United States Office of the inscsctor General Seotember 198.9
Environmental Protection 401 M St. SW
Agency Washington. OC 20460
&EPA ERA'S Office of the
Inspector General
Annual
Superfund Report
to the Congress
for Fiscal 1988
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FOREWORD
This is our second Annual Superfund Report to the Congress,
covering fiscal 1988 activities. The Superfund Amendments and
Reauthorization Act of 1986 (SARA) requires the Office of
Inspector General (OIG) to annually audit the Superfund program
and to provide an annual report to Congress on these required
audits.
The advent of the Superfund program created new and unique
cost accounting requirements. EPA over the past several years
has responded to these new requirements by significantly
improving its ability to accurately account for and document
Superfund costs. However, we found that the Agency still needs
to take corrective action for fiscal 1988 in the areas of: (1)
accounting for and controlling personal property; (2) allocating
general support services costs; and (3) recording accounts
receivable.
In addition to reviewing Agency performance, we also take a
proactive role assisting EPA management to prevent future
problems. This includes review of draft documents and
participation in EPA work group meetings. Superfund program
areas with a particularly high level of OIG proactive work during
fiscal 1988 included the removal program, technical assistance
grants to citizens' groups and cooperative agreements with
States.
The EPA Administrator is required by SARA to submit to
Congress an annual Superfund progress report on January 1 of each
year covering activities during the prior fiscal year. EPA's
first such report, due January 1, 1988, was submitted May 11,
1989. We are required by SARA to review that report for
reasonableness and accuracy; and our report is to be included in
the Agency report. We have summarized the results of our first
such review in this report.
We will continue to assist Agency management to deliver the
most effective and efficient Superfund program through a
comprehensive program of audits, investigations and fraud
prevention.
ohn C. Martin
nspector General
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TABLE OF CONTENTS
Page
Purpose 1
Background 3
Hazardous Substance Superfund 5
Cooperative Agreements 10
Remedial Investigations and Feasibility Studies 19
Other Internal and Management Audits 22
Financial and Compliance Audits 44
Assistance to EPA Management 46
Review of Agency's Superfund Progress Report 49
Exhibit I - Hazardous Substance Superfund
Schedule of Obligations 51
Exhibit II - Hazardous Substance Superfund
Schedule of Disbursements .54
Exhibit III - Superfund Audit Reports Issued
During Fiscal 1988 57
Appendix A - Acronyms and Abbreviations 62
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PURPOSE
This report is provided pursuant to Section lll(k) of the
Comprehensive Environmental Response, Compensation, and Liability
Act (CERCLA) of 1980, as amended. The Superfund Amendments and
Reauthorization Act (SARA) of 1986 amended that section of CERCLA
to add several annual requirements for the Inspector General of
each Federal agency carrying out CERCLA authorities. These
requirements include four audit areas and an annual report to
Congress regarding the required audit work. This report covers
fiscal 1988 audits of Superfund activities. The required four
audit areas are discussed below.
This report contains chapters on three of the four mandated
areas where we performed reviews. We are also summarizing other
Superfund audit work and assistance to EPA management which we
performed during fiscal 1988. In addition to fulfilling the
statutory requirements, the objectives of this report include
providing the Congress with significant results of all of our
Superfund audit work and a better understanding of how the Office
of Inspector General is carrying out its purposes with respect to
the Superfund program.
Trust Fund
CERCLA requires ". . .an annual audit of all payments,
obligations, reimbursements, or other uses of the Fund in the
prior fiscal year . . . ." We call this our Trust Fund audit and
it constitutes a financial and compliance audit of EPA
obligations and disbursements from the Hazardous Substance
Superfund during the fiscal year.
Claims
CERCLA requires an annual audit to assure "... that claims
are being appropriately and expeditiously considered . . . ."
Since SARA did not include natural resource damage claims as
allowable Fund expenditures, the only claims provided in CERCLA,
as amended, are response claims. No claims were submitted during
fiscal 1988. In future years, we will audit claims which are of
sufficient size to be considered material.
Cooperative Agreements
CERCLA requires audits ". . . of a sample of agreements with
States (in accordance with the provisions of the Single Audit
Act) carrying out response actions under this title . . . ." We
perform financial and compliance audits of cooperative agreements
with States. In some instances, our audits also review program
performance. In addition, we sometimes review EPA regional
management of the cooperative agreement program. Due to the
large number of cooperative agreements audited in recent fiscal
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years, and the time needed to obtain audit services contracts, we
completed only one audit of a Superfund response cooperative
agreement and one other Superfund assistance audit in fiscal
1988. Several others were initiated in fiscal 1988, but not
completed until fiscal 1989.
Remedial Investigations/Feasibility Studies fRI/FSl
CERCLA requires our "... examination of remedial
investigations and feasibility studies prepared for remedial
actions . . . ." Our RI/FS examinations provide a technical
review of the adequacy of the studies to provide a sound
technical basis for remedial action decisions. These
examinations maybe done as part of audits of EPA management or as
special reviews by our technical staff. At the time SARA was
enacted, we had not performed any such examinations and our
available technical resources for this purpose were limited.
Only one report on RI/FS examinations was issued during fiscal
1988, although others were in progress.
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BACKGROUND
The "Superfund" program was established by the Comprehensive
Environmental Response, Compensation, and Liability Act of 1980
(CERCLA), Public Law 96-510, enacted on December 11, 1980. The
Superfund program was created to protect public health and the
environment from release, or threat of release, of hazardous
substances from abandoned hazardous waste sites and other sources
where response was not required by other Federal laws. A Trust
Fund was established by CERCLA to provide funding for responses
ranging from control of emergency situations to permanent
remedies at uncontrolled sites. CERCLA authorized a $1.6 billion
program financed by a five-year environmental tax on industry and
some general revenues. CERCLA requires that response, or payment
for response, be sought from those responsible for the problem,
including property owners, generators, and transporters.
CERCLA was revised and expanded by the Superfund Amendments
and Reauthorization Act of 1986 (SARA), Public Law 99-499,
enacted October 17, 1986. SARA reinstituted the environmental
tax and expanded the taxing mechanism available for a five-year
period. It authorized an $8.5 billion program for the 1987-1991
period. The Trust Fund was renamed the Hazardous Substance
Superfund.
The basic regulatory blueprint for the Superfund program is
the National Oil and Hazardous Substances Contingency Plan (NCP),
40 CFR Part 300. The NCP was first published in 1968 as part of
the Federal Water Pollution Control Plan, and has been
substantially revised to meet CERCLA requirements. The NCP lays
out two broad categories of response: removals and remedial
response. Removals are relatively short-term responses and
modify an earlier program under the Clean Water Act. Remedial
response is long-term planning and action to provide permanent
remedies for serious abandoned or uncontrolled hazardous waste
sites.
