH. SUPPORT
, WY
L CORP . , . CA
L CORP . , CA
IS,. VA
-
Audit
Control Number
D9AKL4-09-0193
D9AFL4-03-0453
D9AFL4-05-0211
D9AFL3-05-0362
D9AKL3-03-0292
D9AKL4-03-0454
D9AJL3-03-0247
D9AFL4-03-0189
D9AFL4-03-0451
D9AFL4-03-0190
D9AGL3-10-0119
D9AGL4-10-0072
P9AGL2-10-0089
D9AGL3-10-0033
D9AJL4-04-0237
D9AKL4-03-0277
D9AFL4-03-0276
D9AFL4-03-0273
D9AGL3-09-0226
D9AFL4-02-0112
D9AFL4-02-0173
D9AJL3-03-0441
D9AFN3-C1-0275
D9AGL3-09-0250
D9AKL3-04-0312
D9AKL3-06-0153
D9AKL4-06-0072
D9AKL4-06-0090
D9AKL4-04-0117
P9AHP2-23-0022
P9AHP2-23-0021
E9AKP3-23-0013
D9AKL3-03-0380
E9AKP4-05-0291
E9AKP4-05-0241
D9AKL3-05-0330
D9AKL3-05-0333
D9AKL4-08-0048
D9AFL4-03-0188
D9AKL4-03-0450
D9AGL3-09-0227
D9AGL4-09-0153
D9AKL3-03-0375
D9AFL4-03-0146
H9AGN4-10-0082
Date
Report
Issued
6/23/94
8/25/94
6/17/94
1/10/94
10/19/93
9/23/94
7/14/94
5/16/94
9/23/94
5/10/94
10/21/93
5/ 3/94
3/28/94
12/21/93
8/24/94
6/14/94
6/14/94
6/ 7/94
10/13/93
5/20/94
9/ 8/94
ll/ 9/93
11/15/93
10/21/93
10/13/93
10/27/93
3/24/94
4/29/94
3/31/94
10/ 1/93
10/ 7/93
10/15/93
10/19/93
9/30/94
6/21/94
10/12/93
10/12/93
5/10/94
5/16/94
9/22/94
10/13/93
5/18/94
10/19/93
5/16/94
6/ 7/94
-------
EPA Office of the Inspector General Annual Superfund Report to the Conqress for Fiscal 1994 61
EXHIBIT 1
4 OF 7
SUPERFUND REVIEW REPORTS
ISSUED DURING FISCAL 1994
CONTRACT AUDITS (continued)
Final
Report
Number
Auditee
• Audit
Control Number
Date
Report
Issued
Interim Audits
4100031
4400050
4100106
4100021
4100130
4100352
4100314
4100396
4400019
4100566
4100436
4100560
4100512
4100398
4100309
4100417
4100489
4100045
4100272
4400035
4400036
4100532
4100308
4100136
4100492
4100371
4100372
4100373
4100295
4100156
4100293
4100016
4100019
4100299
4400003
4100365
4100085
4100086
4100083
4100094
4100071
4100090
4100413
4100354
4100353
AEROSPACE, CA-FISCAL 1991
ALLIANCE TECHNOLOGIES CORP.', MA- SUBCONTRACT
ARTHUR YOUNG AND CO., DC-MGMT. SUPP . SERV.
BECHTEL NATIONAL, INC., CA-FISCAL 1990
BOO2, ALLEN & HAMILTON, VA-4/89-3/90
C.C. JOHNSON & MALHOTRA, MD-FISCAL 1989
CDM FEDERAL PROGRAMS CORPORATION, VA-1939
CDM FEDERAL PROGRAMS CORPORATION, VA-ARCS
CET ENV. SERVICES, WA-ERCS EQUIP. RATE REV.
