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Inspector General Division
Conducting the Audit: Mid-Atlantic Audit Division
Philadelphia, Pennsylvania
Region Covered: Region 3
Program Offices Involved: Hazardous Waste Management Division
Grants and Audit Management Branch
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1
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
OFFICE OF THE INSPECTOR GENERAL
MID-ATLANTIC DIVISION
841 Chestnut Building
Philadelphia, Pennsylvania 19107-4431
(215) 597-0497
Washington Branch Office:
2800 Crystal Drive
Arlington, VA 22202
(703) 308-8242
September 19, 1995
MEMORANDUM
SUBJECT:
Final Audit Report on Delaware Superfund Cooperative
Agreements V-00335a and V-003620
Audit Report No. ll5FFL5-03-0177X5100489
.Jt_J /"-' -' '^
/ Lj-
FROM:
TO:
P. Ronald Gandolto
Divisional Inspector Geney&l for Audit
Mid-Atlantic Audit Divisq^
/on
Michael McCabe
Regional Administrator
Region 3
We have attached a copy of the final audit report on Delaware
Superfund Cooperative Agreements. The overall objectives of our
audit were to determine whether:
Cooperative agreement number V-003620 was adequately
monitored,
" Delaware Department of Natural Resources and Environmental
Control (DNREC) complied with the requirements of
cooperative agreement V-003620, and
Costs claimed under V-003350 were allowable, allocable, and
reasonable.
This audit report contains findings that describe problems the
Office of the Inspector General (OIG) has identified and
corrective actions the OIG recommends. This audit report
represents the opinion of the OIG. Final determinations on
matters in this audit report will be made by EPA managers in
accordance with established EPA audit resolution procedures.
Accordingly, the findings described in this audit report do not
necessarily represent the final EPA position.
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Audit of DE Superfund Cooperative Agreements
Our draft report was issued on July 20, 1995. We received your
response and a written response from the grantee. Both responses
were included, in full, as appendixes to our report. In
addition, we have addressed the comments throughout the report as
appropriate.
Action Required
In accordance with EPA Order 2750, you, as the action official
are required to provide this office a written response to the
audit report within 90 days of the final audit report date. For
corrective actions planned but not completed by your response
date, reference to specific milestone dates will assist this
office in deciding whether to close this report. We have no
objections to the further release of this report to the public.
Should there be any questions, contact me or Martin Pinto of my
staff at (215) 597-0497.
Attachment
11
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EXECUTIVE SUMMARY
PURPOSE
The objectives of our audit were to determine whether:
1) cooperative agreement number V-003620, totaling $2,268,310,
was adequately monitored; 2) DNREC complied with the requirements
of cooperative agreement V-003620; and 3) total costs claimed of
$220,897 under cooperative agreement V-003350 were reasonable,
allowable, and allocable.
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. The Superfund Amendments and
Reauthorization Act of 1986 (SARA), Public Law 99-499, enacted
October 17, 1986, revised and expanded CERCLA. SARA required the
DIG to examine a sample of cooperative agreements awarded to
states carrying out response actions. The results of these
examinations, including this audit report, are reported annually
to Congress.
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 including preliminary
assessments, site inspections, remedial investigations,
feasibility studies, remedial designs, remedial actions,
maintenance of completed remedies, and management assistance of
State involvement in Federally managed projects.
Ill
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RESULTS-IN-BRIEF
We found cooperative agreement number V-003620, totaling
$2,268,310, was not adequately monitored by EPA or DNREC and
DNREC did not comply with 7 of the 13 special condition
requirements. In addition, we found total costs claimed of
$220,897 under cooperative agreement V-003350 were unsupported by
adequate source documentation.
PRINCIPLE FINDINGS
DNREC DID NOT COMPLY WITH THE SPECIAL CONDITIONS
DNREC did not comply with 7 of 13 (54%) special conditions under
cooperative agreement V-003620. This occurred because:
1) EPA did not properly monitor the special conditions
including progress reports to ensure compliance as required
by EPA's Assistance Administration Manual; and
2) DNREC did not ensure that special conditions and
performance goals were achieved as required by 40 CFR
31.40.
As a result of the noncompliance, the objectives of the special
conditions were not achieved and EPA was unaware of the status of
activities to be performed. In addition, EPA awarded $174,777 in
excess of DNREC's needs that could have been used for other
Superfund proj ects.
INADEQUATE SOURCE DOCUMENTATION
We questioned all costs totaling $220,897, claimed under pre-
remedial cooperative agreement V-003350 because DNREC did not
maintain adequate source documentation. In accordance with 40
CFR 35.6705 and 40 CFR 30.500, DNREC must maintain all official
records for each assistance award for 10 years following the
submission of the final Financial Status Report (FSR). DNREC
submitted its final FSR on July 5, 1988 and was required to
maintain source documentation until July 5, 1998. The records
maintained must adequately document the following: amounts
IV
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received and expended, property purchased, time charged, and
compliance with applicable standards. We found DNREC did not
maintain these records. Factors contributing to this condition
were:
1) EPA did not notify DNREC of this requirement until the
cooperative agreement was closed, and
2) the closeout of the cooperative agreement was
inordinately delayed over four years by EPA.
Without adequate source documentation, we were unable to express
an opinion on the allowability of costs claimed. Also, EPA and
DNREC may be unable to recover Superfund expenditures under
future cost recovery actions for work performed under this
cooperative agreement.
RECOMMENDATIONS
We recommend the Regional Administrator:
1. Monitor DNREC's compliance with the special conditions of
the Superfund cooperative agreements, and require the
activities and tasks included in the workplan to be
completed.
2. Require EPA project officers to adequately monitor
cooperative agreements.
3. Obtain adequate support from DNREC for costs claimed under
the pre-remedial cooperative agreement V-003350 or recover
the Federal share of questioned costs.
4. Ensure all recipients of CERCLA-funded grants, cooperative
agreements, and contracts comply with the 10 year record
retention requirement as stipulated in 40 CFR 35.6705.
5. Close out grants and cooperative agreements in a timely
manner as required by Assistance Administration Manual,
Chapter 40 - Closeout of Assistance Agreements.
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REGION RESPONSE AND PIG EVALUATION
1. The Region did not respond to the first finding regarding
DNREC's non-compliance with 7 of 13 special conditions under
cooperative agreement V-003620.
