United States
      Environmental Protection
      Agency
               EPA-350-R-96-005
               February 1997
    4»EPA Office of the
      Inspector General
      Report to Congress
 nn
 n
IG

n-m
      Fiscal 1996


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           Office  of Inspector  General
  The Inspector General Act of 1978, as amended, created Offices of
  Inspector General (OIG) to consolidate existing investigative and audit
  resources in independent organizations headed by Inspectors General.
  For fiscal 1996, the EPA OIG received $40 million (including about
  $4.5 million in Agency support costs) and a funded staffing level of
  388  full-time equivalent positions.  The Inspector General (IG) is
  appointed by, and can  be  removed  only  by, the President.  The
  mission of the OIG, as stated in the IG Act, is to:
     •  Conduct and supervise independent and objective audits and
        investigations relating to agency programs and operations.
     •  Promote economy, effectiveness,  and efficiency in EPA.
     •  Prevent and  detect  fraud,  waste, and abuse in  agency
        programs.
     •  Review and make recommendations regarding existing and
        proposed  legislation  and  regulations relating  to  agency
        programs and operations.
     •  Keep the agency head and the Congress fully and currently
        informed of problems in agency programs.

  To ensure objectivity, the IG Act provides the IGs:
     •  Independence to determine what reviews to perform.
     •  Access to all information necessary for the reviews.
     •  Authority to publish findings and recommendations.
                           Who's Who
                       Inspector General
                       Nikki L. Tinsley (Acting)

                       Deputy Inspector General
                       Nikki L. Tinsley
Office of Audit

Kenneth A. Konz
Assistant IG

James O. Rauch
Principal Deputy

Elissa R. Karpf
Deputy for External Audits

Michael D. Simmons
Deputy for Internal Audits
Office of Management

John C. Jones
Assistant IG
  Kenneth D. Hockman
  Policy & Resources Mgmt
Office of Investigations

Allen P. Fallin
Assistant IG

Emmett D. Dashiell, Jr.
Deputy Assistant IG
  John T. Walsh
  Program Management Division

  Asa R. Frost
  Information Resources Management Division

  Michael J. Binder
  Budget & Reports Staff
  Robert F. Eagen
  Engineering & Scientific Assistance

  Patricia H. Hill
  AOP Audits and Assistance
  Divisional Inspectors General are listed on the back page.

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     /as of Significant  DIG Concern
Financial Management

The  OIG  has  reported in several  audits that EPA's  accounting
systems  do not provide complete,  consistent, reliable, and timely
data.  Although the Agency has  made a number of significant
improvements in financial management, additional actions are needed
to ensure that EPA has  trained staff, policies, procedures, and
systems to carry out these responsibilities effectively.

Management of Extramural Resources

EPA  relies extensively.on contractors and others to assist in cleaning
up pollution, setting the environmental agenda for the future, and
providing goods and services.  While we commend and support the
Agency's initiatives, management problems continue in this area.
We proposed grants administration as a material weakness candidate
for fiscal 1996.

Superfund

For three Superfund sites examined,  the prolonged time spent
studying sites and designing remedies continues to result in higher
cleanup  costs  and  ongoing  risks to  public  health and  the
environment.   We are also concerned with inadequate oversight of
interagency agreements resulting in cost overruns and  inefficient
cleanup  implementation.    Further, improvement  is  needed in
evaluating the quality of  laboratory data used for  making public
health  risk assessments,  developing  alternatives,  and  designing
remedies for potentially responsible party and Federal facility cleanup.

Air Programs

The  majority of published emission factors,  used  to estimate
emissions from a source when more reliable emissions data are not
available, were rated  low for  reliability  and  many  had not been
updated since 1988. EPA's use of industry partnerships to assist in
the development of emission  factors increased the risk that  non-
representative   or  inaccurate  factors   would  be   developed.
Accordingly, we  nominated emissions factor development as a
material  weakness  candidate for fiscal  1996.     Also,  state
enforcement programs have a limited deterrent effect because  they
are not well-publicized and often do not  assess the economic benefit
of violations.