CH2M HILL, INC., OR-ARCS REGION 3-1988-89
CH2M HILL, INC., OR-ARCS REGION 5-1988-89
CH2M HILL, INC., OR-ARCS REGION 6-1988-89
CH2M HILL, INC., OR-ARCS WEST-1989
CH2M HILL, INC., OR-REM/FIT-1987-89
CH2M HILL, INC., OR-REM IV-1987-89
CH2M HILL, INC., OR-TECH 1-1987-88
CH2M HILL, INC., OR-TECH 11-1988-89
DEV. PLANNING & RES. ASSOC., INC., KS-CAS
DEV. PLANNING & RES. ASSOC., INC., KS-FY91
DONOHUE, WI-ARCS REG. 5 REM. PLANNING COSTS
DONOHUE, WI-ARCS REG. 5 PROG. MGMT. COSTS
DYNAMAC, INC., MD-FISCAL 1989
ENVIRONMENTAL MGMT SUPPORT, MD-FY1987-88
GENERAL SCIENCES CORP., MD-8/89-7/91
H+GCL, INC., NM-FY90 DIRECT & INDIRECT COSTS
KENDRICK AND CO., DC-FISCAL YEARS 1984-86
KENDRICK AND CO., DC-FISCAL YEAR 1987
KENDRICK AND CO., DC-FISCAL YEARS 1989-90
KEYDATA SYSTEMS, INC., VA-7/89-9/92
LAWRENCE JOHNSON- & ASSOCIATES, MD-7/88-6/89
LOS ALAMOS TECH. ASSOC., NM-ARCS SUBCONTRACT
MONTGOMERY WATSON AMERICAS, INC., CA-FY89
MONTGOMERY WATSON AMERICAS, INC., CA-FY90
NUS CORP. , MD-1988
OHM REMEDIATION, OH-ERCS 2, ZONE 2-FY91
RESOURCE APPLICATIONS, INC., VA-FY 1990-91
ROY F. WESTON, PA- ARCS REGION 1
ROY F. WESTON, PA- ARCS REGIONS 9 & 10
ROY F. WESTON, PA- CALENDAR 1990
ROY F. WESTON, PA- CALENDAR 1990
ROY F. WESTON, PA-OHMSETT, HWERL, CINC.
ROY F. WESTON, PA-SERVICE FEES-1990
SHANNON & WILSON, WA-1990 DIRECT & INDIRECT
TECHNICAL RESOURCES, INC., MD-FISCAL 1988
TECHNICAL RESOURCES, INC., MD-FISCAL 1989
D9BGL4-09-0036
E9BHP3-01-0123
D9BFL3-03-0302
D9BGL2-09-0223
D9BFL3-03-0319
D9BFL4-03-0338
D9BFL4-03-0328
D9BFL2-03-0295
D9BHP3-10-0093
P9BGL4-10-0147
P9BGL4-10-0124
P9BGL4-10-0149
P9BGL4-10-0132
P9BGL4-10-0107
P9BGL4-10-0083
P9BGL4-10-0117
P9BGL4-10-0129
D9BJL3-07-0144
D9BJL4-07-0065
P9BGP3-23-0309
P9BGP3-23-0309
D9BFL4-03-0502
D9BFL4-03-0317
D9BFL2-03'-0203
D9BKL4-06-0151
D9BFL4-03-0363
D9BFL4-03-0364
D9BFL4-03-0365
D9BKL2-03-0599
D9BFL2-03-0460
D9BKL4-06-0102
D9BGL4-09-0031
D9BGL4-09-0035
D9BKL4-03-0148
P9BHP2-23-0405
D9BFL2-03-0584
D9BFL2-03-0272
D9BFL2-03-0274
D9BFL2-03-0146
D9BKL4-03-0109
D9BFL2-03-0275
D9BFL4-03-0104
D9BGL4-10-0119
D9BFL4-03-0339
D9BFL2-03-0471
10/19/93
4/ 4/94
12/ 6/93
10/18/93
12/17/93
6/ 1/94
5/23/94
6/ 9/94
1/19/94
9/28/94
6/29/94
9/26/94
8/30/94
6/10/94
5/19/94
6/22/94
8/16/94
10/25/93
5/10/94
3/ 4/94
3/ 4/94
9/22/94
5/18/94
12/21/93
8/17/94
6/ 7/94
6/ 7/94
6/ 7/94
5/18/94
I/ 3/94
5/18/94
10/14/93
10/15/93
5/18/94
10/13/93
6/ 7/94
li/19/93
11/19/93
11/19/93
11/30/93
11/15/93
11/24/93
6/21/94
6/ 1/94
6/ 1/94
-------
EPA Office of the Inspector General Annual Superfund Report to the Congress for Fiscal 1994 62
EXHIBIT 1
5 OF 7
SUPERFUND REVIEW REPORTS
ISSUED DURING FISCAL 1994
CONTRACT AUDITS (continued)
Final
Report
Number Audi tee
Interim Audits (continued)