2. The Region responded that regulations effective during the
grant period for cooperative agreement V-003350, only
required the grantee to keep source documentation through
July 5, 1991. The Region responded they would accept costs
based on the reconciliation of the Final Status Report
submitted on July 5, 1988.
Our position remained unchanged because the ten year record
retention requirement became effective before the previous
three-year requirement elapsed and before EPA closed the
cooperative agreement. DNREC was required to maintain
records until July 5, 1998.
DNREC RESPONSE AND PIG EVALUATION
1. Regarding the recycled paper special condition under
cooperative agreement V-003620, DNREC responded that some
recycled paper was purchased. Our report remained unchanged
because interviews with DNREC's New Castle office revealed
that recycled paper was not used to prepare the quarterly
progress reports submitted to EPA. The special condition
requires the use of recycled paper for all reports.
2. DNREC objected to our recommendation to the Regional
Administrator to obtain supporting documentation from DNREC
or to require DNREC to pay back the Federal Share of
cooperative agreement V-003350. DNREC agreed that if EPA
had performed the close out of the cooperative agreement in
a timely manner, they would have been notified of the change
in the record retention requirement prior to the end of the
three year requirement and could have maintained adequate
source documentation. DNREC responded that it was following
the regulations it knew existed at the time the records were
destroyed. Our position remained unchanged for the reasons
stated above under Region Response and OIG Evaluation.
VI
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TRANSMITTAL MEMORANDUM i
EXECUTIVE SUMMARY .' iii
CHAPTERS
1 INTRODUCTION 1
PURPOSE 1
BACKGROUND 1
SCOPE AND METHODOLOGY 3
PRIOR AUDIT COVERAGE 7
2 DNREC DID NOT COMPLY WITH THE SPECIAL CONDITIONS 9
NON-COMPLIANCE WITH SPECIAL CONDITIONS 10
EXCESS OBLIGATED FEDERAL FUNDS 17
3 INADEQUATE SOURCE DOCUMENTATION 21
APPENDIX I: ACRONYMS 27
APPENDIX II: REGION RESPONSE 29
APPENDIX III: DNREC RESPONSE 31
APPENDIX IV: DISTRIBUTION 35
VI1
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CHAPTER 1
INTRODUCTION
PURPOSE
From November 1983 to September 1993, the Environmental
Protection Agency (EPA) awarded funds totaling $12 million under
37 cooperative agreements to the Delaware Department of Natural
Resources and Environmental Control (DNREC). The objectives of
our audit were to determine whether: 1) cooperative agreement
number V-003620, totaling $2,268,310, was adequately monitored;
2) DNREC complied with the requirements of cooperative agreement
V-003620; and 3) total costs claimed of $220,897 under
cooperative agreement V-003350 were reasonable, allowable, and
allocable.
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 a 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.
The Superfund Amendments and Reauthorization Act of 1986 {SARA) ,
Public Law 99-499, enacted October 17, 1986, revised and expanded
CERCLA. SARA reinstated the environmental tax and expanded the
taxing mechanism available for a five-year period. It authorized
$8.5 billion for the Superfund program from 1987 to 1991. 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.
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SARA required the OIG to examine a sample of cooperative
agreements awarded to states carrying out response actions. The
results of these examinations, including this audit report, are
reported annually to Congress.
CERCLA section 104(c)(3) does not allow EPA to fund remedial
cleanups unless the State enters into a contract or cooperative
agreement with EPA to provide certain assurances, including cost
sharing. 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
assessments, remedial and removal cleanups, and enforcement
activities.
Remedial cooperative agreements provide funding to clean up or
treat hazardous waste at a single site or multiple sites within a
State. These cooperative agreements may be lengthy in duration
because remedial responses, from the planning stage to
accomplishment of the completed remedy, frequently take five
years or longer.
Core cooperative agreements provide a means to fund functions of
the Delaware program which were not directly associated with a
specific site. Core cooperative agreements were for activities
such as, program management, supervision, fiscal management,
contract administration, quality assurance, risk assessment,
training, legal assistance, and other miscellaneous items. Core
cooperative agreement number V-003620 was amended seven times and
provided DNREC $2,268,310 during the project period from
September 1, 1991 to August 31, 1994.
Pre-remedial cooperative agreements provide funding to DNREC to
conduct preliminary assessments, site inspections, site
inspection follow ups, hazardous ranking scores, and management
..assistance. These activities allow DNREC to evaluate sites for
potential inclusion on the Superfund National Priorities List.
The pre-remedial cooperative agreement number V-003350 was for
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Audit of DE Superfund Cooperative Agreements
$220,897 and had a project period from October 1, 1985 to March
31, 1988.
To assist the reader in obtaining a proper understanding of the
report, key terms used in this report for cooperative agreement
number V-003350 are defined below:
Costs Claimed: Costs identified by DNREC as eligible for Federal
participation on an outlay report submitted to EPA. Costs
claimed totaled $220,897.
Costs Questioned Unsupported: Costs not supported by adequate
documentation. Unsupported costs totaled $220,897.
EPA Payments to Date: This amount included funds disbursed by
EPA to DNREC. Total EPA payments were $220,897.
Balance Due EPA; This amount should not be construed as being
the final determination of questioned costs. The amount may vary
depending upon EPA resolution. The balance due EPA is $220,897.
SCOPE AND METHODOLOGY
We conducted a performance audit of the core cooperative
agreement number V-003620 and a financial audit of the pre-
remedial cooperative agreement number V-003350. We performed the
audit in accordance with the Government Auditing Standards (1991
Revision) issued by the Comptroller General of the United States.
Our examination included such tests of the accounting records and
other auditing procedures as we considered necessary.
We performed both our survey and audit, at DNREC offices in Dover
and New Castle, Delaware, as well as the EPA Region 3 Hazardous
Waste Management Division (HWMD) and Grants Management Division
(GMD) offices in Philadelphia, Pennsylvania.
Of the 37 cooperative agreements which EPA awarded to DNREC, we
judgementally selected three to review during the survey: a core
award, a pre-remedial award, and a remedial award. This report
addresses the core and pre-remedial awards. We considered the
following factors in selecting the cooperative agreements:
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" Type of cooperative agreement,
» Length of project period, and
Date and amount of award.