Information Resources Management (IRM)

EPA's IRM program is critical to the success of all program activities.
The Agency's IRM program has been hampered by serious problems
for years. In 1996,  we reported that the Year 2000 problem could
cause failure of major EPA systems because computers store years
in two-digit  numeric fields, and the  "00"  entry  could result in
incorrect  computations.    Although  the  Office  of  Information
Resources Management (OIRM) has raised Agency awareness of data
processing problems associated with the Year 2000 problem, OIRM
needs to accelerate its actions to  reduce the imminent threat of
major systems failure.

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   Profile  of Activities and Results
                                              Fiscal 1996
                                             (dollars in millions)
Audit Operations	

• Questioned Costs (Ineligible, Unsupported, and
  Unnecessary/Unreasonable)
 -Total'                                         $291.4
 - Federal Share                                  $209.1

• Recommended Efficiencies
  (Funds be Put to Better Use)
   Total'                                          $62.2
 - Federal Share                                   $ 62.2

• Costs Disallowed to be Recovered
 - Federal Share                                   $ 59.1
   (costs which EPA management
   agrees are unallowable and
   is committed to recover or
   offset against future payments)

• Costs Disallowed as Cost Efficiency
 - Federal Share                                    $20.0
   (funds made available by EPA
   management's commitment to
   implement OIG recommendations)

• Recoveries from Audit                              $48.9
  Resolutions of Current and Prior
  Periods (cash  collections or offsets
  to future payments) * *

• Total Reports  Issued by OIG                           498

Investigative Operations	

• Fines and Recoveries (including civil)                   $5.6
• Investigations Opened                                 116
• Investigations Closed                                  142
• Indictments of Persons or Firms                         11
• Convictions of Persons or Firms                         11
• Administrative Actions Taken Against
  EPA Employees                                       23
• Civil Judgements                                       6

Fraud Detection and  Prevention Operations	

• Debarments, Suspensions, and
  Compliance Agreements                               17
  (actions to deny persons or firms from
  participating in EPA activities
  because of misconduct or poor
  performance)
• Hotline Cases Opened                                 21
• Hotline Cases Processed and Closed                    30
• Legislative and Regulatory Items Reviewed               83
• Personnel Security Investigations Adjudicated            602

 *  Questioned Costs  and Recommended Efficiencies are subject to
   change in the audit resolution process.
• * Information on recoveries is provided by the EPA Financial
   Management Division and is unaudited.

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      idit Activities
During this fiscal year, our audit efforts resulted in more than $60
million  in  recommended efficiencies,  nearly  $300  million  in
questioned  costs,  and  approximately  $50 million  in  Agency
recoveries from audit resolutions. The following represents some of
our most significant findings which resulted  from the 498 reports
issued by the OIG.

Inadequate  Oversight of  Drinking  Water  Programs Puts
Children at Risk
Region 3 did not require states to  provide information about their
lead and copper monitoring of small public water systems (PWS)
delaying  enforcement actions for removal of excessive lead from
drinking water consumed by children and infants.   In total, 40
percent of the small schools and day care centers we reviewed did
not comply with various aspects of the Lead and Copper Rule (LCR)
of the Safe Drinking  Water Act, yet the states did not inform EPA
until almost two years later.  The Agency also could not  evaluate
whether PWSs were  reducing lead in their  drinking water.  One
school provided more than 500 children, teachers, and  others with
drinking water that had more than four times the lead allowed by the
LCR.   States also did not  inform EPA  that several  PWSs had
excessive  copper in  drinking  water.  Further, there were several
adverse conditions  that EPA  should have  addressed  during its
reviews of state drinking water programs.  The Agency generally
agreed to  take appropriate actions to resolve  the audit issues.
However, Region 3 did not agree that states were required to provide
information concerning small PWSs.

Establishment of Supercomputing Center Violated Laws and
Potentially Wasted  Millions
EPA circumvented the General Services Administration  (GSA),
violated several laws, and acted without legislative authority  by using
a contractor  to acquire a building  for the National Environmental
Supercomputing Center (NESC) independent of GSA for an additional
$3.8 million over the five-year lease.  The Agency pre-selected  a
supercomputer site which  was twice  as large  as needed, and
manipulated the procurement process to have its contractor lease the
building which required significant renovation.  In effect, the Agency
gave government property to the developer by approving permanent
improvements to the NESC building as part of lease costs charged to
the contract.  EPA also exceeded its authority and violated Federal
law by obligating the government to reimburse its contractor $3.7
million for a lease that ran four and one-half  years longer than the
Agency's available appropriation. EPA's administration of the NESC
subcontract further violated  Federal laws  and  regulations, and
documentation  of significant decisions and activities related to the
establishment of the NESC was not preserved to protect the  interests
of the government.  The Agency disputed many of the findings but
agreed to implement the majority of recommendations.

