United States Environmental Protection Agency Office of Inspector General 401 M Street, SW Washington DC 20460 wEPA Office of Inspector General Report to The Congress for the six month period October 1,1983 to March 31,1984 Pursuant to Section 5(b) of Public Law 95-452 ------- Foreword In my first full semiannual period as the Inspector General. I con- centrated much of my attention on making our Office a more recognized and respected entity m EPA By combining additional staff with new technology, deliberate planning and innovative techniques, we have come a long way in improving our own efficiency and effectiveness During this peri- od we formed a Fraud Prevention Task Force to chart the future focus of our prevention and detection efforts, established an ADP unit to provide auditors and investigators with more power- ful tools to examine records and data; entered into-a Memoran- dum of Understanding to provide us with independent legal counsel; acquired the personnel security program to assure compliance with national security directives; initiated in-house management assessment reviews; improved our policy manual system; and increased the training of our staff members By promoting the independent role of the Office of Inspector General, we are encouraging employees, grantees, and the pub- lic to cooperate in preventing, detecting, and reporting instances of wrongdoing to us. During this period we initiated an aggres- sive awareness campaign concerning the activities of the OIG and the Hotline; assisted the Agency in implementing the Feder- al Managers' Financial Integrity Act; conducted seminars on pre- venting bid rigging; and created the Committee on Fraud, Waste and Mismanagement to initiate Agency-wide participation in this effort. Our initiatives during this 6-month period are beginning to yield noticeable changes in Agency operations and increased interest by Agency officials. I will continue taking actions to improve the operations of the OIG, its visibility and significance to the Agency. John C. Martin Inspector General ------- Contents Executive Summary 3 Profile of Activities and Results 5 Establishment of the OIG in EPA - Its Role and Authority.... 6 Organization and Staffing 6 Purpose and Requirements of the OIG Semiannual Report .. 8 Section I - Significant Problems, Abuses, Recommendations. 9 Summary of Audit Activities and Results 9 Agency Management 10 Construction Grants 12 Superfund 17 Other Grants and Contracts 18 Section II - Audit Resolution 19 Audit Follow-up 20 Previously Reported Items - Action Not Completed 21 Section III - Prosecutive Actions 22 Summary of Investigative Activities 22 Description of Selected Prosecutive Actions 23 Description of Selected Administrative Actions Against EPA Em- ployees 25 Section IV - Fraud Prevention and Management Im- provements 26 Review of Proposed Legislation and Regulations 26 Suspension and Debartment Activities 27 Seminars to Prevent Bid Rigging 27 Committee on Fraud, Waste, and Mismanagement 28 Implementing The Federal Managers' Financial Integrity Act 28 Employee and Public Awareness Activities 29 Hotline Activities : 29 Fraud Prevention Task Force 30 Memorandum of Understanding 30 Establishment of ADP Unit :... = 30 Personnel Security Program 31 Training/Policy Development/Management Assess/pent Reviews 31 Section V - Delinquent Debts 32 Appendix - Listing of Audit Reports Issued 33 ------- Executive Summary Section I - Significant Problems, Abuses and Recommendations 1. Region Unable To Account For $2.5 Million In Property The Denver Regional Office did not devote sufficient re- sources to effectively manage or control an estimated $2.5 million of property (page 10). 2. Additional Actions Are Needed To Improve EPA's Internal Controls Although EPA has made sig- nificant progress in a short pe- riod, it still needs to do more in developing, implementing, and evaluating the adequacy of internal accounting and ad- ministrative controls to comply with OMB Circular A-123 and the Federal Managers' Finan- cial Integrity Act (page 10). 3. EPA Officials Were Not Adhering To Regulations For Reporting Noncompliance EPA Officials were not adhering to regulations for reporting noncompliance with the effluent discharge stan- dards of the Clean Water Act (page 11). 4. EPA's Permit Issuance Procedures Need Im- provement To Ensure Safe Disposal Of Hazardous Waste Specifications and conditions of a permit issued by EPA for ocean incineration of hazardous waste were changed without public notice or proper authorization (pagel 1). 5. Bid Rigging And False Claims Chronic In Construc- tion Projects Many contactors are de- frauding the government on EPA construction projects. The OIG has identified a pattern of bid rigging on $16 million of contracts for wastewater treat- ment facilities and false claims of performance on $8 million of contracts for sewer rehabilitation (page 12). 6. Management And Design Deficiencies Undermine $25 Million Sewer Project Poor planning, design, and construction prevented the Maiden, West Virginia, sewage treatment system from meeting Federal pollution stan- dards. Financial problems of the grantee may jeopardize the entire project (page 13). 7. Grantee Claims $1.14 Mil- lion In Excessive Costs Aiken County Public Service Authority, South Carolina, claimed ineligible costs totalling $1.14 million resulting from improperly administering and controlling three grants for a wastewater treatment sys- tem (page 13). 8. Grantee Claims $768,000 For Reservoir That Won't Hold Water The Cedar City Corporation, Utah, claimed $768,000 for the design and construction of an unusable reservoir as part of a $2.8 million wastewater treat- ment facility (page 14). 9. Grantee Claims Ineligible Costs In Excess Of $1 Million Including $867,000 Pre- viously Disallowed The Groveland Community Services District, Groveland, California, claimed ineligible costs totalling $1,054,000 for a wastewater construction grant including $867,000 that had been previously disallowed, but remained on the grantees records for reimbursement (page 14). 10. Grantee Fails To Control Grant Receipts And Ex- penditures The City of Santa Rosa, Cali- fornia, failed to control the use of EPA grant funds by claiming $702,000 for unnecessary ac- quisitions of land, construction beyond the scope of the approved wastewater treat- ment grant project, and in- come earned by investing grant funds (pagel 5). 11. Grantee Bills EPA More Than $700,000 In Excessive Costs While Ignoring Re- sponsibility To Review Claims Engineers maintaining the rec- ords and preparing claims for the Warwick Township Muni- cipal Authority, Litiz, Pennsyl- vania, did not adequately review billings to identify ex- cessive charges or screen claims to eliminate ineligible costs before submitting them to the Authority and EPA for repayment (page 15). 12. Grantee Bills EPA For Purchase Of Excess Land The Sacramento Regional County Sanitation District claimed $584,000 of ineligible costs for the purchase of land under a construction grant (pagel 6). 13. Grantee Claims Costs For Treatment System That Will Not Be Used The Wheaton Sanitary District, Illinois, claimed the $325,000 cost of a sludge treatment system that will not be used (page 16). ------- 14. Grantee Claims Cost For Dual Employment Of In- spectors The grantee claimed costs for two resident inspectors who were simultaneously employed and paid by both the grantee and the grantee's consultant engineer. The inspections made by these inspectors were incomplete (page 16). 15. Extensive Overcharges Identified In Cleanup At Drum Recycling Facility A half-million dollars in questionable billings followed IT Corporation's cleanup of a pollution emergency. The con- tractor's inadequate account- ing system permitted billings to EPA for ineligible items and made it difficult to identify the actual cost incurred for in- dividual projects (page 17). 16. Atlanta University Misus- es $222,000 of Training Grants Grants totalling $222,000 with Atlanta University Center, Inc., for student training in water pollution control were not ade- quately managed nor used for the intended purposes (page 18). Section II - Audit Resolution Despite considerable effort by EPA Officials and OIG staff to resolve audit reports, im- provements are needed to assure that Agency responses to audit reports are provided in a timely manner. While the number of unresolved audits declined on an overall basis during this 6-month period, the proportion of audits unresolved after 6 months increased dra- matically. In addition. Regional officials issued a final de- termination on one major audit with substantial costs ques- tioned without discussing their differences with OIG staff. The Inspector General is working closely with the Audit Follow- up Official to improve pro- cedures as well as the timeli- ness and adequacy of re- sponses to audit reports. Agency officials sustained $17.8 million of costs ques- tioned on audit reports and collected $13.2 million (page 19). Section III - Prosecutive Actions During this period, we con- centrated much of our effort on closing outstanding in- vestigation cases. We closed 89 cases, a significantly great- er number than in previous periods, reducing our inventory of open cases by 40 (18%) (page 22). The Municipal and Industrial Pipe Services, Ltd., (MIPS) defrauded the United States, State and local gov- ernments of $8 million for sewer rehabilitation work, much of which was never done. As a result of our in- vestigation of Municipal and Industrial Pipe Services, Ltd., four persons have been con- victed, fined and sentenced (page23). The OIG continued its investigation of evidence that EPA contractors are rigging bids on wastewater treatment facilities. As of March 31, 1984, a total of 17 guilty pleas were entered. During this period, five in- dividuals or entities pled guilty and received sentences for bid rigging (page 24). Section IV - Fraud Prevention and Management Improvements Seminars To Prevent Bid Rigging To improve the ability of gov- ernment officials' to detect and prevent bid rigging, EPA's Office of Inspector General worked jointly with the Anti- trust Division of the U.S. De- partment of Justice in de- veloping and presenting semi- nars titled "Efforts to Prevent Bid Rigging." These seminars were presented to 417 partici- pants including 149 non EPA employees in all ten regions (page 27). Committee On Fraud, Waste, And Mismanagement In- itiated At EPA The Administrator has ex- pressed his commitment for increasing coordination and participation in the Agency's fraud prevention efforts by es- tablishing an Agency Com- mittee on Fraud, Waste, and Mismanagement. This com- mittee will advise the Adminis- trator on policy matters associ- ated with minimizing occurr- ences of fraud, waste, and mismanagement in EPA pro- grams and activities (page 28). OIG Assists EPA In Im- plementing The Federal Managers' Financial Integrity Act The Federal Managers' Finan- cial Integrity Act requires that the internal accounting and ad- ministrative controls of each Executive Agency be es- tablished and that Agencies evaluate their systems of inter- nal control. To help implement the requirements of the Act, the Administrator requested, and the OIG provided the Agency with technical assis- tance and conducted an in- dependent evaluation of the Agency's progress in im- plementing the Act (page 28). Employee And Public Aware- ness Activities Our office used several media to inform the public, EPA gran- tees, and EPA employees about their responsibility to prevent, detect, and report in- stances of fraud, waste, or abuse. These included produc- tion of the first IG Highlights, EPA Video Monitors, publica- tions, and mailings to State Agencies (page29). Hotline Activities The OIG hotline center re- ceived 51 new complaints, processed 141 complaints, and closed 71 complaints during the reporting period. Of the 71 cases closed, 67 were not valid and did not require action while 4 cases resulted in en- vironmental or administrative corrective action (page29). Management Improvements Our office has taken several significant actions to improve its own economy, efficiency, and effectiveness including (1) forming a task force to identify future detection priorities; (2) undertaking a memorandum of understanding creating an In- spector General Division in the Office of General Counsel; (3) establishing an automatic data processing unit; (4) transferring the personnel security program to OIG; (5) providing more training to staff members; (6) expanding and refining the policy issuance system; and (7) conducting management assessment re- views to assure the quality of OIG operations. ------- Profile of Results Audit Operations Questioned and Set Aside Costs (Costs which are ineligible or lacking support.) Amount October 1,1983 to March 31, 1984 $157 Million Sustained Costs for Recovery and Savings $16.4 Million (Costs which EPA management agrees are inelig- ible and is committed to recover or offset against future payments.) Cost Efficiencies or Deobligations $1.4 Million (Funds made available by implementing recom- mendations in OIG Internal and Management audits.) EPA Audits Performed by the OIG 223 EPA Audits Performed By Another Federal 620 Agency, State Auditors or Independent Public Accountants Audit Reports Resovled 878 (Agreement by Agency officials to take satis- factory corrective action.) Investigative Operations Fines and Recoveries $538,366 Investigation Cases Opened 49 Investigation Cases Closed 89 Investigation Cases Pending (3/31/84) 180 Investigation Cases Referred for Prosecution 23 Indictments/Convictions of Persons or Firms 16 Adminis'viative Actions Taken Against EPA Employees 14 Fraud Detection and Prevention Operations Debarments, Suspensions, Voluntary Ex- 39 elusions and Settlement Agreements (Actions to deny persons or firms from participating in EPA programs or operations because of misconduct or poor performance.) Hotline Complaints Received 51 Hotline Complaints Processed and Closed 71 Proposed Legislation and Regulations Reviewed 34 ------- Establishment of the OIG in EPA - Its Role and Authority Offices of Inspector General were created by the Inspector General Act of 1978 (P.L 95- 452) to consolidate existing in- vestigative and audit resources in independent organizations headed by Inspectors General. EPA's Office of Inspector General (OIG) was established in January of 1980. As an Agency with a massive public works budget, EPA is vulner- able to various kinds of finan- cial abuses. OIG's role is to re- view EPA's financial transac- tions, investigate allegations or evidence of possible criminal and civil violations, and pro- mote economic, efficient and effective operations within the Agency. It is also responsible for reviewing EPA regulations and legislation. The Inspector General for EPA reports di- rectly to the Administrator and has the authority to: Initiate and carry out in- dependent and objective au- dits and investigations, Issue subpoenas for evi- dence and information, Obtain access to any mate- rials in the Agency, Report serious or flagrant problems to Congress, Select and appoint OIG em- ployees, and Enter into contracts. The Inspector General is ap- pointed by, and can only be removed by, the President. This independence protects the OIG from interference and allows it to function as the Agency's fiscal and operational watchdog. Organization and Staffing The Office of Inspector Gener- al functions through three ma- jor offices, each headed by an Assistant Inspector General. These offices are the: (1) Office of Audit; (2) Office-of Investigation; and (3) Office of Management and Technical Assessment. Nationally, there are five Divisional Inspectors General for Audit and five Di- visional Inspectors General for Investigation who direct staffs of auditors and investigators and who report to the appro- priate Assistant Inspector General in Headquarters. Office Staffing Distribution - FY 84 Ceiling Headquarters Field Total Inspector General Audit Investigation 4 26 8 133 44 4 159 52 Management and Technical Assessment 21 21 Total 59 177 236 ------- Office of Inspector General - Who's Who Headquarters Ernest E. Bradley III Assistant Inspector General Kenneth A. Konz Deputy James 0. Rauch Director Anna M. Virbick Director 1 of Audit Inspector General Deputy Inspector General Office of Investigations John C. Martin Donald E. Kirke 1 Office of Ma and Tec Assess I Operations Staff I Technical Services Staff Paul E. Olson Assistant Inspector General John E. Barden Deputy Roscoe R. Davis Assistant Inspector General Technical Assessment and Fraud Prevention Division Administrative and Management Services Division John C. Jones Director Edwin N. Canady Director Divisional Inspectors General Region 7 (Audit), 8, 9.10 Truman R. Beeler, Audit Jonathan P. Sweeney, Investigation Region 5 & 7 (Investigation) Anthony C. Carrollo, Audit Vacant, Investigation Region 1 ft 2 MAIN4 Sanford Wolf, Audit * Robert M. Byrnes, Investigation Region 4 & 6 Leslie M. Buie, Audit Ervin E. Boehl, Investigation (Acting) Boston i.i. New York Phllnd«lph!a 'EL Region 3 Paul R. Gandolfo, Audit James J. Hagen, Jr., Investigation Headquarters Steven A. McNamara, Internal Audit ------- Purpose and Requirements of the Office of Inspector General Semiannual Report The Inspector General Act of 1978 (P.L. 95^52) requires the Inspector General to keep the