Our survey began with an entrance conference on June 8, 1994 and
ended on November 3, 1994. The overall objectives of our survey
were to determine the nature and extent of subsequent audit
effort in areas which may warrant a detailed audit and to provide
a basis for planning a detailed audit.
As a result of the survey, we found that DNREC's quarterly
progress reports did not provide the status of the commitments in
the cooperative agreements. In addition, Region 3 did not
require due dates for completing many of these commitments. We
also found that DNREC did not maintain complete financial records
for the pre-remedial cooperative agreement as required by EPA
regulations. Our limited evaluation of the special conditions
during the survey phase revealed that DNREC did not comply with
many of the special conditions in the cooperative agreement. For
these reasons, we focused on the monitoring issues specifically
related to special conditions and progress reports under the core
program cooperative agreement number V-003620. In addition, we
limited the scope of our audit to further evaluations of the
unsupported costs under pre-remedial cooperative agreement number
V-003350. Our audit fieldwork was conducted between November 3,
1994 and January 31, 1995.
Our audit included tests of financial records and other
procedures we considered necessary under the circumstances. We
interviewed project officers from the HWMD and grant specialists
from GMD. In addition, we interviewed DNREC employees. We
examined various records and documents, including: progress
reports, correspondence, invoices, payment vouchers, and
timesheets.
In assessing compliance with Federal requirements, we referred
primarily to the following criteria:
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Title 40 CFR Parts 30, 31, and 35;
EPA Assistance Administration Manual;
EPA Automated Clearing House (ACH) Payment System Manual;
EPA Letter of Credit - Treasury Financial Communications
System (LOC-TFCS) Manual; and
EPA Manual: Managing Your Grant and Cooperative Agreement:
Project Officer Responsibilities.
The scope of our internal control work was limited to
understanding and evaluating: 1) the policies and procedures used
by EPA to monitor its cooperative agreements; and, 2) DNREC's
internal control structure as related to our audit objectives and
DNREC's administration of the cooperative agreements. Our
objective was not to express an opinion on the internal controls,
and our work would not necessarily disclose all matters in the
internal control structure that might be considered material
weaknesses or reportable conditions. Because of inherent
limitations in any internal control structure, losses,
noncompliance, or misstatements could occur and not be detected.
We assessed the control risk in order to plan our audit and to
determine the nature, timing, and extent of our testing. Our
risk assessment of the internal controls disclosed that the
control risk for the audit as a whole was low, except for the
procurement system which we assessed as medium.
Moreover, we reviewed Region 3 HWMD's Report on Internal Controls
for fiscal years 1992 and 1993. The report was prepared to
comply with the Federal Managers' Financial Integrity Act
(Integrity Act). We also analyzed the Annual Assurance Letter
for fiscal year 1994. One significant weakness identified during
the Agency's Integrity Act review process was the Region's
monitoring of the Superfund cooperative agreements awarded to the
State of Virginia. We found a similar weakness in the monitoring
of the Superfund cooperative agreements awarded to DNREC. This
is fully discussed under Chapter 2 of this report. None of the
other weaknesses cited in this audit report were previously
disclosed by Region 3.
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On January 25, 1994, the management consulting firm of Booz Allen
& Hamilton (BAH) issued a report on DNREC's capabilities in
meeting Superfund financial management and documentation
requirements for cost recovery. The scope of this review was
limited to the examination of DNREC's site-specific financial
documentation and recordkeeping practices. The report identified
several areas related to financial management that needed
improvement. Our report discusses some of these issues as they
relate to our audit objectives.
We reviewed the BAH report and DNREC's corrective action plan for
resolving the identified issues. We believe that the corrective
action plan prepared by DNREC appeared adequate to address the
issues. We discussed the report and the corrective action plan
with DNREC officials. We were informed that they were proceeding
with the implementation of the corrective action plan. We did
not follow up on all the issues identified in the BAH report in
order to prevent duplicative audit effort. Our survey revealed
that two of the issues in the report were specifically related to
our objectives. We included these issues within the scope of our
audit. These issues included:
1. Receding and reconciling timesheets was delayed. DNREC's
accounting system initially charged employees' labor costs
against a designated account. DNREC periodically corrected
the charges based on allocations recorded on the timesheets.
The delay in receding and reconciling timesheets resulted in
inaccurate financial reporting to program managers in DNREC.
2. Backup documentation for the Automated Clearing House (ACH)
payment requests did not provide a complete audit trail of
the amount requested.
We issued a draft report on July 20, 1995. We received written
responses from Region 3 and the DNREC. Both responses were
included, in full, as appendixes to our report. We conducted a
telephonic exit conference with DNREC on August 31, 1995. Region
3 elected not to have an exit conference. We have addressed
Region 3's and DNREC's comments throughout the report as
.appropriate.
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PRIOR AUDIT COVERAGE
EPA's Office of the Inspector General (OIG) issued several
financial and performance reports on Superfund cooperative
agreements awarded to States in Region 3 including, Virginia,
West Virginia, Pennsylvania, and Maryland. Generally, these
reports identified monitoring issues and questioned costs similar
to this audit.
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CHAPTER 2
DNREC DID NOT COMPLY WITH THE SPECIAL CONDITIONS
DNREC did not comply with 7 of 13 (54%) special conditions under
cooperative agreement V-003620. This occurred because:
1) EPA did not properly monitor the special conditions
including progress reports to ensure compliance as required
by EPA's Assistance Administration Manual; and
2) DNREC did not ensure that special conditions and
performance goals were achieved as required by 40 CFR
31.40.
As a result of the noncompliance, the objectives of the special
conditions were not achieved and EPA was unaware of the status of
activities to be performed. In addition, EPA awarded $174,777 in
excess of DNREC's needs that could have been used for other
Superfund projects.
According to EPA's Assistance Administration Manual, the project
officer is critical to the successful completion of work
performed under an EPA assistance agreement. The amount of
involvement a project officer has in the grantee's performance is
determined by the type of assistance award. Under a cooperative
agreement, there should be significant involvement by the project
officer during all stages of a project, including site visits,
telephone calls, and meetings. The project officer is the
primary point of contact and must:
monitor the technical aspects of the work performed,
ensure the recipient complies with the terms of the
assistance agreement,
review the financial status reports to ensure that the
funds are used properly, and
insist on the timely submission of high quality progress
reports.
