SEPA
united Slates
Environmental' Protection
Agency
April 1998
EPA's Office of the
Inspector General
Annual
Superfund Report
to the Congress
forFisca!1997
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EPA Office of Inspector General Annual Super-fund Report to the Congress for Fiscal 1997
laboratory data quality, and amend its data
quality objectives guidance.
We worked jointly with EPA's Office of
Acquisition Management to review
implementation of forty 1992 contract
management recommendations made by
EPA's Standing Committee on Contracts
Management (now called the Resource
Management Committee). We found
indications of potential vulnerabilities in
(1) personal services, (2) contractor access
to confidential or sensitive data, and
(3) contractor conflicts of interest.
We reviewed a number of contracts
management issues in response to a request
from the Office of Management and Budget.
We found EPA relies extensively on cost-
reimbursement level-of-effort (LOE) contracts
that essentially buy hours, not results,
thereby placing the burden of cost control on
the government. The Agency's cultural
preference for LOE contracts, insufficient
knowledge of alternative contract types, lack
of program accountability for the type of
contract to be awarded, inability to clearly
define its needs, and broad contract
statements of work have perpetuated this
continuing reliance on LOE contracts and
precluded a complete transition to more
efficient, cost-effective contract types.
We found EPA did not always adequately
prepare and effectively use independent
government cost estmates to analyze
.proposed contract costs or to establish
prenegotiation objectives. EPA relied heavily
on contractors' estimates, often choosing to
award contracts and related work at amounts
closer to that proposed by the contractor
rather than the EPA estimate. EPA's ability
to properly estimate its needs and related
costs and effectively use these estimates in
contract negotiations is crucial for the
Agency's transition to more performance-
based service contracts.
The Agency indicated it generally agreed with
our findings and would implement our
recommendations for improvement. We will
continue to review the Agency's efforts to
improve its contracts management, and will
work cooperatively with the Agency in this
endeavor.
Our Superfund investigative efforts continued
to produce fines, restitutions, recoveries, and
convictions for fraud and other improper
actions of EPA contractors. A former
analytical laboratory executive received a
prison sentence of one year and one day for
falsely claiming to analyze and dispose of
waste. A major EPA contractor agreed to
pay as much as $2.4 million to replace
defective backfill used in cleaning up a
Superfund site. Several other EPA
contractors agreed to settlements arising out
of false claims and fraud charges.
The Administration proposed in its fiscal 1998
budget to eliminate the requirement to issue
this report, along with the specific annual
audits the report is required to summarize.
This report is largely duplicatiye of our
semiannual reports. Elimination of the
specific audit requirements will allow us to
focus our audit efforts each year on those
areas where they can be most productive.
We hope the Congress will approve this
recommendation.
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.
\_ .
Nikki L. Tinsley ^
Acting Inspector General
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EPA Office of Inspector General Annual Superfund Report to the Congress for Fiscal 1997 Hi
TABLE OF CONTENTS
PURPOSE .' 1
BACKGROUND 2
ASSISTANCE TO EPA MANAGEMENT 3
HAZARDOUS SUBSTANCE SUPERFUND 6
Superfund Receives First Unqualified Opinion on Balance Sheet, But Further
Improvements Still Needed , 6
COOPERATIVE AGREEMENTS AND CREDITS ! 8
Missouri Needed to Ensure Accuracy of Accounting Data 8
REMEDIAL INVESTIGATIONS AND FEASIBILITY STUDIES 10
Cleanup Acceleration Efforts at Greenwood Chemical Unsuccessful 10
RESPONSE CLAIMS 11
Colbert Landfill Claim Raised Cost Issues ' 11
CONTRACTS 13
Potential Vulnerabilities in Contracts Management May Still Exist 13
Inadequate Supporting Documentation and Misclassified Costs 15
Proposed Labor Costs Overstated by $87,601 and Unsupported by $3,042,852 15
INTERNAL AUDITS AND SPECIAL REVIEWS 16
Serious Environmental Data Quality Problems Impair Federal Facility Superfund Cleanups
. 16
Superfund Oversight Bills to Responsible Parties Were Delayed for Years 17
Superfund Oversight Costs Were Not Billed or Collected Timely 18
INVESTIGATIVE ACTIVITY 20
EXHIBIT 1: SUPERFUND REPORTS ISSUED DURING FISCAL 1997 : 23
APPENDIX: ACRONYMS AND ABBREVIATIONS 27
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EPA Office of Inspector General Annual Superfund Report to the Congress for Fiscal 1997
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
1997 OIG Superfund activities. We discuss
the required four audit areas below.
This report contains chapters on the
mandated audit areas. We also summarize
other significant Superfund audit work,
assistance to EPA management, and
Superfund investigative work. We exceed
the statutory requirements by providing
Congress with the significant results of
Superfund work beyond that specifically
mandated in section 111 (k).
Trust Fund
CERCLA requires ". . . an annual audit of all
payments, obligations, reimbursements, or
other uses of the Fund in the prior fiscal year.
. . ." We now meet this requirement through
the financial statement audit required by the
Government Management Reform Act.
Claims
CERCLA requires an annual audit to assure
". . . that claims are being appropriately and
expeditiously considered . . :" Since SARA
did not include natural resource damage
claims as allowable Fund expenditures, the
only claims provided in CERCLA, as
amended, are response claims.
Cooperative Agreements
CERCLA requires audits ". . . of a sample of
agreements with States (in accordance with
the provisions of the Single Audit Act)
carrying out response actions under this title
. . .", We perform financial and compliance
audits of cooperative agreements with States
and political subdivisions. Some of our audits
also review program performance.
Remedial Investigations/Feasibility
Studies (RI/FS)
CERCLA requires our". . . examination of
remedial investigations and feasibility studies
prepared for remedial actions ..." Our
RI/FS examinations review the adequacy of
the studies to provide a sound technical basis
for remedial action decisions. We usually
perform these examinations as special
reviews by our technical staff.
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EPA Office of Inspector General Annual Superfund Report to the Congress for Fiscal 1997
BACKGROUND
The Comprehensive Environmental
Response, Compensation, and Liability Act of
1980 (CERCLA), Public Law 96-510, enacted
on December 11, 1980, established the
"Superfund" program. The purpose of the
Superfund program is to protect public health
and the environment from the release, or
threat of release, of hazardous substances
from abandoned hazardous waste sites and
other sources where other Federal laws do
not require response. CERCLA established
a Hazardous Substance Response Trust
Fund to provide funding for responses
ranging from control of emergencies to
permanent remedies at uncontrolled sites.
CERCLA authorized a $1.6 billion program
financed by a five-year environmental tax on
industry and some general revenues.
CERCLA requires EPA to seek response, or
payment for response, from those
responsible for the problem, including
property owners, generators, and
transporters.
The Superfund Amendments and
Reauthorization Act of 1986 (SARA), Public
Law 99-499, enacted October 17, 1986,
revised and expanded CERCLA. SARA
reinstituted the environmental tax and
expanded the taxing mechanism available for
a five-year period. It authorized an $8.5
billion program for the 1987-1991 period. It
renamed, the Trust Fund the Hazardous
Substance Superfund. The Budget
Reconciliation Act of 1990 reauthorized the
program for three additional years and
extended the taxing mechanism for four
additional years. Congress has continued to
fund Superfund after expiration of the "
authorization and the taxing mechanism.
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), updated at least
annually. The NPL consists primarily of sites
ranked based on a standard scoring system,
which evaluates their threat to public health
and the environment. In addition, CERCLA
allowed each State to designate its highest
priority site, without regard to the ranking
system.
CERCLA section 104(c)(3) does not allow
EPA to fund remedial actions unless the
State in which the release occurs enters into
a contract or cooperative agreement with
EPA to provide certain assurances, including
cost sharing. At most sites, the State must
pay 10 percent of the costs of remedial
action. EPA may fund 100 percent of site
assessment activities (preliminary
assessments, site inspections), remedial
planning (remedial investigations, feasibility
studies, remedial designs), and removals.
For facilities operated by a State or political
subdivision at the time of disposal of
hazardous substances, the State must pay
50 percent of all response costs, including
removals and remedial planning previously
conducted.
CERCLA sections 104(c)(3) and 104(d)
authorize EPA to enter into cooperative
agreements with States or political
subdivisions to take, or to participate in, any
necessary actions provided under CERCLA.
A cooperative agreement serves to delineate
EPA and State responsibilities for actions to
be taken at the site, obtains required
assurances, and commits Federal funds.
EPA uses cooperative agreements to
encourage State participation in the full range
of Superfund activities - site assessment,
remedial, removal, and enforcement.
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EPA Office of Inspector General Annual Super-fund Report to the Congress for Fiscal 1997
ASSISTANCE TO EPA MANAGEMENT
Besides performing audits and investigations,
the OIG responds to EPA management
requests for review of vulnerable program
areas and OIG input in the development of
regulations, manuals, directives, guidance,
and procurements. These are 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.
OIG staff also participate in conferences and
EPA work groups to provide input. The OIG
continued to be active in fiscal 1997 in such
assistance to EPA management in the
Superfund area. We summarize below some
of our major activities assisting management.
Controls Over Emergency Removal
Actions at Methyl Parathion Sites
At the Agency's request we. assessed
controls over emergency Superfund removal
actions at sites contaminated with methyl
parathion. Methyl parathion, a highly toxic
pesticide registered for outdoor agricultural
use, was illegally sprayed inside numerous
businesses and residences. The methyl
parathion removal actions included
environmental and biological sampling,
resident relocation, and residence
decontamination and restoration,
We found that EPA could strengthen controls
over the emergency removal process for
methyl parathion. The lack of clear and
concise guidance resulted in potential risks in
implementing new sampling procedures to
detect excessive levels of methyl parathion in
residents, and increased costs and delays in
completion of residential restorations. EPA
did not adequately address resources to
collect and analyze the samples, subsequent
monitoring, or procedures for disclosure and
notification of changes in residential
occupancy. Without adequate resources and
procedures, implementation of the new
procedures could result in reduced
effectiveness of the program and create
increased exposure and adverse health
effects.