Administrator and Congress fully and currently informed about problems and de- ficiencies in the Agency's op- erations and the necessity for and progress of corrective ac- tion. The Act further specifies that semiannual reports will be provided to the Administrator by April 30. and October 31, and to Congress 30 days later. The Administrator may trans- mit comments to Congress along with the report, but may not change any part of the re- port. The specific reporting re- quirements prescribed in the Inspector General Act of 1978 are listed below. Also, in- cluded are additional require- ments resulting from Senate Report No. 96-829 on the Sup- plemental Appropriation and Rescission Act of 1980 (P.L. 96-304). Source Section and Page IV INSPECTOR GENERAL ACT Section 4(a)(2) - Review of Legislation and Reg- ulations Section 5(a)(1) - Significant Problems, Abuses, and Deficiencies Section 5(a)(2) - Recommendations with Re- spect to Significant Problems, Abuses and Deficiencies Section 5(a)(3) - Prior Significant Recommenda- tions Not Yet Implemented Section 5(a)(4) - Matters Referred to Pro- secutive Authorities Section 5(a)(5) and 6(b)(2) - Summary of In- stances Where Information was Refused Section 5(a)(6) - Listing of Audit Reports SENATE REPORT NO. 96-829 Senate Report Page 11, Resolution of Audits Senate Report Page 12, Delinquent Debts 26 9 9 19 22 Appendix 33 V 19 32 'There were no instances where information or assistance requested by the Inspector General was refused during this reporting period. Accord- ingly, we have nothing to report concerning Sections 5(a)<5) and 6fb)(2) of the Inspector General Act of 1978. ------- Section I - Significant Problems, Abuses, and Recommendations As required by Section 5(a)(1) and (2) the Inspector General Act of 1978, this section identifies significant problems, abuses, and de- ficiencies relating to the Agency's programs and op- erations along with recom- mendations for the current period. The findings de- scribed in this section re- sulted from audits per- formed or supervised by the Office of Audit and reviews conducted by the Office of Investigation. Because these represent some of our most significant findings, they should not be considered representative of the overall adequacy of EPA Manage- ment. This section is divided into five areas: Summary of Au- dit Activity and Results; Agency Management; Con- struction Grants; Super-fund, and Other Grants and Con- tracts. Summary of Audit Activities and Results 140 120 100 80 60 40 20 $136 CO z - o CO cc o Q $18 $3 CONSTRUCTION GRANTS AND CONTRACTS SUPERFUND Questioned and Set Aside Costs by Type of Audit OTHER FEDERAL AGENCY 393 REPORTS EPA OIG 223 REPORTS CONSTRUCTION 312 REPORTS SUPERFUND 39 REPORTS STATE AUDITORS 49 REPORTS PUB. ACCOUNTANTS 178 REPORTS /^_ ' INTERNAL & ' 1 I \v ./arm > < c MANAGEMENT 28 REPORTS OTHER GRANT & CONTRACT 464 REPORTS Distribution of Audit Reports Issued by Source Distributions of Audit Reports Issued by Type ------- Agency Management The Inspector General Act re- quires the OIG to initiate re- views and other activities to promote economy and effi- ciency and to detect and pre- vent fraud, waste, and mis- management in EPA programs and operations. Internal and Management audits are con- ducted to accomplish these objectives largely by evaluating the adequacy and performance of internal controls. The following are the most significant Internal and Man- agement audit findings and recommendations: Region Unable To Account For $2.5 Million In Property Problem The Denver Regional Office did not devote sufficient re- sources to effectively man- age or control an estimated $2.5 million of property. We Found That The property management system in Region 8 was in- adequate to provide account- ability for personal property en- trusted to the Region. The criteria and procedures for property management in EPA Property Management Regula- tions were not followed be- cause the Region did not place sufficient priority or assign suf- ficient resources to manage property. The following are specific deficiencies: The Region did not take physical inventories or tag property for identification. The Region did not record approximately $250,000 of property acquired during Fiscal Year 1983. The Region did not segre- gate or report excess property to GSA for disposal resulting in large amounts of new furniture being stored outside and sub- sequently ruined. The Region acquired un- needed furniture from GSA ex- cess property registers. The Region did not maintain records of property loaned to other Federal agencies. We Recommended That The Regional Administrator assign the resources neces- sary to establish and maintain a property management sys- tem which complies with Agency regulations. We fur- ther recommended: Annual physical inventories; Timely posting of receipts and disposal of property; Removal of lost property from inventory records; Affixing of decal numbers to accountable property; and Timely reporting of excess property for disposal action. What Action Was Taken Although a lack of records pre- vented an exact determination of dollar impact resulting from the above deficiencies, the Re- gional Administrator and pro- gram officials agreed with all audit findings. The audit report was issued to the Regional Administrator, Region 8, on March 26, 1984. A response to the audit report is due by July 26, 1984. Additional Actions Are Needed to Improve EPA's Internal Controls Problem Although EPA has made significant progress in a short period, it still needs to do more in developing, implementing, and evaluat- ing the adequacy of internal accounting and administra- tive controls to comply with OMB Circular A-123 and the Federal Managers' Financial Integrity Act. Background OMB Circular A-123, as amended August 1983. es- tablished internal control stan- dards and a system of Agency responsibilities and require- ments to address the numer- ous instances of fraud, waste, abuse, and mismanagement in Federal Government op- erations. Congress expressed support for this effort by passing the Federal Managers' Financial Integrity Act. The Act requires that: internal account- ing and administrative control standards be prescribed by the Comptroller General; annual evaluations of internal account- ing and administrative controls be conducted by each ex- ecutive agency; and an annual statement (beginning Decem- ber 31, 1983) be submitted by the head of each executive agency to the President and the Congress. At the Adminis- trator's request, the OIG con- ducted an independent evalua- tion to determine whether the Agency evaluated its internal accounting and administrative systems in accordance with the policies and standards of OMB Circular A-123 and the Act. We Found That Overall, the Agency's process to evaluate its system of inter- nal accounting and administra- tive controls was developed and conducted in a reasonable and prudent manner. How- ever, the Agency's process did not start until mid-August 1983, is still evolving, and additional work is needed to further develop and improve it. The Agency experienced a rapid turnover of officials and senior employees in early 1983, and generally did not take subsequent actions for several months after com- pleting vulnerability assess- ments in 1982. Because of these conditions, the Agency lost momentum, got signifi- cantly behind in implementing the Act, and had to rapidly plan, implement, and complete a very broad scope process in less than 4 months. Although the Agency made significant progress since August 1983 to revive its evaluation process, more needs to be done to make the overall process more efficient and effective. The Agency needs to implement the remaining phases of its planned process in 1984. 10 ------- We Recommended That The Administrator direct the Assistant Administrator for Ad- ministration and Resource Management to: Issue the Agency's order on internal control policies and standards; Establish an Agency-wide procedure to ensure that proc- ess results are completed in an effective and timely manner and properly documented; Ensure that performance agreements for appropriate levels of management are modified yearly to include internal control responsibilities; and Ensure that Agency em- ployees receive proper training and guidance to carry out their responsibilities. What Action Was Taken The audit report was issued to the Administrator on Decem- ber 15, 1983. Agency man- agement has generally agreed with the report and its recom- mendations. A formal re- sponse is due by April 15,1984. EPA Officials Were Not Adhering to Regulations for Reporting Noncompliance Problem EPA Officials were not adhering to regulations for reporting noncompliance with the effluent discharge standards of the Clean Water Act. What We Found Federal regulations require identification of facilities in noncompliance with water quality standards in Quarterly Noncompliance Reports (QNCR) until the noncom- pliance is resolved. An OIG re- view determined that an un- dated and unsigned EPA memorandum established as a national policy for reporting only "significant noncom- pliance" in the QNCR. This re- sulted in a 15 percent reduc- tion in the number of facilities listed in the QNCRs between June and December 1982 in Region 6 where the review was initially conducted. In addition, administrative orders were issued to further de- crease the reported instances of noncompliance by allowing interim deviations from water quality standards which match- ed or exceeded those of par- ticular facilities. Once an ad- ministrative order was issued for a facility, it was removed from the QNCR. These actions produced a false indication of success in obtaining com- pliance, since neither the memorandum nor the adminis- trative orders increased water quality or the true degree of compliance. What Action Was Taken A report prepared by the Office of Investigation detailing the results of the review was submitted to the Deputy Ad- ministrator on December 22, 1983. The Deputy Administra- tor agreed to take corrective action and provide a progress report by July, 1984. EPA's Permit Issuance Procedures Need Improvement To Ensure Safe Disposal of Hazardous Waste Problem Specifications and con- ditions of a permit issued by EPA for ocean incineration of hazardous waste were changed without public notice or proper authorization. We Found That Significant changes were made in the language of a re- search permit issued to Chem- ical Waste Management, Inc. and Ocean Combustion Ser- vice B.V. after the public notification period expired. One such change allowed the legal, although inadvertent, in- cineration of highly toxic dioxin laden waste not intended by the Agency. Agency officials could not explain who had made this change, or when and why it was made. We Recommended That The Former Assistant Adminis- trator for Water: Expeditiously issue formal permit procedures; and Develop and implement poli- cies to ensure that any dif- ferences between the public notice version and final version of the permit are documented and the rationale explained. What Action Was Taken In commenting on the draft audit report, the Director of the Office of Water Regula- tions and Standards indicated that the above recommenda- tions will be implemented. The audit report was issued to the Assistant Administrator for Water on December 20, 1983. A written report on actions taken on the recommendations is due by April 20, 1984. 11 ------- Construction Grants EP/4's wastewater treatment works construction grants pro- gram is the largest single pro- gram the Agency administers. Under the provisions of Public Law 92- 500, as amended, the Agency is authorized to make grants covering up to 75 or 85 percent of the eligible costs of constructing wastewater treat- ment facilities. Through Febru- ary 1984, $1.0 billion was obli- gated on 483 construction projects this fiscal year. The construction grants program represents $2.4 billion or 69 percent of EPA's total fiscal 1984 budget. As of February 29, 1984, EPA had 8,429 ac- tive construction grants representing $20.9 billion of Federal obligations. Bid Rigging and False Claims Chronic in Construction Projects Problem Many contractors are de- frauding the government on EPA construction projects. The OIG has identified a pat- tern of bid rigging on $16 million of contracts for wastewater treatment facili- ties and false claims of per- formance on $8 million of contracts for sewer rehabilitation. What We Found A team of OIG auditors and in- vestigators working with De- partment of Justice antitrust attorneys uncovered evidence that bids had been rigged on numereous Agency projects by as many as 20 different con- tractors on one job. Often the low bid was illegally set by the contractors at $1 million or more over actual engineering cost estimates. The Municipal and Industrial Pipe Services, Ltd. (MIPS) defrauded the United States, State and local governments of $8 million for sewer rehabilitation work, much of which was never done. The contractor's scheme involved not performing re- quired tests and repairs, dis- torting test results and fabricating progress reports over a 10 year period. Sewer pipes that were dug up show- ed that little or none of the claimed repairs had been per- formed. What Action Was Taken As a result of our in- vestigations of bid rigging, 17 persons or firms have been convicted. Details of actions taken this reporting period are described in Section III, Pro- secutive Actions, of this re- port. The Inspector General has given the detection and prevention of bid rigging his highest priority by committing resources to continue in- vestigative and prosecutive efforts. In addition, the OIG and De- partment of Justice jointly de- veloped and presented semi- nars, "Efforts to Prevent Bid Rigging," in each region and Headquarters. These seminars are discussed in Section IV, Fraud Prevention and Man- agement Improvements, of this report. As a result of our investiga- tion of Municipal and Industrial Pipe Services, Ltd., 4 persons have been convicted, fined, and sentenced. Additional de- tails concerning this case are described in Section III, Pro- secutive Actions, of this re- port. The OIG followed up on this case by holding a con- ference on fraud in sewer rehabilitation projects and de- veloping plans to appoint a national coordinator for ongoing detection and preven- tion of this type of fraud. 12 ------- Management And Design Deficiencies Undermine $25 Million Sewer Project AUDIT PROFILE Problem Poor planning, design, and construction prevented the Maiden, West Virginia, sew- age treatment system from meeting Federal pollution standards. Financial prob- lems of the grantee may jeopardize the entire project. We Found That Despite the grantee's (Maiden. West Virginia) claims for Federal funding totalling $22.7 million, pollution standards are not being met. Technical re- views identified three primary problem areas: Hydraulic overloading caused by uncontrolled pumping. Power outages and/or vol- tage fluctuations. Other design and construc- tion deficiencies. Failure by the financially trou- bled grantee to provide or obtain funds for corrective work may jeopardize the entire project, resulting in continuing pollution Furthermore. EPA is challenging claims totalling $3.3 million for ineligible con- struction and paving costs, and unneeded equipment. We Recommend That EPA provide assistance to enforce contract provisions and ensure compliance with pollution standards. The grantee explore all pos- sible sources of additional funding to make the necessary project corrections EPA disallow ineligible project costs What Action Was Taken The audit report was issued to the Regional Administrator. Region 3. on December 9, 1983 A response to the repon is due on April 9, 1984 Audited Costs Questioned Costs i I I 02 4 6 8 10 12 14 16 18 20 22 24 DOLLARS IN MILLIONS Grantee Claims $1.14 Million In Excessive Costs We Recommended That AUDIT PROFILE Audited Costs Problem Aiken County Public Service Authority, South Carolina, claimed ineligible costs totalling $1.14 million resulting from improperly administering and con- trolling three grants for a wastewater treatment sys- tem. We Found That The grantee maintained an ac- counting system which failed to provide cumulative totals for expenses or documentary sup- port for engineering and ad- ministrative fees which con- sistently exceeded allowable limits. In addition, the grantee transferred funds between grants and executed change orders to contracts without negotiating terms or specifica- tions. The audit report ques- tioned the eligibility of $1.14 million including: Duplicate billings of $168,000 from the consulting engineers for general supervi- sion salaries; Excessive project inspection and transportation costs of $131.000; and Architectural engineering fees of $247,000 for additional services which which were not required by contract terms In addition, the grantee has received approximately $149,000 in overpayments from EPA and claimed $25 million for defective equipment and faulty workmanship. EPA officials ensure that the grantee corrects and improves its accounting system prior to processing future awards or claims for payment. EPA officials initiate action to recover the Federal share of the questioned costs, including the overpayment to the gran- tee. EPA officials set aside $2.5 million pending correction