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In accordance with 40 CFR 31.40, grantees are responsible for
managing the day-to-day operations of activities performed under
the cooperative agreement. Grantees must also ensure compliance
with applicable Federal requirements and that performance goals
are achieved.
Our review of the project officer's file disclosed minimal
evidence that EPA monitored the cooperative agreement.
Specifically, we found no documentation to indicate routine
monitoring, such as phone logs, or evidence that the project
officer ensured the special conditions were complied with. Also,
the project officer did not ensure that the content of the
progress reports was sufficient. Although EPA's project officer
performed site visits to DNREC on a regular basis, there was no
indication of discussions related to non-compliance with special
conditions.
A. NON-COMPLIANCE WITH SPECIAL CONDITIONS
SPECIAL CONDITIONS
Progress Reports
ACH Payment System
Fair Share Percentage
MBE/WBE Submittal of SF-334
Content of Publicized Documents
Recycled Paper
Award Subject to 40 CFR Part 35, Subpart O
Debarred/Suspended Contractors
Small Business Rural Areas Affirmative Steps
Prompt Payment Act
Budget Period Cost
Drug-Free Workplace
Indirect Cost Rates
COMPLIANCE
No
No
No
No
No
NO
No
Yes
Yes
Yes
Yes
Yes
Yes
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Progress Reports
Timely and adequate progress reports ensure that EPA project
officers are aware of the status of activities being performed by
the State under the cooperative agreement. Progress reports are
an essential management tool that should be utilized by EPA
project officers.
We examined progress reports submitted to EPA by DNREC for the
period covering October, 1991 to September, 1994. The special
conditions of the cooperative agreement and 40 CFR 35.6650 cited
several specific items to be included in the progress reports, as
listed below. However, we found that DNREC's progress reports
did not contain any of the following required items.
1) An explanation of work accomplished during the reporting
period, delays or other problems, if any, and a
description of the corrective measures that are planned.
2) A comparison of the percentage of the project completed
to the project schedule, and an explanation of
significant discrepancies.
3) A comparison of the estimated funds spent to date
against planned expenditures and an explanation of
significant discrepancies.
4) An estimate of the time and funds needed to complete the
work required in the cooperative agreement. Also, a
comparison of that estimate to the time and funds
remaining, and a justification for any increase.
In addition to these missing items, the progress reports did not
identify the status of all the activities and related tasks
included in the workplan as required by 40 CFR 35.6650 (a) . The
core cooperative agreement provided funding to support the
overall activities for the Superfund program, such as, fiscal and
contract management, training, quality assurance, clerical, and
general support. Tasks which comprise fiscal and contract
management include: reviewing and improving the State procurement
process, coordinating the negotiation and execution of new
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contracts for Superfund sites, and administering close-out
activities.
Specifically, the workplan listed thirteen activities and their
related tasks, but the progress reports summarized information
into four areas that were not directly related to these
activities. The progress reports were inadequate because DNREC
did ,not identify if the activities and tasks were completed,
amended, delayed, or deleted. Without this information, the
project officer could not use the progress reports to determine
the status of activities and tasks. Therefore, he could not
monitor the cooperative agreement and ensure that the objectives
of the activities and tasks were achieved.
During our audit fieldwork, we reviewed a sample of progress
reports prepared by another state in Region 3. West Virginia's
progress reports identified each activity included in the core
program cooperative agreement workplan and summarized the status
of work performed under each activity.
DNREC personnel agreed that the status of each of the 13
activities was not provided in the progress reports. This
occurred because DNREC summarized information into general
categories such as Management and Supervision instead of focusing
on the activities and tasks identified in the workplan. DNREC
personnel told us that EPA was pleased with the format and used
their progress reports as a model for other states to follow.
However, the special condition clearly identified exactly what
DNREC was required to address in each progress report. We
believe the reports are inadequate because they did not meet
these requirements.
Although the content of the progress reports was inadequate,
DNREC complied with the timeliness requirement. The special
conditions and 40 CFR 35.6650 required these reports to be
prepared quarterly and submitted within thirty days of the end of
the reporting period. We found DNREC submitted their progress
reports in a timely manner.
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ACH Payments
We found DNREC did not comply with the special condition related
to the Automated Clearing House (ACH) payment system.
Specifically, we found that the following four requirements were
not, met.
1) Payment Requests will be based on disbursement needs.
The EPA-ACH Payment System Manual requires requests for funds to
be based on immediate disbursement requirements and that funds
received be disbursed as soon as possible to minimize the Federal
cash on hand. We reviewed DNREC's Cash Balance Reports for
February, 1993 for cooperative agreement V-003620. We found that
DNREC maintained large amounts of Federal cash on hand, exceeding
$130,000. This issue was previously identified to DNREC and
Region 3 in the BAH report issued on January 25, 1994. According
to DNREC personnel, ACH payment requests were prepared prior to
negative cash balances occurring. In response to the BAH report,
DNREC decided to change their policy and to only draw funds when
accounts are negative. Although we did not ensure that DNREC
consistently applied this new policy, we noted that cash balances
in February, March and June of 1994 were usually negative.
2) Timely reporting of cash disbursements and balances as
required by the EPA-ACH Payment System Manual.
EPA's Letter of Credit Manual and ACH Payment System Manual
require Federal Cash Transactions Reports to be submitted. Until
June 30, 1991, these reports were required to be submitted
quarterly. After June 30, 1991, the reports were required semi-
annually. These reports should be utilized to determine whether
funds were disbursed timely and whether DNREC was accumulating
large balances on hand.
We reviewed a total of 28 Federal Cash Transactions Reports for
the period beginning January 1, 1986 and ending June 30, 1994.
Of these 28 reports, 23 (82%) were late. Of these late reports,
12 were over 30 days late. Consequently, EPA was not always
aware of the current status of funds.
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3) For drawdowns under the EPA-ACH payment process, the
recipient will show on the payment request, the cooperative
agreement number, the appropriate EPA account number, and the
drawdown amount applicable to the activity account.