CERCLA recognized that the Federal Government can only
assume responsibility for remedial response at a limited number
of sites representing the greatest public threat. Therefore, EPA
must maintain a National Priorities List (NPL), which must be
updated at least annually. The NPL is composed primarily of
sites which have been ranked on the basis of a standard scoring
system, which evaluates their potential threat to public health.
In addition, each state was allowed to designate its highest
priority site, without regard to the ranking system.
CERCLA section 104(c)(3) provides that no remedial actions
shall be taken unless the State in which the release occurs
enters into a contract or cooperative agreement with EPA to
provide certain assurances, including cost sharing. At most
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sites, the State must pay 10 percent of the costs of remedial
action. Preremedial activities (preliminary assessments, site
inspections), remedial planning (remedial investigations,
feasibility studies, remedial designs), and removals may be
funded at 100 percent by EPA. For facilities operated by a State
or political subdivision at the time of disposal of hazardous
substances, the State must pay 50 percent of all response costs,
including removals and remedial planning previously conducted.
CERCLA 104(d)(l) provides that if a State or political
subdivision is determined to have the capability to respond to
the issues addressed in the Act, they may be authorized to
respond by use of a contract or cooperative agreement. As a
result, most States have participated in some part of the
Superfund program. CERCLA 104(d)(2) provides a remedy to the
Federal Government for failure of a State or political
subdivision to perform satisfactorily.
The use of cooperative agreements is authorized by sections
104(c)(3) and 104(d) of CERCLA. Cooperative agreements allow a
State or political subdivision to take, or to participate in, any
necessary actions provided under CERCLA, given that the State or
political subdivision possess the necessary skills and
capabilities to do so. These actions are normally addressed in
the cooperative agreement as performance goals and objectives.
The agreement is also used to delineate EPA and State
responsibilities for actions to be taken at the site, to obtain
required assurances, and as a commitment of Federal funding. EPA
uses the cooperative agreement as a means of encouraging State
participation in Superfund activities such as the preremedial
programs, State management assistance on EPA lead activities, and
State lead sites.
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HAZARDOUS SUBSTANCE SUPERFUND
SCOPE AND OBJECTIVES
We contracted with an independent public accounting (IPA)
firm to perform an audit of EPA's portion of the Hazardous
Substance Superfund (Trust Fund) for the fiscal year ended
September 30, 1988. This audit included tests of the accounting
records at EPA's 10 regional offices, 3 major laboratory
facilities and Headquarters. The IPA also evaluated the internal
accounting controls for Superfund at those locations and the
National Enforcement Investigations Center (NEIC), including a
review of electronic data processing (EDP) controls; and
performed other auditing procedures that were considered
necessary in the circumstances. Additionally, the IPA reviewed
the status of findings and recommendations included in the prior
audit report covering the fiscal year ended September 30, 1987.
As part of the audit, the IPA selectively tested (using
statistical samples) transactions which obligated and disbursed
funds for Superfund activities. The objectives of this audit
were to determine if:
(1) The Schedules of Obligations and Disbursements
were presented fairly in accordance with
applicable laws, regulations and guidelines;
(2) EPA management complied with laws and regulations
which, if not followed, might have a material
effect upon the Schedules of Obligations and
Disbursements; and
(3) EPA established an adequate system of internal
accounting control to ensure the reliability of
applicable financial management records.
It was not within the scope of this audit to determine the
allowability and allocability of the general support services
cost pools that were accumulated and allocated to Superfund or to
verify the bases for these allocations. Audit procedures for
cost allocations were limited to reviewing methodologies, testing
the mathematical accuracy, and verifying that the allocations
were made in a timely manner. The review of EDP controls was
limited to the source document and data entry controls on
obligation and disbursement transactions.
SUMMARY OF FINDINGS
The advent of the Superfund program created new and unique
cost accounting requirements which previously were not necessary.
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EPA's accounting system, like those of most government agencies,
was geared to account for costs on an appropriation basis.
Therefore, EPA needed to enhance its existing accounting system.
EPA over the past several years has responded to these new
requirements by significantly improving its ability to accurately
account for and document Superfund costs.
In response to a prior audit report, which covered fiscal
1987 financial transactions, the Agency indicated that corrective
action would be taken in the areas cited in that report.
However, the corrective actions described were not scheduled to
take place until after fiscal 1988. The IPA found that the
Agency still needs to take corrective actions for fiscal 1988 in
the areas of (1) accounting for and controlling personal
property; (2) recording and managing accounts receivable; and (3)
allocating general support services costs.
FINDINGS
1. FINANCIAL RESULTS OF AUDIT
During fiscal 1988, EPA obligated over $1.4
billion and disbursed over $790 million. The IPA
questioned amounts that were recorded more than once,
that did not agree with supporting documentation or for
which supporting documentation was not available. In
addition, they questioned costs for general support
services improperly allocated to the Trust Fund. The
financial results of this audit are summarized below
and detailed in exhibits I and II.
Total Accepted Questioned1
Fiscal 1988 $1,462,291,365 $1,462,200,219 $ 91,146
Obligations
Fiscal 1988 $ 790,352,173 $ 790,120,106 $232,067
Disbursements
The IPA recommended that EPA review and resolve
the questioned transactions.
2. ACCOUNTING FOR AND CONTROLLING PERSONAL PROPERTY
EPA needs to improve its accounting for and
controlling personal property. The audit disclosed the
Superfund interest in the property was not properly
protected since: (i) items were not always recorded in
EPA's management records; (ii) some items could not be
1 Questioned costs are costs that are unallowable under the
provisions of applicable laws, regulations, or policies.
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located; and (ill) annual physical inventories were not
taken at all locations.
The IPA identified 303 items of personal property
that should have been included in EPA's Personal
Property Accounting System (PPAS), but were not. The
cost of this property exceeded $2.2 million. There
were various reasons why EPA property purchases were
not recorded in the property records. In some cases,
receiving documents were not sent by contracting
offices or custodial officers to EPA's property
accountable officers (PAOs) when property was ordered
or received. For example, the IPA found that Superfund
property valued at $516,301 purchased by one location
for another location had not been recorded in PPAS
because documents were not forwarded to the PAOs.
The IPA also discovered EPA could not locate 95
items of personal property selected for physical
inspection. These items were valued at $321,307. No
complete annual physical inventories or reconciliations
were performed for fiscal 1988 at Regions 3, 4, 5, 6,
9, and 10; NEIC; and laboratories located at
Narragansett, Rhode Island, and Duluth, Minnesota.
Such physical inventories are required by Agency
directives, and would have identified missing property.
The IPA recommended that Agency management:
o require the appropriate property accountable
officers to retain copies of certifications that
corrections of property records have been made,
along with supporting documentation, for review by
the auditors;
o require that the auditors be provided with copies
of the guidance to be issued on procedures for the
reconciliation of property and accounting records;
and
o require custodial officers at Region 2 to sign
Memorandums of Acceptance by Custodial Officers
according to Agency policy, or change the Agency
guidance to eliminate the requirement for a signed
memorandum of acceptance.