of the equipment and work- manship deficiencies. What Action Was Taken The audit repon was issued to the Chief, Facilities Construc- tion Branch, Region 4, on November 30, 1983. The Re- gion had not provided its re- sponse to the report, which was due on March 30, 1984. because of ongoing litigation Questioned £t Setaside Costs 5 10 15 20 25 30 DOLLARS IN MILLIONS I 35 13 ------- AUDIT PROFILE Audited Costs I - ' Questioned Costs I I I .5 1 1.5 2 25 DOLLARS IN MILLIONS Grantee Claims $768,000 for Reservoir That Won't Hold Water Problem The Cedar City Corporation, Utah, claimed $768,000 for the design and construction of an unusable reservoir as part of a $2.8 million wastewater treatment facil- ity. We Found That The Cedar City wastewater treatment facility was planned. designed, and constructed to pump effluent from the water treatment facility into a stor- age reservoir. However, the system cannot be used as planned due to faulty design assumptions and other de- ficiencies. We found the following conditions: First, the reservoir would not retain water. The rate that water is absorbed into the floor of the reservoir is so high that the water cannot be stored. Apparently, the reservoir floor is not thick enough to reduce the absorption rate Second, the City determined that the utility costs of pumping effluent from the treatment facility to the reservoir in- creased five fold from the amount originally planned and was not cost beneficial. Third, farmers near the treatment facility are utilizing the effluent for irrigation purposes, there- fore, the water storage is not needed. As a result of these conditions we questioned $768,731 of costs claimed for the design, inspection, and construction of the reservoir We Recommended: That the Regional Administra- tor disallow $768,731 of costs associated with the faulty re- servoir We also recom- mended that the grantee repay $576,548 to EPA and $30,244 to the Four Corners Regional Commission. What Action Was Taken The audit report was issued to the Regional Administrator, Region 8. on November 14, 1983 As of March 31, 1984, we have not received a re- sponse to the report which was due on March 13, 1984 AUDIT PROFILE 5 1 1.5 2 DOLLARS IN MILLIONS Grantee Claims Ineligible Costs in Excess of $1 Million Including $867,000 Previously Disallowed Problem The Groveland Community Services District, Groveland, , g California, claimed ineligible ' costs totalling $1,054,182 for a wastewater construction grant including $867,000 that had been previously disallowed but remained on the grantees records for reimbursement. We Found That The grantee consistently claimed 100 percent of the costs associated with the plan- ning, designing, and construc- tion of an interceptor, wastewater treatment plant. and disposal facility, even though the California State Water Resources Control Board had advised the grantee of the allowable portion of costs under the grant. Of the $2,358,014 claimed, we ques- tioned $1,054,182 of ineligible costs including $182.822 for technical services and $867,712 for construction which had been previously dis- allowed by the State Board The grantee did not have the necessary accounting pro- cedures to assure deletion of ineligible costs from ex- penditure claims. We Recommended That The grantee be advised that $1,054,182 of costs ques- tioned are disallowed for Federal grant participation. The grantee be instructed to segregate costs in its account- ing system and assure that only eligible costs are included in its grant reimbursement claims. What Action Was Taken The grantee's representatives generally concurred with the draft audit results, except for $263,961 of the costs ques- tioned. The audit report was issued to the Regional Ad- ministrator, Region 9, on Jan- uary 31, 1984 A response to the report is due by May 30. 1984. 14 ------- Grantee Fails to Control Grant Receipts and Expenditures AUDIT PROFILE Problem The City of Santa Rosa, Cali- fornia, failed to control the use of EPA grant funds by claiming $702,000 for un- necessary acquisitions of land, construction beyond the scope of the approved wastewater treatment grant project, and income earned by investing grant funds. We Found That The grantee for the Laguna Effluent Disposal System claimed excessive and inelig- ible costs, during every stage of project constuction, totalling $702.000. The $702,000 costs questioned included: $302,000 claimed for the purchase of 54 acres of land m excess of the total amount approved; $185,000 for construction outside the scope of the approved project; and $169,000 of interest income earned by investing construc- tion costs claimed. In addition,the grantee was overpaid $97,713 of Federal funds. We Recommended That The Regional Administrator advise the grantee that the $702,000 of costs claimed are disallowed for Federal grant participation. What Action Was Taken In response to the draft audit report, the grantee did not concur with the $ 169.000 au- dit adjustment for interest in- come or comment on other costs questioned. The audit re- port was issued to the Region- al Administrator, Region 9, on January 30, 7984. A response to the audit report is due by May 30, 1984. Audited Costs Questioned Costs I I I 12345 DOLLARS IN MILLIONS Grantee Bills EPA More Than $700,000 In Excessive Costs While Ignoring Responsibility to Review Claims AUDIT PROFILE Problem Engineers maintaining the records and preparing claims for the Warwick Township Municipal Authority, Litiz, Pennsylvania, did not ade- quately review billings to identify excessive charges or screen claims to eliminate ineligible costs before sub- mitting them to the Author- ity and EPA for payment. We Found That The grantee delegated respon- sibility for grant administration to the architectual engineer, kept no records, did not moni- tor the work of the engineer, or perform an adequate review of costs claimed. Questioned costs totaling $732.000 were attributed to the following overclaimed and unallowable costs: $450,000 for paving work performed beyond the scope of the contracts; $60.000 for an ineligible right-of-way survey and sub- division plan; $130,000 for ineligible house sewer connections; and $28,000 for ineligible equip- ment. We Recommended That The grantee take a more ac- tive role in overseeing grant projects to avoid overclaims, and that the Region take appropriate action to recover the Federal share of excessive and ineligible costs. What Action Was Taken The grantee elected not to re- spond to the draft report. The final audit report was issued to the Regional Administrator, Region 3, on December 16. 1983 A response to the audit report is due by April 16, 1984 Audited Costs Questioned Costs 234567 DOLLARS IN MILLIONS 15 ------- AUDIT PROFILE Audited Costs Questioned Costs 1 234567 DOLLARS IN MILLIONS Grantee Bills EPA for Purchase of Excess Land Problem The Sacramento Regional County Sanitation District claimed $584,000 of inelig- ible costs for the purchase of land under a construction grant. We Found That The grantee purchased over 100 acres of land for $584.000, as a wetland mitiga- tion measure unnecessary to the treatment process. The District was required by Feder- al and State agencies to pro- vide land for the project. The cost of the land was included in project costs submitted to EPA for Federal funding. How- ever land costs are only eligi- ble for Federal funding when such land is an intergal part of the treatment process. State auditors reviewing the project questioned the costs of this land based on regulatory re- quirements. In reviewing the grant files, the auditors found that EPA Regional officials had stated "federal law. does not allow, as an eligible cost, the acquisition of land as a mitiga- tion measure." This position was subsequently reaffirmed by legal opinions from the Re- gional General Counsel. We Recommended That The Regional Administrator advise the grantee that ques- tioned costs totalling $597,226, including the total amount for the purchase of land, are disallowed for Feder- al grant participation. Also, that EPA should recover $316.371 of Federal funds from the grantee. What Action Was Taken The audit report was issued to the Regional Administrator, Region 9, on December 74, 7984 A response to the audit report is due by April 14, 1984 i AUDIT PROFILE Audited Costs Questioned Costs I 2.5 1 1.5 DOLLARS IN MILLIONS 3.5 4 Grantee Claims Costs For Treatment System That Will Not Be Used Problem The Wheaton Sanitary Dis- trict, Illinois, claimed the $325,000 cost of a sludge treatment system that will not be used. We Found That The grantee decided not to use a sludge treatment sys- tem due to severe odor prob- lems resulting from its use and the cost of keeping the system operable. The grantee is seeking to dispose of the equipment. We Recommend That The cost of the treatment sys- tem not be eligible for Federal funding. The grantee should be held responsible for failure of the system to operate as expected. What Action Was Taken The grantee has indicated in- tentions to dispose of the sys- tem and return 75 percent of the recovered costs to EPA. However, the $325,000 of cost remains questioned until this action is taken. The audit report was issued to the Regional Administrator, Region 5, on January 19, 1984. A response to the audit report is due by May 19, 1984. AUDIT PROFILE Audited Costs J Questioned Costs I I T I .5 1 1.5 2 DOLLARS IN MILLIONS Grantee Claims Costs for Dual Employment of Inspectors Problem The grantee claimed costs for two resident inspectors who were simultaneously employed and paid by both 25 the grantee and the gran- tee's consultant engineer. The inspections made by these inspectors were in- complete. We Fouhd That Although two individuals were working for the local gov- ernment, the consulting engi- neer responsible for providing resident inspection services on the Lafayette, Tennessee, EPA construction grant hired these individuals to provide full time resident inspection services. During the project, the engi- neer charged the city more than $110,000 for the services of these individuals. The dual employment prevented the resident inspectors from being at the job site on a continuous basis to observe the construc- tion, violating the resident in- spection contract that provided for full time resident inspec- tion. Specifically, the in- spectors did not: 16 ------- Maintain the minutes of progress meetings and job conferences; Verify and record the results of tests and inspections by other inspectors; Maintain orderly files of cor- respondence and proiect data at the job sites; Maintain detailed daily logs or diaries including references to hours of the day, weather conditions, principal visitors. daily activities, and observa- tions of testing procedures; Prepare reports of work progress, inspections, and tests; and Prepare a list of items that required correction or verify that the corrections had been made before final inspection We Recommended That Region 4 declare the S110,000 ineligible and take appropriate action to recover the Federal share of these expenditures. What Action Was Taken The audit report was issued to the Chief Facilities Construc- tion Branch, Region 4, on Jan- uary 9, 1984 A response to the audit report is due by May 9. 1984. Super-fund Program The Superfund Program was created by the Comprehensive Environmental Response Com- pensation and Liabilities Act of 1980 (CERCLA). The Act pro- vides a $1.6 billion trust fund for removal and remedial ac- tions, liability, compensation, cleanup, and emergency re- sponse for hazardous sub- stances released into the en- vironment and uncontrolled and abandoned waste sites. The parties responsible for the hazardous substances are li- able for cleaning up the site themselves or reimbusing the government to do it. States in which there is a release of hazardous materials may qualify for assistance from the Superfund by agreeing to pay 10 percent of the costs of remedial actions, or 50 percent if the source of the hazard was owned by the State or local government. Costs claimed by the State from Superfund must be clear- ly eligible and supported Extensive Overcharges Identified In Cleanup At Drum Recycling Facility Problem A half-million dollars in questionable billings fol- lowed IT Corporation's cleanup of a pollution emergency. The contractor's inadequate accounting sys- tem permitted billings to EPA for ineligible items and made it difficult to identify the actual cost incurred for individual projects. We Found That EPA awarded $1.3 million in contracts for emergency cleanup following a fire at the General Disposal Company paint and chemical recycling facility in Sante Fe Springs, California. The contractor, IT Corporation, did not maintain an adequate accounting sys- tem for the identification of in- dividual project costs. This re- sulted in the contractor billing EPA $163,000 for ineligible costs including: Full cost for items on which the contractor received vendor discounts; Full use rather than standby equipment rates; Labor charges for normal commuting time; Charges in excess of actual material and equipment rental costs; and Duplicate payments to ven- dors Other questionable billings in- cluded (1) $291,000 for a non- competative. unapproved, un- written subcontract; and (2) $50,000 for unsupported mate- rial handling and other charges. We Recommend That EPA disallow $163,000 of ineligible costs. EPA review the $341,000 of questionable billings for eligibil- ity. EPA advise the IT Corpora- tion that its accounting system is inadequate for EPA con- tracts. What Action Was Taken The audit report was issued to the Procurement Contracts Management Division, on November 10, 1983 A response to the audit report was due on March 9. 1984. We had not received a re- sponse to the report as of March 31, 1984. AUDIT PROFILE Audited Costs Questioned Costs I .4 .6 .8 DOLLARS IN MILLIONS I 1 2 1.4 ------- Other Grants and Contracts These are independent re- views of the records and per- formance of individual gran- tees and contractors made in accordance with the U.S. General Accounting Office standards for audit of gov- ernmental organizations, pro- grams, activities, and func- tions. These audits are con- ducted to determine the accuracy of financial state- ments and the degree of com- pliance with statutes, regula- tions, and terms of the agree- ments under which Federal funds are made available. AUDIT PROFILE Audited Costs Questioned Costs I 05 I .15 I 25 .1 .15 .2 .25 .3 DOLLARS IN MILLIONS Atlanta University Misuses $222,000 of Training Grants Problem Grants totalling $222,000 with Atlanta University Cen- ter, Inc., for student training in water pollution control 35 were not adequately man- aged nor used for the in- tended purposes. We Found That Federal grants are awarded to train undergraduates in a water pollution control design engineering program. We questioned all $222,000 of costs claimed, as the grantee failed to comply with program requirements for: student en- rollments; controls to ensure that the funds were used by the proper students and for eli- gible expenses; and documen- tation and support for grant computations and ex- penditures Grants were not properly managed and grant objectives were not met as evidenced by the following: Students participating in the program did not take the re- quired courses in the water quality program. Supporting documentation for costs claimed, such as time cards, invoices, cancelled checks, etc., were neither maintained nor available for re- view. Reimbursement claims ex- ceeded project record ex- penses Indirect costs were claimed without obtaining an approved indirect cost rate-. We Recommended That The EPA Grants Administration Division recover $222,000 from the Atlanta University Center Inc., and the Atlanta University make improvements to ensure future compliance with EPA regulations and grant conditions including: Establishment of a policy requiring the maintenance of records pertaining to Federally- funded projects; Development and im- plementation of procedures ensuring that students are en- rolled in the proper courses for program participation; and Development and im- plementation of procedures and controls to ensure com- pliance with grant conditions. What Action Was Taken The audit report was issued to the Chief, Grants Administra- tion Division on January 16, 1984. A response to the audit report is due by May 76, 1984. 18 ------- Section II - Audit Resolution As required by the Inspector General Act, this section de- scribes significant problems and recommendations iden- tified in previous Semi- annual Reports which re- main unresolved. Also, as re- quired by the Supplemental Appropriations and Rescis- sion Acts of 1980 and 1981, this section includes a sum- mary of unresolved audits and a list of officials respon- sible for resolving audit find- ings over 6 months old. EPA officials continued ex- pending considerable efforts to resolve audit reports Corre- sponding to all Regional Admi- nistrators and Headquarters officials responsible for audit resolution, EPA's follow-up official and the Inspector General reemphasized the need for timely audit resolu- tion. The Deputy Administrator has also expressed a com- mitment to improve audit reso- lution by scheduling it as a ma- jor topic at future meetings with top Agency officials Despite considerable effort by EPA officials and DIG staff to resolve audit reports, im- provements are needed to assure that Agency responses to audit reports are timely During this period EPA man- agement resolved 878 audits and sustained $17.8 million of questioned costs including $164 million for recovery and $1.4 million of cost reductions. Also, EPA recovered $13.2 mil- lion from audit resolutions of current and prior periods, in- cluding $2.9 million in cash and $10.3 million of offsets against billings. Follow-Up on Audit Findings While the inventory of unresolved audits declined from 598 to 563 during this 6-month period, the number of unresolved audit reports over 6 months old continued to increase dramatically. 