Major Delays in Super-fund Cleanups  Increased Costs and
Potential  Health Risks
Despite identification  between  12 and  15  years ago, the three
Superfund  sites we reviewed  were still  not cleaned up.  The
prolonged time spent studying sites and designing remedies resulted
in higher cleanup costs and continued risks to public health and the
environment.  First, the Whitmoyer Laboratories site in Pennsylvania
entered the Superfund cleanup pipeline in  1984, but is still without

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completed actions. In 1988, an on-site vault containing
pounds of hazardous waste targeted for  removal at a
million, was not removed and the vault cleanup is being handled by
the remedial program at an estimated cost of $18 million.  Second,
the Wasatch Chemical site in Utah was discovered in 1980, but is
not  yet fully  cleaned  up.   In  1985,  EPA proposed  further
investigation and possible removal of an evaporation pond suspected
of contaminating ground water, but neither occurred. For the next
ten years, EPA conducted enforcement negotiations and two removal
actions, completed site studies, and began the remedial action.  In
1994, EPA  began cleanup using  innovative technology .at nearly
twice the original estimated  $3.3 million cost.  TJiird, the Southern
Maryland Wood Treating site was discovered in  1981, and although
$30 million has been spent on removal and remedial actions, the site
still is not cleaned up.  The Agency was not required to respond to
our report since the case studies were designed to "support a long-
range audit plan.

Over  $100  Million  in  Government  Property,  Including
Vehicles, Improperly Provided to Contractors
EPA has acquired hundreds of passenger vehicles in violation  of
statutory  restrictions.   In February 1996, the  Agency  reported
$138.3 million in government property held by contractors, despite
regulations requiring contractors to furnish all necessary property.
Included in the property are EPA-owned vehicles, buses, and vans
leased from the General Services  Administration for the Agency's
shuttle  bus  service,  and  scientific  equipment  used  at  EPA
laboratories.  The Office of Acquisition Management acknowledged
that it has become Agency-wide routine practice to provide property
(including vehicles)   to  contractors even  though prohibited by the
Federal Acquisition Regulation (FAR). In addition, EPA has incurred
expenses for over ten  years by maintaining  property inventories
despite a FAR provision specifying that the contractor's property
control records are sufficient. The Agency generally agree'd with our
recommendations and  committed to issuing  a policy  to  clarify
circumstances in which EPA may furnish property to contractors.

State LUST Programs Need to Focus on Most Hazardous Sites
Despite states' progress cleaning up Leaking Underground Storage
Tanks (LUST), enforcement and oversight of corrective action  to
protect human health and the environment was not adequate at  126
of the 249 high risk sites reviewed, including those with petroleum-
cohtaminated ground water. Most states had procedures focusing
corrective action on high risk sites,  but did not always follow them.
For example, one state was aware of a leaking underground tank but
took no action for 12 years, and then discovered that the site was
near a public water supply and posed a significant threat.  Another
state did not identify some sites that were  the most environmentally
threatening  to ground  water.   In  addition,  there were major
differences in results among state cost recovery programs. Of the
states reviewed, two  recovered significant amounts from owners
and  operators, three achieved partial recoveries, and two did not
have cost recovery  programs.  Also, state activity  reports were
generally unreliable and usually overstated program results, including
one  state that overstated cleanups by 47 percent.  The Agency
generally  disagreed  with our findings, but  agreed  with  the
recommendations or presented alternative actions  to meet their
intent.