3. ACCOUNTS RECEIVABLE
A review of Superfund accounts receivable
indicated that improvements were needed to ensure
that: (1) all receivables are recorded in a timely
manner; (2) action is taken to ensure collection of
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debts; and (3) the dollar value of each receivable is
recorded correctly in the Agency's Financial Management
System (FMS). For the purposes of this report,
accounts receivable are defined as moneys due EPA, such
as refunds for overpayments of contracts, cooperative
agreements or grants; repayment of travel advances;
penalties; and cost recovery actions.
A non-statistical sample of 40 collections
totaling $37,470,396, out of a total collection
universe of $61,059,052, disclosed that 24, totaling
$25,928,734, were not recorded as receivables until
after a check in payment was received. Generally,
these receivables should have been recorded by the
Headquarters finance office based on documents provided
by others. To ensure more timely recording of
receivables, Agency management shifted this
responsibility to the regional finance offices for
fiscal 1989. This measure, along with better
procedures and close communication between the program
and finance offices, should improve timeliness in
recording receivables.
Improvements were needed in collection actions to
ensure that debtors promptly pay the Agency. The IPA
noted that one regional finance office was not sending
demand letters to debtors for receivables over 31 days
old. Such demand letters are required by Agency
directives. Additionally, the accounting report for
the Headquarters finance office did not separate the
current portion of installment receivables. Thus, it
was misleading and ineffective in identifying when
collection action was needed.
The IPA found that incorrect amounts for accounts
receivable were entered into FMS. An account
receivable for $22,232 was incorrectly recorded as
$222,232, resulting in an overstatement of accounts
receivable of $200,000. In addition, the auditors
noted that another receivable for $2,717,447 was
entered three times, resulting in an overstatement of
accounts receivable of $5,434,894. As a result,
Superfund accounts receivable at Headquarters were
overstated by $5,634,894, as of September 30, 1988.
4. ALLOCATION OF GENERAL SUPPORT SERVICES COSTS
EPA needs to improve and implement clear and
concise procedures for allocating general support
services costs to ensure costs charged to Superfund
represent actual benefits received. The IPA found that
allocations of general support services costs as well
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as personnel support costs were not always made, and
that the methodology used to allocate telephone
expenses at Region 3 was not an authorized method. The
IPA questioned $60,670 of obligations and $47,385 of
disbursements, which were the differences between the
unauthorized method used by Region 3 and the authorized
method, which requires using full-time equivalent (FTE)
ratios.
Also, at Region 1, due to administrative ceiling
limitations, $15,005 of allocable costs were not
allocated to the Superfund appropriation. In addition,
Cincinnati's Financial Management Center excluded 1,574
hours from their personnel support cost allocation to
Superfund, amounting to approximately $16,932, due to
ceiling limitations. From the IPA's analysis of
Superfund ceiling limitations Agency-wide, it appeared
that the Region 1 and Cincinnati costs could have been
charged to Superfund.
The IPA recommended that Agency management:
o retain documentation supporting the adjustments to
Region 3's cost allocations for review by the
auditors; and
o review the budgetary ceilings at Region 1 and
Cincinnati to ensure that all appropriate
Superfund support costs can be charged to
Superfund in the future.
AGENCY RESPONSE
The final audit report was issued on September 22, 1989,
Audit Report Number P1SFF8-11-0048-9100488. The Assistant
Administrator for Administration and Resources Management has 90
days to act on the recommendations made in the report and to
report to us on the status of these actions. In response to the
draft audit report, Agency management indicated general agreement
with our recommendations. Many of the problems identified were
addressed through immediate or planned corrective actions.
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COOPERATIVE AGREEMENTS
In fiscal 1988, we issued an audit report covering two
Superfund response cooperative agreements with the New Hampshire
Department of Environmental Services. We also issued an audit
report on a lead-in-soil demonstration project cooperative
agreement with the Trustees of Health and Hospitals of the City
of Boston, Inc. Several other Superfund cooperative agreement
audits were initiated, but not completed, during fiscal 1988.
A. NEW HAMPSHIRE DEPARTMENT OF ENVIRONMENTAL SERVICES
Scope and Objectives
We conducted an interim audit of the New Hampshire
Department of Environmental Services Water Supply and
Pollution Control Division administration of its cooperative
agreements for remedial activities at the Nashua and Keefe
sites. At the time of our audit field work, the State body
administering the agreements was called the New Hampshire
Water Supply and Pollution Control Commission. The primary
objectives of our review were:
1. To determine the adequacy, effectiveness and
reliability of procurement, accounting and
management controls exercised by the State in
administering its cooperative agreements;
2. To ascertain the State's compliance with
provisions of the cooperative agreements and
applicable EPA regulations and instructions; and
3. To determine the reasonableness, allocability and
allowability of the costs claimed under the
cooperative agreements through June 30, 1985.
Findings
1. State Resident Engineer and On-Scene Coordinator
Services Were Procured Without Competition
The Commission awarded consulting engineer service
agreements for resident engineer and on-scene coordinator
services with current and former Commission employees in a
manner that did not afford maximum free and open
competition. The Commission awarded contracts with four
engineers on a sole source noncompetitive basis. Three of
the four engineers terminated their employment with the
Commission on one day, and on the following day executed a
contract with the Commission at a higher rate of pay. One
of the engineers was rehired by the Commission at the
completion of the contract period at the same annual salary
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paid when previously employed by the Commission to provide a
continuation of the type of services provided under the
contract. The Commission paid for health insurance, FICA
taxes, mileage and vacations for the engineers under
contract; benefits normally provided only to employees of
the Commission. The Commission's contracting procedures
violated applicable Federal and State regulations. As a
result, we set aside $163,268 in costs claimed for EPA
review.
2. Commission Needs to Perform Cost Analysis of Negotiated
Change Orders
The Commission had not documented the performance of
cost analyses of contract change orders in excess of
$10,000, as required by applicable Federal regulations. For
one contract, a change order increased the contract price by
60 percent. For another contract, a change order increased
the contract price by 46 percent. In addition, one of the
change orders included an excessive pay rate for a Safety
Officer. As a result, we set aside $565,211 in costs
claimed for EPA review.
3. Commission Has Not Complied With Superfund Procurement
Requirements
There was no evidence that the Commission had evaluated
its procurement system and certified that it met EPA
procurement requirements or, in the absence of such a
certification, allowed an EPA preaward review of proposed
procurement actions. As a result, there were limited
assurances that the Commission's procurements were made in
accordance with applicable Federal regulations. The
Commission's procurement system was certified in 1976 under
EPA's construction grant regulations, but was never
certified under regulations applicable to Superfund
cooperative agreements.
