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

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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

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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

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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).

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 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.

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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

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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

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                        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

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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.

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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

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 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

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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

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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

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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

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         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

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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

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         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

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•  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


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 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

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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

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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

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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

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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 efforts—by
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

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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

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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

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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

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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

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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

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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

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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

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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

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                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

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