Air  Program Goals  Impaired  by  Limited  Emission  Factor
Development
The Agency increased emission factors (used to estimate a source's
air pollutant emissions when more reliable data are not available) for
stationary and area sources from 2,073 in 1985 to over 16,000 in

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         owever, 7,840 factors were not rated, the vast majority
         published, and 4,865 published factors were rated below
average or poor for reliability, thereby reducing the effectiveness of
government and industry efforts to control air pollution.  Further, EPA
had not published emission factors for specific activities in the wood
products,  food  processing,  agricultural  related,  and  chemical
processes industries.  Significant funding reductions to the emission
factor development program materially affected EPA's ability to meet
the increased demand for quality emission factors, and the majority
of states did not use the funds EPA allocated for factor development
because Agency grant guidance was not timely or specific enough to
implement thfc program. In addition, EPA initiated partnerships with
industries to obtain assistance in emission factor development even
though   biased  or  unrepresentative  emission  factors  may  be
developed because industries have a financial motive to use emission
factors that produce low emission estimates to avoid obtaining a
permit or to pay lower annual fees.   The Agency concluded that
weaknesses in their emission factor development program did not
represent a material weakness in the FMFIA process, but agreed to
improve the program.

EPA Needs More Reliable Budgeting and Accounting
A pattern of errors in EPA's budgeting and accounting practices for
personnel  resources   made  financial  management  information
unreliable  for ensuring  compliance  with  congressional intent.
Outdated workload models were used to allocate personnel resources
resulting in regions not receiving resources  where they planned to
use them.  However, the regions did not reprogram the reallocation
of personnel costs  and they were inaccurately accumulated and
reported.  Thus, significant errors existed in two (of five regions
reviewed) regions' charging of personnel costs used to  develop
subsequent program budgets.  EPA's budget was not consistently
executed in the regions the way it was requested by Headquarters
and appropriated by Congress.   Therefore, many reprogrammings
were required to try to  reconcile the differences.  The Agency's ad
hoc creation of program elements over time reduced the consistency
and  comparability  of  budget   and  financial   data  for  internal
management purposes.   The  current budget structure  cannot
efficiently  capture  the information  required  to implement the
Government Performance and  Results Act because the activities do
not always align with  existing program  elements.   The Agency
agreed with most recommendations and has taken action to correct
some of the problems.

Inadequate Management of Contractors  Led to  Ineffective
and Costly Programs
Ineffective planning and inadequate oversight of a major contractor's
performance resulted in  some of the products and services procured
being untimely and/or  of questionable value.   The Green  Lights
program was more costly than necessary because EPA authorized the
contractor  to  perform  questionable  work without analyzing its
benefit or necessity. Also, one of the measures of the program was
misleading  because  the Agency  emphasized  the  number  and
prominence of its participants while omitting that many had made
little or no progress.  EPA did not adequately plan individual projects
under the Indoor Air Quality program resulting in unnecessary delays,
modifications, and increased costs. Three of the projects continued
for as many as six years, over several contract periods, exceeding
the original budgets by more than  $1  million.  In addition, the
administrative   costs  to  promote   EPA's  Local  Government
Reimbursement program were unreasonable in relation to the low
response.  During fiscal  1995, the Agency reimbursed approximately
$95,000 to four local  governments, yet paid  over $300,000 for
contracts to administer the  program.   The Agency disagreed with

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some specific issues, but agreed with most of the recomme
and has taken many actions to improve the Green Lights p'A

Improvements Needed  in EPA and  State Air Enforcement
Programs
Although Regions 5 and 6 and the states we reviewed had effective
aspects of their air enforcement programs, penalties often lacked an
economic benefit  component, enforcement  actions were  seldom
publicized, and air enforcement data were incomplete, inconsistent,
and untimely.  Region 5 and Michigan assessed the economic benefit
violators gained from noncompliance with air pollution regulations
when assessing fines,  but Indiana, Illinois, Wisconsin, Texas, and
Louisiana usually did not.  Penalties lacking an economic  benefit
component  are  not effective, since  it may  be less expensive to
violate the law than to comply with  it.  Regions 5 and 6 and the
states  reviewed  did  not  adequately publish  the  results  of
enforcement actions resulting-in companies having less incentive to
achieve or maintain compliance with regulations without the pressure
of public  opinion generated  by publicity. Region 5 had conducted
some compliance assistance activities but had not developed a core
program infrastructure of clear direction, priorities, or performance
measures, and was unable  to communicate a consistent compliance
assistance approach.  Region 6 worked with states to develop and
maintain  active  compliance assistance  programs, but did  not
complete timely enforcement actions against violators.  The Agency
agreed with our findings and recommendations.