4. Inadequate Property Management Standards
The Commission did not maintain its property records in
accordance with property management standards required by
applicable EPA regulations. The Commission (i) charged
equipment costs to site-specific cooperative agreements
which were used in the general operations of the Commission;
(ii) failed to maintain property records for all equipment;
and (iii) made no periodic reconciliation of physical
inventory to verify current use and continued need for
property acquired with Federal funds. As a result, the
Commission could not assure proper control and
accountability over property purchased with Federal funds.
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Recommendations
We recommended that EPA Region 1:
o Instruct its staff to review the propriety of the
Commission's actions in the execution of the sole
source contracts with engineers. In performing
this review, staff should require the Commission
to provide their:
1. basis for contractor selection;
2. written justification for selection of the
procurement method used rather than utilizing
the Commission's pregualified list; and
3. basis for award cost or price, including cost
or price analysis made as well as
justification for the payment of benefits
such as health insurance, FICA and vacations.
A legal opinion should be requested as to whether
the practice has violated any existing Federal or
State law. Based upon the results of the review,
any costs not properly incurred or deemed
ineligible for other reasons should be reimbursed
by the Commission to the Superfund account.
o The Commission be instructed to award contracts
only if the conform to prescribed Federal and
State procurement procedures. EPA should closely
monitor the Commission's compliance.
o Instruct the Commission to perform a cost analysis
of the change orders and provide justification for
the amount of the costs charged under the
agreement. Should the Commission be unable or
unwilling to adequately support the costs as
reasonable, EPA should disallow that portion which
is not adequately supported as reasonable.
o Instruct the EPA Regional Counsel to provide an
opinion as to whether a recipient can segment its
procurement system and certify its compliance with
EPA regulations in a piecemeal manner. Should
such a practice be deemed unacceptable, the
Commission should be requested to provide the
required certification for its entire procurement
system. Should the Commission be unable or
unwilling to provide such a certification, or
until such time as such a certification is
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provided, the Commission should be instructed to
provide all proposed procurements to EPA for
preaward reviews as required by 40 CFR Part 33.
o EPA staff review the adequacy of the improvements
implemented by the Commission to its property
management system to assure that:
1. Property records are current;
2. Superfund equipment purchases are in
compliance with Federal property management
standards; and
3. Proper credit was provided for the cost of
equipment which was improperly charged to the
Superfund cooperative agreements.
Agency Response
In response to the report, EPA Region 1:
o Directed the New Hampshire Department of Environmental
Services (NHDES) to comply with EPA regulations in all
future procurements, and provide EPA with a copy of
revised procedures for the procurement of engineering
services consistent with those regulations.
o Directed NHDES to provide all proposed procurements to
EPA for pre-award reviews until the required
certification of its entire procurement system is
provided and reviewed and accepted by EPA.
o Obtained documentation supporting change order costs.
o Directed NHDES to credit the cooperative agreements for
$28,701 in costs disallowed for inadequately documented
miscellaneous purchases, fringe benefits for consultant
engineers and ineligible property costs.
o Agreed to review the NHDES1 property management system
to insure proper control of property purchases and
disposition, and instruct NHDES to conduct a physical
inventory as required by EPA regulation.
B. TRUSTEES OF. HEALTH AND HOSPITALS OF THE CITY OF BOSTON, INC.
Scope and Objectives
We conducted an interim audit of the administration of
a lead-in-soil demonstration project cooperative agreement
awarded to the Trustees of Health and Hospitals of the City
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of Boston, Incorporated. The Trustees have designated this
project as the Lead Free Kids (LFK) program. Our audit
covered the period May 27, 1987 to February 29, 1988. The
objectives of the review were to determine whether the
Trustees:
1. charged costs to the LFK program which were
necessary, reasonable and eligible under the terms
of the cooperative agreement;
2. were managing the LFK program in an efficient and
effective manner; and
3. were meeting the program objectives established by
the cooperative agreement.
Findings
1. The Trustees Have Not Implemented the Lead-in-Soil
Demonstration Program in a Timely Manner
A project to determine the effect of lead contaminated
soil on the blood levels of children had yet to be
implemented due to the Trustees slow progress in developing
a sound program design. The delay had been caused by
conflicting expectations regarding the roles EPA and the
Trustees were to play in designing the project, unsettled
scientific issues, a change in program direction, and
compliance with the Massachusetts Lead Law. As of September
1988, the Region 1 Administrator approved a design proposed
by the Trustees. Both EPA and the Trustees needed to
improve the management of this project through better
communication and understanding of their responsibilities.
EPA needed to be aggressive in ensuring that the Trustees
fulfill their responsibilities rather than taking on the
duties itself. The Trustees needed to be more aggressive in
accepting and carrying out their responsibilities. The
Trustees also needed to be flexible in adjusting to the
changes of a demonstration project.
2. Need to Strengthen Administrative Controls
The Trustees needed to exert greater administrative
control over program activities. The Trustees had
established procedures regarding procurement, payroll,
inventory and reporting requirements; however, compliance
had been limited in these areas. Without strong
administrative controls in all areas, EPA had limited
assurance that Federal funds were efficiently expended. We
set aside $107,054 in consultant fees as a result of poor
procurement practices and the need for further documentation
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of services provided. The administrative weaknesses are
summarized below:
a. Weak Procurement Practices. The Trustees had not
assured that the LFK staff complies with the
principles of open and free competition when
obtaining consultant services. As a result, we
set aside $107,054. The Trustees published a
Request for Proposals (RFP) that did not contain
all the necessary information to enable a
prospective offeror to prepare a proposal, failed
to provide sufficient time for preparation of a
proposal, and did not contain all evaluation
criteria with the relative importance attached to
each criterion. Our review of the proposals
indicated that qualified firms were rejected,
while there was not documentation of the
qualifications of the two selected firms. One
firm began providing contracted services five days
before the final date for submissions under the
RFP.
b. Poor Contract Management. The Trustees did not
execute written contracts with the two consultants
who received the largest consultant fees. Without
an executed agreement, EPA had limited assurance
that the consultants would provide all services
agreed upon in accordance with Federal cost
principles. For a third consultant, a contract
was executed with the City of Boston's Office of
Environmental Affairs rather than with the
Trustees.
c. Unsupported Consultant Services. Satisfactory
evidence for justification of the work performed
by one consultant was not provided by the
Trustees. The consultant was hired to provide
recruitment services. However, there is little
evidence that the consultant provided all the
recruitment duties per its bid proposal. In
addition, this consultant provided community
relations work and charged $16,625 for sending
pamphlets and telephoning various community
organizations. We have contacted some of these
organizations and found that the organization
staff had either not heard of the LFK program or
received minimal information either by phone or
pamphlet. The documentation provided did not
support the costs. We set aside recruitment costs
of $19,250 and community relations costs of
$16,625.