271 3/83 9/83 3/84 Unresolved Audits Over 6 Months Old As of the End of the 3 Prior Periods The Agency's increased emphasis on audit resolution has suc- cessfully stimulated efforts to resolve audit reports Since March 31, 1984, the number of unresolved audits over 6 months has decreased significantly. If this effort continues during the next reporting period, the trend of unresolved audits over 6-months old should be reversed ------- Action Officials for Audit Reports Outstanding more than 6 Months as of March 31, 1984 Action Official Number of No or Responses Reports Invalid in Process1 Responses EPA Contracts Director, Procurement and 20 20 Contracts Management Divi- sion EPA Grants Programs Director, Grants Administra- 44 tion Division Assistant Administrator for 1 I Solid Waste and Emergency Response Regional Administrator 41 41 Region 1 Regional Administrator 58 57 I Region 2 Regional Administrator 38 21 17 Region 3 Regional Administrator 33 32 1 Region 4 Regional Administrator 11 8 3 Region 5 Regional Administrator 44 Region 6 Regional Administrator 55 Region 7 Regional Administrator II 8 3 Region 8 Regional Administrator 43 24 19 Region 9 Regional Administrator 2 2 Region 10 . Grand Total 27! 225 46 'The numbers in this column represent reports responses (1) DIG has received and is evaluating; (2) to be referred to Audit Resolution Board; and (3) in litigation or requiring special study. EPA Allows $9 Million Of Costs Without Consulting OIG Without consulting the Office of Inspector General (OIG), Re- gion 5 officials issued a final determination in October 1983, accepting more than $9 million of costs questioned in an OIG report. Although our office immediately requested an explanation for the Region's determinations, Region 5 did not send us any detailed rationale until early April 1984, almost 6 months later. Even then the response did not pro- vide, in our opinion, necessary evidence to show that our findings were incorrect. The Northeast Ohio Regional Sewer District (NEORSD), re- ceived an EPA grant to build a regional sewer interceptor, but failed to hold a contractor li- able when the contractor's im- proper construction techniques resulted in a tunnel collapse delaying project completion. As a result of the collapse, the grantee requested Federal funding of $800,000 of costs which were the contractor's responsibility and five other unnecessary change orders totalling $11.2 million. Our preliminary results in- dicated that these claims were not acceptable. The OIG staff with the assistance of the Bureau of Mines and repre- sentatives of the Office of General Counsel performed a thorough engineering evalua- tion of the construction prob- lem and a legal analysis of the contract provisions and con- cluded that the collapse was due to the contractor's im- proper construction techniques for which it should have been held accountable. NEORSD should have denied the con- tractor's claim and directed it to proceed with performance. Had the contractor failed to proceed, NEORSD could have filed for immediate termina- tion of the contract by default. Project completion could then have been made with a new contractor and any increased costs could have been reco- vered from the prior contractor. Because, in our opinion, the contractor was at fault, we found the $800,000 change order to rehabilitate the col- lapsed area and the five sub- sequent change orders resulting from the collapse to be ineligible for Federal pay- ment. On April 30, 1983, we issued an audit report which questioned the $9 million Federal share of these costs. On October 14, 1983, Re- gion 5 officials, without con- sultation with OIG staff who performed the audit, issued a final determination which accepted all of the costs which had been questioned. Our office followed up to obtain an explanation in Octo- ber 1983. December 1983. and February 1984. It was not until April 2, 1984, almost 6 months after the decision was made, that we were furnished a detailed explanation of the Region's decision. This re- sponse did not provide any technical information which would cause us to change our position. Instead, it focused on the legal aspects of what con- stitutes differing site con- ditions. In this regard, counsel assisting the Region and the OIG disagreed significantly in their interpretations. While the disposition of the above was not satisfactory to the OIG, actions have been taken to preclude such circum- stances in the future. Agree- ment has been reacned that the EPA Order on Audit Reso- lution will be revised to require consultation between action officials and the OIG on all ma- jor audit reports which ques- tion more than $100,000. If the Action official and the OIG cannot agree, final determina- tion will be withheld until the matter has been referred to 20 ------- Headquarters for ultimate deci- sion by the Audit Resolution Board. In our opinion, this pro- cedure assures that appropri- ate decisions are made on au- dit findings and recommenda- tions. Previously Reported Items - Corrective Actions Not Taken As required by the Inspector General Act, the following lists the significant problems identi- fied in previous OIG Semi- annual reports which have not been fully resolved by Agency officials as of March 31, 1984. There were 37 reports in- cluded in all previous Semi- annual Reports, 23 have been resolved, the 14 remaining un- resolved are listed below. Report Number 30236 30232 30324 30353 20929 20473 10937 11556 11490 30672 31256 31104 31608 31220 Grantee/Contractor Pierce County, Washington Huntington, Utah Jet Line Services, Inc. Peabody Clean Industry Hagerstown, Maryland Washington Suburban Sanitary Commission, Maryland West Windsor, New Jersey Washington Suburban Sanitary Commission District of Columbia Massachusetts Department of Environmental Quality Engineer- ing EPA Region IX Survey of Obliga- tions Arbuckle Public Service District, Minden West Virginia Miami-Dade County Water and Sewage Authority City of Delano, California Issued Date 12/23/82 11/30/82 12/30/82 01/21/83 05/10/82 02/11/82 05/06/81 09/11/81 08/28/81 02/28/83 06/30/83 05/25/83 08/18/83 06/13/83 Status* 2 1 1 5 3 4 4 4 3 1 2 2 1 1 "Explanation of Status Codes 1. No response 2. Response being evaluated 3. Issue being referred to Audits Resolution Board 4. Resolution delayed pending required studies or litigation 5. Incomplete Response 21 ------- Section III - Prosecutive Actions The following is a summary of investigative activities during this reporting period. These actions include crimi- nal matters investigated which resulted in pro- secutions and convictions, and investigations of viola- tions of Agency regulations and policies. Summary of Investigative Case Activity During this period, we con- centrated much of our effort on closing outstanding in- vestigation cases. We closed 89 cases, a significantly great- er number than in previous periods, reducing our inventory of open cases by 40 (18%). Pending Cases as of September 30. 1983 220 New Cases Opened This Period Cases Closed This Period Pending Cases as of March 31. 1984 49 89 180 FRAUD (FALSE CLAIMS ft STATEMENTS) 83 CASES ANTITRUST 22 CASES ADMINISTRATION 12 CASES THEFT OR ABUSE OF GOVERNMENT PROPERTY 28 CASES OTHER 4 CASES CONFLICT OF INTEREST 31 CASES Profile of Pending Active Cases By Category of Investigation WATER 106 CASES AIR 7 CASES TOXICS 7 CASES ADMINISTRATION 23 CASES RESEARCH 18 CASES SOLID WASTE 9 CASES OTHER 10 CASES Profile of Pending Active Cases By EPA Office Unit Investigative Cases Referred For Prosecutive Action During this period, we referred 23 cases to the U.S. De- partment of Justice for pro- secutive consideration. Cases declined for prosecutive action are returned to the Agency for administrative action. Cases Referred and Accepted for Prosecution 8 Cases Referred and Declined for Prosecution 15 Results of Prosecutive Actions Investigative efforts resulted in the following court actions during this reporting period in- cluding those from our bid rigging and sewer rehabilita- tion cases. Indictments 7 Convictions 9 Fines and Recoveries $538.633 Years Imprisonment 9 Years Probation 15 Personnel and Administrative Actions Taken Against EPA Employees During this reporting period 14 administrative actions were taken against EPA employees resulting from our in- vestigations of violations of Agency policies or regulations. Suspensions 2 Resignation During Proposed Action 1 Reprimands 5 Repayment of Funds 6 22 ------- Description of Selected Prosecutive Actions A brief description of some of the matters referred to pro- secutive authorities or pro- secutive actions taken during this reporting period follows. Some of these actions re- sulted from investigations in- itiated prior to October 1, 1983. Conspiracy, False Statements, Mail Fraud David Wirt, his wife Judith, and their son, Gordon, owners and executive officers of Mu- nicipal and Industrial Pipe Ser- vices (MIPS), pled guilty on January 13, 1984, to de- frauding the government on sewer projects. David was sentenced to 8 years in prison. Gordon and Judith were given prison terms of 33 months and 6 months respectively. Each was fined $10,000. The 47 count indictment charged the Wirts with a 10 year, $8 mil- lion scheme, to defraud the Federal government on sewer maintenance projects by failing to perform tests and repairs that they were paid to perform while they distorted test re- sults and fabricated progress reports. The scheme involved several states and three for- eign countries. The MIPS investigation be- gan in October 1981, after two former MIPS employees re- ported to city officials in Marietta, Georgia, that David Wirt was defrauding the Federal government on an EPA sewer rehabilitation project by deliberately pinching test hoses and failing to use grout in sealing sewer lines. At the time they were hired, Wirt had told the employees that the sewer rehabilitation busi- ness "was just a scam anyway." When evidence showed that about half of the company's contracts were with U.S. mili- tary installations, including several foreign bases, the In- spector General's office re- quested assistance from the Defense Criminal Investigative Service of the Department of Defense. Rehabilitating a sewer pipe involves cleaning by high- pressure water jet, followed by television inspection with remote cameras drawn through the pipe from one manhole to the next by cable. Each joint is air-tested for leaks, and leaking joints are sealed with two liquid com- pounds that, when combined, gel into a grout substance. Televising, testing, and sealing are accomplished from inside a van parked near one of the manholes. City inspectors monitor these procedures while sitting beside the TV operator in the van. Wirt claimed to have sealed defective sewer pipe joints with grout when none was ap- plied by installing hidden switches in company's televi- sion inspection trucks to re- route grout back into the truck tank while the meter registerd it as going to seal sewer pipe joints. Wirt manipulated his con- tacts whenever possible to provide for payment according to the number of pipe joints found to be defective. His main effort thereafter was to thwart inspection effortsby keeping inspectors off the trucks, and "blitzing" job sites with more TV trucks and crews than there were in- spectors to monitor them. He spread out his trucks and crews as far as possible over the project, keeping inspectors in travel status between units, faking equipment breakdowns when inspectors approached a unit, and devising strategies to make the inspectors extremely uncomfortable in the TV trucks. When these and other tac- tics failed, repair crews and Wirt himself at times resorted to intimidation of the in- spectors, sometimes threatening violence, physical injury or lawsuits. To corroborate the testi- mony of former employees, sewer pipes were dug up at Air Force bases in Mississippi and Texas and at an EPA- funded project in Moultrie, Georgia. Analysis of pipe sam- ples at EPA's National Enforce- ment Investigations Center in Denver showed that in places where grout was said to have been applied, there was actually little or no grout at all. Bid Rigging - The Prosecutions Continue As described in our last Semi- annual Report and in Section I, Significant Problem Abuses and Recommendations of this report, the OIG is continuing its investigation of evidence that EPA contractors are rigging bids on wastewater treatment facilities. Beginning with contractors who pre- viously had been indicted and convicted under Department of Transportation programs, our staff analyzed numerous construction contracts in North Carolina, South Carolina, and Tennessee and concluded that a pattern indicative of bid rigging existed. Investigations are being conducted through- out Region 4 and will be ex- panded to other regions. As of March 31, 1984, a to- tal of 17 guilty pleas were en- tered. During the period covered by this report, five in- dividuals or entities pled guilty to having violated Section 1 of the Sherman Act (15 USC 1) and received sentences. On November 9, 1983, Den- nis L. Moorehead, President, Carolina Pipeline Contractors, Inc., Graniteville, South Caro- lina, pled guilty to a charge that he and co-conspirators 23 ------- Carolina Pipeline Contractors. Inc., Graniteville, South Caro- lina, pled guilty to a charge that he and co-conspirators submitted collusive, noncom- petitive bids to the Town of Winnsboro, South Carolina. The collusive bids were sub- mitted to have one of the con- spirators receive an award of $1,689,820 to perform utility construction in connection with the EPA-funded utility construction project known as Sewer Systems Improvements. Moorehead was sentenced to 90 days imprisonment. On March 2, 1984, CFW Construction Co., Inc., pled guilty to a charge that it and co-conspirators submitted col- lusive, noncompetitive bids to Chester. South Carolina, in order that one of the con- spirators would receive an award of $2,077,651 to work on an EPA-funded sewer project. CFW Construction Company was fined $100,000. On December 21, 1983, John B. Wilson, Vice-President and General Manager of McDowell Construction Co., Chattanooga, Tennessee, pled guilty to a charge that he and co-conspirators submitted non- competitive bids on a project involving Hixson Interceptor Sewer System, Chattanooga Interceptor Sewer System. The collusive bids were sub- mitted so that one of the con- spirators would receive an award of $5,939,055 to work on the EPA-funded project. Wilson was sentenced to 30 months imprisonment which was suspended with the ex- ception of four months. He was fined $25,000 and ordered to perform 100 hours of community service. On December 2, 1983, Pre- ston Carroll Co., Inc., pled guil- ty to a charge that it and co- conspirators submitted col- lusive, noncompetitive bids on a project involving the Central Wastewater Treatment Plant, Conway, South Carolina. The collusive bids were submitted so that one of the conspirators would receive an award of $1,865,505 to work on the EPA-funded project. Preston Carroll Company, Inc., was fined $125,000. In addition, Frank A. Shepard, Executive Vice President of Preston Car- roll Company, was convicted of bid rigging and sentenced on November 4, 1983, to 120 days in prison. On March 12, 1984, W. E. Boyette and his company, Watson Electric Company, Wil- son, North Carolina, pled guilty to charges that they and co- conspirators submitted col- lusive, non-competitive bids on an electrical contract at a wastewater treatment facility in Orange County, South Caro- lina. The collusive bids were submitted so that an artificially high contract award of $626,300 would be made for an EPA-funded project. Boyette was sentenced to 7'/2 months imprisonment. Watson Electric Company was fined $248,000. Perjury, False Statements A former EPA consultant, David B. Twedell, was sent- enced on January 23, 1984, to I year in prison after pleading guilty to fabricating his aca- demic credentials. As a geologist for JRB Associates, McLean, Virgina, Twedell su- pervised test drillings at Love Canal and other hazardous waste sites and appeared in court as an expert witness for the government while working on a number of major EPA projects between December 1979 and November 1981. He claimed to have a Ph.D and a B.S. in geology from the Uni- versity of Houston where, in fact, he was dismissed for academic failure within only a few semesters. 