Hazardous  Waste Risks Reduced,  but Inadequate Oversight
Resulted in Cost Overruns and Inefficient Cleanup
Region  8  responded  to  the  Summitville,  CO,  Superfund  site
emergency by reducing hazardous waste risks. However, the Region
did not adequately oversee Interagency Agreements (IAG) with the
Department  of  Interior's   Bureau  of Reclamation  (Reclamation)
resulting in seven  cost overruns totaling nearly  $7.3 million and an
inefficient cleanup.  The  Region  did  not enforce IAG terms and
conditions requiring Reclamation to submit current monthly progress
and cost reports. Payment requests were routinely approved without
reviewing required supporting  documentation.  In addition, the
Agency did not ensure that Reclamation used contracting methods
which would keep cleanup  costs down, and created an unnecessary
layer of general and administrative expenses, and profit, by allowing
Reclamation's contractor to procure subcontractors for cleanup.  The
Agency also created  a new contract vulnerability by  permitting
Reclamation to award both a fixed-price construction contract and a
related site-support time-and-materials delivery order to the same
contractor thereby providing an opportunity to  avoid losses and/or
maximize profits by mischarging costs.  The Agency issued new
guidance to improve IAG oversight and was preparing a workplan to
address the recommendations.

FACA Committees' Costs Nearly Doubled Since 1993
EPA's cost  to operate  Federal Advispry Committee Act (FACA)
committees  has increased from $4.9 million for 31 committees in
1993 to over $9 million for 22 committees in 1995.  The number of
Agency personnel involved  in FACA committee operations has grown
from 38 staff at a cost of $2.2 million in fiscal 1993, to 65 staff at
a cost of $3.6 million in fiscal 1995.  EPA's decentralized operations
appeared  to  contribute  to a duplication of similar administrative
functions resulting in the involvement  of more and higher paid
personnel than  necessary.   Although  a  central  Agency  office
administers FACA and consolidates cost data,  it  has no control over
individual  FACA committee funds, costs, or priorities since  each
program office funds  the  FACA committees it establishes.   The
Agency agreed to review FACA  administration functions.

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      Million Questioned on San Francisco Projects
        rded nine construction grants totaling $414,711,579 for the
design and construction of wastewater treatment facilities for the
Southwest Ocean Outfall Project, the Southeast Water Pollution
Control Plant, the Oceanside Water Pollution Control Plant, and
Bayside  pump stations, force mains,  and outfall  consolidation
projects.  The City and  County of San Francisco claimed $19.9
million of ineligible architectural engineering costs and other project
costs allocable to other Federal facilities, and costs outside the scope
of the approved  project.  We also questioned as  unreasonable
$164,198,771 of project  costs  related  to underused facilities.
Although the Southwest Ocean Outfall Project and the Oceanside
Water Pollution Control Plant were  designed with  a 450  million
gallons per day capacity, only five percent of the capacity was being
used.  In another audit, we found the City and County of San
Francisco also claimed  $2,812,732  of ineligible costs from EPA
grants for wastewater treatment facilities.

Over $18 Million Questioned on WSSC Claims
EPA awarded two construction grants totaling $45,053,170 to the
Washington   Suburban  Sanitary  Commission  (WSSC)  for the
construction  of modifications to an existing facility to provide an
advanced wastewater treatment plant, and additions to the Western
Branch wastewater treatment plant for additional solids and liquid
handling  facilities.    WSSC claimed  $7,481,336  of  ineligible
construction,  engineering,  and  administrative  costs.   We  also
questioned as unsupported  $8,897, 656  of construction change
orders that had not received an eligibility determination, delay costs
that could not be verified, and  miscellaneous costs  for which the
grantee  could not  provide  documentation.    Additionally,  we
questioned $1,826,158 as unreasonable  costs related to facility
segments and equipment that had been abandoned.

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   Investigative  Activities
During this fiscal year,  our  investigative efforts resulted  in  11
indictments, 11 convictions, and $5.6 million of fines and recoveries
from persons or firms who defrauded the Agency.