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d. Lack of Control Over Payroll Recordkeepinq. The
leave and attendance records maintained by the LFK
staff could not be reconciled to the Trustees1
payroll records. The program staff did not follow
the Trustees' personnel policies, nor did they
obtain an exemption from these policies. As a
result, some employees were overpaid.
e. Property Management Records Not Maintained. The
Trustees did not maintain property management
records for equipment purchased with Federal
funds. Without proper controls, EPA had limited
assurance that assets were properly safeguarded
and that equipment purchased for the program was
not used for other activities.
f. Non-Compliance With Reporting Requirements. The
Trustees did not provide timely reports in
accordance with various special conditions of the
cooperative agreement. EPA cannot properly
monitor the project's financial and operational
activities without the agreed upon reports.
g. Budgetary Controls Not Implemented. The Trustees'
system to monitor budgets was not being used for
this project. The Trustees' Compliance Manager
advised us attempts to obtain a budget from the
Project Manager were futile. Our review did not
disclose any unauthorized expenditures; however,
by not adhering to a system of controls, EPA had
limited assurance that future expenditures will be
controlled.
Recommendat ions
We recommended that EPA Region 1:
o Clarify the roles and responsibilities EPA and the
Trustees will assume, set deadlines for tasks,
impose sanctions when warranted, and approve key
program personnel who have been committed to
specific tasks by the Trustees.
o Instruct the Trustees to explain why the RFP was
not more specific regarding selection criteria,
why none of the twelve offerers were considered
qualified, how the two selected consultants had
considerable experience as opposed to the other
offerers, and why a contract was awarded prior to
the deadline for proposal submissions. EPA staff
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should review the Trustees' procurement actions
during future monitoring visits.
o Instruct the Trustees to award all contracts in
accordance with Federal regulations, sign all
contracts, ensure that services and costs are
specifically defined in all contracts, ensure that
amendments or change orders are issued for
contract changes, and submit contracts over
$10,000 for EPA review to assure compliance with
all Federal regulations.
o Require the Trustees to fully document the need
for and use of consultant services for recruitment
and community relations. EPA should determine
ineligible those costs for which adequate
documentation is not obtained or for which the
charges were not reasonable.
o Instruct the Trustees to document that LFK payroll
records have been reconciled to the Trustees
payroll records, adjust leave consistent with the
Trustees Personnel Manual, develop an internal
control system to assure accurate source
documentation for payroll costs, and train LFK
program staff in Trustees' personnel policies.
o Instruct the Trustees to provide EPA with evidence
that all equipment purchased with Federal funds is
properly recorded for inventory, that mileage logs
are utilized, and vehicle keys are properly
safeguarded.
o Instruct the Trustees to provide assurance they
will meet reporting deadlines.
o Ensure that the Trustees take appropriate actions
to implement proper budgetary controls for this
project.
Agency Response
In response to our final report, the Agency:
o Amended cooperative agreement special conditions to
define roles and responsibilities of EPA and the
Trustees; set deadlines for tasks; incorporate
sanctions, where appropriate; ensure that procurements
are conducted properly and contracts properly executed;
and implement proper budgetary controls.
o Approved four key LFK project personnel.
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o Obtained documentation from the Trustees on recruitment
and community relations activities conducted by a
consultant, and the costs charged for them.
o Disallowed $8,250 in consultant community relations
charges.
o Required the Trustees to submit future consultant
invoices and proper support documentation for them.
o Directed the Trustees to comply with their personnel
policies in relation to the LFK project.
o Required Trustees to maintain proper inventory records,
mileage logs and vehicle key security.
o Emphasized to Trustees their responsibility to submit
required reports.
The allowability of consultant recruitment charges was
not yet resolved when this report was prepared.
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REMEDIAL INVESTIGATIONS AND FEASIBILITY STUDIES
While we had begun a number of examinations of remedial
investigations/feasibility studies (RI/FSs), we issued only one
report on such reviews during fiscal 1988. This report covered
our reviews of two RI/FSs. The two reviewed were of the Pioneer
Sand site in Pensacola, Florida and the Whitehouse Waste Oil Pits
site in Whitehouse, Florida. Both RI/FSs were performed under
cooperative agreements with the Florida Department of
Environmental Regulation (FDER).
Pioneer Sand
Our review of the Pioneer Sand project files provided no
evidence of technical problems related to the RI/FS.
Whitehouse Waste Oil Pits
Our technical review of the Whitehouse Waste Oil Pits
project files found the RI/FS to be adequate. It satisfied the
stated intent of the published program guidance and criteria and
selected applicable alternative criteria for site remediation.
The record of decision (ROD) for the Whitehouse site was
signed on May 30, 1985. The selected remedy consisted of:
o Construction of a slurry wall around the entire site;
o Extraction and treatment of all contaminated
groundwater;
o Removal of contaminated sediments from the northeast
tributary of McGirts Creek; and
o Grading of the site surface and recapping the area with
low permeability material.
While the RI/FS was considered technically adequate, there
were technical problems that delayed the entire remedial action
process. Controversy surrounding the remedial alternative
selected for the Whitehouse site was generated when the remedial
design engineer indicated that the groundwater treatment process
selected for the site was inappropriate. This resulted from a
treatability study which determined that the removal of non-
volatile organics utilizing carbon absorption was not feasible.
In addition, results of the study indicated that the Operation
and Maintenance (O&M) costs had been substantially underestimated
due to the quantities of chemical additives required in the
treatment process resulting in an increase in the sludge volume.
Additionally, the reliability of the analysis of the shallow.
aquifer performed by the U.S. Geological Survey was questioned
because of problems encountered during the pumping test. Twenty-
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four months after the ROD was signed, the design engineer relayed
three concerns to the U.S. Army Corps of Engineers, EPA and FDER
which resulted in suspension of further design activities until
additional studies were completed. These studies were to:
o Provide additional chemical characterization of the
groundwater, define the physical and chemical
properties of the waste oil sludge, and determine the
vertical and horizontal limits of the groundwater plume
and the sludge;
o Design, install and pump-test a test recovery well
within the contaminated area to determine the aquifer
contents and the time variations of contaminant
concentrations in the groundwater; and
o Investigate any "new cleanup technology" that might be
employed at the site.
When we inspected the site in September 1987, we observed
numerous areas where the cap had eroded. We also noted two
locations where the hazardous waste had broken through the cap.
The FDER representative accompanying us stated the hot summer
weather caused the cap to crack allowing the material to "boil
up" through the cap.
The information generated by the groundwater treatability
study would have been more useful and effective had it been
accomplished during the feasibility study. This would have
resulted in less confusion and delays in determining the ultimate
groundwater treatment process to be utilized, thus eliminating
the delays encountered by additional water treatment studies.
It was suggested by FDER that improvements in technology and
cost breakthroughs in the field of hazardous waste cleanup be
investigated to determine if a less costly remedial action was
available to effect site cleanup. As of September 1988, more
than three years after the ROD was signed, no decision had been
made regarding final configuration of the remedial design. The
treatability study performed by the Office of Research and
Development found solidification to be an appropriate remedy;
however, additional testing would be required. A treatability
study for the Hume Extraction Process, a new technology, was
planned to begin within the following month. Region 4 officials
estimated a decision on the design configuration would be made by
February 1989.