Lack of clear guidance also contributed to
inconsistencies in decisions to clean up
contaminated businesses, the potential for
fraudulent and excessive relocation costs,
and inconsistencies in the documentation of
personal property items. The lack of specific
detail in some regions could expose EPA to
fraudulent claims and additional expenses
should residents dispute reimbursements
and/or claim items as missing or damaged.
We issued a report (7400069) to the Acting
Assistant Administrator for-Solid Waste and
Emergency Response on September 23,
1997. We suggested that EPA modify
existing guidance and develop new guidance
to address emergency removal actions at.
methyl parathion sites. EPA has issued
several new directives which address some
of our concerns.
Financial Management
Grant Accrual - During the fiscal 1996
financial statement audit, the Agency did not
have documentation available allowing us to
determine if the statement fairly presented
the accrual for grant liabilities: The grant
accrual represents amounts owed grantees
for costs they have incurred, but for which
they have not billed EPA. In fiscal 1997, we
participated on an Agency workgroup to
develop a proposed solution. The workgroup
decided that the best approach to resolving
this issue was to request accrual information
from a sample of grantees. This method
required the Agency to seek OMB approval
to obtain this information from grantees. We
helped the Agency determine the types of
information needed, reviewed the Agency's
request letter to the grantees, and selected
the sample of grantees. We also worked
closely with the Agency in clarifying problems
with calculating the grant accrual. Our work
put the Agency in a sound position to develop
a supportable year-end grant accrual and
cleared a longstanding obstacle to issuing an
unqualified opinion on the Agency's financial
statements.
Superfund State Contracts - During the fiscal
1996 financial statement audit, we
determined that EPA materially misstated
reimbursements earned, unearned advances,
and unbilled receivables related to Superfund
State Contracts (SSCs). Based on our audit
analysis, we provided adjustments to fairly
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EPA Office of Inspector General Annual Superfund Report to the Congress for Fiscal 1997
-present the financial statements. During
fiscal 1997, we provided the Agency with an
analytical tool to use in analyzing SSCs, so
finance offices could uniformly and properly
recognize SSC revenue. We also worked
with headquarters officials to clarify the
information needed to properly analyze the
account balances.
Response Claims
CERCLA requires us to review claims
submitted by potentially responsible parties
performing responses preauthorized by EPA.
We help Superfund program officials adjust,
as necessary, and pay the claims. During
fiscal 1997, we consulted with Superfund
officials who were considering streamlining
their claim procedures. As part of this effort,
we provided information on laws and
regulations concerning claim payment,
contracting, and Federal fund audits. EPA is
continuing to consider streamlining the claims
procedures, and we anticipate providing
additional advice and assistance during fiscal
1998.
National Environmental Performance
Partnership System
We actively participated with Region 5 in the
negotiation of Environmental Performance
Partnership Agreements for five states in
Region 5. Each Agreement represents a
comprehensive strategy of how Region 5 and
.the state will work together to improve the
quality of the state's air, water, and land. Our
role in the process was to ensure that the
Agreements met all regulatory requirements
and were adequate to ensure state
accountability for funds received from EPA.
We continue to work with Region 5 to
improve the quality of the Agreements in
meeting the goals of the National
Environmental Performance Partnership
System.
Information Resources Management
(IRM)
Several prior audits identified concerns with
EPA's IRM program which provides Agency
policies and guidance for Superfund and
other programs. Therefore, during fiscal
1997, we reviewed several revisions to the
Agency's IRM policies. We reviewed those
parts of Directive 2100 which establish
Agency policies for Public Access to EPA
Information and Data Standards. In addition,
we provided comments to EPA's
Infrastructure Desktop Subcommittee
regarding proposed changes to the Agency's
Desktop Standard Operating System, and
also assisted the Agency in formulating a
comprehensive policy on Management
Integrity, EPA Order 1000.24. During the
course of our reviews, we met with Agency
IRM Officials to discuss ways to improve or
enhance the policies before they finalized
them. We also contributed to the Agency's
response to Federal Register notices
regarding National Institute of Standards and
Technology plans to revise Federal
Information Processing Standard 186, Digital
Signature Standard.
In addition, we participated in Agency
workgroups associated with EPA's initiative
to Reinvent Environmental Information,
aimed at accelerating and strengthening our
capacity to use information effectively to
manage environmental programs and
enhancing public access to the information
needed to make decisions about health and
environmental issues.
Throughout the year, we continued to
participate in the Agency's Travel Steering
Committee. The Committee is responsible
for implementing the best automated system
for EPA, integrating changes in regulations,
and re-engineering and standardizing .our .
internal processes. OIG participation
resulted in a unified, complementary
approach to achieving these goals while
addressing procurement, software, and
accounting concerns.
During fiscal 1997, we participated with
Agency personnel in the implementation of
upgrades and enhancements to the Agency's
Integrated Financial Management System
(IFMS). Based on our involvement, we made
observations and formulated suggestions for
improving strategic management of IFMS'
software maintenance and upgrade
processes, which the Agency's Financial
Management Division favorably received.
In addition, we introduced monitoring
software to several Agency Local Area
Networks (LANs) which access and/or
process sensitive Agency data (e.g.,
financial, Confidential Business Information).
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EPA Office of Inspector General Annual Superfund Report to the Congress for Fiscal 1997
Introducing appropriate personnel to this
software tool may expedite the use of it
across the Agency and, therefore, aid
Agency security personnel in their overall
mission. Also, briefing Agency personnel on
specific LAN security findings prompts timely
corrective actions, promotes security
awareness for electronic data, and reduces
the level of risk on individual LAN servers.
We conducted several regional audits which
noted deficient physical and environmental
controls which degrade the security and
reliability of the regional computer facilities
and data.
Throughout the year, we also met with key
officials in the IRM community to address
new and outstanding audit issues which
affect the reliability of Agency information
systems data. In particular, we briefed the
Chief Information Officer regarding an
emerging material weakness (i.e., lack of
validated general support' system and major
application security plans) so that his staff
had additional time to address the deficiency
before EPA's annual management
assessment process began.
Superfund Reauthorization
We continued to stay abreast of the
consideration of reauthorization of
Superfund, consulting with Agency and
Congressional officials. During fiscal 1997,
several OIG staff met with staff of the House
Transportation and Infrastructure Committee
to discuss what lessons they could learn from
our audit work to help in their consideration of
reauthorization issues.
Consultation on Program Development
We continued to respond to Agency requests
for advice as EPA developed procedures and
guidance on Superfund matters. For
example, the Office of Enforcement and
Compliance Assurance consulted with us
about procedures for disbursements to
potentially responsible parties under special
accounts to assure proper accountability for
the funds.
Work with Other OIGs
We have continued to respond to many
inquiries from OIGs of other Federal
agencies for advice and assistance in
handling Superfund audit issues applying to
their agencies. We held two meetings with
staff of the National Aeronautics and Space
Administration OIG regarding their
Superfund-related work, and provided them
with documents and contact points to assist
in their audits. We provided information
related to pump and treat remedies to the
Department of Defense OIG to assist their
audit work.
Superfund Issue Area Plan
in July 1997, we issued a Superfund Issue
Area Plan to focus our future Superfund
performance audit work. Our overall goal is
to determine the effectiveness of Agency
efforts to improve the Superfund Program.
The Plan identified four priority issue areas
for the 1998-1999 audit planning period to
enable us to address the overall goal. We
selected areas based on importance to
EPA's environmental goals, potential for
improving Agency program operations, and
input from Agency management and OIG
personnel. The four priority audit areas are
Superfund reform initiatives; enforcement;
state and tribal roles in Superfund; and
priority setting and risk. We will update the
plan periodically.
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EPA Office of Inspector General Annual Superfund Report to the Congress for Fiscal 1997
HAZARDOUS SUBSTANCE SUPERFUND
The Government Management Reform Act
requires Federal agencies to prepare annual
audited financial statements. The
requirement for audited financial statements
was enacted to help bring about
improvements in agencies' financial
management practices, systems and controls
so that timely, reliable information is available
for managing Federal programs. One of the
major entities covered by these financial
statements is the Hazardous Substance
Superfund Trust Fund. The EPA OIG's
requirement to audit EPA's financial
statements also meets our CERCLA audit
requirement to annually audit the Superfund
Trust Fund, which we previously referred to
as our Trust Fund audit. The summary below
of our fiscal 1997 financial statement audit
concentrates on findings related to the
financial statements of the Hazardous
Substance Superfund.
Superfund Receives First
Unqualified Opinion on Balance
Sheet But Further Improvements
Still Needed
Findings in Brief
During fiscal 1997, EPA continued to
improve its financial reporting systems
and practices. We also worked jointly
with the Agency to improve the accuracy
and reliability of the Agency's financial
statements. As a rejsult, we issued an
unqualified or clean opinion on the
Superfund Trust Fund Statement of
Financial Position, but still had to qualify
our opinion on the Superfund Trust Fund
Statement of Operations and Changes in
Net Position.
We Found That
• The Fiscal 1997 Statement of Financial
Position (Balance Sheet) fairly presented
the financial position of the Superfund
Trust Fund and EPA as a whole.
• The Fiscal 1997 Statement of Operations
and Changes in Net Position (Income
and Expense Statement) fairly presented
the results of operations for EPA as a
whole. However, material errors in one
region's accounting for its unbilled
Superfund oversight costs prevented us
from being able to determine if the
Statement fairly presented the fiscal
1997 Superfund Trust Fund beginning
balance for unbilled oversight costs. The
beginning balance for unbilled oversight
costs affected fiscal 1997 revenue.
Therefore, except for the effects of any .
adjustments that might have been
necessary to correct the revenue
reported, the Consolidating Statement of
Operations and Changes in Net Position
fairly presented the fiscal 1997 results of
operations of the Superfund Trust Fund.
Additional information on this issue
follows.
Material Internal Control Weakness
In evaluating the Agency's internal controls,
we identified weaknesses in the Agency's
accounting for unbilled Superfund oversight
costs. The Agency incurs these costs to
monitor cleanups of hazardous waste sites
performed by potentially responsible parties.