Former California Lab Manager and Director Sentenced
Eureka Laboratories, Inc.  (Eureka), of Sacramento, California, was
sentenced  in December 1995 to 60 months probation, fined $1.5
million, and ordered to pay restitution of $322,422.   Kuen  Lee, a
former Eureka laboratory manager, was sentenced in December 1995
to 5 months incarceration  followed by 36 months probation and 250
hours of community service.  Chung  Li, former Eureka Director of
Laboratory Services, was sentenced in November 1995 to 24 months
incarceration followed  by 36  months probation and 250 hours of
community service.  The  defendants  conspired to falsify  analytical
test results and calibration of laboratory equipment compromising the
accuracy and  reliability of the test results vital to the successful
identification  of  hazardous substances  and  the remediation  of
hazardous waste  sites. Eureka is an analytical services laboratory
contracted by several government agencies to test water, soil, and
air samples for pollutants and toxins.  The  case was investigated by
the EPA DIG, the U.S. Army Criminal Investigation Command, the
U.S. Air Force Office of  Special Investigations, and'the California
Environmental Protection  Agency.

Florida Export Company and Official Sentenced
Marman USA, Inc. (Marman), a Florida pesticide export company,
and its vice-president, Robert T. Renes, were sentenced in July 1996
after  each pleaded  guilty  to  forging a  government  seal.   The
corporation was  sentenced to  two  years  probation and  fined
$350,000. Renes was sentenced to three years probation and fined
$150,000.  Marman falsified documentation included in a package
submitted for a pesticide product registration in Ecuador, along with
notarized documents signed by EPA employees under the official seal
of EPA.   The  case  was investigated by the  EPA DIG  with the
assistance of the  EPA Criminal Investigations Division and the U.S.
Customs Service.

Former Employee Sentenced in AM EX Scam
Jean Safford, a former EPA secretary, was sentenced in December
1995 to  24  months  in  prison to  be followed  by three  years
probation, fined $120,000, and ordered to pay restitution of $7,200.
Stafford  pleaded guilty  in August  1995 after an investigation
disclosed  a scheme to use at least eight fraudulently obtained
American Express government credit cards.  The case was initiated
based on information that an unknown EPA employee had obtained
an  American  Express government  credit  card  by using false
identification and charged  over  $10,000 in goods and services over
a three-week period.  The case was investigated jointly by the EPA
OIG, Secret Service, and Postal Inspection Service.

Training Provider Guilty of Selling Certificates
Robert G. Cooley, former owner and operator of I. P.C. Chicago, Inc.,
a business  authorized to  provide certified asbestos abatement
training, pleaded guilty in July 1996 to mail fraud.  In June 1996,
Cooley was charged with defrauding the Illinois Department of Public
Health and  EPA  by selling training  certificates to workers and
contractors without requiring class attendance.  These certificates

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       ed to obtain the initial and renewal state licenses to work on
        state- and federally-funded  projects,  including  asbestos
abatement projects in public schools.  Depending on the course,
Cooley charged  $75 to $550 for the training  certificates.  The
investigation was conducted jointly by the EPA DIG, the FBI, the
General  Services  Administration  DIG, and the  EPA  Criminal
Investigations Division.

Corporate President Pleads Guilty to Conspiracy
Robert Feller, president of Non Hazardous Incineration (NHI), a non-
hazardous waste broker in New Jersey, pleaded guilty to conspiracy
to create and distribute a phony EPA approval letter in April 1996.
Feller knew that one of NHI's major clients produced transdermal
nicotine patches and attempted to persuade several people  at EPA to
reclassify the patches as non-hazardous waste.  When EPA refused
Feller's request, he conspired to create and distribute a phony EPA
letter stating that transdermal nicotine patches were not classified as
hazardous waste. The case was investigated by the EPA  DIG.

Illinois Businessmen Charged with Conspiracy
William Foss, president of Loyalty Environmental, Inc. (Loyalty), of
Skokie, Illinois, a private company engaged  primarily in  asbestos
abatement, was indicted in May 1996  for  conspiracy and making
false  statements.   Also charged  were Mark  Zander, a Loyalty
estimator and salesman; Michael Cahill, an estimator and  salesman
employed by Eau Claire Mechanical Insulation of Orland Park, Illinois;
and David Shewmake, an insurance agent from Crestwood, Illinois.
In March  1991, the Chicago Board of Education accepted  Loyalty's
bid of $1,290,132 for asbestos abatement at Kennedy High School,
but the bid package did not include a bid bond.  A second round of
bids were accepted on the same job in May 1991, including  one from
Loyalty of  $1,444,015. The indictment charged that Shewmake
obtained a power of attorney form  reflecting  authorization of a bid
bond on behalf of Indiana "Lumberman's" Mutual Insurance  Company
and an embossing device bearing the name of the company from a
local printer.  It further charged that Zander  signed  the fraudulent
document as an authorized representative of the insurance  company
with a fictitious name along with William Foss.  The investigation
was conducted by the EPA DIG.