4100146 UNISYS, VA-1989 RTF FAC . MGMT/NPDP SUPPORT
4100471 URS CONSULTANTS, INC., WA-ARCS FISCAL 1989
4100311 VERSAR, INC., VA-7/87-6/89
4100548 VIGYAN RESEARCH ASSOCIATES, VA-FISCAL 1990
4100502 WADE MILLER & ASSOCIATES, VA-FY 1991-92
4100538 WESTINGHOUSE REMEDIATION SERVICES, GA-FY91
4400039 WW ENGINEERING CO., MI-ARCS 1-FISCAL 1992
Final Audits
4100226 CH2M HILL, INC., OR- ARCS -REGION 4
4100397 ECOLOGY & ENVIRONMENT, NY-NIAGARA FALLS
4100498 HDR ENGINEERING, INC., NE-ARCS SUBCONTRACT
4100092 ROY F. WESTON, PA-REMEDIAL SERVICES
4100297 ROY F. WESTON, PA-ARCS-9/28/89-9/30/91
4100439 SCIENCE APPLICATIONS INT'L CORP., CA-R&D
4100228 VIAR, VA-CONTRACT NO. 68-01-6702
4100529 WILLIAMS -RUSSELL & JOHNSON, GA-REM V
Indirect Costs
4100227 ALLIANCE TECHNOLOGIES CORP., MA-7/88-6/89
4100292 ALLIANCE TECHNOLOGIES CORP., MA-7/89-6/90
4100329 ALLIANCE TECHNOLOGIES CORP., MA-7/90-6/91
4400034 DONOHUE, WI-FISCAL 1991
4300021 'GUARDIAN ENVIRON. SERVICES, DE-11/90-10/91
4100041 INSTITUTE FOR TECHNOLOGY DEV. , MS-FY86
4100042 INSTITUTE FOR TECHNOLOGY DEV., MS-FY87
4100043 INSTITUTE FOR TECHNOLOGY DEV., MS-FY88
4100044 INSTITUTE FOR TECHNOLOGY DEV., MS-FY89
4100400 MANTECH TECHNOLOGY, NC-1990
4100419 MANTECH TECHNOLOGY, NC-1991
4100251 MIDWEST RESEARCH INSTITUTE, MO
4100252 MIDWEST RESEARCH INSTITUTE, MO
4100542 NUS CORP., MD-FY94 PROVISIONAL BILLING RATES
4400097 PRC ENVIRONMENTAL MGMT ., IL-BONUSES 1990-92
4100078 ROY F. WESTON, PA-CALENDAR 1992
4100362 ROY F. WESTON, PA-CALENDAR 1993 RATES
4100244 SEAWARD SERVICES, INC., FL-FISCAL 1991
4100474 TRC .COMPANIES, INC., CT-CORPORATE G & A
4100266 WESTINGHOUSE REMEDIATION SERVICES, GA-FY91
4400040 WW ENGINEERING CO., MI-ARCS 1-FISCAL 1992
Audit
Control Number
D9BFL2-03-0235
D9BGL3-10-0088
D9BFL2-03-0220
D9BFL2-03-0438
D9BFL2-03-0598
E9BGL3-04-0234
P9BGP3-23-0133
P9CGL2-10-0127
P9CGL2-02-0283
D9CGL4-07-0035
D9CKL4-03-0105
•D9CFL3-03-0283
D9CGL4-09-0077
D9CKL2-03-0316
D9CKL4-04-0215
P9DGL2-01-0247
P9DGL2-01-0247
P9DGL2-01-0247
P9DGP3-23-0287
P9DFN3-03-0126
D9DKL4-04-0038
D9DKL4-04-0039
D9DKL4-04-0040
D9DKL4-04-0041
D9DKL2-04-0375
D9DKL2-04-0376
D9DGL4-07-0058
D9DGL4-07-0059
D9DFL4-03-0508
E9DKP4-05-0070
D9DFL2-03-0398
D9DFL4-03-0368
D9DKL2-04-0314
P9DGL2-01-0220
E9DHL3-04-0253
P9DGP3-23-0132
Date
Report
Issued
12/22/93
8/ 2/94
5/23/94
9/23/94
8/25/94
9/22/94
. 3/18/94
3/29/94
6/ 9/94
8/24/94
11/24/93
5/18/94
7/ 7/94
3/30/94
9/19/94
3/29/94
5/16/94
5/26/94
3/ 4/94
I/ 5/94
10/22/93
10/22/93
10/22/93
10/22/93
6/13/94
6/23/94
4/18/94
4/18/94
9/23/94
8/12/94
11/19/93
6/ 7/94
4/ 7/94
8/ 3/94
5/ 3/94
3/18/94
-------
EPA Office of the Inspector General Annual Superfund Report to the Congress for Fiscal 1994 63
EXHIBIT 1
6 OF 7
SUPERFUND REVIEW REPORTS