We examined 30 payment requests covering the period from October,
1991 through November, 1994 to determine if they contained the
appropriate cooperative agreement numbers, EPA account numbers,
and activity assignment codes. We also examined the balance on
hand for each request. Accurate reporting is essential in order
for the project officer to adequately monitor and reconcile funds
awarded and disbursed.
We found no errors in the recording of the cooperative agreement
number. However, deficiencies were noted in several other areas.
For example, three or 10 percent of the account numbers were
recorded incorrectly. In addition, our audit disclosed that
DNREC always entered $0 for balance on hand. DNREC personnel
stated that EPA did not require the balance on hand to be entered
on the form. Without accurate reporting of the cash balance on
hand, EPA cannot determine if the State is disbursing the funds
timely, in compliance with the ACH payment process.
4) Financial Status Reports are to be submitted to EPA, within
90 days after the end of the overall cooperative agreement.
According to 40 CFR 35.6670, Financial Status Reports are due
annually, 90 days after the end of the Federal fiscal year.
During the period of our review, DNREC was required to submit
three FSRs, one for each Federal fiscal year of the project.
These reports were due December 1, 1992, 1993, and 1994. We
found DNREC did not submit the three required FSRs timely. For
example, the FSR due December 1, 1992, was not submitted until
February 15, 1994, over a year late. Further, this FSR required
revisions. The revised FSR was received on March 3, 1994, over
15 months late. This FSR included financial information for
fiscal years 1992 and 1993. The FSR that was due December 1,
1994 has not yet been submitted at the time of our review and was
over six months late.
The information contained on FSRs is necessary for effective
management and oversight of the cooperative agreement. EPA must
14
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Audit of DE Superfund Cooperative Agreements
review the FSRs and compare the funding levels, both Federal and
State, with progress on the project. Without the timely and
accurate reporting of the FSRs, the EPA project officer cannot
ensure that requested funds were commensurate to the progress
made during the period.
Fair Share Percentage
EPA's policy is to ensure that recipients of EPA funds award a
fair share of subagreement funding to Minority Business
Enterprises (MBE) and Women-Owned Business Enterprises (WBE).
The State of Delaware negotiated a "Fair Share" objective of not
less than eight percent with EPA. Therefore, the State of
Delaware agreed to award at least eight percent of its
subagreement funding under EPA projects to small, minority, and
women-owned businesses.
We reviewed the State's compliance for Federal fiscal years 1991
through 1994. We found the State did not meet the eight percent
objective during 1991 and 1993. DNREC personnel informed us that
the goals were not consistently met because the State's previous
procurement system was inadequate. Specifically, the State's
procurement system did not require affirmative steps to assure
that small, minority, and women-owned businesses were used. As a
result, EPA did not meet its objective of assuring that small,
minority, and women-owned entities were provided the opportunity
to participate in subagreement awards under EPA financial
assistance agreements. However, DNREC personnel informed us they
began implementing a new procurement system in fiscal year 1994.
In addition, DNREC has developed a procurement and property
manual which identifies the affirmative steps that the State must
take to assure that small, minority, and women-owned entities are
provided the opportunity to receive subagreements. However, it
does not require DNREC to achieve the eight percent goal
negotiated with EPA.
MBE/WBE Reporting "
In addition to the eight percent negotiated fair share objective,
the State of Delaware was required to submit 12 reports of the
MBE/WBE utilization under Federal assistance agreements.
However, these reports did not contain accurate information.
15
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Audit of DE Superfund Cooperative Agreements
Specifically, all 12 reports required an explanation of the
reasons for non-attainment, but only 2 reports provided the
explanation. The State's utilization reports are essential in
order for EPA to compile information regarding the nationwide
utilization of minority businesses under EPA assistance
agreements, as mandated by the U.S. Department of Commerce.
Content of Publicized Documents
CERCLA mandates adequate public notification of Federal
participation in Superfund projects and programs. When issuing
documents describing projects or programs funded under the core
cooperative agreement, DNREC must indicate the percentage and
dollar amount of Federal funding. These documents include
statements issued to the public, press releases, requests for
proposals (RFP), and invitations for bids (IFB).
DNREC personnel informed us they had not implemented this special
condition because EPA Region 3 prepared most of the documents to
be released to the public. Also, DNREC personnel stated that
RFPs and IFBs do not contain this information because the State
requires these documents to be prepared by a central State office
outside of DNREC. It is important to include this information
because contractors submitting proposals in response to the RFPs
and IFBs will be unaware that they will be expected to comply
with Federal requirements.
Recycled Paper
DNREC was required by a special condition to use recycled paper
for all reports, including progress reports sent to EPA. We
found that recycled paper was not used at the New Castle,
Delaware office where the progress reports were prepared. DNREC
personnel stated recycled paper was not used because the
photocopy machine would malfunction. EPA Order 1000.25 directed
EPA to use and to promote the use of recycled paper. The
objective of 'this requirement was to reduce and recycle twenty-
five percent of municipal solid waste and to create and develop
stable markets for products containing recovered materials.
,DNREC's non-compliance with this special condition hindered EPA's
objective.
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Audit of DE Superfund Cooperative Agreements
Title 40 CFR Part 35 Subpart O
Title 40 CFR Part 35 Subpart O contains recipient requirements
for administering CERCLA-funded cooperative agreements. Subpart
O includes the regulations for progress reports. DNREC's
progress reports did not contain any of the required items cited
in 40 CFR 35.6650, as discussed previously under Progress
Reports. The progress reports were inadequate because DNREC
focused on positions rather than activities when summarizing
information.for the progress reports. Consequently, EPA could
not thoroughly monitor the cooperative agreement and could not
ensure that objectives of the special conditions were being
achieved.
EPA awarded excess funding to DNREC under cooperative agreement
V-003620. Of the $2,268,310 awarded under this cooperative
.agreement, $270,537 was obligated for capacity assurance. Under
capacity assurance, DNREC must assure the availability of
treatment or disposal facilities which have an adequate capacity
for the destruction, treatment, or secure disposition of all
hazardous wastes that are generated within the State. We found
that DNREC had not used $174,777 or 65 percent of the $270,537
obligated for capacity assurance. As of the date of our report,
DNREC personnel were unable to justify their requests for
additional capacity assurance funding. In our opinion, these
funds could have been used more efficiently, either for
additional Superfund awards to DNREC or other states. The chart
below provides the specific amounts and the months these funds
were left unused.