EPA Contractor Employee Indicted for Soliciting Kickback
Keith McCullough, a contractor employee in Region 3, was indicted
in September 1996 for allegedly soliciting a kickback related to  a
government contract.  According to the indictment, McCullough
entered into  an  agreement  with  Cabletron  Systems,  Inc.,  of
Rochester, New Hampshire, for a ten percent  kickback on  the value
of a Local Area Network contract that he would facilitate  awarding
to Cabletron.  McCullough was  an  employee  of  Management
Technology, Inc., which was contracted by  the General Services
Administration  to  run  the computer  room in Region  3.   The
investigation was conducted jointly by the EPA DIG and the FBI.

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   Fraud  Prevention  Activities
Suspension and Debarment Activities
EPA's policy is to do business only with contractors and assistance
recipients who are honest and responsible. EPA enforces this policy
by suspending  or debarring contractors, assistance recipients, or
individuals  within those  organizations,  from  further  contracts or
assistance  for acting improperly, having a history of substandard
work, or willfully failing to perform on EPA- or other federally-funded
activities.  Both procurement and nonprocurement debarments or
suspensions by one agency are effective in all  agencies.

In fiscal 1996, 17 debarment, suspension, or compliance agreement
actions were taken, based on the work of the DIG, including the
following:

  •   EPA  debarred Keith L. Westbrook in November 1995 for three
      years.  Westbrook had pleaded guilty to felony theft charges
      as a  conspirator in a $1.2 million embezzlement of funds used
      to construct sewage treatment plants and other water quality
      improvements in Maryland.

  •    In March 1996, EPA suspended Khemsafe Environmental, Inc.,
      and its president, Inno Obiorah, after a multi-count indictment
      involving  larceny,  fraud, and  falsifying  business  records.
      Many of the offenses occurred in  conjunction with asbestos
      removal in schools.

  •    In June 1996, EPA debarred Scott R.  Rippey, a Commissioned
      Officer  of the U.S.  Public Health  Service,  and  William
      Burkhardt, a  Food and  Drug  Administration employee, for
      knowingly filing false confidential statements of employment
      and financial interest.  Both failed to disclose their ownership
      and employment interest in Biosearch Limited, New England
      Scientific, and Biological Analytical Laboratories  (BAD. EPA
      contracted with BAL on the Narragansett Bay project.

  •    EPA  suspended Pauline M. Ewald, President, Environmental
      Compliance Organization (ECO) in November  1995.  In its
      proposals to obtain contacts from the recipients of Superfund
      Technical Assistance Grants, ECO submitted false resumes
      by misrepresenting  degrees and professional certifications,
      including those for people not employed by ECO.
Personnel  Security Program
The Personnel Security Program is one of the Agency's first lines of
defense against fraud, using background investigations to review the
integrity of EPA employees and contractors.  During fiscal 1996, the
OIG reviewed and adjudicated 602 investigations.  Based on the,
OIG's activities, the Agency took  appropriate  actions,  including
terminations and reprimands for falsification or omission on SF- 171s
or security questionnaires.

Hotline  Activities
The OIG Hotline opened 21 new cases and completed and closed 30
cases during  fiscal 1996.   Of the  30 cases closed, 9 resulted in
environmental,  prosecutive, or administrative  corrective  action.
Cases that did not  have  immediate  validity due  to  insufficient

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            may be used to identify trends or patterns of potentially
 vulnewrole areas for future reviews.

i The following are examples of corrective action resulting from calls
 to the OIG Hotline:
       • A  complainant alleged time and attendance abuse and
         falsification  of timekeeping  documents by a  regional
         employee.   The allegations  were substantiated  and  the
         timekeeper was suspended and given a written reprimand.