24 ------- Description of Selected Administrative Actions Taken Against EPA Employees The Senate Report of the Sup- plemental Appropriations and Rescission Bill stated that appropriate administrative ac- tion is expected to be taken in cases where employees have acted improperly. Selected administrative ac- tions taken against EPA em- ployees during the semiannual reporting period in connection with audits and investigations are shown below. Offer of Gratuity False Claims Fred M. Newman, an officer of Energy Resourcs Co., Inc. was debarred from doing business with EPA for three years on January 3, 1984, for violating a settlement agreement entered into as a result of a previous violation. Newman pled guilty to one count of offering a gratuity to an EPA employee in appreciation of the employees evaluation of a $3 million con- tract proposal by Newman's firm. As a result of these charges, Newman entered into a settlement agreement on April 15, 1983, to exclude him- self from certain procurement activities with all Federal ex- ecutive branch agencies and to not have contact with any Federal government pro- curement personnel. Sub- sequently, Newman violated the agreement by partici- pating in the procurement process on a Department of Interior contract during the summer of 1983. An auditor resigned on March 8, 1984, during a pending re- moval action, and reimbursed EPA $652 for submitting false travel claims over a two year period. The OIG investigation showed that the employee submitted bogus receipts with his travel vouchers and over- stated his actual expenses by $652. The overstated ex- penses included inflated and fabricated costs for meals and limousine trips. The employee created limousine receipts from blank receipt forms. 25 ------- Section IV - Fraud Prevention and Management Improvements This section describes sever- al activities of the Office of Inspector General to pro- mote economy and efficien- cy and to prevent and detect fraud, waste, and abuse in the administration of EPA programs and operations. This section includes in- formation required by sta- tute, recommended by Sen- ate Report, or as deemed appropriate by the Inspector General. Review of Proposed Legislation and Regulations We reviewed 28 Agency directives and 6 pieces of pro- posed legislation for the period ended March 31, 1984. The most significant items reviewed are summarized as follows: OMB Draft Guidelines for Legislation Involving Federal Criminal Law Enforcement Activities We questioned the need for the circular and whether the preclearance criteria would be inconsistent with the spirit and letter of the Inspector General Act of 1978. We believe that those guide- lines would undermine the in- dependence of the DIG in per- forming its mandated function. We also think it is unusual for a particular class of legisla- tion to be the subject of an OMB Circular, especially since the Department of Justice has the expertise in this area. Additionally, we question those provisions of the circular addressing authorities which the Agency or the Inspectors General already have. S.1510 "Uniform Single Audit Act of 1983" We believe the definition of "entity" and "Federal assis- tance" as stated in Sections 7502(1) and 7502(2) are un- clear. The Congress may have intended the definition of ent- ity in these sections to include quasigovernmental entities not included in the standard defini- tion of local government. How- ever, because this is not spe- cifically stated, the definition could include private sector commercial contractors. OMB Circular A-102, Attach- ment P, limits single audits to State and local govern- ments and Indian tribal governments that receive Federal assis- tance. We do not believe single audits of private com- mercial contractors would pro- vide adequate audit coverage to meet the Federal gov- ernments needs. We are very concerned about the extent of audit coverage for EPA's wastewater treatment con- struction grants program which involves large numbers of commercial companies having contracts with State and local governments funded under Federal assistance pro- grams. We believe that audit coverage of these contractors for compliance with appropri- ate regulations and contract re- quirements can only be ade- quately provided through au- dits conducted by Government auditors and will not be satis- fied through single audits. To avoid further confusion regarding these definitions, the intent of the Congress should be made clear by specifically stating whether or not single audits are required for private commercial contractors. We recommend that these entities be specifically excluded from audit under this legislation. The definition of "cognizant agency" appears to restrict in- volvement by Federal audit or- ganizations and does not pro- vide for Federal oversight of the basic audit work per- formed during the single audit by a grantee's independent au- ditors. We believe the defini- tion of cognizant audit agency, contained in OMB Circular A- 102, Attachment P, should be substituted in this section. RCRA Confidential Business Information Security Manual The Inspector General Act of 1978 gives the OIG broad re- sponsibilites to promote econ- omy and efficiency and detect fraud and abuse in Agency programs and operations. The OIG has the concurrent re- sponsibility of performing in- dependent investigations of wrongful disclosures of CBI and audits of the adequacy of security controls. We suggest the first sentence of Chapter II, Part C be changed to read: "The OIG is responsible for oversight of RCRA CBI op- erations and for conducting au- dits and investigations as it de- ems appropriate." Review of Contract Management Manual, Chapters 1 through 9 We see significant potential vulnerabilities in subparagraph 56(7) of this Manual. This subparagraph permits one program office to use its funds (account number) to fund another program office's work assignment when the latter office has insufficient funds to cover costs billed. The difficulty could arise when it is time to make final adjustment as required by 31 U.S.C 1534. This statute, permits charging one appropriation for the benefit of another, but requires that a final adjustment be made to both accounts by the close of the fiscal year. In our opinion, these adjustments are unnecessary if the program offices adequately monitor and are held fully accountable for each work assignment. If a program office does not have sufficient funds, it should (1) not issue a new work order; (2) stop work on a work order alreadly issued; or (3) request additional funds from the Office of the Comptroller. In conclusion, we believe with adequate contract management up front, there is no need to manipulate the financial aspects of the contract. Therefore, we recommend that this part be deleted, and that proper contract management be stressed instead. 26 ------- Suspension and Debarment Activities EPA's policy is to do business only with contractors, gran- tees, and persons who are re- sponsible, honest, and who comply with applicable rules and regulations. EPA enforces this policy by suspending or debarring any organization or person for acting improperly, having a history of substan- dard work or willfully failing to perform on EPA or other Federally funded activities. Suspensions and debarments deny participation in Agency programs and activities to those who represent a risk of abuse to the Government. The EPA Grants Administra- tion Division operates the sus- pension and debarment pro- gram in EPA with OIG pro- viding statutory oversight. Acting by Agency request or by its own authority, the OIG conducts audits, in- vestigations, and engineering studies, obtains documents and seeks prosecutive actions necessary to determine whether there is a cause for a debarment. A summary of sus- pension and debarment activi- ties and results follows: Summary of Suspension and Debarment Activities October 1, 1983 - March 31,1984 Requests for Investigation Cases Completed Debarments Voluntary Exclusions Other Settlements Dismissed Cases Closed After Investigation Total Active Cases Under OIG Investigation Under Review by Pro- gram Officials or OGC Proposed for Debarment Suspended or Suspended/Proposed for Debarment Other Pending Total 26 15 7 17 0 15 54 36 7 17 2 68 Seminars to Prevent Bid Rigging Bid rigging by contractors doing business with the Feder- al Government is one of the most flagrant, chronic, and concealable forms of fraud against the government. Bid rigging is the preconceived agreement between con- tractors to illegally influence the awarding or pricing of competitively bid contracts. To improve the ability of government officials' to detect and prevent bid rigging, EPA's Office of Inspector General worked jointly with the Anti- trust Division of the U.S. De- partment of Justice in de- veloping and presenting semi- nars titled "Efforts to Prevent Bid Rigging." These seminars provide participants with in- formation about bid rigging, advice on techniques for de- tecting and preventing bid rigging schemes, case studies, and answers to specific ques- tions about antitrust activities. They also provide a vehicle for future cooperative efforts be- tween the EPA OIG, State governments, and other Feder- al agencies. Topics covered in the half day seminars include: Antitrust Division, responsibi- lities; Criminal and civil provisions of the Sherman Antitrust Act; Programs susceptible to antitrust practices; and Detecting bid rigging, price fixing, and other types of collu- sion. Copies of the Department of Justice publication "Think Anti- trust" are provided to each participant. "Efforts to Prevent Bid Rigging." was presented to 417 participants including 149 non-EPA employees in all ten Federal regions. Non-EPA em- ployee participants included members of State legislatures, State agency officials. State Offices of Inspector General and Attorney General, and offi- cials from other Federal agen- cies. 27 ------- Committee on Fraud, Waste, and Mismanagement Initiated at EPA A number of events both with- in and outside the Agency, illustrate a commitment to in- crease the emphasis on eliminating fraud, waste, and mismanagement in the ad- ministration of Federal pro- grams and operations. The President, Congress, and top management in the Executive Branch have taken steps to assure that this commitment is met. Government-wide initiatives such as Reform 88 and the es- tablishment of a Prevention Committee by the President's Council on Integrity and Effi- ciency (PCIE) serve to under- score this current emphasis on prevention activities. Establishment of the CFWM The Administrator and Deputy Administrator have expressed their commitment for in- creasing coordination and par- ticipation in the Agency's fraud prevention efforts by establish- ing an Agency Committee on Fraud, Waste, and Mis- management. This committee will advise the Administrator on policy matters associated with minimizing occurrences of fraud, waste, and mis- management in EPA programs and activities. Close coordination between the Inspector General and those responsible for program design and execution is re- quired to maximize the use of our resources in achieving the Agency's mission. The Com- mittee consists of representa- tives from all principal offices in EPA including Regional Administrators. The Inspector General, as Chairperson, coor- dinates and guides Committee activities. Further, the DIG pro- vides technical assistance and support to the Committee in undertaking its various projects. Functions of the Committee The CFWM will recommend appropriate action relating to policy, planning, implementa- tion, and resource require- ments necessary to curb fraud, waste, and mis- management. More specifical- ly, the Committee will under- take projects and provide rec- ommendations on matters concerning: (1) increasing EPA employees' awareness of their responsibilities to detect and prevent fraud, waste, and mis- management in the Agency's programs and activities; (2) de- veloping policies and goals and implementing strategies that minimize the opportunities for the occurrence of fraud, waste, and mismanagement; (3) identifying the areas con- sidered to be sensitive to fraud, waste, and mis- management; (4) identifying the management and internal controls best suited for de- tecting and preventing fraud; and (5) developing other fraud related programs as necessary. AcciC+C Tne Federal Managers' Finan- **ddldl9 cial Integrity Act requires that the internal accounting and ad- ministrative controls of each CD A ||-| r . Implementing theExecutive Agency be Managers' Integrity Act _. . - tablished in accordance with Financial standards prescribed by the Comptroller General and that OMB establish guidelines by which the Agencies can eval- uate their systems of internal control. The Act further re- quires annual statements (beginning December 31, 1 983), from the head of each Executive Agency to the President and Congress de- scribing the Agency's level of compliance, identifying materi- al weaknesses, and outlining corrective plans. OMB revised Circular A-1 23 on August 16, 1983, to include the new re- quirements contained in the Act. To help implement the re- quirements of the Act, the Ad- ministrator requested the OIG to provide the Agency with technical assistance and to conduct an independent evaluation of the Agency's progress in implementing the Act. The Administrator's Requests are Fulfilled By the OIG 1. The Office of Audit evalu- ated the Agency's overall im- plementation of the -Act. (See Section I.) 2. The Office of Management and Technical Assessment provided guidance and tech- nical assistance to the Agency in the following activities: Developing guidelines and material used to train Agency staff in the requirements of internal control reviews; Briefing top management officials as to their responsibili- ties and requirements for fulfilling the requirements of the Act; Monitoring the performance of teams performing the inter- nal control reviews and evaluating the internal control problems identified by Agency staff; Determining the material weaknesses identified during the internal control review process and preparing the Administrator's assurance letter to the President and Congress; Drafting Agency plans for continuing the internal control review process in Fiscal 1984; and Assuring that the OIG com- pleted its portion of the inter- nal control review. 28 ------- Employee and Public Awareness Activities One of the most powerful ways of achieving the objec- tives of the OIG is to regularly inform EPA employees, gran- tees and firms participating in EPA programs, and the public about the OIG and to make them aware of their responsi- bility to prevent, detect, and report instances of fraud, waste, and abuse. Such a pro- gram was initiated during this semiannual reporting period using a variety of mediums tar- geted to reach specific seg- ments of the EPA concerned population. IG Highlights. This digest ver- sion of the Inspector General Semiannual Report to Con- gress was produced and dis- tributed to all EPA employees for the first time in February 1984. IG Highlights provides information about the activities of the OIG, significant prob- lems, recommendations, and abuses reported to EPA man- agement and Congress, and a listing of telephone numbers of the EPA OIG Hotline and each of the Divisional In- spectors General. EPA Video Monitors. EPA op- erates a closed circuit video channel to inform employees of current events and impor- tant information. The OIG has begun submitting video an- nouncements for transmission over this channel to inform employees about the OIG Hot- line. Publications. To inform dif- ferent groups about OIG op- erations, we have been working with the EPA Office of Public Affairs to publish arti- cles in several different EPA publications. During this reporting period, articles con- cerning the OIG appeared in the EPA Times, the employee newspaper, the EPA Man- agement Memo for EPA man- agers, and the EPA Journal. State Agencies. State agen cies act as grantees or local administrators for many EPA programs, grants, and projects. These groups often are in the best position to detect, pre- vent, and report fraud, waste or abuse. This reporting period we developed mailing lists of these agencies and solicited their help by mailing them literature about the EPA OIG and encouraging the use of the OIG Hotline to report any wrongdoing. Hotline Activities During this reporting period the OIG increased its publicity of the EPA OIG hotline by emphasizing to employees, grantees, and the public their responsibility to detect, pre- vent, and report instances of fraud, waste, or mismanage- ment. The OIG hotline center re- ceived 51 new complaints, processed 141 complaints, and closed 71 complaints during the reporting period. Of the 71 cases closed, 67 were not valid and did not require action while 4 cases resulted in environmental or administra- tive corrective action. The following chart shows the sources of complaints re- ceived this period. 