ISSUED DURING FISCAL 1994
CONTRACT AUDITS (continued)
Final >
Report
Number
System
4100389
4100134
4100219
4100393
4400067
4400049
4400055
4400082
4400031
4400048
4300042
4100242
4400028
4400064
4400027
4400008
4100210
4400013
4400060
4100140
4100435
4100144
4100065
4100066
4100337
4100069
4100077
4100087
4100067
4100068
4100070
4100374
4100074
4100082
4100091
4100392
4100073
4100081
4100072
4100080
4100084
4100116
Auditee
Surveys
BOOZ, ALLEN & HAMILTON, VA- TIMEKEEPING
CHEMICAL WASTE MANAGEMENT, INC., WV
CH2M HILL, INC., OR- PROJECT CONTROL SYSTEM
CH2M HILL, INC., OR- SUBCONTRACT ADM. SYSTEM
COMPUTER SCIENCE CORP . , VA-LABOR TRANSFERS
ECOLOGY & ENVIRONMENT, NY-BILLING SYSTEM
ECOLOGY & ENVIRONMENT, NY- COST IMPACT
. ECOLOGY & ENVIRONMENT, NY-DISCLOSURE STATE.
ECOLOGY & ENVIRONMENT, NY- ESTIMATING SYSTEM
ECOLOGY & ENVIRONMENT, NY- INTERNAL CONTROLS
ICF CORP., VA-CAS 405, SUBCONTRACT BILLING
MANTECH RESEARCH, NC-DISCLOSURE STATEMENT
OHM REMEDIATION, OH-COST ACCOUNTING '
OHM REMEDIATION, OH-DESTRUCTION OF RECORDS
OHM REMEDIATION, OH-DISCLOSURE STATEMENT
OHM REMEDIATION, OH-FAR COMPLIANCE
PRC ENVIRONMENTAL MGMT., IL-ACCT'G SYSTEM
REIDEL ENV. SERVICES, OR-REV. CAS DISCL.
REIDEL ENV. SERVICES, OR- FIN. CAPABILITY
RESOURCE APPLICATIONS, INC., VA-EST. SYSTEM
RESOURCE APPLICATIONS, INC., VA-TIMEKEEPING
ROY F. WESTON, PA-BILLING SYSTEM
ROY F. WESTON, PA-CALENDAR 1992
ROY F. WESTON, PA-CAS 404 COMPLIANCE
ROY F. WESTON, PA-CAS 406 COMPLIANCE
ROY F. WESTON, PA-CAS 408 COMPLIANCE
ROY F. WESTON, PA-CAS 409 COMPLIANCE
ROY F. WESTON, PA-CAS 410 COMPLIANCE
ROY F. WESTON, PA-CAS 412 COMPLIANCE
ROY F. WESTON, PA-CAS 413 COMPLIANCE
ROY F. WESTON, PA-CAS 414 COMPLIANCE
ROY F. WESTON, PA-CAS 415 COMPLIANCE
ROY F. WESTON, PA-CAS 416 COMPLIANCE
ROY F. WESTON, PA-CAS 420 COMPLIANCE
ROY F. WESTON, PA- COMPENSATION SYSTEM
ROY F. WESTON, PA- EDP CONTROLS
ROY F. WESTON, PA-ESTIMATING SYSTEM
ROY F. WESTON, PA- FLOOR CHECK
ROY F. WESTON, PA- INTERNAL CONTROLS
ROY F. WESTON, PA-LABOR PRACTICES
ROY F. WESTON, PA-TRAVEL PROCUREMENT
TECHLAW, INC., VA-ACCOUNTING SYSTEM CHANGE
Audit
Control Number
D9EFL4-03-0154
D9EFL3-03-0054
P9EGLO-10-0037
P9EGL4-10-0077
D9EFP2-03-0312
P9EFP3-02-0192
P9EFP4-02-0040
E9EFP4-02-0155
P9EGP1-02-0157
P9EFP2-02-0267
E9EFN4-22-0149
D9EKL4-04-0110
E9EHP3-23-0008
E9EHT4-23-0016
E9EHP3-23-0008
E9EHP3-23-0004
E9EKL3-05-0174
E9EGP3-10-0111
E9EHP4-10-0044
D9EFL4-03-0102
D9EFL4-03-0353
D9EFL3-03-0295
D9EFL3-C3-0074
D9EFL3-03-0186
D9EFL4-03-0352
D9EFL3-03-0187
D9EFL3-03-0128
D9EFL3-03-0182
D9EFL3-03-0184
D9EFL3-03-0185
D9EFL3-03-0183
D9EFL4-03-0361
D9EFL2-03-0100
D9EFL2-03-0099
D9EKL4-03-0106
D9EFL3-03-0093
D9EFL2-03-0098
D9EFL3-03-0296
D9EFL3-03-0188
D9EFL3-03-0143
D9EFL2-03-0135