      •  A complainant alleged misuse of government resources by
         a senior Headquarters official.  A review disclosed that the
         official had  conducted personal business on government
         time using government resources.  The official received an
         oral reprimand.

       • A complainant alleged that a regional manager  frequently
         engaged in  inappropriate speech and  behavior.   The
         allegations   were  substantiated  and the  manager  was
         directed to attend training on cultural diversity and sexual
         harassment.

 OIG Streamlining and Management Improvement
 The OIG continued to improve its efficiency and value to the Agency
 through  organizational streamlining,  strategic  planning,  and
 technology.   To meet  Government Performance and Results Act
 requirements, a team  of Office of Audit, Office of Investigations, and
 Office of Management staff developed an OIG Strategic Plan that will
 guide our future audit and investigative activities. All three offices
 were preparing or enhancing performance  measures, and  the OIG
 also worked on customer service  plans that  will  identify who  our
 customers are, how often we will survey them, what we will ask,
 and how we will  use  responses to  improve operations.

 The OIG streamlined  OIG Manual Chapters, bulletins, and guidance
 to eliminate one-half of internal regulations as required by executive
 order. In addition, OIG offices participated  in developing a new OIG
 management information system that will consolidate and enhance
 the usefulness of information on the multiple systems in use. Our
 system  plan, which  is  being developed by a GSA contractor and
 includes input from both Headquarters and field office staff, specifies
 our    system    needs,   computer   equipment,   software,
 telecommunications requirements, cost estimates, and schedules.
 We also reviewed workload to determine long-range staffing needs
 which will form the basis for the OIG position management plan that
 will allocate resources among offices and locations.

• The OIG participated as  a full partner in implementing EPA's National
 Environmental Performance Partnership System (NEPPS) to ensure
 success of the program. .We participated in Agency workgroups to
 rewrite Federal regulations that affect performance partnership grants
 and   OIG divisional  staff  worked  directly with regional  staff  on
 NEPPS issues.   We  also reviewed two demonstration grants to
 identify lessons learned from these early endeavors. In addition, OIG
 staff participated as panel  members at  EPA's 'National Grants
 Management Conference and All  States  Conference,  and gave
 presentations at the Assistance Agreement Project Officer Training
 courses sponsored by the Agency's program offices.

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   Divisional  Inspectors  General
                Audit
Headquarters
Regions 1  & 2


Region 3
    Headquarters Audit Division
    Edward Gekosky

    Financial Audit Division
    Melissa M. Heist

    Washington Contract
    Division
    Gordon C. Milbourn III

    Eastern Audit Division
    Paul D. McKechnie

    Mid-Atlantic Audit Division
    Carl A. Jannetti
Region 4 & RTP    Southern Audit Division
                  Mary M. Boyer
Region 5
    Northern Audit Division
    Anthony C. Carrollo
Regions 6, 7 & 8   Central Audit Division
                  Bennie S. Salem
Regions 9 & 10
    Western Audit Division
    Truman R. Beeler

Investigations
(703) 308-8222


(202)260-1479


(703) 308-8224



(617) 565-3160


(215) 566-5800


(404) 562-9830


(312) 353-2486


(913) 551-7878


(415) 744-2445
Headquarters


Regions 1, 2 & 3
Regions 4, 5, 6
        &7
Regions 8, 9
       & 10
    Washington Field Division   (703) 308-8282
    David Sermos
    Eastern Investigations
    Division
    Thomas L. Papineau

    Central Investigations
    Division
    Ailverdes Cornelious

    Western Investigations
    Division
    Mark Vallerga
(617)565-3928
(312)353-2507
(206)553-1273
If you are aware of any fraud, waste, or mismanagement, please
contact the EPA Inspector  General Hotline or the appropriate
Divisional Inspector General. Information is confidential. The Hotline
may be reached at (202) 260-4977.

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     GET A HOLD
     ON  SPENDING
REPORT FRAUD, WASTE, OR ABUSE TO THE
   INSPECTOR GENERAL
        HOTLINE
   •  INFORMATION IS CONFIDENTIAL

        202-260-4977
US. ENVMONMBfTAL mOTECtlON AGENCY • OFFICE OP THE DiSrECTO* GENERAL • 4*1 M STREET S.W. WASHINGTON, D.C. IMM

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