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Audit of DE Superfund Cooperative Agreements
UNUSED OBLIGATED FUNDS FOR CAPACITY ASSURANCE
COOPERATIVE AGREEMENT V- 003 620
AS OF JANUARY, 1995
DATE OF
AWARD AND
AMENDMENTS
August 30, 1991
September 23, 1992
February 18, 1993
September 9, 1993
September 30, 1993
July 11, 1994
TOTALS
AMOUNT OF
AWARD
$90,760
12,033
62,606
84,183
20,000
955
$270,537
AMOUNT
UNUSED
$ o
7,033
62,606
84,183
20,000
955
$174,777
MONTHS
FUNDS
UNUSED
0
27
22
25
25
5
We compared the dollar amounts approved in the award and
subsequent amendments to information included in EPA's accounting
system as of January 3, 1995. Our review revealed that EPA
continued to award additional funds for capacity assurance
although large balances were unused for as long as 27 months.
RECOMMENDATIONS
We recommend that the Region 3 Administrator:
1. Monitor DNREC's-compliance with the special conditions of the
Superfund cooperative agreements, and require the activities
and tasks included in the workplan to be completed.
2. Ensure DNREC implements the corrective actions planned as a
result of the Booz, Allen, and Hamilton report issued on
January 25, 1994.
"3. Require project officers to adequately monitor cooperative
agreements. Specifically, project officers should:
18
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Audit of DE Superfund Cooperative Agreements
a) Insist on high quality progress reports that include, as
minimum, all of the information required in 40 CFR
35.6650 and a status of each activity in the workplan;
b) Review and analyze the progress reports to determine
whether DNREC is meeting the tasks contained in the
workplan; and
c) Monitor funds awarded and disbursed to ensure that funds
are awarded as needed and that amendments are not in
excess of DNREC's needs.
REGION RESPONSE AND PIG EVALUATION
The Region did not respond to this finding.
DNREC RESPONSE AND PIG EVALUATION
1. DNREC requested we cite the regulation which requires
progress reports identify the status of all the activities
and related tasks included in the workplan.
We concur. We have added the specific regulation. Our draft
report only identifies 40 CFR 35.6650 under Progress Reports.
Paragraph (a) of this regulation requires grantees to submit
quarterly progress reports on the activities delineated in the
Statement of Work.
2. DNREC stated that even though there was no recycled paper in
stock at the time of your (DIG) survey, typically a fraction
of every order of copy paper is recycled paper.
Our report remains unchanged. Interviews of DNREC's New Castle
office revealed that recycled paper was not used to prepare the
quarterly progress reports submitted to EPA. The special
condition requires the use of recycled paper for all reports.
3." DNREC's written response stated that the correct amount of
unliquidated obligations was $152,242, not the $174,777
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Audit of DE Superfund Cooperative Agreements
identified in our report. In addition, DNREC provided a
breakout supporting an amount of $134,384.
Our position remains unchanged. Our amount is based on EPA's
financial information system and is supported by documentation.
Even though DNREC personnel provided information from their
accounting system supporting a lower amount, DNREC did not
justify their requests for this additional capacity assurance
funding. We maintain that these funds could have been used more
efficiently for additional Superfund awards to either DNREC or to
other states.
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Audit of DE Superfund Cooperative Agreements
CHAPTER 3
INADEQUATE SOURCE DOCUMENTATION
We questioned all costs totaling $220,897, claimed under pre-
remedial cooperative agreement V-003350 because DNREC did not
maintain adequate source documentation. In accordance with 40
CFR 35.6705 and 40 CFR 30.500, DNREC must maintain all official
records for each assistance award for 10 years following the
submission of the final Financial Status Report (FSR). DNREC
submitted its final FSR on July 5, 1988 and was required to
maintain source documentation until July 5, 1998. The records
maintained must adequately document the following: amounts
received and expended, property purchased, time charges, and
compliance with applicable standards. We found DNREC did not
maintain these records. Factors contributing to this condition
were:
1} EPA did not notify DNREC of this requirement until the
cooperative agreement was closed, and
2) the closeout of the cooperative agreement was
inordinately delayed over four years by EPA.
Without adequate source documentation, we were unable to express
an opinion on the allowability of costs claimed. Also, EPA and
DNREC may be unable to recover Superfund expenditures under
future cost recovery actions for work performed under this
cooperative agreement.
The following schedule shows that all costs claimed totaling
$220,897 have been questioned as unsupported.
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Audit of DE Superfund Cooperative Agreements
Analysis Of Allowability Of Costs Claimed
For The Period October 1. 1985 to March 31. 1988
Under EPA Cooperative Agreement V-003350 Awarded To
DE Department of Natural Resources and Environmental Control
AUDITOR'S OPINION
Cost Costs Costs Questioned
Category Claimed Unsupported
Salaries $124,237 $124,237
Travel 4,000 4,000
Contractual 38,965 38,965
Supplies 4,328 4,328
Capital 26,715 26,715
Indirect 22.652 22.652
Total $220.897 $220.897
Federal Share Claimed and Reviewed 100% $220,897
Less: Federal Share Questioned:
Unsupported 220.897
Allowable Federal Share $ 0
Payments To Date 220.897
Balance Due EPA $220.897
During the survey, DNREC could not provide original documentation
for the costs claimed under the cooperative agreement. DNREC did
provide monthly printouts of expenditures. However, these
printouts were not supported by original documentation and could
no't be reconciled to payment requests or FSRs.
Title 40 CFR 30.501 required DNREC to maintain their records
until July 5, 1991, three years after submitting the final FSR on
July 5, 1988. However, this regulation was superseded by 40 CFR
35.6705, which states that records must be maintained for ten
years following the submission of the final FSR. The ten year
record retention requirement became effective before the previous
.three-year requirement elapsed and before EPA closed the
cooperative agreement. Therefore, we believe, DNREC was required
to maintain records for ten years. Specifically, we determined
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Audit of DE Superfund Cooperative Agreements
that DNREC should have maintained their records until July 5,
1998.
The closeout of a financial assistance project is the final
process used by EPA to determine that the recipient has completed
all required substantive work and complied with all applicable
administrative requirements under the agreement. The Project
Officer must assure the Grants Management Division (GMD) within
90 days of project completion that all work has been
satisfactorily completed and all technical conditions have been
met. The Project Officer must also notify the GMD of the proper
handling of any personal property purchased under the agreement
and any unliquidated funds.