D9EFL3-03-0175
Date
Report
Issued
6/ 8/94
12/21/93
3/23/94
6/ 8/94
6/ 7/94
4/ 4/94
4/26/94
7/20/94
2/24/94
4/ 1/94
8/15/94
4/ 5/94
2/ 4/94
5/20/94
2/ 4/94
12/ 3/93
3/18/94
12/20/93
5/11/94
12/21/93
6/28/94
12/22/93
11/15/93
11/15/93
6/ 1/94
11/15/93
11/19/93
11/19/93
11/15/93
11/15/93
11/15/93
6/ 7/94
11/15/93
11/19/93
11/24/93
6/ 8/94
11/15/93
11/19/93
11/15/93
11/19/93
11/19/93
12/ 8/93
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EPA Office of the Inspector General Annual Superfund Report to the Congress for Fiscal 1994 64
EXHIBIT 1
7 OF 7
SUPERFUND REVIEW REPORTS
ISSUED DURING FISCAL 1994
CONTRACT AUDITS (continued)
Final
Report
Number Auditee
System Surveys (continued)
4100387 VIAR, VA-ADVISORY & ANALYT. ASST. CONTRACT
4100302 VIAR, VA-CAS 410 NONCOMPLIANCE
41001,73 VIAR, VA-CAS 418 COMPLIANCE
4100138 VIAR, VA-CAS DISCLOSURE STATEMENT ADEQUACY
Audit
Control Number
D9EFL3-03-0230
D9EFL4-03-0311
D9EFL4-03-0150
D9EFL3-03-0138
4100131 VIAR, VA-CAS DISCLOSURE STATEMENT COMPLIANCE D9EFL3-03-0367
Program Reviews
4100222 REIDEL ENV. SERVICES, OR-BILLING SYSTEM
4400109 REIDEL ENV. SERVICES, OR-DISCLOSURE STATE.
4400051 WESTINGHOUSE REMEDIATION SERVICES, GA-1990
P9FGL2-10-0123
E9FGP4-10-0074
E9FKG4-04-0159
Date
Report
Issued
6/ 8/94
5/18/94
1/10/94
12/21/93
12/17/93
3/25/94
9/22/94
4/13/94
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EPA Office of the Inspector General Annual Superfund Report to the Congress for Fiscal 1994 65
APPENDIX: ACRONYMS AND ABBREVIATIONS
Acct'g Accounting
Adm. Administration
Analyt. Analytical
APO Administrative Project Officer (EPA)
AR Arkansas
ARCS Alternative Remedial Contracting Strategy
Assoc. Associates
Asst. Assistance
ATSDR Agency for Toxic Substances and Disease Registry (HHS)
AZ Arizona
CA California
CAS Cost Accounting Standards
CDC Centers for Disease Control and Prevention (HHS)
CERCLA Comprehensive Environmental Response, Compensation, and
Liability Act of 1980, as amended
CERCLIS Comprehensive Environmental Response, Compensation, and
Liability Information System, the Superfund management
information system
CFO Chief Financial Officer(s)
Cine. Cincinnati
CLP Contract Laboratory Program
Co. Company
CO Contracting Officer or Colorado
COI Conflict of interest
Cong. Congressional
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EPA Office of the Inspector General Annual Superfund Report to the Congress for Fiscal 1994 66
Corp. Corporation
CT Connecticut
DC District of Columbia
DE Delaware
Dept. Department
Dev. Development
Disci. Disclosure
DOI Department of the Interior
DOJ Department of Justice
DOT Department of Transportation
EDP Electronic data processing
EHRT Environmental Health, Research and Testing, Inc.