They are recoverable from these parties
based on the terms and conditions of
Consent Decrees or Orders. Regional
personnel estimate the amount of unbilled .
oversight costs at the end of the fiscal year
so they can include them in the financial
statements.
Two of the six regions we audited
encountered difficulties in estimating their
unbilled oversight costs. Based on the
concerns we raised, the Agency performed
additional work in these two regions to revise
the estimate of .unbilled oversight costs. Our
supplemental audit work still found material
errors in one region's recalculated beginning
balance. The difficulties encountered by
Agency personnel in developing an estimate
of unbilled oversight costs were primarily
related to. inadequate tracking of Superfund
sites. EPA devoted substantial resources to
manually generate an estimate since most of
the necessary data was not readily available.
The obstacles encountered in estimating the
unbilled oversight costs also make billing of
these costs a formidable task: The Agency
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EPA Office of Inspector General Annual Superfund Report to the Congress for Fiscal 1997
estimated it had $162 million of unbilled
oversight costs at the end of fiscal 1997.
Noncompliance Issues
We did not identify any instances of
noncompliance with laws and regulations that
would result in material misstatements to the
audited financial statements.
The Federal Financial Management
Improvement Act (FFMIA) requires us, during
our annual financial statement audits, to
determine whether EPA's financial
management systems substantially comply
with. Federal financial management system
requirements, applicable accounting
standards, and the, Standard General Ledger
at the transaction level. We determined that,
as of September 30, 1997, the Agency did
not substantially comply with FFMIA
requirements. In addition to the previously
reported material weakness concerning
accounting for Superfund oversight costs, we
also identified the following noncompliance
issues which could impact the accounting for
the Superfund Trust Fund:
• Year 2000 Activities - The Agency's
Core Financial Systems and the
EPA Payroll and Personnel System
(EPAYS) did not have required
management controls, including
approved formal decision papers
and system plans, to provide
reasonable assurance that EPA will
complete Year 2000 activities before
the systems are subject to failure.
Maintenance projects for Year 2000
fixes exceeded dollar thresholds
without obtaining required
management approvals.
• Financial Systems Security (also
reported as a material weakness in
EPA's fiscal 1997 Integrity Act
Report) - As of September 30, 1997,
the Agency's Core Financial
Systems and EPAYS did not have
required application security plans.
• Financial Systems Inventory Data -
There was no assurance that the
fiscal 1996 financial systems annual
inventory data, required by OMB
Circulars A-127 and A-11 was
consistent, comparable and
accurate.
• Annual Update of Chief Financial
Officer (CFO) Financial
Management Report and Five-Year
Plan - EPA omitted significant
system changes in the financial
systems inventory from its annual
update to the CFO Financial
Management Report and Five Year
Plan 1994 -1999, dated October
1996.
What Action Was Taken
We issued our final report (8100058) to the
Acting CFO on March 2, 1998. In responding
to our draft report, the Acting CFO agreed
that the Agency needed to improve the
timeliness of its oversight cost billings.
Regarding FFMIA compliance, the Acting
CFO stated the Agency was in substantial
compliance with the requirements of the Act.
We recognize that the Agency took a number
of significant steps to address the
noncompliance issues after the end of fiscal
1997, and scheduled additional actions for
completion later. We will evaluate the
adequacy of these corrective actions and
report Agency progress in our Semiannual
Report to the Congress. The Agency's
response to our final report is due by June 1,
1998.
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EPA Office of Inspector General Annual Superfund Report to the Congress for Fiscal 1997
COOPERATIVE AGREEMENTS AND CREDITS
In fiscal 1997, we issued reports on a
cooperative agreement with the Missouri
Department of Natural Resources and on
credits claimed by the State of Washington
for the Boomsnub site. We summarize the
cooperative agreement audit report below.
Missouri Needed to Ensure
Accuracy of Accounting Data
Findings in Brief
The Missouri Department of Natural
Resources (MDNR) improved its ability to
accumulate, and report expenditures with
the implementation of its Integrated
Administrative System (IAS). However,
MDNR had not ensured the accuracy and
completeness of IAS processed data by
reconciljng IAS data to the data in
Missouri's official accounting system.
Background
MDNR had 13 active Superfund cooperative
agreements in 1996, totaling more than $4
million in Federal assistance. The
agreements provided funding to identify,
assess, and respond to sites which
potentially threatened public health and the
environment from the uncontrolled release of
hazardous substances. We reviewed the two
agreements that had the highest claimed
costs, with total funding levels of $1.7 million
and total claimed costs of $1.2 million.
We Found That
In an April 1992 audit report we reported
several internal control and compliance
issues. Since then, MDNR improved its
ability to accumulate and report Federal
expenditures with the implementation of its
Integrated Administrative System (IAS). IAS
improved MDNR's allocation of personnel
costs to federally funded projects. Also, IAS
reported costs incurred using Federal object
class cost categories which allowed MDNR to
more efficiently track federally funded
projects.
While MDNR improved its reporting
capabilities with IAS, MDNR had not ensured
the accuracy and completeness of IAS
processed data. MDNR had not reconciled
IAS system data to data in Statewide
Accounting for Missouri (SAM), Missouri's
official accounting system. As a result,
MDNR was not assured IAS generated
accurate grant and project cost data. The
lack of reconciliations was a control problem
that affected all EPA financial assistance to
MDNR.
In addition, MDNR had not documented its
methodology, standards, or guidelines for
verifying the accuracy and completeness of
IAS data. MDNR needed to prepare
documentation of IAS processes, control
procedures, and exception reporting
responsibilities. We also thought that MDNR
should have an independent assessment
conducted on the propriety, reliability, and
accuracy of IAS.
We Recommended That
The Regional Administrator, Region 7, direct
MDNR to:
1. Develop and implement procedures
to consistently reconcile all IAS cost
data to SAM.
2. Document its methodology,
standards, or guidelines for verifying
the accuracy and completeness of
IAS data.
3. Establish clear standard procedures
for addressing exception report
issues and ensure responsibilities
are clearly defined.
4. Consider obtaining an independent
assessment of the reliability and
completeness of IAS processed data
and the adequacy of IAS controls.
5. Develop a transaction level detail
report which supports the IAS
standard report cost summaries.
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EPA Office of Inspector General Annual Superfund Report to the Congress for Fiscal 1997
What Action Was Taken
We issued the final report (7100220) to the
Regional Administrator,. Region 7, on June 9,
1997. In response to our draft report, MDNR
generally agreed with our findings and
recommendations, and indicated it had
initiated appropriate corrective actions. In its
Final Determination Letter to MDNR of
September 23, 1997, the Region imposed
requirements on MDNR consistent with our
recommendations.
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EPA Office of Inspector General Annual Superfund Report to the Congress for Fiscal 1997
10
REMEDIAL INVESTIGATIONS AND FEASIBILITY STUDIES
In fiscal 1997, we issued a technical report
on remedial investigation/feasibility study
(RI/FS) activities at one Superfund site. The
OIG Engineering and Science Staff
conducted this review, which we summarize
below.
Cleanup Acceleration Efforts at
Greenwood Chemical
Unsuccessful
Findings in Brief
Region 3 attempted to take advantage of
existing information about the Greenwood
Chemical Company (GCC) Superfund site
to accelerate the cleanup process.
However, new information made the
Region's accelerated timetable no longer
feasible.
Background
The GCC site in Newtown, Virginia, was used
historically as a batch processing facility for
the production of various organic compounds
for the industrial, pharmaceutical, and
pesticide trades. The site had a long history
of safety violations, fish kills, and cattle kills.
A 1985 explosion and fire killed four workers.
EPA began investigative work at the site in
1985, and listed it on the National Priorities
List in 1987. -
EPA completed a removal action at the site in
mid-1988. The Region dealt with the
remaining contamination problems at the site
through a series of remedial actions.
We Found That
EPA Region 3 generally performed remedial
planning activities at the site in a manner
consistent with the National Contingency
Plan and applicable guidance. Because the
Region realized the availability of an
abundance of existing information about site
conditions, it sought to accelerate the
cleanup process. Its cleanup strategy
involved establishing cleanup priorities .
through identification of operable units (OUs),
not completing a complete separate remedial
investigation before issuing the Record of
Decision (ROD) for OU1, and conducting
focused feasibility studies.
While the Region's efforts to accelerate
cleanup were commendable, additional site
information resulted in two significant
changes in the OU1 ROD after EPA issued it.
The Region eventually referred to each of
these as a separate OU. Enforcement
activities and difficulties in finding an
acceptable location for a rail transfer facility
resulted in further delays. As a result, EPA
did not complete the remedial action for OU1
until September 1996, five years later than
the Region originally hoped.
The changing plans for site remediation
resulted in a variety of inconsistent
designations of OUs in the site Administrative
Record. This made the Administrative
Record of limited use to the public in
understanding EPA's site cleanup decisions.
We Suggested That
While we made no formal recommendations,
we did offer the Region some suggestions to
avoid a recurrence of a confusing
Administrative Record at other Superfund
sites. We suggested that the Region:
• Develop periodic revised editions of
the Administrative Record Index that
clarify what documents exist for OUs
and list planning documents with the
appropriate OU.
• Produce more frequent Fact Sheets
to explain the ramifications of later
decisions on statements made in
RODs and other earlier site
documents.
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EPA Office of Inspector General Annual Superfund Report to the Congress for Fiscal 1997
11
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." The
President delegated this authority to the EPA
Administrator under Executive Order 12580,
January 26, 1987, who further delegated it to
EPA's Office of Solid Waste and Emergency
Response (OSWER). Authority for decisions
regarding claims against the Fund is currently
delegated to the Director, Office of
Emergency and Remedial Response.
During fiscal 1997, we issued one desk
review report on a response claim,
summarized below.
Colbert Landfill Claim Raised
Cost Issues
Results in Brief
Our desk review of Spokane County's
response claim for the Colbert Landfill
site raised several issues regarding
allowability of costs, which are possibly
moot due to a limit in the amount EPA is
obligated to pay. We also raised an issue
about the effect of Spokane County's
receipt of other funds for the response on
the amount EPA should reimburse the
County.