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Recommendations
We recommended that EPA Region 4:
o implement a high priority permanent site remedy and
escalate their evaluation of the new technologies to be
used at the Whitehouse site as required by SARA; and
o establish a priority completion schedule and closely
monitor additional studies to allow resumption of the
remedial design so final remedial cleanup action can be
accomplished.
Aaencv Response
EPA Region 4, responded that it agreed that a more permanent
site remedy should be considered for the Whitehouse Waste Oil
Pits site. Treatability studies for the most promising
alternative would take about a year. EPA was to meet with FDER
to make a decision whether to implement the present remedy or
begin the treatability phase. Since EPA responded to the audit,
it has contracted for additional feasibility study work.
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OTHER INTERNAL AND MANAGEMENT AUDITS
In addition to reviews required by CERCLA, as amended, we
reviewed other aspects of EPA's management of the Superfund
program, as our resources permitted. Such reviews completed in
fiscal 1988 are summarized below.
A. REGION 4'S MANAGEMENT OF SIGNIFICANT SUPERFUND REMOVAL
ACTIONS
Scope and Objectives
Our objective was to evaluate Region 4's effectiveness
and efficiency in managing significant removal actions at
Superfund sites. Specifically, we determined whether:
1. Sites were properly evaluated and classified as
removals in accordance with the guidelines set forth in
the National Contingency Plan.
2. Immediate removal was the most effective and efficient
option at the time.
3. The cleanup method selected was appropriate for the
site.
4. Actions taken mitigated the site hazards.
5. Environmental laws were adhered to during the removal
action, or deviations therefrom were properly
justified.
6. Responsible parties were identified and appropriately
pursued to share in the cost of the cleanup.
We selected two significant (costs of over $1 million)
removal actions from nine on-going removals in Region 4 as
of April 1987. These removals were at the Peak Oil site
near Tampa, Florida and the General Refining site near
Savannah, Georgia. In addition to work by our audit and
engineering staffs, the EPA National Enforcement
Investigations Center (NEIC) performed for us site
investigations at both sites.
Findings
1. Immediate Removal Authority Exceeded
Region 4 continued unwarranted immediate removal
activities after stabilizing the hazards at the General
Refining and Peak Oil sites. At both sites, the on-scene
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coordinators (OSCs) took immediate actions to stabilize the
site hazards. The hazards at General Refining were
stabilized within one month with less than $50,000 expended.
At Peak Oil, stabilization occurred within four months with
less than $255,000 expended. In the case of Peak Oil, the
site should have been referred to the region's remedial
personnel for an extended evaluation and assessment. The
General Refining site should have been considered for a
planned removal or cooperative agreement with the State.
However, instead of taking the proper action, Region 4
arranged for the mobilization, funding and testing of
unproven cleanup technologies selected for the respective
sites. The continuation of cleanup activities under the
auspices of immediate removal was not justified and should
not have been undertaken. The OSCs presented misleading
reports and gained approval for work beyond the statutory
dollar ($1 million) and time (6 month) limits allowed by the
immediate removal authority. As a result, Region 4 expended
$5.3 million over two years which exceeded the immediate
removal authority.
2. Commercial Testing and Development Funded
Region 4 funded commercial testing and development of
two hazardous waste treatment prototypes: Shirco Infrared
Systems1 infrared incinerator and Resources Conservation
Company's Basic Extraction Sludge Treatment (BEST) unit. To
fund the tests, Region 4 side-stepped several internal
controls; such as permitting, delisting and contracting
regulations. Region 4's selection of the two technologies
was speculative and unsupported by scientific or engineering
fact. Nonetheless, both prototypes were used to conduct
full-scale operations at removal sites prior to evidence the
manufacturer's performance claims were true. In selecting
the technologies for testing. Region 4 did not apply
appropriate funding and testing controls. As a result of
the region's actions, the two commercial enterprises
benefitted from tests costing the Superfund $5.3 million.
The costs of the tests conducted should have been borne by
the technology manufacturers; thus the funds expended were
misused.
3. Incineration Did Not Meet Standards
The prototype incinerator did not meet requirements set
forth by the Toxic Substances Control Act, the Resource
Conservation and Recovery Act and EPA's own policies.
Region 4, by not following its own stated testing plan for
the incinerator, allowed production-level operations to
commence without first conducting required tests. The first
formal test burn was conducted after five months of burning
2,257 tons of hazardous waste. Burning was then allowed to
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continue after formal tests indicated the prototype
incinerator did not meet incineration standards.
Consequently, PCBs and particulates (mainly lead) were
released into the air and thousands of gallons of wastewater
containing lead were sent to the local wastewater treatment
plant.
4. Regional Cleanup Preempted State Action
Region 4 preempted the State of Florida's planned
cleanup of the Peak Oil site. Florida officials had
notified the region of their intentions to conduct a removal
at the Peak Oil site. The region initially indicated that
time and budgetary constraints prevented EPA involvement.
However, the region later became interested in the site.
Due to confusing discussions and letters, the State delayed
its plan to incinerate at Peak Oil under a false impression
it needed an incineration permit. Region 4 never offered a
contractual agreement for a State-lead cleanup, and
eventually took over cleanup of the site. The region's
actions discouraged the State's participation. If the State
had funded all or part of the cleanup, the EPA could have
used the Superfund money spent at Peak Oil on other
Superfund sites.
5. Enforcement Action Incomplete
EPA did not take adequate action to pursue a
responsible party cleanup for the General Refining site.
Regional personnel did not follow proper enforcement
procedures after coming to a conclusion the responsible
party was financially incapable of cleaning up the site.
The decision to finance the cleanup with Superfund monies
was based on verbal representations of indigence made by the
responsible party. However, written correspondence from the
responsible party is not as clear, since he states he would
help in any way with site cleanup. Nonetheless, regional
personnel started cleanup without first giving the
responsible party an opportunity to respond to a legal
notice. Further, the region continued to preclude
responsible party involvement after evidence was available
to indicate the responsible party may have had financial
assets. As a result, EPA may have unnecessarily spent
Superfund monies to clean up the site, as well as possibly
lost any opportunity to recover treble damages from the
involved responsible party.
6. Questionable Contracting Methods
Contracting methods used to fund testing and
development of unproven technologies did not follow
established Agency procurement policies and procedures. For
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instance, delivery orders did not include total known costs
or scope of work, and cost comparisons were not properly
supported. Also, EPA personnel allowed contractors to start
work prior (up to eight months) to signing delivery orders
and did not subject the technology manufacturers to the
competitive bidding process. As a result, several
procurement procedures, which should have prevented the
activities carried on at General Refining and Peak Oil after
the stabilization of the site hazards, did not affect the
projects at all.