EPA notified DNREC of the close-out of the cooperative agreement
and ten year record retention requirement on February 9, 1993.
The close-out was completed over four and one-half years after
the final FSR was submitted by DNREC on July 5, 1988. We believe
that this is an inordinate delay in the closeout process. The
procedures for timely closeout of all completed projects are
contained in the Assistance Administration Manual. Chapter 40 -
Closeout of Assistance Agreements. According to the manual, the
actual closeout process should begin 3 or 4 months before the
scheduled end of the project.
Our audit revealed that Grants Management Division delayed the
closeout process over three of the four years, and Hazardous
Waste Management Division had delayed the process a total of ten
months. We believe, if EPA had informed DNREC and performed the
closeout of the cooperative agreement in a timely manner, DNREC
would have been notified of the change in the record retention
requirement prior to the end of the previous three year
requirement and DNREC could have maintained adequate source
documentation.
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Audit of DE Superfund Cooperative Agreements
RECOMMENDATIONS
We recommend the Regional Administrator of Region 3:
1. Obtain adequate support from DNREC for costs claimed under
the pre-remedial cooperative agreement V-003350 or recover
the Federal share of questioned costs.
2. Ensure all recipients of CERCLA-funded grants, cooperative
agreements, and contracts comply with the 10 year record
retention requirement as stipulated in 40 CFR 35.6705.
3. Close out grants and cooperative agreements in a timely
manner as required by Assistance Administration Manual.
Chapter 40 - Closeout of Assistance Agreements.
REGION RESPONSE AND OIQ EVALUATION
Region 3 responded that regulations effective during the grant
period (September 28, 1985 to July 5, 1988) only required the
grantee to keep source documentation through July 5, 1991. The
Region believes the grantee should not be held accountable for
records disposed by the grantee prior to the audit conducted in
1995. The Region responded they would accept costs based on the
reconciliation of the Final Status Report submitted on July 5,
1988.
Our position remains unchanged. The ten year record retention
requirement became effective before the previous three-year
requirement elapsed and before EPA closed the cooperative
agreement. DNREC was required to maintain records until July 5,
1998.
DNREC RESPONSE AND PIG EVALUATION
DNREC objected to our recommendation to the Regional
Administrator to obtain supporting documentation from DNREC or to
require DNREC to pay back the Federal Share of the cooperative
agreement funds. DNREC agreed that if EPA had performed the
close out of the cooperative agreement in a timely manner, they
24
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Audit of DE Super-fund Cooperative Agreements
would have been notified of the change in the record retention
requirement prior to the end of the three year requirement. In
that case, DNREC could have maintained adequate source
documentation. Not having heard on the closure of the
cooperative agreement, DNREC proceeded to get rid of the
cooperative agreement records in an effort to reduce the volume
of files to be retained. In February, 1993, EPA formally closed
the cooperative agreement and informed DNREC of the requirement
to retain the records for ten years instead of three years.
Unfortunately, the records had been destroyed by then. DNREC was
following the regulations it knew existed at the time the records
were destroyed.
Our position remains unchanged as discussed above under the
Region Response and OIG Evaluation.
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Audit of DE Superfund Cooperative Agreements
APPENDIX I
ACRONYMS
ACH Automated Clearing House
CERCLA The Comprehensive Environmental Response, Compensation,
and Liability Act of 1980 (CERCLA)
CFR U.S. Code of Federal Regulations
DNREC Department of Natural Resources and Environmental
Control (State of Delaware)
EPA U.S. Environmental Protection Agency
FSR Financial Status Report
GMD EPA, Region 3's Grants Management Division
HWMD EPA Region 3's Hazardous Waste Management Division
IFB Invitation for Bid
LOC-TFCS Letter of Credit - U.S. Department of Treasury,
Financial Communications System
MBE Minority Business Enterprise
OIG EPA-Office of the Inspector General
RFP Request for Proposal
SARA .The Superfund Amendments and Reauthorization Act of
1986
SF-334 Standard Form 334
WBE Women's Business Enterprise
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APPENDIX II
Page 1 of 1
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION III
841 Chestnut Building
Philadelphia. Pennsylvania 19107
SUBJECT:
FROM:
TO:
Response to Draft Audit Report of
Delaware Superfund Co-Operative
Agreements V-003620, and/^r-003350
W. Michael HcCabe
Regional Adminis
DATE:
SEP I I I995
(3RA00)
P. Ronald Gandolfo
Divisional Inspector General for Audit (3AIOO)
Thank you for the opportunity to comment on the draft audit
report. The Grants and Audit Management Branch (GAMB) has
reviewed the report and believes the issue on records retention
should be clarified.
In the report the auditors identified $220,897 as
unsupported costs claimed under Superfund Pre-remedial
Co-operative agreement V-003350 for Delaware, because the grantee
failed to maintain adequate source documentation. However, based
on regulations effective during the grant period (September 28,
1985 to July 5, 1988) , the grantee was only required to keep
source documentation through July 5, 1991. Since the costs
identified by the IG as "unsupported" were based on an audit
conducted in 1995, the Region believes the grantee should not be
held accountable for records disposed by the grantee prior to the
audit. Thus, the Region would accept costs based on the
reconciliation of the Final Status Report submitted on July 5,
1988.
We hope that this response resolves the issues identified in
the audit. If you should have any questions on this matter,
please contact Robert Reed at 7-7805.
29
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APPENDIX III
Page 1 of 4
STATE OF DELAWARE
DEPARTMENT OF NATURAL RESOURCES
& ENVIRONMENTAL CONTROL
89 KINGS HIGHWAY
P.O. Box 14O1
OFFICE OF THE DOVER. DELAWARE 199O3 TELEPHONE: (3O2) 739 - 44O3
SECRETARY FAX. (302)739-6242
August 30,1995
Mr. P. Ronald Gandolfo
Divisional Inspector General for Audit
Mid Atlantic Division
U.S. EPA-Region in
841 Chestnut Building
Philadelphia, PA 19107
Subject: RESPONSE TO RECOMMENDATIONS IN THE DRAFT
REPORT ON AUDIT OF DELAWARE SUPERFUND
COOPERATIVE AGREEMENTS V-003620 AND V-003350
Dear Mr. Gandolfo:
This is in response to your "Draft" audit report dated July 20,1995, mentioned above. I offer
the following comments on the factual accuracy of the data presented:
SCOPE AND METHODOLOGY
Page 4, Para 3
"Of the 37 cooperative agreements which EPA awarded to DNREC we judgmentally selected
three to review during the survey: (emphasis added) a core award, a pre-remedial award, and a
remedial award. This report addresses the core and pre-remedial awards."