Background
A Preauthorization Decision Document (PDD)
authorized EPA payment of 11.5% of the
costs of implementing a Superfund remedy at
the Colbert Landfill site in Colbert,
Washington, conducted by Spokane County.
EPA and the County subsequently entered
into a consent decree requiring the County to
complete the remedy, and allowing it to claim
reimbursement of up to $1.4 million of its
costs from EPA. The County submitted a
final claim for total costs of $13,540,308. Of
this, $1,557,135 would be EPA's
proportionate share before applying the
consent decree's $1.4 million limit. EPA
requested the OIG's assistance in adjusting
this claim.
We Found That
We raised questions for EPA review about
three parts of the County's claim:
• The County purchased and charged
to the project $115,652 in
equipment. The County had not
obtained EPA approval to purchase
this equipment, although OMB
Circular A-87 requires specific
approval of the Federal agency for
purchase of equipment.
• The County claimed fees of
$194,176 on contracts which
provided for compensation based on
a cost plus percentage of cost basis
prohibited by Federal regulations.
• The County claimed other direct
costs of $621,900, consisting
primarily of costs for water
sampling/testing, administrative
expenses, and phone and electric
bills. OMB Circular A-87 allows
utilities costs-with approval of the
Federal agency. Additionally, some
of these costs may be considered
operation and maintenance costs.
The PDD made long-term operation
and maintenance costs ineligible for
EPA reimbursement.
Subtraction of the costs we found ineligible
would reduce the County's claimed total
costs to $12,608,580. Of this, EPA's 11.5%
share would be $1,449,987, which still
exceeds the consent decree's $1.4 million
limit.
We also noted that the County reported
receipt or anticipated receipt of $19,435,827
from the State of Washington, the Colbert
Landfill Trust (containing payments by
responsible parties), insurance settlements,
and EPA, an amount greatly exceeding the
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EPA Office of Inspector General Annual Superfund Report to the Congress for Fiscal 1997 12
County's claimed costs. The County noted
they have an obligation for operation and
maintenance of the treatment facility at the
site and other potential future site costs.
However, the PDD made long-term operation
and maintenance costs ineligible for EPA
reimbursement. EPA needs an interpretation
of the consent decree and the PDD to
determine the effect of the funds received
from other sources on the amount of the
County's costs eligible for reimbursement
from EPA.
We Recommended That
We considered this review to be an advisory
service rather than an audit, so we did not
include formal recommendations in our
report.
What Action Was Taken
We issued our desk review report (7200011)
to the designated response claims official in
the Office of Emergency and Remedial
Response (OERR) on June 6, 1997.
Because the report contained no
recommendations, no response was
required. OERR subsequently authorized
payment of $1.4 million to Spokane County in
settlement of the claim.
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CONTRACTS
The (DIG 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 and special
reviews 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. These
audits also play an integral part in supporting
EPA's cost recovery actions.
Of the 115 contract reports we issued in
fiscal 1997, 67 covered incurred costs under
EPA contracts. Another 14 of our reports
were initial pricing reviews in which we
reviewed costs proposed by offerers or
bidders seeking EPA contract awards.
Because these are only proposed costs, our
reviews do not question costs but rather
recommend as efficiencies costs that we
believe EPA should not incur. We also
issued 4 reports on proposed indirect cost
rates, 20 system survey reports, 2 program
review reports, and 8 Cost Accounting
Standards 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 1997, our
Superfund contract reviews were performed
as follows:
By OIG Staff 23 '
By Defense Contract Audit Agency 91
By Independent Public Accountants 1
We also conduct performance reviews of
EPA's management of contracts and
procurement.
We summarize below two of our contract
management review reports (in one
summary) and two of our contract financial
review reports.
Potential Vulnerabilities in
Contracts Management May Still
Exist
Exhibit I contains a listinc
reports issued by the OK
of all Superfund
I during fiscal 1997.
In June 1992, the Standing Committee on
Contracts Management-now the Resource
Management Committee-identified seven
problem areas and made forty
recommendations to correct longstanding
weaknesses in contracts management.
During fiscal 1997, we performed a survey
jointly with EPA's Office of Acquisition
Management to determine whether these
initiatives were implemented and effective in
correcting the identified weaknesses. We
found indications of potential vulnerabilities in
(1) personal services, (2) contractor access
to confidential or sensitive data, and
(3) contractor conflicts of interest.
Although we reported on the status of our
work to date, we will continue to conduct
additional audit work in each of these areas
to assess the potential vulnerabilities. We
issued a survey report (7400070) to the
Acting Assistant Administrator for
Administration and Resources Management
on September 30, 1997.
In response to an Office of Management and
Budget request, we reviewed EPA's: (1) use
of fixed-price contracts, (2) accuracy of
independent government cost estimates
(IGCEs), (3) contract capacity, (4) use of
award and incentive fees, (5) use of
completion vs. term forms, (6) length of base
and option periods, (7) management of
Response Action Contracts (RACs),
(8) competition of task orders under RACs,
and (9) use of performance-based service
contracting. We found that EPA has made
some progress in correcting past problems
related to IGCEs and the management of
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EPA Office of Inspector General Annual Super-fund Report to the Congress for Fiscal 1997
14
award fee contracts, such as issuing IGCE
guidance, requiring IGCEs for all significant
contract actions, and limiting award fees to
above-satisfactory performance. However,
EPA still needed to improve and had
substantial opportunities to lessen its
dependence on cost-reimbursable, level-of-
effort contracts and move toward more
efficient, results-oriented contracting
mechanisms.
EPA relies extensively on cost-
reimbursement level-of-effort (LOE) contracts
that essentially buy hours, not results,
thereby placing the burden of cost control on
the government. The Agency's cultural
preference for LOE contracts, insufficient
knowledge of alternative contract types, lack
of program accountability for the type of
contract to be awarded, inability to clearly
define its needs, and broad contract
statements of work have perpetuated this
continuing reliance on LOE contracts and
precluded a complete transition to more
efficient, cost-effective contract types.
EPA awarded RACs with adequate
competition and in accordance with
prescribed procurement procedures. EPA
intended contract provisions that appeared to
provide opportunities for competition of RACs
work assignments only for use in capacity
shortfalls and conflict of interest situations
and, according to EPA contract managers,
use of these provisions to compete work
assignments could potentially increase
contract costs. Although RACs provided for
using more efficient completion form work
assignments, the contracts did not include
any incentives to induce program staff to use
this contracting mechanism.
We found EPA did not always adequately
prepare and effectively use IGCEs to analyze
proposed contract costs or to establish
prenegotiation objectives. A good IGCE that
identifies activities and deliverables and
assigns estimated costs to these activities
provides a baseline to track actual versus
estimated costs and identify potential cost
overruns, thus promoting cost-effective
contracts. In certain instances, IGCEs did
not include detailed cost estimates and
represented projections of available funding
rather than actual cost estimates to complete
contract requirements. Also, EPA had not
implemented procedures for evaluating past
IGCEs or accumulating historical cost
information for preparation of current and
future IGCEs. As a result, EPA relied heavily
on contractors' estimates, often choosing to
award contracts and related work at amounts
closer to that proposed by the contractor
rather than the EPA estimate. EPA's ability
to properly estimate its needs and related
costs and effectively use these estimates in
contract negotiations is crucial for the
Agency's transition to more performance-
based service contracts.
We Recommended That
The Acting Assistant Administrator for
Administration and Resources Management,
in coordination with other appropriate senior
managers:
• Provide program personnel with
proper training in cost estimation
and alternative contract types.
• Require that IGCEs contain
estimated costs for each work
assignment task and be effectively
used for contract cost negotiations.
• Develop processes to evaluate the
quality of IGCEs and create
historical cost databases for use in
preparing IGCEs.
• Establish program goals for awards
of completion, fixed-price, and
performance-based contracts.
• Require Senior Resource Officials to
implement OMB's policy that
requires documented justification for
use of contract types other than
performance-based.
• Develop a strategy for meeting
OMB's contract reform goals.
• Where appropriate, modify award
fee plans for current contracts with
more than two years until expiration
to limit awards to above satisfactory
ratings.
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EPA Office of Inspector General Annual Superfund Report to the Congress for Fiscal 1997
15
What Action Was Taken
We issued the final audit report (7100301) to
the Acting Assistant Administrator for
Administration and Resources Management
on September 30, 1997. In response to the
draft report, the Acting Assistant
Administrator generally agreed with the
findings and proposed actions to implement
report recommendations. At the time we
prepared this Annual Report, we were
evaluating the Agency's response to the final
report.
Inadequate Supporting
Documentation and Misclassified
Costs
An audit of an incurred cost proposal resulted
in questioned indirect pool costs of
$2,861,238. The questioned costs consisted
of numerous unallowable, unallocable, and
misclassified costs. Our findings included
costs of $281,686 associated with the
contractor's annual meeting which the
contractor incorrectly classified in its
accounting records. This resulted in an
inequitable allocation to government
contracts. In addition, the contractor
incorrectly classified computer and
reproduction activities as overhead expenses
rather than accumulating and accounting for
them in a separate service center. This
increased the risk of an inequitable allocation
of costs to government contracts. Finally, the
contractor improperly included marketing
costs pf $2,365,406 in the general and
administrative pool. We questioned this
entire amount because it included
unallowable costs, unsupported costs, and
costs which did not have a causal/beneficial
relationship to government contracts and
should not have been allocated to them.
Proposed Labor Costs
Overstated by $87,601 and
Unsupported by $3.042,852
An audit of $11,265,658 of labor costs
incurred under an EPA contract disclosed
$87,601 of questioned costs and $3,042,852
of unsupported costs. The questioned costs
exceeded the costs the contractor actually
paid. The unsupported costs were labor costs
which the contractor's accounting records did
not adequately support. The contractor was
unable to provide the necessary assurance
that it had actually paid employees all the
hours claimed. In addition, we were unable to
apply audit procedures to determine if the
labor amounts claimed were reasonable,
allocable, and allowable under the Federal
Acquisition Regulation since the contractor's
accounting records did not always adequately
segregate labor costs. The EPA Contracting
Officer disallowed the costs we questioned
and applied the ineligible percentage to the
costs we indicated were unsupported.