39% EPA EMPLOYEES 20 CASES 59% PUBLIC 30 CASES Sources of Hotline Cases Opened During This Period New Cases = 51 29 ------- Task Force Identifies Future Detection Priorities The Office of Inspector Gener- al began focusing its future efforts and plans by forming a task force to examine tech- niques and methods for de- tecting fraud, waste, and mis- management in Agency pro- grams. Members of the task force, representing each Assis- tant Inspector General and Di- visional Inspector General, identified and ranked ten potentially vulnerable areas and recommended approaches for reviewing those areas. Identification and ranking of vulnerable areas was based upon seven characteristics of susceptibility to fraud and key program issues and offices known to need DIG review. The task force helped chart the future direction of DIG efforts by serving as a forum for creative ideas and by pooling knowledge of ways for preventing and detecting fraud, waste, and mis- management. Memorandum of Understanding During this semiannual reporting period the Office of Inspector General entered into an agreement with the EPA Office of General Counsel. By a Memorandum of Under- standing dated November 10, 1984, the Inspector General Division was established with- in the Office of General Coun- sel to provide legal services to the Office of Inspector General in conjunction with audits and investigations. This includes advice on the issuance of sub- poenas, the drafting, inter- preting and application of sta- tutes, regulations and policies, reports to Congress, and Freedom of Information Act re- quests. The Memorandum of Understanding further affirms the independent status of the Inspector General by formalizing its relationships with the Office of General Counsel. Automatic Data Processing Unit Established inOIG The ADP Audit Unit was es- tablished this semiannual reporting period in the OIG to provide Agency management the assurance that EPA ADP resources are used in an effi- cient, effective, manner. EPA is a large user of ADP technol- ogy and is committed to in- creasing its use to help carry out many of its programs. The ADP Audit Unit also provides expert technical assistance on using the computer (micro- computers and large main- frames) as an audit and in- vestigative tool and provides auditors and investigators the capability to examine data on large computer files. During this semiannual reporting period, the ADP Au- dits Unit began assisting major investigative effort to identify potential bid rigging by EPA contractors. An integral part of this effort is the use of micro- computers to look for key bid rigging indicators. The ADP Audits Unit is also evaluating the adequacy of internal con- trols built into EPA's auto- mated payroll system, and is also assisting in an audit of the Chemical Information System. With the addition of this unit, the Office of Inspector General has enhanced its audit in- dependence. For example, re- cently the ADP Audit Unit an- alyzed computerized data from the Grants Information Con- tract System which will be used to plan future audits. ------- Personnel Security Program Transferred to OIG The personnel security pro- gram was transferred to the Office of Inspector General on October 16, 1984. This pro- gram is responsible for ensuring that initial and con- tinuing employment of per- sonnel is consistent with the national security requirements. Previously, insufficient re- sources created a backlog of cases for adjudication, in- consistent classifications of position sensitivity, and a general lack of attention to the importance of the program. Following its transfer to the OIG, we initiated program im- provements and provided ade- quate staffing to eliminate the backlog and attain compliance with regulations. Future plans for the program include reclassifying the sensitivity of positions, con- ducting investigations of con- tractor personnel, rewriting the personnel security manual, automating the investigation process, and enhancing per- sonnel security awareness. Policy Issuance System Expanded and Improved We revised our policy issuance system this period to provide improved guidance, con- sistency, and timeliness in OIG operations. The system was revised to include an OIG Manual for permanent policy issues and periodic bulletins and memoranda for policy issues of limited or temporary applicability. Nine of the 29 manual chapters originally planned were issued this peri- od. Development of the remaining chapters and scheduling of additional ones will continue. Training Gets New Direction With the addition of new staff members and a need for new methods and technology, the Office of Inspector General has expanded and formalized its training program. Priorities this period concentrated on basic auditor and investigator training, supervisory de- velopment, operational au- diting, and the use of micro- computers. We provided 5,190 hours of training to 137 mem- bers of our staff, a dramatic in- crease over prior periods. By presenting three courses under a contractual arrange- ment with the Interagency Au- ditor Training Program of the USDA Graduate School, we trained 68 staff members for the cost of 30 individual enroll- ments. Management Assessment Reviews Assure the Quality of OIG Operations During this reporting period, the OIG initiated an in-house Management Assessment Re- view (MAR) program to measure the extent OIG offices are implementing and following OIG policies and standards, and to assess the quality of OIG products. The MAR program provides for periodic reviews of all OIG au- dit and investigative field office activities, administrative and management functions, and staff performance. MARs specifically evaluate: How effectively and effi- ciently the OIG's organizational entities are fulfilling assigned responsibilities; The quality of managerial skills used to achieve agreed upon objectives; Work procedures and prac- tices and their effect on the quantity and quality of results; The coordination and cohesiveness of overall di- rection; and The relevance of policies, priorities, and standards with regard to changing conditions and emerging issues. MAR teams are composed of auditors from the OIG's Office of Management and Technical Assessment, aug- mented by senior auditors and investigators on loan from our field divisions. This in- dependent group, reporting to the Assistant Inspector Gener- al for Management and Tech- nical Assessment, allows for an objective evaluation of both audit and investigative offices. 31 ------- Section V - Delinquent Debts The Supplemental Appro- priations and Rescission act of 1980 (Public Law 96-304), requires the Inspector General to report on EPA's delinquent debts and efforts to improve the collection of such debts. Review of Collection Pro- cedures We reviewed accounts receiv- able and collection procedures in 10 of the Agency's 15 servicing finance offices (SFOs). Our review disclosed that controls were adequate and aggressive collection ac- tions were generally taken. However, in a few instances, several SFOs could have com- plied more fully with Agency procedures regarding followup on delinquent debts and assessment of interest. In this regard, we found that six of the 10 SFOs did not always issue the required demand let- ters at appropriate intervals (30, 60, and 90 days), while five did not always assess interest on debts. For one SFO, unassessed interest amounted to about $59,000. We also noted that two SFO's had not reconciled their general ledger to the accounts receivable subsidiary records. However, these SFOs in- dicated that they would cor- rect these discrepancies. Claims Office Actions When SFOs determine that debts are uncollectible, they are forwarded to the EPA Claims Officer for disposition. The Claims Officer may com- promise, terminate, or sus- pend further collection efforts on debts under $20,000. De- bts over $20,000 must be for- warded to the General Ac- counting Office or the De- partment of Justice for approv- al of the final resolution of de- bts. For this reporting period, the Claims Officer: (1) authorized a writeoff on ten debts totalling $51,876; (2) collected on seven debts totalling $32,490; (3) compromised on six debts totalling $38,653 for $18,072; and (4) suspended further col- lection efforts on one debt amounting to $3,236. Further, during this period the Claims Officer did not refer any debts to the General Accounting Office or Department of Jus- tice. As of March 31, 1984, there were 107 accounts re- ceivable valued at $2,254.209 in the Claims Office. Of the $2.3 million, about $968,000 represents debt amounts be- tween 1 to 2 years old while about $1 million are over 2 years old. We are currently conducting an audit of the Claims Office. Agency Initiatives The Office of the Inspector General was requested by the EPA Claims Office, Office of General Counsel, to review financial statements and assess the ability of four de- btors to repay their debts. We concluded that the debtors either had the ability to repay or that the financial informa- tion submitted was not cur- rent. In addition, the Agency's Comptroller issued a notice on "Reporting of Debt Informa- tion to Credit Agencies." This notice establishes Agency poli- cy and procedures for the reporting of debt information to credit reporting agencies and complies with OMB Bulle- tin 83-21, "Use of Credit Reporting Agencies." Agency Collection Efforts The Financial Management Di- vision provided the following summary of EPA's collection efforts for the period October 1, 1983 through March 31, 1984, and accounts receivable as of March 31, 1984. Notes Collections Amounts Written off Interest Assessments Interest Collections Accounts Receivable: Under 90 days old Over 90 days old Interagency agreements Total $4,032,372 $52,707 $1,467.121 $186,947 $2,130,294 12.505,827 1 3,117,424 2 $17.753,545 Note 1: Almost 80 percent of this amount constitutes receivables which are being appealed. Collection actions are suspended until the appeals process is complete. Note 2: This amount is for debts owed EPA by other Federal agencies. Since these debts do not have an impact on the U.S. Treasury, we have not included them in the regular accounts receivable figures. However, it is still important to note that these debts impact the Agency's budget. Approximately 21 percent of the total in this category is over 90 days old. 32 ------- Appendix - Audit Reports Issued The Inspector General Act requires the identification of each audit report completed or issued by the OIG duirng the reporting period. The following listing categorizes audit reports by type and region. AUDIT CONTROL NUMBER AUDITEE FINAL REPORT ISSUED 1. INTERNAL AND MANAGEMENT AUDITS E1LM4010005-40266 REGION 1 INTERNAL CONTROL ASSESSMENTS TOTAL OF REGION 1 = 1 E1LM4020008-40265 REGION 2 INTERNAL CONTROL ASSESSMENTS TOTAL OF REGION 2 = 1 ElAM4030135-40802 DELINQUENT DEBT REVIEW E1Z03030248-40392 REGION 3 GOV'T VEHICLES-PA E1Z04030023-40316 REGION 3 FMFIA REVIEW TOTAL OF REGION 3 = 3 E1AM4040036-40459 FED MGR'S FIN INTEG ACT E1ZM4040061-40555 R = 4 IMPREST FUND MONTGOMERY AL ElAM4040125 -40795 R4 REVIEW OF DELINQUENT DBTSGA TOTAL OF REGION 4 = 3 E1H03050384-40320 I&M DELINQUENT DEBTS R5 E1H03050385-40215 I&M DELINQUENT DEBTS CINCY E1LD4050019-40258 I&M INTERNAL CONTROL ASSESSMENTS TOTAL OF REGION 5 = 3 E1Z03060199-40018 R6 DELINQUENT DEBT REVIEW TX E1AM406003&40233 FED MGRS FIN INTEG ACT R-6 E1AM4060093-40769 R6 DELINQUENT DEBT REVIEW TOTAL OF REGION 6 = 3 E1AM4080017-40587 EPA R8 YEAR END SPENDING CO E1Z03080082-40804 EPA R-8 PROPERTY MGMT CO E1VW3080081-40068 REGION 7 UNLIQUIDATED OBL TOTAL OF REGION 8 = 3 E1AM4090018-40588 EPA R9 YEAR END SPENDING CA E1LD4090016-40268 R = 9 INTERNAL CONTROL ASSESS CA TOTAL OF REGION 9 = 2 E1AM4100022-40589 EPA RX YR END SPENDING = MISC WA E1Z03100039-40264 REGION 10 PROPERTY MGMT WA E1LD4100015-40269 R10 INTERNAL CONTROL ASSESS WA TOTAL OF REGION 10 = 3 E1ZW3110044-40393 OFFICE OF WATER REGS & STDS E1ZM4110018-40560 CONSULTING SVCS CONTRACTS E1ZM3110045-40365 EPA IMPLEMENTATION OF FMFIA E1ZM3110037^0119 EPA'S USE OF GOV'T VEHICLES E1Cw3110019-40043 CONSTRUC GRANT-SPECIAL PROJ TOTAL OF HQ = 5 TOTAL INTERNAL & MANGEMENT AUDITS = 27 11/28/83 11/28/83 03/26/84 12/20/83 12/07/83 11/25/83 01/26/84 03/21/84 12/07/83 11/16/83 11/25/83 10/05/83 11/21/83 03/21/84 02/03/84 03/26/84 10/19/83 02/03/84 11/22/83 02/03/84 11/28/83 11/23/83 12/20/83 01/30/84 12/15/83 10/08/83 10/12/83 2. CONSTRUCTION GRANT E2CD3010118-40561 E2CD4010006-40562 E2CW3010147-40327 E2CW3010079-40167 E2CW3010071-40414 E2CW301014&40112 E2CW3010160-40530 E2CW3010109-40403 E2CW3010108-40055 E2CW3010159-40391 E2CW3010112-40538 E2CW3010148-40466 E2CW3010131-40024 E2CW3010172-40531 E2CW3010162-40046 E2CW3010144-40415 E2CW3010100-40216 AUDITS METCALF 7 EDDY INC MA METCALF & EDDY INC MA MIDDLETOWN OLD TOWN PLAINFIELD CT LITCHFIELD MERIDEN AMESBURY MEDWAY MA NEW CASTLE AMESBURY FAIRFIELD WALTHAM MA WORCHESTER MA NHWSPCC LENOX HARTFORD 01/27/84 01/27/84 12/09/83 11/07/83 12/27/83 10/26/83 01/19/84 12/23/83 10/18/83 12/20/83 01/20/84 01/09/84 10/11/83 01/19/84 10/13/83 12/27/83 11/17/83 33 ------- AUDIT CONTROL NUMBER AUDITEE E2CW3010143-40071 E2CW301 01 42-4041 7 P2CW3010103-40771 P2CW301 0078-40564 P2CW30 10057-40803 P2CW301 0099^0782 P2CW301 0038-40668 P2CW3010151-40798 P2CW301 1077^0757 S2CW301 01 39-40278 S2CW301 01 02-40797 TOTAL OF E2CW20201 68^0520 E2CW4020041 -40235 E2CW4020039-40192 E2DW1 020002^0800 TOTAL OF E2CW2030203-40193 E2CW2030350-40831 E2CW20301 35-40748 E2CW1 03022 1-40534 E2CW1 030358-40832 E2CW1 030200-40636 E2CW3030 164-40537 E2CW3030269-40395 P2BW1 030420-40314 P2CW1 030452-40386 P2CW1 0301 14-40464 P2CD3030147^0137 P2CW30302 17-40608 P2CW30301 77-40597 P2CW30302 15-40370 P2CW30301 84-40598 P2CW3030 11 0-40442 P2CW30301 71 -40596 P2CW3030089-40443 P2CW30301 98-401 04 P2CW3030 199-40788 P2CW3030 165-40 190 P2CW3030037-40016 P2CW30301 74-40787 P2CW303010&40042 P2CW30301 69-40796 P2CW303021 3-40532 P2CW3030 186-40599 P2CW3030006-40017 P2CW30301 58-40463 P2CW3030374-4061 1 P2CW3030346-40610 P2CW3030279-40369 P2CW3030272^t0524 P2CW303027 1-40609 P2CW3030263-40495 P2CW3030259-40494 P2CW3030238-40372 P2CW30302 18^0385 P2CW3030206-40522 S2CW2030460-40444 S2CW2030408-40371 S2CW2030226-40515 NEW HAMPSHIRE WSPCC NH MADAWASKA ME GREENVILLE NH NEW HAMPSHIRE WATER SUPPLY NH ELLINGTON CT LEWISTON-AUBURN ME LANCASTER NH MARSHFIELD VT VERGENNES MEDWAY PLAINVILLE MA REGION 1 = 28 BASORA & RODRIGUEZ PR ALEXANDRIA BAY VILLAGE NY OXFORD TOWN OF NJ MIDDLESEX COUNTY SA NJ REGION 2 = 4 BERKS-MONTGOMERY AUTHORITY-PA EAST PENNSBORO TOWNSHIP-PA W ELIZABETH SANITARY AUTH-PA NEW CASTLE COUNTY-DE ROANOKE CITY-VA WILMINGTON CITY COUNCIL-DE WILLARDS TOWN-MD ANNE ARUNDEL-MD MALDEN PUBLIC SERVICE DIST-WV PORTER TOWER-PA CARROLL COUNTY-MD ST JOSEPH MISSOURI ASSIST-MD DOVER CITY-DE FINCASTLE-VA LEWISTOWN BOROUGH-PA COLFAX PSD-WV BRADLEY PSD-WV ALLEGANY COUNTY-MD ST. MARY'S CITY-WV BRIDGEWATER BOROUGH-PA SOUTH BOSTON CITY-VA HAMPTON TOWNSHIP-PA NEWPORT NESW CITY-VA WSSC-MD FINDLAY TOWNSHIP-PA ANNE ARUNDEL COUNTY-MD WEST MIFFLIN-PA BRUCETON/BRANDONVILLE PSD-WV HAMPTON ROADS SANI DISTRICT-VA WESTERNPORT-MD NEW CASTLE COUNTY-DE PALMYRA-PA SOUTH MIDDLETON-PA TAMAQUA-PA NEW CASTLE-PA SEAFORD CITY-DE SOUTH MIDDLETON-PA DOVER CITY-DE LAUREL MAYOR & COUNCIL-DE WEST DONEGAL TOWNSHIP-PA ANNVILLE TWP AUTH-PA WARWICK TOWNSHIP-PA FAIRVIEW TOWNSHIP-PA FINAL REPORT ISSUED 10/20/83 12/28/83 03/19/84 01/27/84 03/26/84 03/19/84 02/24/84 03/23/84 03/15/84 11/30/83 03/23/84 01/17/84 11/21/83 11/09/83 03/23/84 11/09/83 03/30/84 03/14/84 01/20/84 03/03/84 02/15/84 01/20/84 12/22/83 12/07/83 12/20/83 01/06/84 10/31/83 02/09/84 02/07/84 12/16/83 02/07/84 12/29/83 02/07/84 12/29/83 10/25/83 03/20/84 11/08/83 10/05/83 03/20/84 10/13/83 03/23/84 01/18/84 02/07/84 10/05/83 01/06/84 02/09/84 02/09/84 12/16/83 01/18/84 02/09/84 01/12/84 01/12/84 1 2/1 6/83 1 2/20/83 01/18/84 1 2/29/83 1 2/1 6/83 01/17/84 34 ------- AUDIT CONTROL NUMBER AUDITEE S2CW1 03041 6-40623 S2CW3030054-40624 S2CW3030038-40234 S2CW3030096-40514 TOTAL OF E2CW2040338-40057 E2CW2040332-40145 E2CW2040227-40505 E2CW2040174-40122 E2CW1 04001 8-40011 E2CW3040205-40053 E2CW30401 67-40056 E2CW3040081 -40050 E2CW304001 6-40341 E2CW3040267-40476 E2CW3040206-40222 E2CW3040263-40509 P2CW2040238-40349 P2CW2040246-40346 P2CW2040250-40127 P2CW2040277-40340 P2CW2040327-40343 P2CW2040341 -40345 P2CW2040344-40093 P2CW2040353-40342 P2CW20401 80-40299 P2CW20401 65-40059 P2CW1 040 106-40350 P2CW20401 64-40009 P2CW20401 37-40252 P2CW20401 10-40048 P2CW2040059-40351 P2CW3040277-40470 P2CW3040295-40510 P2CW304031 3-40471 P2CW3040251-40814 P2CW2040260-40816 P2CW3040 199^0765 P2CW3040255-40815 P2CW3040250-40126 P2CW3040059-40051 P2CW3040046-40508 P2CW3040233-40298 P2CW3040053-40338 P2CW30401 61 -40763 P2CW30401 31 -40726 P2CW3040 186-402 19 P2CW30401 56-40095 P2CW30401 84-40221 P2CW3040064-40277 P2CW30401 98-40764 P2CW30401 85^0469 P2CW30401 96-40344 P2CW30401 30-40010 P2CW30401 57-40008 P2CW3040056-40054 P2CW30401 83-40147 P2CW3030060-40556 P2CW30401 33-40727 P2CW3040051 -40492 S2CW3040024^10094 P2CW4040037-40817 NEW OXFORD MUN AUTH-PA WARWICK TOWNSHIP-PA BRIGHTON TOWNSHIP-PA JACKSON TOWNSHIP AUTHORITY-PA REGION 3 = 47 DECATUR TN CARTHAGE TN COLUMBIA SC JACKSON MS DELRAY BEACH FL FT MEADE FAISON NC CLAVE RT CITY KY ATLANTA GA GWINNETT CO GA STARKVILLE MAIDEN NC LOUISVILLE KY ZEBULON NC GLASGOW LOUISVILLE KY DANVILLE LOUISVILLE KY BOWLING GREEN KY LEXINGTON KY DRY RIDGE KY GAINESVILLE FL LOUISVILLE JEFFERSON CO DYERSBURG TN WCRSA GREENVILLE SC BENSON NC LOUISVILLE KY BRULINGTON NC JACKSON MS SUMTER SC LOUISBURG NC DEMOPOLIS AL PALM BEACH CO FL MERIDIAN MS TUSCALOOSA AL CLEARY HEIGHTS WSD MIAMI DADE WATER & SEWER FL CLINTON NC LOUISVILLE KY MIAMI/DADE WATER & SEWER FL MIAMI DATE WATER & SEWER WILMINGTON NC ADEL GA WINSTON/SALEM CITY/CO UTIL NC AIKEN CO PSA SC MIAMI DADE WSA FL WARREN COUNTY NC PINEALLAS CO FL VIDALIA PASCAGOULA MS YORK SC CHERRYVILLE NC MIAMI DADE WATER & SEWER FL MIAMI DADE WATER & SEWER FL MIAMI DADE WATER & SEWER FL NASHVILLE TN TUSCALOOSA AL FINAL REPORT