7. Sites Remained Contaminated
Lead and PCB still contaminated the General Refining
and Peak Oil sites at the conclusion of our review. Post-
treatment testing disclosed that the sites are not clear of
the hazards which originally attracted the EPA's attention;
cleanup efforts are still needed to dispose of on-site
contaminated materials after the expending of $6 million.
At both sites, the primary problem is waste piles which
contain excessive levels of lead. The problems at both
sites stem from EPA personnel misjudging the capabilities of
the selected treatment technologies and the fact that
neither technology worked as promised by the manufacturer.
Three of four manufacturer-advertised merits of the BEST
system proved inaccurate during actual use of the prototype.
At Peak Oil, the OSC did not adequately address the problems
associated with the site's lead contamination. The infrared
incinerator was advertised as offering a permanent solution
to the known lead hazard; a claim which EPA personnel
discounted from the beginning. Nonetheless, the incinerator
was used and lead remains a hazard at the site.
Recommendations
We recommended that EPA Region 4:
o Establish and implement adequate controls to ensure
that removals did not continue beyond limits
established by CERCLA, as amended, and the National
Contingency Plan.
o Establish and implement a formal review process for
proposed exemptions from statutory time and dollar
limits to ensure that the conditions for the exemptions
have been met. This process should include
verification of site conditions where appropriate.
o Ensure that adequate testing and independent
verification is conducted whenever consideration is
given to selecting a technology that has not been
proven for the type of waste being treated.
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Establish and implement adequate internal controls to
ensure that removal actions are conducted in accordance
with applicable environmental standards. These
controls should include frequent monitoring of affected
media and treatment products, and provision for
suspension of operations until needed corrective
measures are implemented to the extent the immediacy of
the hazard permits.
Establish and implement adequate internal controls to
ensure that state-funded response at removal sites are
facilitated appropriately, and that Federal funds are
reserved for sites where response by another party is
not feasible.
Establish and implement adequate internal controls to
ensure compliance with Headquarters enforcement
directives and guidance. This includes taking all
appropriate measures to obtain response from
potentially responsible parties and to provide the
strongest possible basis for cost recovery.
Establish and implement adequate internal controls to
ensure that on-scene coordinators do not go beyond the
limits of their authority by permitting contractors to
begin work and incur expenses prior to obtaining the
contracting officer's approval.
Establish and implement standard documentation and
filing procedures to ensure project files contain
complete documentation of the history of site planning,
authorizations and response actions taken.
Establish and implement adequate controls to ensure
that contract delivery order scopes of work prepared by
regional personnel are clearly defined, avoid open-
ended wording and require contractors to meet
performance objectives for proprietary technologies.
Establish and implement adequate controls to ensure
that on-scene coordinators effectively monitor
contractors to achieve treatment standards required by
contractual terms.
Take appropriate measures to ensure that the hazards
remaining at General Refining and Peak Oil after prior
removal activities are adequately addressed.
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Agency Response
During the audit resolution process, EPA Region 4
indicated that it will:
o Comply with new Agency procedures regarding the
preparation and approval of action memorandums
involving the statutory limits, and document
supervisory review of the memorandums;
o Incorporate available technological expertise in the
decision process when identifying possible
treatment/destruction technologies to determine their
protectiveness, economies, degree of field provability,
and impact on statutory limits;
o Use, where appropriate, bench and field treatability
studies and field demonstration results to develop the
best technical evaluation of potential technology for a
removal action;
o Comply with new Agency procedures regarding approval
levels required when considering the use of alternative
technology at removal sites;
o Maintain a strong and aggressive testing program to
ensure that removal actions are conducted in accordance
with applicable environmental standards;
o Suspend response operations, where necessary, when
environmental standards specified in contractual
obligations are not met;
o Comply with new Agency procedures regarding which
environmental standards must be met in removal actions;
o Pursue recovery of a portion of the funds awarded
Haztech, as a result of the Haztech/Shirco litigation,
due to failure of the incinerator to meet certain
performance standards;
o Reserve Federal funds only for those sites where
response by responsible parties is not feasible;
o Pursue cost recovery against the PRPs for the General
Refinery site;
o Aggressively use administrative orders and
notice/access to information letters with PRPs;
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o Use site-specific competitive bidding, Pre-Qualified
Offerers Procurement Strategy, or other appropriate
bidding procedures to obtain specialized technologies;
o Comply with new Agency procedures regarding
standardized site files, establishment of on-scene
coordinator administrative support positions, and use
of the Removal Cost Management System;
o Have regional contracting officers support the on-scene
coordinators so that delivery orders and other
documents involving contractor direction or performance
are sufficiently clear and identify the objectives to
be met, and contractual terms are met; and
o Conduct additional cleanup activities at the General
Refining and Peak Oil sites.
The question of which environmental standards apply to
the incinerator used at Peak Oil has not yet been resolved.
The Audit Review Group is assisting in resolution of the
audit.
B. EPA'S UTILIZATION OF THE ZONE I FIELD INVESTIGATION TEAM
Scope and Objectives
We reviewed EPA's utilization of the Zone I Field
Investigation Team (FIT) contract with the NUS Corporation.
This contract provides for the performance of preliminary
assessments (PAs), site inspections (Sis), Hazard Ranking
System scoring, special studies and enforcement support for
sites in EPA Regions 1, 2, 3 and 4. We evaluated FIT
operations from the award of the contract on November 1,
1986 through December 31, 1987.
Findings
1. FIT Program Management
Agency management of the FIT program was deficient.
The EPA project officer did not provide the required
oversight. As a result, there were four somewhat diverse
regional programs, rather than a single uniform FIT program.
Coupled with this lack of centralized control, EPA
Headquarters delayed taking action to correct problems in
Regions 1 and 2 for almost a year. This lack of oversight
contributed to a number of additional deficiencies in EPA's
management of the FIT program, which are discussed in the
remaining findings.
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2. Award Fee Process
EPA needs to improve implementation of the award fee
process in order to better assess the adequacy of the work
performed by NUS. In general, the process was not carried
out uniformly among the regions; however, the most serious
deficiencies occurred in Regions 1 and 2. We reviewed
performance packages submitted for EPA evaluation over the
first year of the contract and found that:
o Rating packages generally covered the minimum number of
hours required by EPA only be including large amounts
of support tasks.
o Ratings were overgenerous and did not comply with EPA
guidance.
o NUS was paid award fees for deficient work, as well as
for work that was beyond the scope of the pre-remedial
program.
o EPA Headquarters planned to allow the rollover of
unawarded fees. We believe this action is unwarranted
because it will increase the total fees available.
3. Excessive Support Charges
Overall, Zone I statistics indicated that the FIT
offices spent less than half their time on their primary
mission, i.e., preliminary assessments, site inspections and
Hazard Ranking System scores. Most of the non-primary
mission charges related to support activities such as
training, equipment maintenance, program management, general
technical assistance and quality assurance. We concluded
that some of the projects were of questionable value to the
Government, and that EPA must redirect the focus of the FIT
offices to their primary mission, the pre-remedial program.