J
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INTERNAL AUDITS AND SPECIAL REVIEWS
In addition to reviews required by CERCLA,
as amended, we conduct other reviews of
EPA's management of the Superfund
program. We summarize below some
particularly significant internal audits and
special reviews completed in fiscal 1997 not
summarized elsewhere in this Report.
Serious Environmental Data
Quality Problems Impair Federal
Facility Superfund Cleanups
Findings in Brief
EPA and Federal facilities need sufficient
procedures to ensure that environmental
laboratory data is of acceptable quality.
Sharing information on poor performers
and effective quality assurance systems
could have helped avoid millions in
expenditures and years of cleanup delays
at the nine sites audited.
Background
Federal facilities comprise nearly 60 percent
of EPA's Superfund workload under remedial
investigation or feasibility study phases. In
1995, the Department of Defense (DOD) and
the Department of Energy (DOE) had more
than 90 percent of the Federal facility sites on
or pending inclusion on EPA's Superfund
National Priorities List (NPL). Executive
Order 12580 gave DOD and DOE cleanup
responsibilities at their NPL sites, and the
National Contingency Plan further defined
their responsibilities but did not describe
EPA's oversight role for these cleanups.
Since 1992, environmental data quality had
been a material weakness in the Agency's
management control system.
We Found That
Federal facilities had experienced serious
problems with the quality of laboratory
analyses used to make cleanup decisions,
and there was evidence these problems were
widespread. For example, extensive
laboratory fraud was found at one laboratory,
which DOD used at 28 sites in three EPA
regions, resulting in about $5 million of lost
data and associated expenses. In another
case, EPA suspended a laboratory which did
work at five DOD sites in two EPA regions.
At one site, this laboratory and another
produced $2.5 million of data found
unusable, delaying cleanup two years. We
believe that one of the primary reasons for
these problems was that EPA's oversight role
at Federal facility Superfund cleanups was
unclear due to ambiguous legal authorities.
Also, remedial project managers generally
relied on Federal facilities to ensure
compliance with quality assurance project
plan (QAPP) requirements.
Of the 19 QAPPs audited at nine sites in
Regions 8, 9, and 10, data quality objectives
(the driving component of QAPPs) were not
established or properly defined for 14 of
them, the regional quality assurance staffs
did not approve 13 QAPPs, and a QAPP was
not used to collect data for one site. Eleven
QAPPs did not include data validation,
laboratory audits, or magnetic tape
availability, activities which we found
particularly effective in detecting
inappropriate quality data. Further, EPA's
guidance for preparing QAPPs did not
require these data quality activities when
warranted. Poor quality data can lead to
incorrect decisions resulting in inadequate
health protection or expenditures for
unneeded cleanup remedies.
EPA had not worked with DOD or DOE in
assessing their environmental data quality
systems department-wide, which would have
identified significant deficiencies. Because of
problems with their quality assurance
systems, EPA could not presume laboratory
analyses conducted at DOD and DOE
Superfund sites to be of appropriate quality
for decision making. DOD did not have a
system for tracking laboratory performance
and sharing laboratory audit results with
other military services or Federal agencies.
The DOE Office of Inspector General found
problems with DOE's commercial laboratory
quality assurance program allowing
laboratories that failed to qualify or were
suspended at one site to continue testing
samples for other sites.
The Federal government had no system to
share laboratory evaluations even though
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EPA Office of Inspector General Annual Superfund Report to the Congress for Fiscal 1997
17
such a system could help avoid the use of
incompetent laboratories and the costs of
duplicate audits. EPA lacked procedures for
exchanging laboratory performance
information between its own programs, and
for ensuring that poor quality data was not
used at Federal facility Superfund sites. The
Federal Facilities Restoration and Reuse
Office, which develops guidance and policy
for Superfund cleanups at Federal sites, and
one EPA region had not documented their
data quality systems in acceptable quality
management plans. Also, EPA had not
established performance measures for
environmental data quality at Superfund
sites.
We Recommended That
The Acting Assistant Administrator for Solid
Waste and Emergency Response:
• Work with the regions to ensure that
Federal facility Superfund QAPPs
include requirements that are based
on well-defined data quality
objectives.
• Develop a national quality
management plan and performance
measures for the environmental data
quality system.
• Issue guidance specifying regional
oversight responsibilities for Federal
facility Superfund cleanups and
establish procedures for ensuring
fraudulent or poor quality data is not
used.
• Assess the adequacy of DOD's and
DOE's environmental data
management systems and create a
forum for sharing environmental
laboratory evaluations among
Federal agencies.
The Assistant Administrator for Research and
Development:
• Refine the data quality objectives
process and work with the Federal
Facilities Restoration and Reuse
Office and regions to develop
acceptable quality management
plans.
The Assistant Administrator for Enforcement
and Compliance Assurance:
• Request modification of Executive
Order 12580 to expressly identify
EPA's oversight role for
environmental data quality.
What Action Was Taken
We issued the final audit report (7100132) to
the respective Assistant Administrators on
March 20, 1997. In responding to the draft
and final reports, Agency officials generally
agreed with the findings and
recommendations, and stated that EPA
would develop a framework for a minimum
quality assurance program for Federal
facilities. Also, the Agency agreed to assess
the adequacy of DOD's and DOE's
environmentaldata quality systems, issue
regional guidance addressing the oversight of
laboratory data quality, and amend its data
quality objectives guidance.
Superfund Oversight Bills to
Responsible Parties Were
Delayed for Years •
Findings in Brief
Region 3 took extraordinary amounts of
time to bill responsible parties for
recovery of Superfund oversight costs. In
several instances, delays amounted to
years, even though the Region should
have sent the bills annually.
Consequently, the Agency sometimes
agreed to responsible party challenges to
significant Agency costs.
Background
EPA incurs oversight costs while monitoring
cleanup work performed by responsible
parties at "Enforcement-lead" Superfund
sites. Such costs can include charges for
Agency personnel, EPA contractors, or state
employees. EPA recovers these costs
through the use of enforcement documents,
which are legally binding agreements
between the Agency and the responsible
parties.
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EPA Office of Inspector General Annual Superfund Report to the Congress for Fiscal 1997
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We Found That
Region 3 had 76 enforcement dockets for
sites with annual billing provisions during
fiscal 1996. Of the 15 dockets we reviewed,
there were:
• Eight instances where the Region
delayed the bills, in one case for
seven years.
• Three instances where the
responsible parties complained that
the billing delays adversely affected
their ability to verify what the Region
was billing.
• Four instances where the
responsible parties requested
documents to support earlier bills,
and the Region took between eight
months and seven years to provide
them.
• Four instances where the Region
had never sent any bills, even
though it had incurred costs as far
back as 1988.
Delays occurred because oversight billings
were considered a low priority, and there was
a reluctance by Superfund program
personnel to relinquish control of the billings
to financial personnel. As a result,
reimbursement to the Superfund Trust Fund
was delayed, and the responsible parties
were given additional opportunities to
challenge the charges, causing more delays.
The Region's delay in assessing oversight
bills sometimes resulted in other problems
with a cumulative effect of not recovering
oversight costs from the responsible party.
For example, when the Region delayed
submitting a bill for more than six years, the
responsible party challenged $185,525 in
indirect costs and the Region settled for only
$19,472. Had the Region submitted the bill
timely, it could have resolved the indirect cost
issue early enough to possibly recover these
costs.
In another instance, the Region was unable
to bill a responsible party $149,000 for State
oversight costs. Under the terms of a Multi-
Site Cooperative Agreement, EPA paid the
State of Maryland for assistance in
overseeing cleanups, and then billed the,
responsible parties. The Region delayed
billing the responsible parties for six years
and excluded $149,000 it had already paid to
the State because the Maryland Department
of the Environment had destroyed the time
sheets needed to verify the costs. If Region
3 had submitted a bill in accordance with the
enforcement document, it might have learned
of the problem years earlier.
We Recommended That
The Regional Administrator, Region 3:
• Ensure billing of oversight costs in
accordance with the enforcement
agreements signed by the Region,
e.g., on their anniversary date.
• Determine if Maryland's Department
of the Environment lacks time
sheets to support oversight charges
at Superfund sites covered by other
cooperative agreements.
• Initiate sanctions against the State
of Maryland's Department of the
Environment if it does not adhere to
the record-keeping and retention
criteria stipulated by the Code of
Federal Regulations.
What Action Was Taken
We issued the final report (7100292) to the
Regional Administrator, Region 3, on
September 22, 1997. In its final response to
our report dated January 20, 1998, the
Region concurred with our recommendations
and reported that it had taken steps to
eliminate the backlog and had developed
procedures to assure that billings are current
in the future.
Superfund Oversight Costs Were
Not Billed or Collected Timely
I
Findings in Brief
Region 5 did not promptly establish
receivables, send initial billings, or follow
up on unpaid accounts to responsible
parties for Superfund site oversight costs.
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Background
An important objective of the Superfund
program is recovering funds that EPA spends
cleaning up a Superfund site, including the
cost of overseeing cleanup work that the
responsible party performs, to replenish the
Superfund Trust Fund. Region 5 is
responsible for billing and collecting accounts
receivable for these costs at sites it monitors.
We Found That
Region 5 often took months, and sometimes
years, to establish accounts receivable and
bill responsible parties for Superfund
oversight costs. Of the 24 Superfund site
files we reviewed, EPA billed 17 late and did
not bill 4 at all. In addition, EPA sent 36
percent of letters demanding payment late
and did not send 62 percent at all. Reliance
'on manual procedures contributed to both of
these problems.