ISSUED 02/10/84 02/10/84 11/21/83 01/17/84 10/18/83 11/01/83 01/16/84 10/27/83 10/04/83 10/13/83 10/18/83 10/18/83 12/13/83 01/09/84 11/17/83 01/16/84 12/13/83 12/13/83 10/27/83 12/13/83 12/13/83 12/13/83 10/24/83 12/13/83 12/02/83 10/18/83 12/13/83 10/04/83 11/23/83 10/14/83 12/13/83 01/09/84 01/16/84 01/09/84 03/28/84 03/28/84 03/16/84 03/28/84 10/27/83 10/13/83 10/16/84 12/02/83 12/13/83 03/16/84 03/09/84 11/17/83 10/21/83 11/17/83 11/30/83 03/16/84 01/09/84 12/13/83 10/04/83 10/04/83 10/13/83 11/01/83 01/26/84 03/09/84 01/16/84 10/24/83 03/28/84 35 ------- AUDIT CONTROL NUMBER AUDITEE FINAL REPORT ISSUED 2. CONSTRUCTION GRANT AUDITS P2CW4040009-40577 S2CW20401 47^0646 S2CW004031 6-40467 S2CW3040289-40648 S2CW3040052-40839 P2CW4040049-40818 S2CW3040047^t0647 S2CW3040035-40399 TOTAL OF E2CW2050484-40287 E2BD4050033-40254 E2CW2050480^0136 E2BW1 050251 -401 35 E2CW2050479-40739 E2CW2050229-40527 E2CW2050209-40621 E2CW205001 0-40400 E2BW3050294-40196 E2CW30501 96-40595 E2CW305020&40778 E2CW30501 97-40541 E2CW3050207-40082 P2CW2050 179-40302 P2CW2050239-40140 P2CW2050290-40401 P2CW2050359-40245 P2CW2050372-40806 P2CW2050477-40833 P2CW2050511 -40081 P2CW205061 2-40686 P2CW205061 6-40593 P2CW2050627-40776 P2CW1 050366-40532 P2CW20501 78-4041 6 P2CW20501 67-40239 P2CW1 050300-40592 P2CW1 050276-40259 P2CW1 0501 42-40244 P2CW1 050086-401 43 P2CW20501 55-40779 P2BW0050247-40728 P2CW1 050064-40238 P2CW1 050052-40526 P2BW2050340-40677 P2BW1 0501 86-40303 P2CW20501 19-40591 P2CW1 050027-40240 P2CW20501 13-40288 P2CW2050097-40594 P2CW2050096-40775 P2CD2050050-40257 P2CW0050407-40774 P2CW0050394-40394 P2CW0050325-40142 P2CW3050279-40540 P2CW3050201 -40780 P2CW30501 30-401 39 P2CW305011&40644 P2CW3050069-40525 P2CW3050066-40708 P2CW3050065-40777 MONTGOMERY WATER WKS & SB AL KNOXVILLE TN LAFAYETTE TN COLLIERVILLE TN MOUNT PLEASANT TN JEFFERSON CO COMM AL HARPETH VALLEY UTIL DIST TN NEWPORT UTILITY TN REGION 4 = 65 EFFINGHAM IL CONSOER TOWNSEND GREENE CO (XENIA) OH TURNER CONSTR CO CLEVELAND OH YOUNGSTOWN OH MSD CHICAGO IL MSD CHICAGO IL MSD CHICAGO IL SURGES & NIPLE (CY 78-82) OH BREEZY POINT/PEQUOT LAKES MN CONVERSE IN URBANA OH JEFFERSON OH WASHTENAW CO (ANN ARBOR) Ml OREGON OH LEBANON IN LENAWEE CO (ADRIAN) Ml GRAND RAPIDS Ml FOND DU LAC Wl HOLLAND Ml MMSD MILWAUKEE Wl LIBERTY CENTER OH MIAMI CO (DAYTON) OH WH EATON SD IL WEST SALEM Wl SUPERIOR Wl MTVERNON IL NEW ULM MN UNION GROVE Wl VIROQUA Wl HAMILTON CO (CLEVES) OH MWCC (ST PAUL) (OH FY 75-80) MMSD MILWAUKEE Wl LAKE PEWAUKEE SD (PEWAUKEE) Wl TKDA ST PAUL (OH CY-77-81) MN GRAEF ANHALT (MMSD) (80-81) Wl W TRAVERSE TWP (HARBOR SPRINGS) PRAIRIE DU CHIEN Wl RACINE Wl MIAMI CD (DAYTON) OH GREEN TWP (PARIS) Ml PITTSBURG KS KNIGHTSVILLE TN VERONA Wl MOUNT HOREB Wl BRILLION Wl COLUMBIANA CO (LISBON) OH DU QUOIN IL CARBONDALE IL TOMAH Wl CADILLAC CITY/WEXFORD CO Ml DOVER-EYOTA-ST CHARLES AREA MN 02/01/84 02/17/84 01/09/84 02/17/84 03/30/84 03/28/84 02/17/84 12/22/83 12/02/83 11/23/83 10/28/83 10/31/83 03/13/84 01/18/84 02/09/84 12/22/83 11/10/83 02/06/84 03/19/84 01/23/84 10/21/83 12/05/83 10/31/83 12/22/83 11/22/83 03/26/84 03/30/84 10/21/83 02/29/84 02/06/84 03/19/84 01/19/84 12/27/83 11/22/83 02/06/84 11/25/83 11/23/83 10/31/83 03/19/84 03/09/84 11/22/83 11/18/84 12/28/84 12/05/83 02/06/84 11/22/83 1 2/02/83 02/06/84 03/1 9/84 11/25/83 03/19/84 12/21/83 10/31/83 01/23/84 03/1 9/84 10/31/83 02/1 6/84 01/18/84 03/07/84 03/19/84 36 ------- AUDIT CONTROL NUMBER AUDITEE P2CW3050063-40685 P2CW3050061 -40260 P2CW3050060-40141 P2CW3050055-40807 TOTAL OF E28W30601 88-40669 E2AW3060066-40275 E2CW20601 00-40699 E2CW40600 13-40586 E2CW4060022-40687 E2CW4060055-40785 E2CW3060058^t0485 E2CW3060 11 8-40044 E2CW3060099-40799 E2CW30601 63-40688 E2CW30601 53-40367 E2CW30601 45-40366 E2CW30601 37-4051 3 E2CW30601 92-40484 P2CW3060201 -40843 P2CW30601 98-40842 P2CW30601 95-40841 P2CW30601 91 -40558 P2CW3060037-40013 P2CW3060092-40468 P2CW3060089^0451 P2CW3060059-40220 P2CW3060048-40347 P2CW30601 83-10251 P2CW30601 79-40840 P2CW3060 177-40626 P2CW30601 73-40625 P2CW30601 72-401 44 P2CW3060 154-40250 P2CW3060 11 7-40058 P2CW30601 16-40339 P2CW3060109-40146 P2CW3060094-40382 TOTAL OF E2CW2070046-40654 E2CW2070086-40267 E2CW2070067-40242 E2CW2070454 -40549 E2CW2070424-40300 E2CW2070582-40301 E2CW2070620-40354 P2BW2070361 -40025 P2CW2070050-40326 TOTAL OF P2CW2080101-40152 P2BW4080008-40236 P2BW4080025-40548 P2CW4080024-40547 P2CW3080069-40635 P2CW3080065-40689 P2CW3080061 -40241 P2CW3080058-40571 P2CW3080053-40249 P2CW30800 14-40065 P2CW30800 17-40205 P2CW30800 15-40070 P2CW3080050-40271 MMSD MILWAUKEE Wl BIG LAKE MN LITCHFIELD IL ARENAC CO (STANDISH) Ml REGION 5 = 56 PARIS TX LANTX PONTOTOC CO RURAL SD NO. 5 OK TRINITY TX HOMINY OK HOUSTON TX GRAND CANE LA OBERLIN LA TANGIPAHOA LA ST CHARLES PARISH LA KAUFMAN TX FOLSOM LA DALLAS TX DALLAS TX LOVINGTON NM RUIDOSA/RUIDOSA DOWNS NM DEMING NM EL PASO TX NO LITTLE ROCK SEWER CO AR MERRYVILLE LA CLEAR LAKE CITY TX ELTON LA ST BERNARD SD/LA NO TEXAS NWD TC GLADEWATER TX CHICKASHA OK ST JAMES PARISH POLICE JURY LA DALLAS TX COMMERCE TX TEXAS A&M UN IV TX STEPHENVILLE TX CHINA TX LAFAYETTE LA REGION 6 = 33 INDIANOLA IA WICHITA KS HEBRON NE CITY OF CUBA MO HARLAN IOWA FORT CALHOUN NE EPWORTH IA CEDAR RAPIDS IA PITTSBURG KS REGION 7 = 9 SOUTH ADAMS CO W&S DISTRICT CO PUEBLO CO CITY OF PUEBLO CITY OF CO SOUTH ADAMS CO W&S DISTRICT CO WHITEFISH MT CITY OF SPRINGDALE UT TOWN OF KEMMERER WY CITY OF MANTUA UT TOWN OF KANAB CITY CORPORATION UT UPPER THOMPSON SD ESTES PK CO CEDAR CITY CORP ORATION UT BIG TIMBER MT CITY OF GRANBY SANITATION DISTRICT CO FINAL REPORT ISSUED 02/29/84 11/25/83 10/31/83 03/27/84 02/24/84 11/30/83 03/02/84 02/02/84 03/02/84 03/19/84 01/10/84 10/13/83 03/23/84 03/02/84 12/15/83 12/15/83 01/16/84 01/10/84 03/30/84 03/30/84 03/30/83 01/26/84 10/04/83 01/09/84 12/30/83 11/17/83 12/13/83 11/23/83 03/30/84 02/10/84 02/10/84 11/01/83 11/23/83 10/18/83 12/13/83 11/01/83 12/19/83 02/17/84 11/28/83 11/23/83 01/23/84 12/05/83 12/05/83 12/13/83 10/11/83 12/08/83 11/01/83 11/21/83 01/23/84 01/23/84 02/14/84 03/01/84 11/22/83 01/30/84 1 1/23/83 10/18/83 11/14/83 10/19/83 11/29/83 37 ------- AUDIT CONTROL NUMBER AUDITEE FINAL REPORT ISSUED P2CW3080029-40270 SILVERTHORNE/DILLON JNT SA CO P2CW3080023-40659 GREAT FALLS MT CITY OF P2CW3080022-40069 CARBON COUNTY COMMISSIONERS MT TOTAL OF REGIONS = 16 E2BW209004440574 GROVELAND COMM SD CA E2CW3090058-40237 CONTRA COSTA CSD 7A CA E2CW3090024-40157 LAS VIRGENES CA E2CW3090 138-40834 MONTEREY CO SER AREA CA E2CW3090066-40158 HONOLULU HI CITY & COUNTY OF E2CW30901 36-4051 9 LOCKFORD COMM SER DIST CA E2CW3090 135-40 168 BRENTWOOD CA CITY OF E2CW4090007-40740 HONOLULU CITY & COUNTY HI E2CW30901 60-40552 QUINCY SANITARY DIST CA E2CW3090254-40363 CITY & COUNTY OF HONOLULU HI E2CW3090225-40658 HONOLULU CITY & COUNTY HI E2CW3090205-40493 MORRO BAY CA CITY OF S2BW4090021-40329 SACRAMENTO REGIONAL CSD CA S2BW309021 8-40206 MONTEREY REG WPCA CA S2BW3090 11 0-40478 KENNEDY-JENKS ENGINEERS SF CA S2BW3090085-40528 ENGINEERING SCIENCE ARCADIA CA S2AW3090253-40543- GUSTINE CA CITY OF S2CW3090241 -40529 VENTURA REG CSD CA S2CW3090242-40456 PATTERSON CA CITY OF S2CW3090 185-40455 LOS ANGELES CA CITY OF S2CW30901 8440697 LAKE COUNTY SAN DIST CA S2CW30901 14-40161 REDDING CA CITY OF S2CW30901 82-401 63 TULARE CO DEPT OF EDUCATION CA S2CW3090181-40155 N TAHOE PUD CA S2CW3090022-401 09 ALISO WATER MGMT AGENCY CA S2CW309001 3-40364 SACRAMENTO REGIONAL CSD CA S2CW30901 1 5-40756 LIVERMORE-AMADOR VALLEY MA CA S2CW3090039-40207 LAKE PORT CITY OF CA S2CW30901 79-401 59 BISHOP CA CITY OF S2CW3090 17^40675 CA DEPT OF CORRECTIONS-SUSAN S2CW30901 28-10079 ALISO WATER MGMT AGENCY CA S2CW30901 18-40154 LOS ANGELES CSD WHITTIER CA S2CW30901 33-40573 SANTA ROSA CA CITY OF S2CW30901 32-40656 SANTA ROSA CA CITY OF S2CW3090131-40812 CRESCENTA VALLEY COUNTY WD CA S2CW30901 29-401 60 EAST BAY DISC AUTH CA S2CW30901 77^0837 LOS ANGELES CSD 2 CA S2CW30901 76-40642 VENTURA REGIONAL CSD CA S2CW30901 75-40678 CITY & CO OF SAN FRANCISCO CA S2CW30901 71 -40674 GRASS VALLEY CA CITY OF S2CW3090151-40156 BIG BEAR CA CITY OF S2CW30901 46-401 62 SAN FRANCISCO CITY & COUNTY CA S2CW30901 17-40749 CSD OF LOS ANGELES COUNTY CA S2CW30901 1 6-40572 SACRAMENTO COUNTY CA TOTAL OF REGION 9 = 44 E2AW41 00036-40786 BOISE PUBLIC WORKS DEPT ID E2BW31 00045-401 72 METRO WASTEWATER MGMT COM OR E2CW31 0001 2-40553 BURLEY ID CITY OF E2CW31 00051 -4031 9 COEUR D'ALENE ID CITY OF E2CW31 0001 5-40091 VAL VUE SEWER DIST SETTLE WA E2CW31 0001 6-40243 WOODBURN OF CITY OF E2CW31 00047-40805 ALMIRA WA TOWN OF P2CW31 0001 1-40007 BRUNEAU WATER & SEWER DIST ID P2CW3100001-40103 BOISE CITY OF ID P2CW41 00005-40092 BOISE ID CITY OF TOTAL OF REGION 10 = 10 TOTAL CONSTRUCTION GRANT AUDITS = 312 11/29/83 02/22/84 10/19/83 01/31/84 11/21/83 11/04/83 03/29/84 11/04/83 01/17/84 11/04/83 03/13/84 01/25/84 12/14/83 02/22/84 01/11/84 12/09/83 11/15/83 01/10/84 01/18/84 01/23/84 01/18/84 01/04/84 01/03/84 03/01/84 11/04/83 11/04/83 11/04/83 10/25/83 12/14/83 03/15/84 11/15/83 11/04/83 02/27/84 10/20/83 11/04/83 01/30/84 02/21/84 03/27/84 11/04/83 03/30/84 02/16/84 02/28/84 02/27/84 11/04/83 11/04/83 03/14/84 01/30/84 03/20/84 11/07/83 01/25/84 12/07/83 10/24/83 11/22/83 03/26/84 10/04/83 10/24/83 10/24/83 38 ------- AUDIT CONTROL NUMBER AUDITEE FINAL REPORT ISSUED 3. OTHER GRANT AND C3EC401 0065-40707 D3AM401 0020-401 80 D3AM4010021-40181 D3AM401 0034-40256 D3AM40 10026-40203 D3AM401 0042-40356 D3AM40 10075-40783 D3AM40 10058-40499 D3AM401 0057-40498 D3AM40 10056-40497 D3AM40 10048-40362 D3AM401 0047-40361 D3AM40 10043-40357 D3CM401 0023-401 83 D3CM401 001 9-401 79 D3CM401 0046-40360 D3CM40 10073-40772 D3CM40 10032-40246 D3CM401 0024-40208 D3CM401 001 2-401 69 D3AW401 0074-40773 D3AS401 0033-40247 D3AS401 0004-40047 D3CM401 0060-40535 D3CM401 0045-40359 D3CM401 001 7-401 77 D3CM401 001 5-401 75 D3BM401 0044-40358 D3CM401 001 4-401 74 D3CM401 001 3-401 73 D3DW301 01 85-40279 D3DM401 0025-40202 D3DM401 0051 -40737 D3CS401 001 6-401 76 D3DW201 0225-401 20 D3DW301 01 67-40255 D3DW3010098-40121 D3DW301 0041 -40738 D3DW201 0247-40402 H3AB401 001 8-401 78 H3AM401 0061 -40536 N3GC401 0041 -40355 N3GC40 10062-40563 N3GC401 0063-40633 N3GC401 0069-40711 N3GC401 0070-4071 2 N3GC4010071-40713 P3B0201 0266-40565 P3D01 01 01 14-40607 S3D01 01 01 65-40209 TOTAL OF C3EW4020043-40521 D3AB4020036-40165 D3AM4020063-40488 D3BM4020048-40378 D3AW4020078-40704 D3CM4020031 -40089 D3CM4020033-40087 D3CM4020032-40088 D3CM4020075-40631 D3CM4020067-40632 CONTRACT AUDITS KEENE NH TRC ENVIR CONSULT INC CT TRC ENVIRON CONSULTS INC CT L&C STEINMULLER GMBH GERMANY TRC ENVIR CONSULTS INC CT ARTHUR D LITTLE INC MA CAMP DRESSER & MCKEE INC MA GCA TECHNOLOGY DIV MA ENVIRONMENTAL RESEARCH & TEC M HEALTH EFFECTS INSTITUTE MA PUTNAM HAYES & BARLETT INC M GEREGHTY & MILLER INC NY ARTHUR D LITTLE INC MA ABT ASSOCIATES INC MA ENERGY RESOURCES CO INC MA SPRINGBORN LABS INC CT UNITED TECHNOLOGIES CORP CT ARTHUR D LITTLE INC MA JBF SCIENTIFIC CORP MA ABT ASSOCIATES MA ARTHUR D LITTLE INC MA E C JORDAN CO ME ARTHUR D LITTLE MA THE MITRE CORP MA TRC-ENVIRON CONSULTANTS INC C ENVIRONMENTAL RESH & TECH CO M ENERGY RESOURCES CO INC MA HAMILTON-STANDARD DIV UTC CT ENERGY RESOURCES CO INC MA META SYSTEMS INC MA TIGHE & BOWD ENGINEERS MA TEMPLE BARKER SLOANE INC MA WCH INDUSTRIES MA ENERGY RESOURCES CO INC MA CURRAN ASSOCIATES INC MA HAYDEN HARDING & BUCHANAN MA WRIGHT ENGR LTD VT WCH INDUSTRIES INC MA SEA CONSULTANTS INC MA HARVARD UNIVERSITY MA HARVARD UNIV SCL PUB HEALTH M METRO AREA PLANNING COUNCIL MA CLAREMONT NH GR BRIDGEPORT REG PLAN AGY CT CONNECTICUT RIVER ESTUARY RP C NE CONN REG'L PLAN AGENCY CT CLAREMONT NH WRIGHT PIERCE ME WRIGHT PIERCE ME COFFIN & RICHARDSON INC REGION 1 = 50 INTERSTATE SANITATION COMM NY CORNELL UNIVERSITY NY AUDITS AND SERVEYS INC NY BURNS & ROE IND SERV CORP NJ HYDROQUAL INC NJ FRED C HART ASSOC INC NY FRED C HART ASSOC INC NY FRED C HART ASSOC INC NY FRED C HART ASSOC NY FRED C HART NY 03/07/84 11/08/83 11/08/83 11/25/83 11/10/83 12/14/83 03/19/84 01/12/84 01/12/84 01/12/84 12/14/83 12/14/83 12/14/83 11/08/83 11/08/83 12/14/83 03/19/84 11/23/83 11/16/83 11/04/83 03/19/84 11/23/83 10/14/83 01/20/84 12/14/83 11/08/83 11/08/83 12/14/83 11/08/83 11/08/83 12/01/83 11/10/83 03/12/84 11/08/83 10/27/83 11/25/83 10/27/83 03/13/84 12/23/83 11/08/83 01/20/84 12/14/83 01/27/84 02/14/84 03/08/84 03/08/84 03/08/84 01/27/84 02/08/84 11/15/83 01/18/84 11/03/83 01/11/84 12/16/83 03/05/84 10/14/83 10/14/83 10/14/83 02/13/84 02/13/84 39 ------- AUDIT CONTROL NUMBER AUDITEE D3CM4020062-40487 D3CM4020061 -40486 D3CM4020065-40490 D3CM402006440489 D3DM4020034-40090 D3DM402007640645 E3BW30201 01 -40640 E3CW302009340829 E3CW20201 6740822 E3CW2020055-40813 N3GC4020070-40784 N3GC4020074-40801 P3CP2020065-40760 P3D020201 56-40457 P3D02020057-40413 P3CP1 020058-40759 P3D02020200-40377 TOTAL OF C3EC4030058-40281 C3FC40301 31 -40700 C3EC4030 11 7-40630 C3EC40301 13-4061 2 C3EC4030092-40458 C3EC4030069-40315 C3FC40301 39-40733 C3FC40301 42-40736 C3FC4030059-40309 C3F040301 01 40550 D3A04030066-40312 D3A04030068-40310 D3A04030072-40332 D3A0403007340333 D3A04030074-40334 D3A04030077-40337 D3A04030079-40384 D3A04030095-40477 D3A040301 07-40568 D3A040301 144061 9 D3A0403011 5-40620 D3A040301 18-40637 D3A040301 20-40639 D3A040301 23-40661 D3A040301 37-40731 D3A040301 4640794 D3A04030043-40170 D3A04030050-40189 D3A0403004440171 D3A04030065-40313 D3A04030064-40308 D3A04030061 -40305 D3A0403006040304 D3A0403003540149 D3A0403000940045 D3A0303039940006 D3A0303039840005 D3A0303039740004 D3A0403003440148 D3B0403001 9-40080 D3B0403008440404 D3B040301 0640567 BURNS AND ROE IND SERV CORP NJ FRED C HART ASSOC INC NY GERAGHTY & MILLER NY GERAGHTY & MILLER NY MATHTECH INC NJ MATHEMATICA POLICY RESEARCH N EQB SOLID WASTE AUTHORITY PR DEPT OF HEALTH PR EQB-SOLID WASTE MNG PR PORT AUTHORITY OF NY & NJ NY SUFFOLK COUNTY NY NJ DEPT OF ENV PROT NJ NEW YORK DEP NY LINDEN ROSELLE SA NJ NJ DEPT OF ENV PROTECTION NJ HAZEN SAWYER ENG INC NY REGION 2 = 27 HARVE DEGRACE CITY-MD ST MARY'S COUNTY-MD DELAWARE RIVER BASIN COM-NJ CHESTERFIELD COUNTY-VA SUSQUEHANNA RIVER BASIN COM-PA BOWIE CITY OF-MA CALVERT COUNTY-MD CARROLL COUNTY-MD SNOW HILL TOWN OF-MD WASHINGTON COUNTY-MD INDUSTRIAL ECONOMICS-MA ENVIRON CORPORATION-DC ROY F. WESTON INC-PA JACK FAUCETT ASSOC INC-MD CLEMENT ASSOC INC-VA BOOZ ALLEN & HAMILTON INC-MD GREELEY POLHEMUS GROUP INC-PA MIRANDA ASSOCIATES-MD SYCOM INC-VA CLEMENT ASSOCIATES INC-VA BOOZ ALLEN & HAMILTON INC-MD JRB ASSOCIATES-VA SMC MARTIN INC-PA NUS CORPORATION-MD VERSAR INC-VA ECOLOGICAL ANALYSTS INC-MD JRB ASSOCIATES-VA ICF INCORPORATED-DC ICF INCORPORATED-DC ABT ASSOCIATES INC-MA ROY F WESTON INC-PA WESTAT INCORPORATED-MD KAAREN JOHNSON ASSOC INC-MD ENVIRONMENTAL LAW INSTITUTE-DC GEOMET TECH-MD D'APPOLONIA WASTE MGMT SER-PA MANTECH INTERNATIONAL CORP-VA GEOMET TECHNOLOGIES-MD WESTAT INCORPORATED-MD BIONETICS CORP-VA CORP-NY RADIAN MINE SAFETY APPLIANCES CO-PA FINAL REPORT ISSUED 01/11/84 01/11/84 01/11/84 01/11/84 10/24/83 02/17/84 02/15/84 03/29/84 03/28/84 03/28/84 03/19/84 03/23/84 03/16/84 01/04/84 12/27/83 03/16/84 12/16/83 12/01/83 03/02/84 02/13/84 02/09/84 01/04/84 12/07/83 03/12/84 03/12/84 02/06/83 01/24/84 12/06/83 12/06/83 12/22/83 12/12/83 12/12/83 12/13/83 12/19/83 01/10/84 01/30/84 02/09/84 02/09/84 02/15/84 02/15/84 02/23/84 03/12/84 03/21/84 11/07/83 11/08/83 11/07/83 12/06/83 12/06/83 12/06/83 12/06/83 11/01/83 10/13/83 10/04/83 10/04/83 10/04/83 11/01/83 10/21/83 1 2/23/83 01/30/84 40 ------- AUDIT CONTROL NUMBER AUDITEE FINAL REPORT ISSUED D3A04030032-40151 D3A04030026-40110 D3A03030396-40003 D3A04030017-40077 D3A03030395-40002 D3A04030014-40039 D3A04030013-40038 D3C04030022-40085 D3C04030012-40037 D3C04030087-40431 D3C04030048-40187 D3C04030062-40306 D3C04030049-40188 D3C04030081-40387 D3D04030010-40027 D3D04030016-40076 D3D04030018-40078 D3D04030020-40083 D3D04030021-40084 D3D04030045-40184 D3D04030071-40331 D3D04030082-40388 D3D04030085-40405 D3D04030086-40406 D3D04030105-40566 D3D0403010&40569 D3D04030111-40601 D3D04030121-40643 D3D04020128-40666 D3D04030132- 40701 D3D04030133-40702 D3D04030134-40703 D3C0403008040383 D3C04030078-40368 D3C04030076-40336 D3C04030075-40335 D3C04030063-40307 E3C03030078-40321 E3C02030252-40330 E3D02030061-40194 N3GC4030028-40118 N3GC4030053-40195 N3GC4030070-40317 N3GC4030099-40539 N3GC4030116-40629 N3GC4030140-40734 N3GC4030141-40735 N3GC4030144-40770 H3CU4030127-40665 H3CU4030126-40664 H3A04030067-40311 H3A04030027-40111 H3C0403002440107 H3CU4030125-40663 H3CU4030124-40662 H3C04030033-40150 H3C04030025-40108 TOTAL OF SOBOTKA & COMPANCY INC-DC E.H. PECHAN & ASSOCIATES-VA JACA CORP-PA COM SITE INTERNATIONAL INC-MD BOOZ ALLEN & HAMILTON-MD GEOTRANS INC-VA CLEMENT ASSOCIATES-VA HOFFMAN MUNTER-MD NATIONAL ACADEMY OF SCIENCE-DC ENVIRO CONTROL INC-MD TRACOR JITCO INC-MD RADIAN CORP-TX TRACOR JITCO INC-MD BIOSPHERICS INC-MD FRANKLIN INSTITUTE-PA FRANKLIN INSTITUTE-PA ENVIRONMENTAL LAW INSTITUTE-DC BIONETICS CORP-VA BIONETICS CORP-VA HITTMAN ASSOCIATES-MD FERGUSON BRYON ASSOC INC-DC CRS GROUP ENGINEERS INC-TX HYDROTECHNIC CORP-NY INTERNATIONAL BUSINESS SERV-DC SCOTT ENVIRONMENTAL TECH-PA SKELLY & LOY-PA GENERAL ELECTRIC CO-PA MINE SAFETY APPLIANCES-PA SCJ INC-DC SMC MARTIN INC PA ENERGY & ENVIRON ANALYSIS-VA CALCULON COMP-PA ENVIRONMENTAL LAW INSTITUTE-DC ENVIRON CONTROL INC-MD TRITON CORPORATION-DC GEOMET TECHNOLOGIES INC-MD WAPORA INC-MA DISTRICT OF COLUMBIA GOV'T-DC EDWARD