Enf. Enforcement
Eng. Engineering
ENRD Environment and Natural Resources Division (DOJ)
Env. Environmental
Environ. Environmental
EPA Environmental Protection Agency
Equip. Equipment
ERCS Emergency Response Cleanup Services (EPA contracts)
ESAT Environmental Services Assistance Team (EPA contracts)
ESD Explanation of Significant Differences
Est. Estimating
Fac. Facilities
FACO Financial Administrative Contracting Officer (EPA)
FAR Federal Acquisition Regulation
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EPA Office of the Inspector General Annual Superfund Report to the Congress for Fiscal 1994 67
FEMA
FIT
FL
FMD
FMFIA
FY
GA
G & A
GDNR
HHS
HRS
HWERL
IAG
ID
IFMS
IG
IL.
IN
Inc.
Inst.
Int.
Int'l
IBM
KS
Lab.
MA
Federal Emergency Management Agency
Field Investigation Team
Florida
Financial Management Division (EPA)
Federal Managers' Financial Integrity Act
Fiscal year
Georgia
General and administrative
Georgia Department of Natural Resources
Department of Health and Human Services
Hazard Ranking System
Hazardous Waste Engineering Research Laboratory (EPA)
Interagency agreement
Idaho
Integrated Financial Management System (EPA)
Inspector General
Illinois
Indiana
Incorporated
Institute
Internal
International
Information resources management
Kansas
Laboratory
Massachusetts
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EPA Office of the Inspector General Annual Superfund Report to the Congress for Fiscal 1994 68
MD Maryland
Mgmt. Management
Ml Michigan
MN Minnesota
MO Missouri
Mod. Modification
MPCA Minnesota Pollution Control Agency
MS Mississippi
Nat'l National
NC North Carolina
NCR National Oil and Hazardous Substances Contingency Plan, 40 CFR
Part 300
NDPD National Data Processing Division (EPA)
NET National Environmental Testing, Inc.
NIEHS National Institute of Environmental Health Sciences (HHS)
NIH National Institutes of Health (HHS)
NJ New Jersey
NM New Mexico
No. Number
NPL National Priorities List
OAM Office of Acquisition Management (EPA)
OARM Office of Administration and Resources Management (EPA)
OH Ohio
Ol Office of Investigations (EPA OIG)
OIG Office of the Inspector General
OK Oklahoma
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EPA Office of the Inspector General Annual Superfund Report to the Congress for Fiscal 1994 69
OR Oregon
ORD Office of Research and Development (EPA)
OSC On-Scene Coordinator (EPA)
OSWER Office of Solid Waste and Emergency Response (EPA)
PA Pennsylvania or Preliminary Assessment
PA/SI Preliminary Assessment/Site Inspection
PHS Public Health Service (HHS)
Poll. Pollution
Procuremt Procurement
\
Prog. Program
QA Quality assurance
Qual. Quality
R&D Research and development
RGB Releases Control Branch (EPA)
RCMS Removal Cost Management System
Reg. Region
'Res. Research
Rev. Revision
Rl Remedial Investigation
RI/FS Remedial Investigation/Feasibility Study
ROD Record of Decision
RREL Risk Reduction Engineering Laboratory (EPA)
RREL-RCB Risk Reduction Engineering Laboratory-Releases Control Branch
(EPA)
RTP ' Research Triangle Park, NC
SAI Superfund Administrative Improvements
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EPA Office of the Inspector General Annual Superfund Report to the Congress for Fiscal 1994 70
SARA
sc
SI
SIP
SRMAC
SRO
State.
Subst.
Supp.
Tech.
THI
TX
VA
WA
Wl
WV
WY
Superfund Amendments and Reauthorization Act of 1986
South Carolina
Site Inspection
Site Inspection Prioritization
Superfund Senior Regional Management Acquisition Council (EPA)
Superfund Revitalization Office (EPA)
Statement
Substances
Support
Technical
T. Head and Company, Inc.
Texas
Virginia
Washington
Wisconsin
West Virginia
Wyoming
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