The Region's billing practice hindered
collection and 'accounting efforts since annual
billings included only the current year's
oversight charges and excluded unpaid
balances and accumulated interest from prior
years. This practice does not pfoyide the
Region or the responsible party with the
magnitude of the entire unpaid balance or
enough detail to permit reconciliation to
accounting records. Cumulative balance
billings would allow EPA staff to identify and
pursue parties with the highest debt and
allow prioritization of resources in the
collection of unpaid balances.
The Regional Comptroller's Office (RCO)
received payments for accounts receivable
which did not exist in its accounting records
because the Office of Regional Counsel
(ORC) did not forward a number of court
orders needed to establish accounts
receivable. Agency directives require ORC to
send court orders to the RCO, but some
attorneys were unaware of this requirement.
In addition, there was no follow-up system to
ensure that ORC responded to the RCO's
requests for supporting documents. As a
result, Region 5's accounts receivable were
incomplete and the RCO was not able to
match collections to the related receivable.
We Recommended That
The Regional Administrator, Region 5, direct
the Regional Comptroller to:
• Develop and implement specific time
frames for preparing and forwarding
annual oversight bills to responsible
parties.
• Emphasize timely issuance of
dunning letters following annual
oversight billings.
• Modify the new billing and collection
system so that annual billing and
dunning letters include outstanding
unpaid balances.
The Regional Administrator, Region 5, direct
the Regional Counsel to:
• Establish and implement internal
control procedures to routinely follow
up on the RCO's requests for
documentation.
What Action Was Taken
We issued the final report (7100139) to the
Regional Administrator, Region 5, on
March 26, 1997. In responding to the draft
report, the Agency agreed with our findings
and indicated it had implemented or planned
actions to address the report's
recommendations. On September 29, 1997,
the three Regional offices involved in the
billing process signed a Memorandum of
Agreement establishing time frames for each
office's responsibilities. Because Region 5
adequately responded to the draft report, we
needed no response to the final report.
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EPA Office of Inspector General Annual Superfund Report to the Congress for Fiscal 1997
20
INVESTIGATIVE ACTIVITY
During fiscal 1997, our Superfund
investigative efforts resulted in monetary
fines, restitution, and recoveries totaling more
than $2.7 million from one criminal and nine
civil/administrative actions. At the end of
fiscal 1997, we had 54 active Superfund
investigations, 34 percent of all active OIG
investigations at EPA.
The OIG Office of Investigations (Ol) is
continuing a major proactive investigative
effort in the Superfund program. The Ol
continues to focus on all stages of the
Superfund program, with a special emphasis
on contracting for removals and remediation.
As a result of Ol proactive efforts in prior
years, we continue to initiate criminal
investigations across the nation. We have
seen a corresponding increase in the number
of civil cases filed. We expect to see an
increase in significant civil actions as Ol's
investigative emphasis on major Agency
contracting continues to increase.
We give examples of Superfund investigative
activity with results in fiscal 1997 in the
following synopses.
Allegations of Fraud in Methyl
Parathion Program
Ol special agents investigated fraud in the
methyl parathion relocation program. Early in
the investigation, Ol identified systemic
vulnerabilities within the program and helped
establish identification and verification
procedures for subsistence payments to
applicants. Ol suggested other
improvements in the application process to
help protect against abuse and fraud, to
include a certification form with a warning
regarding penalties for false statements, a
medical release form, and interview
questions designed to identify fraudulent
claims. Ol conducted fraud awareness
briefings for Agency and Army Corps of
Engineers personnel who were assisting with
the relocation of residents from contaminated
dwellings and with removal and cleanup
activities, and for other state and local
officials in the affected regions. Individual
investigations have identified ineligible
applicants resulting in cost savings, and
several cases are being prosecuted by the
Department of Justice.
Former Laboratory Chief Executive
Sentenced in Waste-dump Scheme
On December 23, 1996, Alan P. Stevens,
former chief executive of Stevens Analytical
Laboratory in Stoneham, Massachusetts, was
sentenced to serve one year and one day in
Federal prison, ordered to pay $7,467 in
restitution to the victims of his fraud, and
assessed a $50 fee after pleading guilty to
wire fraud. Between May 1993 and May
1996, Stevens posed as a representative of
an environmental laboratory that collected,
tested, and disposed of waste, knowing that
such services would not be provided and
reports of such activities would be false and
fraudulent. Stevens collected waste
materials, some containing Polychlorinated
Biphenyls (PCBs), for analysis and prepared
a false test report with a fraudulent signature,
knowing that the waste had not been tested.
Stevens, claiming to be working for Alliance
Testing and Consulting, contracted to
dispose of six 55-gallon drums of waste oil
containing PCBs when, in fact, Stevens
abandoned them in a highway median area.
At the time, Stevens was under supervised
probation for falsifying water quality test
results for the towns of Lynnfield and
Bedford, Massachusetts. The EPA OIG, the
EPA Criminal Investigations Division, and the
Massachusetts Environmental Strike Force
jointly investigated this case.
Contractor Agreed to Fund Up to $2.4
Million in Cleanup Costs
COM Federal Programs Corporation agreed
to a $2.4 million administrative settlement
with EPA in response to allegations
associated with the cleanup of the Asbestos
Dump Site in Meyersville, New Jersey. EPA
contracted with COM to perform the $8
million cleanup of the site, which is in a
residential area adjacent to the Great Swamp
National Wildlife Refuge. The contract
required COM to remove soil contaminated
with asbestos and replace it with clean fill.
After completion of the cleanup, the EPA OIG
investigated allegations that CDM obtained
-------
EPA Office of Inspector General Annual Superfund Report to the Congress for Fiscal 1997
21
the soil used to replace the asbestos-
contaminated soil from a hazardous waste
site being cleaned up under the New Jersey
State Environmental Cleanup Responsibility
Act. EPA concluded that the soil did not
meet the contract specifications because it
contained unacceptable levels of debris and
chemical contaminants.
The agreement requires COM to pay as
much as $2.4 million in cleanup costs for the
removal and disposal of the defective backfill,
the installment of clean fill, and the
performance of any additional asbestos work
at the site.
Company Agreed to $150,000
Settlement on False Claims Charges
On September 3, 1997, Waste-Iron, Inc., of
Charleston, West Virginia, agreed to a
$150,000 settjement with the United States
Attorney's Office, Eastern District of
Pennsylvania, to resolve allegations that the
company caused the submission of false
subcontract claims through the government's
prime contractor in connection with a
Superfund cleanup. The Fike/Artel Chemical
Superfund site in Nitro, West Virginia
includes a chemical production facility and
various disposal areas for wastes resulting
from chemical processes. Waste-Tron, as a
subcontractor, was responsible for the
transportation and disposal of waste from the
Fike/Artel site. Our investigation resulted in
allegations that Waste-Tron submitted
fraudulent invoices to the prime contractor
that inflated the quantities or nature of the
wastes disppsed, and improperly added
previously billed charges for transportation
and disposal of waste. Waste-Tron was also
paid twice in some instances.
Cleanup Company Settled for $38,000
On January 31, 1997, OHM Remediation
Services Corporation agreed to pay the
government $38,000 to resolve disputed
claims arising from invoices that OHM
submitted to EPA from January 1, 1990,
through December 21, 1995, for cleanup
services on seven contracts. The contracts
and the Federal Acquisition Regulation
required that OHM bill EPA only for those
subcontractor and vendor charges that it had
actually paid at the time it submitted the
invoices. After an inquiry, OHM disclosed
that it had submitted invoices to EPA that
included subcontractor and/or vendor
charges which it had not paid at the time of
submission.
Contractor Required to Pay More than
$92,000
On April 21, 1997, Chemical Waste
Management, Inc. (ChemWaste), of
Bensalem, Pennsylvania, entered into a
settlement agreement with the Department of
Justice requiring ChemWaste to pay $92,685
to resolve civil fraud and contract claims
arising out of work performed at the Moyer
Landfill Superfund site in Montgomery,
Pennsylvania. In 1989, the U.S. Army Corps
of Engineers contracted with ChemWaste for
remediation work at the site. In January
1993, ChemWaste disclosed to the
Department of Defense that ChemWaste
employees had failed to conduct required air
and Geiger counter monitoring at the site.
The EPA OIG and the Defense Criminal
Investigative Service jointly conducted this
investigation.
Company Agreed to Compliance
Agreement After Forgery of EPA
Signature
On December 5, 1996, EPA signed a
compliance agreement with Environmental .
Waste Technology, Inc. (EWT), following an
OIG investigation of an allegation that an
EPA On-Scene Coordinator's (OSC)
signature was forged on two manifests used
to transport hazardous waste from a cleanup
site to an unintended landfill. OHM
Remediation Services, Inc., EPA's prime
contractor, hired EWT to transport hazardous
waste to two approved landfills in Detroit,
Michigan, and Wyandotte, Michigan. The
Detroit landfill rejected waste not approved
for that particular site. An EWT employee,
acting independently, created a new manifest
so that the rejected material could go to
another landfill, and signed the OSC's name
to the manifest. EWT reprimanded its
employee, OHM suspended business with
EWT, and EWT retrained its employees in
subcontract compliance. As part of the
compliance agreement, EWT will change
company policies and procedures to prevent
recurrence of the events. In consideration of
EWT's compliance witb the terms and
conditions of the agreement, EPA will not
-------
EPA Office of Inspector General Annual Superfund Report to the Congress for Fiscal 1997 22
initiate any suspension or debarment action
in conjunction with the forgery. EPA may
initiate suspension and/or debarment
proceedings against EWT if there is a •
material breach of this agreement.