Please specify the disposition of the remedial award. Also it is not clear whether the draft
report pertains to the survey as stated in the quote or an audit as stated in the "subject" of your letter.
31
aood tt&tcvte ctefeetufa (w<
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APPENDIX III
Page 2 of 4
Mr. P. Ronald Gandolfo
August 30, 1995
Page 2
PROGRESS REPORTS
Paee 9. Para 3
"In addition to these missing items, the progress reports did not identify the status of all the
activities and related tasks included in the workplan."
Please cite the regulations or the special conditions that require that the grantee must identify
the status of activities and related tasks included in the workplan.
RECYCLED PAPER
Page 14. Para 1
"We found that recycled paper was not used at the New Castle, Delaware office where the
progress reports were prepared."
Even though there was no recycled paper in stock at the time of your survey, typically a
fraction of every order of copy paper is recycled paper.
EXCESS OBLIGATED FEDERAL FUNDS
Page 14 Para 3
"We found that DNREC had not used $174,777 or 65 percent of the $270,537 obligated for
capacity assurance."
The correct figure is $155,242 and not $174,777.
INADEQUATE SOURCE DOCUMENTATION
Page 20 Para 3
"If EPA had informed DNREC and performed the close-out of the cooperative agreement in a
timely manner, DNREC would have been notified of the change in the record retention requirement
prior to the end of the previous three year requirement, and DNREC could have maintained adequate
source documentation." We concur with this statement. DNREC submitted FSR to EPA in 1988.
32
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APPENDIX III
Page 3 of 4
Mr. P. Ronald Gandolfo
August 30, 1995
PageS
DNREC was required to keep the records only until July, 1991. Not having heard on the closure of
the co-operative agreement, DNREC proceeded to get rid of these records in an effort to reduce the
volume of files to be retained. However, when in February, 1993, EPA formally dosed the
cooperative agreement, it informed DNREC of the new requirement to retain the records for ten years
instead of three years. Unfortunately, the records had been destroyed by thea DNREC was simply
following the regulations it knew existed at the time of destruction of the records.
Therefore it is not appropriate for the auditors to recommend that the Regional Administrator
obtain the support documents from DNREC which do not exist, or to require DNREC to pay back
Federal share of the cooperative agreement funds. DNREC objects to this recommendation.
I appreciate and thank you for allowing the Department the opportunity to comment on the
report.
CAGT:NVR:sfh
nvr95078.doc
cc: Nicholas A. Di Pasquale
N. V. Raman, Superfund
Nancy Marker, RCRA
Sandra Downs
33
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Statement of Account Balances
FY92 Grant 09/01/91 - 08/31/94
Superfund 09030203 - 3592
SAI 91061701 Superfund CORE Cooperative Program
CATEGORY
FEDERAL FUNDS
Salaries and OEC's
Travel
Contractual Services
Supplies
Capital Outlay
REPT,
CAT.
SC21
SC24
SC25
SC26
SC27
Total
Funds
Awarded
$1.053,135.00
$32,452.00
3638,198.00
$84,164.00
$0.00
Indirect Costs SC23 | $179,82400
Total Federal Funds -
Superfund
FEDERAL FUNDS
Salaries and OEC's
Travel
Contractual Services
Supplies
Capital Outlay
Indirect Costs
Total Federal Funds
Capacity Assurance
TOTAL FEDERAL FUNDS
SCA1
SCA4
SCA5
SCAB
SCA7
SCA9
$1,997,773.00
$184.584.00
$8,242.00
$34,145.00
$18,304.00
$0.00
$25,262.00
$270,537.00
$2,268,31000
Disbursements
for the Month of
JUNE
($349.B6)
$0.00
$0.00
$0.00
$0.00
$0.00
' ($349.86)
$0.00
$0.00
$0.00
$0.00
$0.00
$0.00
$0.00
($349.86)
Total
Disbursements
to Date
$1,092,214.99
$34,894.64
$399,608.80
$61,821.51
$0.00
$151,362.02
$1,759,901.96
$106,599.59
$1,022.77
$2,113.67
$12,415.06
$0.00
$14,001.56
$136,152.65
$1,896,054.61
Encumbrances
for the Month of
JUNE
$0.00
$0.00
$0.00
$0.00
$0.00
$0.00
$0.00
$0.00
$0.00
$0.00
$0.00
$0.00
$0.00
$0.00
$0.00
Total
Encumbrances
to Date
$0.00
$0.00
$0.00
$0.00
$0.00
$000
Vear-to-t>ate
Balance
JUNE
($29,079.99)
(52,442.64)
$238,589.20
$2,342.49
$0.00
$23.461.98
. i
$0.00
$0.00
$0.00
$0.00
$000
$0.00
$0.00
$0.00
$0.00
r $237,871.04
$77,984.41
$7.219.23
$32,031.33
$5,888.94
$0.00
$11,260.44
$134,384.35
$372,255.39
56!
Q)
v5
(D
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Audit of DE Superfund Cooperative Agreements
APPENDIX IV
REPORT DISTRIBUTION
Office of the Inspector General
Inspector General (2421)
EPA Headquarters Office
Agency Followup Official (3101), Attention: Assistant
Administrator for Administration and Resources
Management
Agency Followup Coordinator (3304), Attention: Director
Resource Management Division
Director, Financial Management Division (3303F)
Director, Grants Administration Division (3903F)
Associate Administrator for Regional Operations and
State/Local Relations (1501)
Headquarters Library, (M3404)
EPA Regional Office
Regional Administrator, Region 3, (3RAOO)
Audit Followup-Coordinator, (3PM70)
Regional Library, (3PM52)
External Distribution
Delaware Department of Natural Resources and
Environmental Control (DNREC)
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