H. RICHARDSON-DE HOWARD COUNTY-MD LUZERNE COUNTY PLANNING COM-PA AGRICULTURE CONSUMER SERVICE SE VA PLANNING DISTRICT COM-VA WESTMINSTER CITY-MD CRATER PLANNING DISTRICT-VA FREDERICK COUNTY-MD DISTRICT OF COLUMBIA-DOT-DC MONTGOMERY COUNTY-MD THOMAS JEFFERSON UNIVERSITY-PA VIRGINA POLYTECHNIC-VA NGA LEHIGH UNIVERSITY-PA GEORGE WASHINGTON UNIV-DC HOWARD UNIVERSITY-DC VIRGINA COMMONWEALTH UNIV-VA PITTSBURGH UNIVERSiTY-PA GEORGE WASHINGTON UNIV-DC REGIONS = 120 11/01/83 10/25/83 10/04/83 10/20/83 10/04/83 10/12/83 10/12/83 10/21/83 10/12/83 12/29/83 11/08/83 12/06/83 11/08/83 12/19/83 10/12/83 10/20/83 10/20/83 10/21/83 10/21/83 11/08/83 12/12/83 12/19/83 12/23/83 12/23/83 01/30/84 01/30/84 02/07/84 02/16/84 02/23/84 03/02/84 02/02/84 03/02/84 12/19/83 12/15/83 12/13/83 12/13/83 12/06/83 12/08/83 12/12/83 11/10/83 10/27/83 11/10/83 12/07/83 01/20/84 02/13/84 03/12/84 03/12/84 03/19/84 02/23/84 02/23/84 12/06/83 10/25/83 10/25/83 02/23/84 02/23/84 11/01/83 10/25/83 41 ------- AUDIT CONTROL NUMBER AUDITEE C3E04040013^0101 C3EM40401 33-40751 C3EM40401 28-40745 C3EM40401 19-40729 C3EM40401 06-40742 C3EM404009&40653 C3EM4040094-40692 C3EM4040092-40651 C3F04040066^0380 C3F0404001 4-401 02 C3FM4040075-40449 C3FM40401 34-40752 C3FM40401 29-40746 C3FM40401 20-40750 C3FM40401 07-40741 C3FM4040095-40652 C3FM4040093-40691 C3FM4040091^0650 C3FM4040082-40512 D3A03040301-40015 D3AM40401 46-40838 D3AM4040089-40557 D3A0404001 5-40060 D3CM4040030-40098 D3CM404011 1-40628 D3CM4040080-40475 D3CM4040079-40398 D3CM404003 1-40099 D3DM4040052-40212 D3C04040068-40348 H3CU40401 21 -40743 H3CU40401 50-40821 H3CU40401 41 -40820 H3CM4040029-40097 H3AM4040039-40123 H3CM4040063-40297 H3CM4040062^0296 H3A0404001 6-40061 N3GM4040058-40276 N3GM4040081 -40507 N3GM4040074-40381 N3GM4040098-40580 N3GM4040097-40579 N3G0404001 7-40028 N3G04040067^0373 N3GM40401 36-40754 N3GM4040099^0581 N3GM40401 15-40694 N3GM40401 14-40693 N3GM40401 35-40753 N3GM40401 30-40747 N3GM40401 27^0744 N3GM40401 17-40695 N3GM4040032-4021 1 N3GM40401 39-4081 9 N3GM40401 37-40755 N3GM4040048-40214 N3GM4040047-40218 P3C030401 63-40506 TOTAL OF FLA DER FL LEXINGTON/FAYETTE UCG KY DAYTONA BEACH FL COLUMBIA SC MORVEN NC MORRISTOWN TN WINSTON SALEM NC WEST FLA RFC FL FORDSVILLE KY FLA DER FL GREENSBORO NC LEXINGTON/FAYETTE UCG KY DAYTONA BEACH FL COLUMBIA SC MORVEN NC MORRISTOWN TN WINSTON SALEM NC WEST FLA RPC FL HARRODSBURG KY HAZTECH NC KILKELLY ENV ASSOC NC RESEARCH TRIANGLE INST NC UNITED MAINTENANCE SVE NC ACT SYSTEMS FL NORTHRUP SERVICES NC ENVIRONMENTAL SC & ENGR FL PRIEDESEDGWICKAL ACT SYSTEMS FL PRICE WATER HOUSE FL WYLE LABS AL UNIV OF FLORIDA UNIV OF NO FLORIDA FLORIDA ATLANTIC UNIV FL RESEARCH TRIANGLE INST NC UNIV NC RESEARCH TRIANGLE INST NC RESEARCH TRIANGLE INST NC RESEARCH TRIANGLE INST NC ALA DEPT AGRI & INDUCTRIES AL TAMPA BAY RPC FL TENNESSEE (STATE OF) TN JACKSON MS LAKE CITY TN WACCAMAW RPDC SC BIRMINGHAM RPC AL FAYETTEVILLE NC TAMPA FL MAYSVILLE KY BERKLEY CHARLESTON DORCHESTSON LEE COUNTY FL GA DEPT NATURAL RESOURCES GA KNOXVILLE TN VALDOSTA GA SOUTH ALABAMA RPC AL JEFFERSON CO COMM AL GA DEPT OF AGRICULTURE GA WEST FLA RPC FL TUSKEGEE INSTITUTE AL ATLANTA UNIV CENTER GA REGION 4 = 59 FINAL REPORT ISSUED 10/21/83 03/15/84 03/13/84 03/15/84 03/13/84 02/16/84 02/29/84 02/16/84 12/19/83 10/21/83 12/30/83 03/15/84 03/13/84 03/15/84 03/13/84 02/16/84 02/29/84 02/16/84 01/16/84 10/04/83 03/30/84 01/26/84 10/18/83 10/21/83 02/10/84 01/09/84 12/22/83 10/21/83 11/16/83 12/13/83 03/13/84 03/28/84 03/28/84 10/21/83 10/27/83 12/02/83 12/02/83 10/18/83 1 1/30/83 01/16/84 12/19/83 02/01/84 02/01/84 10/14/83 12/16/83 03/15/84 02/01/84 02/29/84 02/29/84 03/15/84 03/13/84 03/13/84 02/2/84 11/16/83 03/28/84 03/1 5/84 11/16/83 11/17/83 01/16/84 42 ------- AUDIT CONTROL NUMBER C3FC4050 125-40671 C3FC40501 18-4061 7 C3FC40501 15-4061 5 C3FC4050096^10503 C3FC4050094-40501 C3FC4050065-40390 C3FC4050041 -40201 C3EC3050389-40020 C3EC3050387-40022 C3FC4050040-40200 C3FC4050021-40129 C3FC3050390-40023 C3FC3050388-40021 C3EW40501 36-40705 C3EC4050031-40130 C3EC4050020-40128 C3EC40501 24-40670 C3EC40501 17-4061 6 C3EC40501 14-4061 4 C3EC4050095-40502 C3EC4050093-40500 C3EC4050064-40389 C3EC4050039-40199 C3EC4050038-40198 D3AB405001 7-40041 D3AB4050029-40105 D3AB40501 03-40546 D3AB4050087-40480 D3AB4050052-40318 C3FW40501 37-40706 D3AB405001 5-40036 D3AB405001 4-40035 D3AB40500 13-40034 D3AB40500 10-40031 D3CB40501 32-40676 D3CB40501 22-40655 D3AB40501 23-40657 D3CB40501 16^061 8 D3CB4050 109-40570 D3CB4050086-40479 D3CB4050050-40286 D3DW3050233-40030 D3CW3050330-40029 H3AB4050034-40138 H3AB4050044-40210 H3AB405001 6-40040 H3AB405001 2-40033 H3AB405001 1-40032 N3GC405001 8-40067 N3GC4050037-40197 N3GC4050028^0106 N3GC40501 13-4061 3 N3GC4050047-40253 N3GC40501 26-40672 N3GC40501 39-40710 N3GC40501 38-40709 N3GC4050 127-40673 AUDITEE AKRON (CY 82) OH NIPC IL FORT WAYNE IN GLS REGION V P&D COMM, Ml BEECHER CITY IL SEMICOG (DETROIT) (FY 83) Ml IHCC (FY 81/82) GLSR5PDC(FY81) FLINT Ml GLS REG, V PDC (FY 80) FLINT M IHCC (FY 83) EDTA (FY 80/81) YOUNGSTOWN OH GLS R5 PDC (FY 81 (FLINT Ml GLS. REG, V PDC (FY 80) FLINT M INDIANAPOLIS (CY 82) IN EDTA FY80/81 YOUNGSTOWN OH EDTA (FY 80/81) YOUNGSTOWN OH AKRON (CY 82) OH NIPC IL FORT WAYNE IN GLS REGION V P&D COMM, Ml BEECHER CITY IL SEMICOG (DETROIT) (FY 83) Ml IHCC (FY 81/82) IHCC (FY 83) DBMS INC IL NT RES INST CHICAGO IL BMI COLUMBUS OH PEDCO CINCINNATI OH POPE-REID ASSOCIATES INC MN INDIANAPOLIS (CY 82) IN POPE-REID ASSOCIATES INC MN ENVIRONMENTAL HEALTH H&T OH ENVIRONMENTAL HEALTH H&T OH PEDCO CINCINNATI OH AT KEARNEY CHICAGO IL DALTON DALTON NEWPORT INC OH ENVIRONMENTAL HEALTH H&T OH GEOTECHNICS INC COLUMBUS OH SYSTEM CORP XENIA OH A T KEARNEY CHICAGO IL CONTROL DATA CORPORATION MN GREELEY & HANSEN (FY 82) GREELEY& HANSEN CHICAGO IL ST SCHOLASTICA COLLEGE MN IITIL MICHIGAN STATE UNIVERSITY Ml IN UNIVERSITY FOUNDATION U OF CINCINNATI OH MICHIGAN DNR(FY 81) GARY (CY 81) IN SC Ml PC (NAZARETH) Ml GREATER EGYPT RP&D COMM IL ROCKFORD IL WAUKESHA CY 82 Wl EVANSVILLE (CY 82) IN SAGINAW (FY 83) IN PEORIA CY 82 IL FINAL REPORT ISSUED 02/24/84 02/09/84 02/09/84 01/12/84 01/12/84 12/20/83 11/08/83 10/07/83 10/07/83 11/08/83 10/27/83 10/07/83 10/07/83 03/05/84 10/27/83 10/27/83 02/24/84 02/09/84 02/09/84 01/12/84 02/12/84 12/20/83 11/08/83 11/08/83 10/12/83 10/24/83 01/23/84 01/10/84 12/07/83 03/07/84 10/12/83 10/12/83 10/12/83 10/12/83 02/27/84 02/21/84 02/22/84 02/09/84 01/30/84 01/10/84 12/01/83 10/12/83 10/12/83 10/31/83 11/16/83 10/12/83 10/12/83 10/12/83 10/19/83 11/08/83 10/25/83 02/09/84 11/23/83 02/24/84 03/08/84 03/08/84 02/24/84 TOTAL OF REGION 5 = 57 43 ------- AUDIT CONTROL NUMBER AUDITEE D3AM4060090-40690 C3F03060204-40052 D3AM4060084-40649 D3AM4060040-40213 D3AM4060025-40125 D3A04060001 -40062 D3A04060002-40063 D3CM4060067-40473 D3CM4060007-40096 D3CM4060042-40289 D3CM4060024-40124 D3CM4960066-40472 D3CM4060045-40292 D3CM4060044-40291 D3CM4060043-40290 D3CM4060064-40397 D3CM4060056-40295 D3CM4060048-40294 D3CM4060046-40293 D3CM4060046-40293 D3CM4060077-40627 D3C04060058-40374 D3DM4060063-40396 D3D04060003-40064 H3CM4060089-40689 H3CU4060047-40217 N3GM4060059-40375 N3GM406007&40578 N3GM406007CM051 1 N3GM4060062-40450 N3GM4060061 -40379 03AM4060068-40474 N3GU4060057-40376 N3G04060006M0049 N3G03060203-40012 N3GM4060092-40722 N3GM4060085-40590 N3G03060202-40014 N3GM40601 00-40726 N3GM4060096-40724 N3GM4060094-40723 TOTAL OF C3FC4070070-40809 C3FC4070069-4081 1 C3FC407002 1-40274 C3FC4070003-40073 D3AH4070032-40408 D3AM4070033-40409 D38M4070039-40418 D3CA4070061 -40681 D3CM4070034-40410 D3CM4070031-40407 D3DM4070042-40440 D3DM4070059^0679 D3CW4070060-40680 N3GC4070048-40544 N3GC4070040-40437 N3GC4070067-40767 KEN E DAVIS HOUSTON TX PALESTINE AR ENGINEERING ENTERPRISES INC OK RICEUNIVTX K W BROWN & ASSOCE TX MAGIC & ASSOC TX MAGIC & ASSOC TX WALK HAYDEL & ASSOC LA CHARLES BARRETT & CO TX RADIAN CORP TX WALK HAYDEL & ASSOC LA WALK HAYDEL & ASSOC LA INTEL SYSTEMS CORP TX RADIAN CORP TX RADIAN CORP TX SUMX CORP TX RADIAN CORP TX RADIAN COPR TX RADINA CORP TX RADIAN CORP TX RADIAN CORP TX EG&G AUTOMOTIVE CHS GROUP ENGRS HOUSTON TX WALK HAYDEL & ASSOC LA FAYETTEVILLE AR OKLA STATE UNIV OK TEXAS RAILROAD COMM TX ASSOC OF CENTRAL OK GOVTS OK SE TEXAS RPC NEW MEXIXO DEPT NAT RES NM DALLAS TX SOLAR AMERICA NM CENTRAL TX COG TX LOWER RIO GRANDE VALLEY TX OSAGE NATION OK NO CENTRAL TEXAS COG TX MONROE LA TX DEPT OF HEALTH TX INDIAN NATIONS COG TX CLEBURNE TX MIDDLE RIO GRANDE COG NM REGION 6 = 40 HUTCHINSON CITY OF KS CEDAR RAPIDS CITY OF IA LIBERAL KS CITY OF BURLINGTON IA CITY OF BLACK & VEATCH CONSUL ENGRS MO MIDWEST RESRCH INST KS CITY MO MIDWEST RESRCH INST KS CITY MO MIDWEST RESEARCH INSTIT KS MO MIDWEST RESRCH INST KS CITY MO MIDWEST RESRCH INST KS CITY MO MIDWEST RESRCH INST KS CITY MO HOWARD NEEDLES TAMMEN & BERG M MIDWEST RESEARCH INSTIT KS MO SPRINGFIELD MO CITY OF KANSAS CITY MO CITY OF IOWA CONSERVATION COMM IA FINAL REPORT ISSUED 02/29/84 10/13/83 02/16/84 11/16/83 10/27/83 10/18/83 10/18/83 01/09/84 10/21/83 12/02/83 10/27/83 01/09/84 12/02/83 12/02/83 12/02/83 12/22/83 12/02/83 12/02/83 12/02/83 12/02/83 02/10/84 12/16/83 12/22/83 10/18/83 02/29/84 11/17/83 12/16/83 02/01/84 01/16/84 12/30/83 12/19/83 01/09/84 12/16/83 10/14/83 10/04/83 03/09/84 02/29/84 10/04/83 03/09/84 03/09/84 03/09/84 03/27/84 03/27/84 11/29/83 10/20/83 12/27/83 12/27/83 12/28/83 02/28/84 12/27/83 12/27/83 1 2/29/83 02/28/84 02/28/84 01/23/84 12/29/83 03/1 6/84 44 ------- AUDIT CONTROL NUMBER AUDITEE N3GC4070051 -40585 N3GC4070072-40825 N3GC4070004-40074 H3B04070054-40641 N3GC407001 9-40272 N3GC4070025-40322 N3GC4070020-40273 TOTAL OF C3FC4080027-40603 D3BM4080021 -40448 D3CM408001 8-4041 9 N3GC408003 1-40789 N3GC4080032-40810 N3GC4080034-40824 N3GC4080033-40823 N3GC4060006-40131 H3B04080004-40075 H3BM4080020-40447 N3GC40800 10-40262 N3GC4080007-40132 H3DM408001 9-40446 N3GC4080022-40517 N3GC408001 1-40263 H3BU4080009-40261 TOTAL OF C3FC40901 07-40808 D3AM4090075-40482 D3AM4090029-40227 D3AM4090032-40230 D3AM409003 1-40229 D3AM4090050^0420 D3AM4090056-40426 D3AM4090065-40441 D3AM4090064-40436 D3AM4090063-40435 D3AM4090062^0434 D3AP4090086-40606 D3CA4090028-40226 D3CA4090048-4041 1 D3CA409009&40682 D3CA4090081 -40575 D3CA4090076-40483 D3CA4090058-40428 D3CM4090025-40223 D3CM4090069-40462 D3CM409005 1-40421 D3CM4090030-40228 D3CM4090030-40228 D3CM4090053-40423 D3CM4090052-40422 MO DEPT OF NATURAL RESOURCES IOWA GEOLOGICAL SURVEY IA WICHITA KS CITY OF MISSOURI UNIV OF COLUMBIA MO SEDGWICK COUNTY WITCHITA KS NEBRASKA NATURAL RES COMM IOWA DEPT OF AGRI DES MOINES REGION 7 = 23 WY DEPT OF ENVIR QUALITY WY DENVER CO UNIV OF H E CRAMER SALT LAKE CITY OF THE SOUTHERN UTE INDIAN TR CO ROSEBUD SIOUX TRIBE CO BLACK HILLS COUNCIL OF GOVT SD MOUNTAINLANDS ASSN OF GOVTS UT GREAT FALLS CITY-CTY PLN BD MT COLORADO ST UNIV FORT COLLINS COLORADO RESEARCH INSTIT OF CO WASATCH FRONT REG COUNCIL UT CHEYENNE RIVER SOUIX TRIBE SD COLORADO RESEARCH INSTIT OF CO CO DEPT OF LOCAL AFFAIRS CO ST OF DEPT OF LABOR & EMPL UTAH UNIVERSITY OF SUL UT REGIONS = 16 HENDERSON CITY OF NV ROCKWELL INTL NEWBURY PARK CA TRW INC REDONDO BEACH CA PACIFIC ENVIR SERV S MONICA CA ENGINEERNG SCIENCE ARCADIA CA GEO/RESOURCE CONSULTANTS SF CA JACOBS ENGINEERING GROUP CA DEL GREEN ASSOC FOSTER CITY CA GEO/RESOURCE CONSULTANTS SF CA SYSTEM DEVELOPMENT COMP CA SYSTEM APPLICATION S HAFAEL CA TETRA TECH PASADENA CA CIC RESEARCH INC SAN DIEGO CA SYSTEM APPLICAT SAN RAFAEL CA AEROSPACE CORP EL SEGUNCO CA PACIFIC ENVIR SERV S MONICA CA ACUREX CORP MOUNTAIN VIEW CA PACIFIC ENVIR SERV S MONICA CA SRI INTERNATIONAL MENLO PARK CA SRI INTERNATIONAL MENLO PARK CA PACIFIC ENVIR SERV S MONICA CA TECHNOLOGY SER COR S MONICA CA TECHNOLOGY SER COR S MONICA CA SYSTEMS CONTROL PALO ALTO CA ENGINEERING SCIENCE ARCADIA CA FINAL REPORT ISSUED 02/02/84 03/29/84 10/20/83 02/16/84 11/29/83 12/08/83 11/29/83 02/07/84 12/29/83 12/28/83 03/20/84 03/27/84 03/29/84 03/29/84 10/27/83 12/29/83 12/29/83 11/25/83 10/27/83 12/29/83 01/17/84 11/25/83 11/25/83 03/27/84 01/10/84 11/17/83 11/17/83 11/17/83 12/28/83 12/28/83 12/19/83 12/29/83 12/29/83 12/29/83 02/07/84 11/17/83 12/27/83 02/28/84 01/31/84 01/10/84 12/28/83 11/17/83 11/04/84 12/28/83 11/17/83 11/17/83 12/28/83 12/28/83 45 ------- AUDIT CONTROL NUMBER AUDITEE D3CM4090054-40424 SCIENCE APPLICAT LA JOLLA CA D3CM40901 00-40684 SCIENCE APPLICATION INC CA D3CM4090085-40604 TRW INC REDONDO BEACH CA D3CM4090084-40584 SRI INTERNATIONAL MENLO PARK CA D3CM4090082^t0582 TRW INC REDONDO BEACH CA D3CM4090077^0504 SRI INTERNATIONAL MENLO PARK CA D3CM4090068-40461 SCIENCE APPLICAT LA JOLLA CA D3CM4090061^0433 BECHTEL NATIONAL SF CA D3CM4090060-40430 MCDONNELL DOUGLASS ASTRO CO CA D3CM4090059-40429 PACIFIC ENVIR SERV S MONICA CA D3DM4090026-40224 CALSCIENCE RESCH HUNTINGTON CA D3DM4090055^0425 ACUREX CORP MOUNTAIN VIEW CA D3DM4090027-40225 AEROCOMP INC COSTA MESA CA D3DM4090099-40683 ENERGY & ENVIR RESCH IRVINE CA D3DM4090083-40583 SRI INTERNATIONAL MENLO PARK CA D3DM4090067-40460 SYSTEMS CONTROL PALO ALTO CA D3DM4090057-40427 ACUREX CORP MOUNTAIN VIEW CA N3GC4090046-40353 SAN DIEGO ASOC OF GOVTS CA N3GC409001 5-401 34 TAHOE REG PLANNING AGENCY CA H3B04090066-40445 NEVADA UNIT OF RENO NV N3GC4090078-4051 6 SANTA BARBARA COUNTY CAPC CA N3GC409001 2-40323 GUAM COMMUNITY COLLEGE AGANA TOTAL OF REGION 9 = 48 C3FC41 00020-40324 GOLDENDALE WA CITY OF C3FC41 0001 8-40284 LONGVIEW WA CITY OF C3FC41 000 17-40283 CHEHALIS WA CITY OF C3FC41 0001 6-40282 VANCOUVER WA PORT OF C3FC41 00044-40827 PUYALLUP CITY OF WA C3FC41 00041 -40792 HOQUIAM CITY OF WA C3FC41 00030-40545 BLAINE WA CITY OF C3FC41 00025-40438 ABERDEEN WA CITY OF C3FC41 00023-40352 HARRAH WA CITY OF C3FC4100021^0325 TACOMA WA CITY OF D3AH41 0001 440232 CH2M HILL INC CORVALLIS OR D3AM41 00035-40634 CH2M HILL CORVALLIS OR D3AM4100082-40576 NERO & ASSOC. PORTLAND OR D3AM41 0001 3-40231 ENVIR EMERGCY RESP PORTLAND OR N3GC41 00033-40605 IDAHO DEPT OF WATER RESOURCE N3GC41 00038-40768 PORTLAND CITY OF OR N3GC41 00045-40828 SPOKANE COUNTY WA N3GC41 00039^0790 THRUSTON COUNTY WA N3GC41 00043-40826 LEWISTON CITY OF ID N3GC41 00040-40791 SEATTLE CITY OF WA N3GC41 0001 9-40285 KING COUNTY SEATTLE WA N3GC41 0001 0-401 33 ANCHORAGE MUNICIPALITY OF AK N3GC410002&40518 METRO SERV DIST OF PORTLAND OR TOTAL OF REGION 10 = 23 E3CH3 11 0032-40554 BUREAU OF EXPLOSIVES TOTAL OF HO = 1 TOTAL OTHER GRANTS & CONTRACT AUDITS = 464 FINAL REPORT ISSUED 12/28/83 02/27/84 02/07/84 02/02/84 02/02/84 01/04/84 01/04/84 12/29/83 12/28/83 12/28/83 11/17/83 12/28/83 11/17/83 02/28/84 02/02/84 01/04/84 12/28/83 12/13/83 10/27/83 12/29/83 01/17/84 12/08/83 12/08/83 12/01/83 12/01/83 12/01/83 03/29/84 03/20/84 01/23/84 12/29/83 12/13/83 12/08/83 11/17/83 02/14/84 01/31/84 11/17/83 02/07/84 03/16/84 03/29/84 03/20/84 03/29/84 03/20/84 12/01/83 10/27/83 01/17/84 01/25/84 46 ------- AUDIT CONTROL NUMBER AUDITEE FINAL REPORT ISSUED 5. SUPERFUND D5AH4010022-40182 E5CH4010035-40835 E5BH3010153-40533 E5BH3010059-40066 GCA CORP MA DEP ENVIR QUALITY ENG-DEQE MA RHODE ISLAND DEPT ENVIR MGMT R NEW HAMPSHIRE WATER SUPPLY NH TOTAL OF REGION 01 = 4 D5AH4020044-40280 ECOLOGY & ENVIRONMENT NY D5AH4020037-40164 FRED C HART ASSOC NY D5BM4020082-40758 CECOS INTERNATIONAL INC NY E5CH3020122-40086 NJS DEPT OF ENV PROTECTION NJ TOTAL OF REGION 02 = 4 E5EM4030036-40721 REMOVAL ACTIONS IN PROGRESS-MD TOTAL OF REGION 03 = 1 E5C03040195-40696 ROADSIDE PCB COOP ARGEEMENT NC E5ED3040271-40766 R4 SUPERFUND PAYROLL GA E5B03040262-40793 PEPPER STEEL ALLOYS MEDLEY = F E5B03040244-40100 R4 COOP AGREEMENT ST OF GA TOTAL OF REGION 04 = 4 D5AH4050042-40166 D5AH4050043-40191 E5CD3050344-40328 E5CH3050261-40667 P5CH3050226-40836 P5CH3050186-40248 0 H MATERIALS FINDLAY OH ACES INC OH 0 H MATERIALS FINDLAY OH 0 H MATERIALS (BRAKE CHEM) OH ENV MGT CORP (UTICA) Ml CHEMICAL WASTE MGT HOLDER TOTAL OF REGION 05 = 6 E5B03060160-40117 R6 COOP CRYSTAL CHEM CO SITE E5B03060159-40116 R6 COOP HARRIS ABANDONED WASTE E5B03060158-40115 R6 COOP SIKES DISPOSAL PIT E5B03060157-40114 H-6 HIGHLANDS ACID PTIS E5B03060156-40113 R-6 COOP BIO ECOLOGY HZD WASTE E5B03060155-40072 R-6COOP/TX FRENCH LIMITED SITE TOTAL OF REGION 06 = 6 D5AH4070041-40439 DEVELOP PLAN & RESCH ASOC KS OTAL OF REGION 07 = 1 D5AH4090017-40153 IT CORP WILINGTON CA D5AH4090045-40432 TETRA TECH PASADEN CA E5CH3090161-40204 IT CORP WILMINGTON CA TOTAL OF REGION 09 = 3 D5EH4110037-40830 D5BH4110026-40714 D5BH4110034-40762 D5BH4110028-40717 D5CH4110035-40761 D5CH4110032-40715 D5CH4110031 ^0720 D5CH4110030-40719 D5CH4110029-40718 D5CH4110027-40716 INTERNAL REVENUE SERVIC SCS ENGINEERS GCA TECHNOLOGY DIVISION NUS CORPORATION ECOLOGY AND ENVIRONMENT CLEMENT ASSOCIATES CAMP DRESSER & MCK MASSACHUSETTS INSTIT OF TECH MIDWEST RESEARCH INSTITUTE GEOMET TECHNOLOGIES INC TOTAL OF HEADQUARTERS = 10 TOTAL SUPERFUND AUDITS = 39 11/08/83 03/30/84 01/19/84 10/18/83 12/01/83 11/03/83 03/16/84 10/24/83 03/08/84 02/29/84 03/16/84 03/21/84 10/21/83 11/04/83 11/08/83 12/09/83 02/23/84 03/30/84 11/29/83 11/01/83 11/04/83 11/01/83 11/01/83 11/01/83 11/01/83 12/29/83 11/01/83 12/29/83 11/10/83 03/08/84 03/08/84 03/07/84 03/08/84 03/26/84 03/08/84 03/08/84 03/08/84 03/08/84 03/09/84 6. ALLEGATIONS E6AP311003&40622 HAZ EVAL DIV TIMEKEEPING TOTAL AUDITS OF ALLEGATIONS = 1 02/06/84 TOTAL AUDITS = 843 47 ------- CONTMT IF YOU KNOW OF ANY FRAUD, WASTE OR ABUSE. INFORMATION IS CONFIDENTIAL CALLER CAN BE ANONYMOUS CASH AWARDS FOR COST SAVINGS DISCLOSURES 800-424-4000 / 202-382-4977 48 ------- |