-------
EPA Office of Inspector General Annual Superfund Report to the Congress for Fiscal 1997
23
SUPERFUND REPORTS
ISSUED DURING FISCAL 1997
Exhibit 1
Page 1of4
Final
Report
Number Description
Date
Audit Report
Control Number Issued
internal and Management Reports
J
Reviews Related To Statutory Requirements (other than IG Act
V
HGf
7200011 Response Claim - Colbert Landfill, WA E9HGM7-10-0003 6/ 6/97'
7400023 RI/FS Review - Greenwood Chemical Co.. VA E1SGG6-14-0010 3/ 6/97
7100062 Superfund Annual Report to Congress Review - FY92-94 E1SFF5-11-0029 11/21/96
Other Performance Audits
7300009 Award and Management of Response Action Contracts
7100292 Billing of Superfund Oversight Costs - Region 3
7100139 Billing of Superfund Oversight Costs - Region 5-
7100301 Contracting at EPA = •
7100288 Emergency Response Management - Region 2
7100132 Federal Facilities Lab. Data Quality at SF Sites
7100140 Superfund Field Sampling Activities - Region -3
Other Special Reviews
7400070 Contract Management Initiatives
7400069 Methyl Parathion Survey
7400004 Nat'l Enforcement Invest. Center Litigation Support
E1SGB6-
E5FFL7-
E1AML6-
E1SKF7-
E1SHF6-
E1SKB6-
E1SKF6-
04-0066
03-0008
05-0079
04-0037
02-0047
09-0041
03-0104
11/29/96
9/22/97
3/26/97
9/30/97
9/16/97
3/20/97
3/27/97
E1YFB7-05-0002 9/30/97
E1SFB7-06-0020 9/23/97
E1SFG6-08-0024 10/29/96
Cooperative Agreement Report
1
7100220 MO Dep't of Natural Resources - PA/SI & Core Program E5BGL6-07-0035 6/ 9/97
State Credit Report
J
7100188 WA - Boomsnub/Airco Site
E5HGL6-10-0027 4/30/97
Interagency Agreement Reports
J
7100285 Agency for Toxic Substances & Disease Registry - FY95 H5BFL7-20-0007
7100013 Army Corps of Engineers - Fiscal 1995
7100293 Army Corps of Engineers - Fiscal 1996
7100148 Nat'l Institute for Env. Health Sciences-Fiscal 1995
7100286 Nat'l Institute for Env. Health Sciences-Fiscal 1996
M5BFL6-20-5001
M5BFL7-20-0007
H5BFL7-20-0007
H5BFL7-20-0007
9/10/97
10/18/96
9/23/97
3/31/97
9/10/97
-------
EPA Office of Inspector General Annual Superfund Report to the Congress for Fiscal 1997 24
SUPERFUND REPORTS
ISSUED DURING FISCAL 1997
Exhibit 1
Page 2 of 4
Contract Reports
I
Final
Report
Number Description
Date
Audit Report
Control Number Issued
Initial Pricing Reviews
7100059 Advanced Technologies, KY
7300007 Agriculture & Priority Pollutants Labs, Inc., CA
7400051 All American Environmental Services, 'MD
7100001 Bay West, MN
7400025 Environmental Quality Management, Inc., OH
7100222 Halliburton NUS, TX
7100134 Industrial Marine Services, Inc., VA •
7400050 'Lockheed Martin Services, TX
7300034 Mel e Associates, Inc., MO
7100239 Roy F. Weston, PA
7100233 S. Cohen & Associates, Inc., VA ;
7400012 S&D Environmental Services, NJ
7100168 Smith Technology Corp., PA
7100196 VFL Technology Corp., PA
Incurred Costs
7100265 Bechtel National, Inc., CA - Fiscal 1994
7100174 Booz, Allen & Hamilton, MD - Fiscal 1995
7100181 COM Federal Programs Corp. - 1992-94
7100153 CH2M Hill, Inc., CO - Fiscal 1994
7100160 CMC, Inc., KY - ERCS Subcontracts - Cost & Pricing
7200016 DESA, Inc., SC - Enforcement Support - Fiscal 1994-95
7100193 Environmental Management Support, Inc., MD - 1993-95
7100156 Halliburton NUS Env. Corp., MD - Fiscal 1991
7100149 Halliburton NUS Env. Corp., MD - Fiscal 1992
7200010 Hydrogeologic, Inc., VA - FY94-95 Internal Controls
7100090 Jacobs Engineering Co. CA - ARCS - Fiscal 1989
7100105 Jacobs Engineering Co. CA - ARCS - Fiscal 1990
7300020 Jacobs Engineering Co. CA - ARCS - Fiscal 1991.
7300024 Jacobs Engineering Co. CA - ARCS - Fiscal 1992J
7300031 Jacobs Engineering Co. CA - ARCS - Fiscal 19921
7300026 Jacobs Engineering Co. CA - ARCS - Fiscal 1993
7100053 Life Systems, Inc. OH - Fiscal 1989
7100054 Life Systems, Inc. OH - Fiscal 1991
7100055 Life Systems, Inc. OH - Fiscal 1992
7100056 Life Systems, Inc. OH - Fiscal 1993
7100057 Life Systems, Inc. OH - Fiscal 1994
7100058 Life Systems, Inc. OH - Fiscal 1995
7100005 Malcolm Pirnie, Inc., NY
7100077 Marasco Newton Group, Ltd., VA - Mgmt. Support - FY95
7100112 Midwest Research Institute, MO
D9AKL6-44-0078 11/14/96
D9AGN6-44-0079 10/30/96
D9AFP7-44-1015 6/16/97
D9AGL6-05-0136 107 1/96
E9AHP7-23-0005 37 5/97
D9AKL7-44-0028 67 9/97
D9AFL6-44-0226 3/19/97
D9AKP7-44-0029 67 9/97
D9AFN7-44-1016 67 2/97
D9AFL7-44-1014 6/26/97
D9AFL7-44-1013 6/16/97
D9AHP7-02-0003 11/26/96
D9AFL7-03-0076 4/17/97
D9AFL6-03-0215 1/22/97
D9BFL7-44-1070 87 5/97
D9BFL6-03-0114 4/18/97
D9BFL5-03-0217 4/22/97
D9BGL5-44-0092 47 1/97
D9BHL6-04-0054 4/15/97
D9BJM6-44-0056 7/16/97
D9BFL6-44-0124 5/13/97
D9BFL2-44-0401 47 4/97
D9BFL3-03-0176 3/31/97
D9BFM7-44-0111 5/28/97
D9BGL5-44-0057 I/ 3/97
D9BGL7-44-0044 1/29/97
D9BGN7-44-0046 2/18/97
D9BGN7-44-0056 3/18/97
D9BGN7-44-0056 5/21/97
D9BGN7-44-0061 4/14/97
D9BGL7-05-0054 11/13/96
D9BGL7-05-0055 11/13/96
D9BGL7-05-0056 11/13/96
D9BGL7-05-0057 11/13/96
D9BGL7-05-0058 11/13/96
D9BGL7-05-0059 11/13/96
E9BFL5-02-0413 107 3/96
D9BFL6-03-0123 127 5/96
D9BKL7-07-0009 2/10/97
7300031 replaces 7300024, incorporating a contractor correction in its claimed rates.
-------
EPA Office of Inspector General Annual Superfund Report to the Congress for Fiscal 1997 25
SUPERFUND REPORTS
ISSUED DURING FISCAL 1997
Exhibit 1
Page 3 of 4
Contract Reports (continued)*
J
Final
Report
Number Description
Incurred Costs (continued)
7100003 Morrison Knudsen Corp
7100117 Morrison Knudsen Corp
7100155 Morrison Knudsen Corp
7100002 Morrison Knudsen Corp.,
Date
Audit Report
Control Number Issued
OH -
ID -
ID -
ID -
ID -
ERCS -
7100128 OHM Remediation,
7100066 PRC Environmental Management
7100071 PRC Environmental Management
PRC Environmental Management
PRC Environmental Management
7100186
7100187
7100282 PRC Environmental Management, IL
7100064 PRC Environmental Management, IL
Reidel Environmental Services, OR
Fiscal 1993 D9BKL7-
Fiscal 1993 D9BKL7-
Fiscal 1993 D9BGL7-
Fiscal 1994 D9BKL5-
1994 D9BHL6-
IL - 1988 E9BKL4-
IL - 1989 ' E9BKL5-
IL - 1990 - CAS 405 E9BKL4-
IL-1991-CAS 418/410/402 E9BKL4-
7100291
7100093
7100044
7100102
7100101
7400061
7400056
VA -
1992
1993 Supplemental
- ERCS - Overtime
1994
Inc., SC-ARCS-1995
Resource Applications, Inc
Roy F. Weston, PA - 1992
Roy F. Weston, PA - 1993
Roy F. Weston, PA - 1994
Rust Env. & Infrastructure
Superior Special Services, WI - ERCS
7200012 Sverdrup Corp., MO - ARCS - 1996-97
7200013 Sverdrup Civil, Inc., MO - ARCS - 1995
7100221 Sverdrup Environmental, Inc., MO - ARCS - 1994
7200014 Sverdrup Environmental, Inc., MO - ARCS - 1995
7100266 TAMS Consultants, Inc., NY - ARCS - 1989-92
TAMS Consultants, Inc., NY - ARCS - 1993-94
Tapanam Associates, Inc., KS - Accounting System
URS Consultant Corp., WA - Fiscal 1994
Viar, VA - 1993-94
7100234
7100118
7100089
7100159
E9BKL6
E9BKL6-
E9BGL6
D9BFL5-
D9BFL4'
D9BFL4-
D9BFL5-
D9BKP7-
D9BHP7-
D9BFM7-
D9BFM7-
D9BFL7-
D9BFM7-
D9BGL7-
D9BGL7
D9BKL7
D9BGL5
D9BFL6
7300040 Westinghouse Remediation Services, GA - ERCS - 1991-9Z9BHN5-
44-0001
44-0010
44-0014
44-0057
23-0013
05-0132
05-0086
05-0135
05-0137
05-0119
05-0139
10-0005
03-0319
03-0053
03-0284
03-0225
44-0044
23-0003
44-1059
44-1058
44-1053
44-1057
02-0028
02-0025
07-0012
44-0029
03-0227
04-0103
10/ 2/96
2/18/97
4/ 2/97
10/ 2/96
3/13/97
11/27/96
127 2/96
4/30/97
4/30/97
8/28/97
11/25/96
9/17/97
1/15/97
117 5/96
1/23/97
1/23/97
7/31/97
7/18/97
6/12/97
6/12/97
67 6/97
6/12/97
87 6/97
6/18/97
2/24/97
I/ 2/97
47 8/97
9/16/97
Final Audits
7100177 Ageiss Environmental, Inc., CO - TES - Fiscal 1994
7100175 Ageiss Environmental, Inc., CO - TES - Fiscal 1995
7100048 Black & Veatch Spec. Proj. Corp., MO-ARCS-Reg. 3-1991
7100121 Black & Veatch Spec. Proj. Corp., MO-ARCS-Reg. 3-1992
7100084 Black & Veatch Spec. Proj. Corp., MO-ARCS-Reg. 4-1990
7100007 Black & Veatch Spec. Proj. Corp., MO-ARCS-Reg. 5-1990
7100047 Black & Veatch Spec. Proj. Corp., MO-ARCS-Reg. 5-1991
7100046 Black & Veatch Spec. Proj. Corp., MO-ARCS-Reg.' 5-1992
7400007 The Mitre Corp., MA
7100167 Roy F. Weston, PA - ARCS - Annual
7100100 Roy F. Weston, PA - ARCS - Final
7100136 Sverdrup Environmental, Inc., MO
7100137 Sverdrup Civil, Inc., MO - ARCS -
7100145 Sverdrup Environmental, -Inc., MO
Closeout FY 1991-94
Closeout
- ARCS - Timekeeping
Timekeeping
- ARCS - 1994
D9CKL7-44
D9CKL7-44
D9CGL5-07
D9CGL5-07
D9CGL5-07
D9CGL4-07
D9CGL4-07
D9CGL4-07
D9CGP6-01
D9CFL6-03
D9CFL6-03
D9CGL5-07
D9CGL5-07
D9CGL5-07
-0014 4/18/97
-0015 4/18/97
-0014 117 7/96
-0014 3/10/97
-0023 12/23/96
-0072 107 3/96
-0072 117 7/96
-0072 117 7/96
-0079 10/28/96
-0148 4/16/97
-0194 1/23/97
-0029 3/26/97
-0029 3/26/97
-0029 3/31/97
-------
EPA Office of Inspector General Annual Superfund Report to the Congress for Fiscal 1997 26
SUPERFUND REPORTS
ISSUED DURING FISCAL 1997
Exhibit 1
Page 4 of 4
Contract Reports (continued)
J
Final
Report
Number Description
Indirect Costs
7100176 Ageiss Environmental, Inc., CO
7100279 DPRA, Inc., KS - Technical Enforcement Serv.
7100104 Reidel Environmental Services, OR - 1990
7100103 Reidel Environmental Services, OR - 1991
.- FY94
Date
Audit Report
Control Number Issued
D9DJL4-44-0054 4/18/97
D9DKL4-44-0078 8/25/97
E9DHL4-10-0067 1/28/97
E9DHL4-10-0067 1/28/97
System
7100017
7100262
7100250
7100230
7400006
7100255
7100289
7400041
7400047
7400003
7400001
7100208
7100151
7100238
7100097
7100083
.7100079
7400014
7400065
7300028
Surveys
Bay West, Inc.
Bechtel National, Inc.
City Environmental, MI
DPRA, Inc., KS - TES - Timekeepinc
Enserch E&C, Inc., NY - CAS 402/4C
Griffin Services, Inc., GA-Edlson,
ICF Kaiser Int
ICF Kaiser Int
ICF Kaiser Int
ICF Kaiser Int
Malcolm Pirnie
Marasco Newton
- Accounting System D9EGL7-
CA - ARCS - Floorcheck ' D9EFL7
- ERCS Sub. .- Account'g System D9EHL7-
D9EFL7-
8/418 D9EGP6-
NJ Lab.-Floorcheck D9EFL7-
E9EFL4-
E9EFP4-
E9EFP4-
E9EFP4-
1 Consulting Group - Disci. Statement
1 Corp. Office - Disclosure Statement
1 Eng. Group - Disclosure Statement
1 Kaiser Tech - Disclosure Statement
Inc., NY'- Floorcheck
E9EFP5-
Group, Ltd., VA-Mgmt. Supp. -Timekeepincf)9EFL7-
i S /-» • /-\X r^ • 1 T • ("•• i r— /-\ r— /~ti r-
Reidel Environmental Services, OR - Billing System
Roy F. Weston, PA - Site Assessment/Technical Asst.
Roy F. Weston, PA - START - Equitable Adjustment
Samsel Services, OH - ERCS sub. - Accounting System
'Smith Environmental Technologies, PA - Floorcheck
TRC Env. Consultants, Inc., MA - Disclosure
TRC Env. Consultants, Inc., MA - Electronic
URS Greiner, WA - Floorcheck & Timekeeping
E9EGL5
D9EFL7-
D9EFL7-
D9EHL7-
D9EFL6-
Statement E9EGP6-
Data Proc.E9EGP5-
D9EGN7-
05-0047
44-1023
44-0096
44-1061
02-0022
44-1094
22-0174
22-0178
22-0177
22-0175
02-0417
44-1039
10-0026
44-0084
03-0031
05-0049
03-0220
01-0640
01-0612
44-0016
10/22/96
8/ 5/97
7/31/97
6/13/97
10/28/96
8/ 1/97
9/17/97
5/ 7/97
5/29/97
10/23/96
107 '2/96
5/21/97
3/31/97
6/26/97
1/23/97
12/17/96
127 6/96
12/24/96
8/22/97
4/22/97
Program Reviews
7300017 GET Environmental, Inc., CA - Internal Controls P9FHN5-09-0077
7300018 NUS Corp., MD - Legal fees for subcontract terminatior09FFN4-44-0512
Cos? Accounting Standards
7100260 Bechtel National, Inc.
7100261 Bechtel National, Inc.
7100263 Gannett Fleming, Inc.
, CA - ARCS - CAS 404/409 D9GFL7-44-1148
, CA -.ARCS - CAS 404/409 D9GFL7-44-1148
PA - Cost Acct'g Standard 405 D9GFL7-44-1147
7100268 Gannett Fleming, Inc., PA - Cost Acct'g Standard 406 D9GFL7-44-1147
7100194 PRC Environmental Management, IL - CAS 405 E9GKL7-05-0095
7100197 PRC Environmental Management, IL - CAS 418/410 E9GKL7-05-0097
7400068 TRC Env. Consultants, Inc., MA - CAS 402 E9GGP5-01-0626
7100126 URS Consultant Corp., WA D9GGL7-44-0013
1/27/97 ;
1/30/97
87 5/97
87 5/97
87 5/97
87 5/97
5/14/97
5/16/97
9/17/97
3/12/97
-------
EPA Office of Inspector General Annual Super-fund Report to the Congress for Fiscal 1997 27
APPENDIX: ACRONYMS AND ABBREVIATIONS
Acct'g Accounting
ARCS Alternative Remedial Contracting Strategy
Asst. Assistance
CA California
CAS Cost Accounting Standards
CERCLA Comprehensive Environmental Response, Compensation, and Liability Act of
1980, as amended
CFO Chief Financial Officer
ChemWaste Chemical Waste Management, Inc.
CO Colorado
Co. . Company
Corp. Corporation
Dep't Department
Disci. Disclosure
DOD Department of Defense (U.S.)
DOE Department of Energy (U.S.)
Eng. Engineering or Engineers
Env. Environmental
EPA Environmental Protection Agency (U.S.)
EPAYS EPA Payroll and Personnel System
ERGS Emergency Response Cleanup Services (EPA contracts)
EWT Environmental Waste Technology, Inc.
FFMIA Federal Financial Management Improvement Act
FY Fiscal Year
GA Georgia
GCC Greenwood Chemical Company
IAS Integrated Administrative System (MDNR)
ID Idaho
-------
EPA Office of Inspector General Annual Superfund Report to the Congress for Fiscal 1997 28
IFMS Integrated Financial Management System (EPA)
IG Inspector General
IGCE Independent Government Cost Estimate
IL Illinois
Inc. Incorporated
Int'l International
Invest. Investigations
IRM Information resources management
KS Kansas
KY Kentucky
Lab. Laboratory
LAN Local Area Network
LOE Level-of-effort (type of contract)
Ltd. Limited
MA Massachusetts
MD Maryland
MDNR Missouri Department of Natural Resources
Mgmt. Management
Ml Michigan
MN Minnesota
MO Missouri
Nat'l National
NCR National Oil and Hazardous Substances Contingency Plan, 40 CFR Part 300
NJ New Jersey
NPL National Priorities List ^
NY New York
OERR Office of Emergency and Remedial Response (EPA OSWER)
OH Ohio
OHM OHM Remediation Services (EPA contractor)
-------
EPA Office of Inspector General Annual Superfund Report to the Congress for Fiscal 1997
29
Ol
DIG
OR
ORC
OSC
OSWER
PA
PA/SI
PCBs
PDD
Proc.
Proj.
PRP
QAPP
RAC
RCO
Reg. •
RI/FS
ROD
SAM
SARA
SC
Serv.
SF
Spec.
SSC
START
Sub.
TES
Office of Investigations (EPA OIG)
Office of the Inspector General
Oregon
Office of Regional Counsel (EPA)
On-Scene Coordinator
Office of Solid Waste and Emergency Response (EPA)
Pennsylvania
Preliminary Assessment/Site Inspection
Polychlorinated Biphenyls
Preauthorization Decision Document
Processing
Projects
Potentially Responsible Party
Quality Assurance Project Plan
Response Action Contract (EPA)
v • / •
Regional Comptroller's Office (EPA)
Region ,
Remedial Investigation/Feasibility Study
Record of Decision
Statewide Accounting for Missouri
Superfund Amendments and Reauthorization Act of 1986
South Carolina
Services
Superfund
Special
Superfund State Contract
Superfund Technical Assessment and Response Team (EPA contracts)
Subcontract or Subcontractor
Technical Enforcement Support (EPA contracts)
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EPA Office of Inspector General Annual Superfund Report to the Congress for Fiscal 1997 30
TX Texas
U.S. United States
VA Virginia .
WA Washington
Wl Wisconsin
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