4. Site Inspection Variations
Disparities existed in the fiscal 1987 site inspections
(Sis) performed in the four regions. The definition of what
constituted an SI, the methods used to select sites and the
actual format of the SI reports depended upon regional
preference. SI reports in two of the regions contained
toxicological assessments, while the other two regions
considered such assessments to be premature. Region 1 Sis
were the most peculiar. Because FIT 1 did not actually
visit 75 percent of the sites, the Sis did not conform to
either the FIT contract or the National Contingency Plan.
Moreover, it took EPA Headquarters over a year to formally
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issue guidance, during which time NUS charged the Agency an
estimated $4.7 million for 158,000 FIT hours spent on SI
projects.
5. Obtaining Required Professional Staffing
EPA needs to ensure that the personnel assigned to each
FIT office satisfy contract staffing requirements. We found
that the managers at two FIT offices did not have the
experience required by the contract.
6. Improving TDD Administration
Procedures for the preparation of Technical Directive
Documents (TDDs) need improvement. The four regions
reviewed did not always comply with contract requirements
and EPA guidance concerning the use of TDDs. We found
several areas requiring improvement such as work initiated
without TDDs, amendments to TDDs not processed and
Acknowledgement of Completion forms not completed. It is
essential that TDDs are processed in accordance with
contract provisions to ensure that the contractor has a
clear understanding of the work requirements. In view of
the significant value of this contract, in excess of $125
million, it is also essential that the services required,
due dates, priority, estimated costs and reporting
requirements are clearly defined before work is initiated.
The lack of clear and complete TDDs could adversely affect
the recovery of costs under CERCLA.
Recommendations
We recommended that EPA:
o Assure that the Project Officer more aggressively
manages and directs overall zone activities under the
NUS contract, more closely monitors regional FIT
operations and initiates corrective measures to rectify
problems as they arise.
o Increase the minimum reporting requirement for FIT
hours from 60 to 80 percent.
o Assure that Regional Project Officers rate contractor
performance in accordance with EPA guidance; and
reserve award fees principally for work related to the
FIT primary mission, granting no award fees for
deficient work.
o Decide on a single rating system, and employ it
uniformly throughout the four regions.
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o Assure that Regional Project Officers authorize no more
than 20 percent of FIT hours as support, eliminate non-
TDD charges, assure that contract invoices are
reconcilable to individual TDDs and direct NUS to
charge FIT support hours in a uniform fashion.
o Assure that regions select SI candidates in accordance
with the Agency's Pre-Remedial Strategy for
Implementing SARA and perform Sis in accordance with
the National Contingency Plan; and decide whether Sis
should include toxicological assessments.
o Obtain the resumes of all current and future FIT office
managers to assure that they satisfy the educational
and experience requirements of the contract.
o Assure that TDDs are administered in accordance with
the FIT Zone Contracts Management Guide.
Agency Response
EPA has indicated it has taken or is taking a number of
actions consistent with our recommendations, including:
o Naming a separate Project Officer for each FIT
contract, to enable each Project Officer to devote
efforts within one FIT zone.
o Incorporating specific performance requirements
relating to sound contract management in the
performance standards of each Project Officer and
Deputy Project Officer.
o Conducting an in-depth review of FIT contract
operations in each region at least once a year.
o Requiring corrective action plans from the contractor
in response to the findings of the Performance
Evaluation Board (PEB).
o At least annually, produce and distribute to all pre-
remedial personnel site assessment policy, priority and
guidance documents.
o Having all Regional Project Officers attend PEB
meetings and meet the following day to discuss the PEB
process and to identify issues and make
recommendations.
o Limiting FIT support hours to no more than 20 percent.
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o Directing NUS to charge support hours in a consistent
and uniform fashion.
o Directing NUS to document support project files to
demonstrate hours charged are reconcilable to services
rendered.
o Through a memorandum to the regions, establishing the
objective of focusing the FIT contract on pre-remedial
activities.
o Using guidance documents and conferences to reiterate
the importance of selecting SI candidates in accordance
with the Agency's Pre-Remedial Strategy for
Implementing SARA.
o Obtaining the resumes of all FIT office managers,
carefully evaluating them to determine qualifications
and issuing approval letters for each office manager.
o Documenting changes in key personnel and the basis for
decisions approving key personnel.
C. MANAGEMENT OF THE TECHNICAL ASSISTANCE TEAM BY REGION 3
Scope and Objectives
The purpose of this audit was to evaluate how
effectively EPA Region 3 managed the Technical Assistance
Team (TAT) contract. This contract provides technical
support for the emergency response program for Zone I
covering four regions. The contract has a potential value
of $120 million and is ongoing until September 30, 1990. We
primarily reviewed TAT documentation for calendar year 1987,
but also reviewed documentation from 1988 in selected
instances. During this audit, we:
1. Examined the TAT contract and EPA policy and
regulations regarding the program;
2. Performed a review of the documents, records and
reports issued under the TAT contract; and
3. Visited several removal sites.
Findings
1. Improvement Needed in the Utilization of Contractor
Personnel
Improvement is needed to ensure that professional
contractor personnel are not used to perform administrative
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type duties. We found that during 1987 approximately 6,100
hours of administrative work, costing about $187,000, were
provided by engineers, scientists and geologists. They
performed such tasks as file organization, referencing,
indexing and working in the Regional Response Center (RRC).
The TAT contract does not provide for the use of
professional level personnel to provide this administrative
support. We believe these contract personnel should be
utilized more efficiently to perform higher priority tasks
which are in the TAT members' field of expertise and in
conformance with the requirements of the contract. Region 3
personnel stated that the use of TAT personnel for
administrative support duties was due to a lack of
sufficient EPA personnel available to perform these tasks.
2. Contractor Monitoring Needs Improvement
Region 3 needs to improve its monitoring of the
contractor's performance. The primary responsibility for
monitoring the contractor's performance is that of the
Deputy Project Officer (DPO). However, we found that the
DPO did not: (1) ensure that required management reports
were accurate and useful, (2) maintain a current log showing
the status of Technical Directive Documents (TDDs), (3)
conduct regional contractor office reviews as required by
EPA guidance, and (4) determine the accuracy of the
contractor's invoices. In order to ensure that the
contractor is progressing satisfactorily in implementing
assigned tasks and in meeting planned financial and
programmatic objectives, it is necessary for EPA to
regularly monitor contractor performance. Adequate
monitoring would also assist in an early identification and
prevention of potential problems that otherwise may
adversely affect the smooth operation and implementation of
the program. We believe that the lack of adequate
monitoring was partially attributable to the fact that the
DPO was not available on a full-time basis to direct the
efforts of the contractor, who incurred costs of $4.4
million under the contract in 1987.
3. Improper Use of Contractor Staff for Personal Services
Region 3 did not comply with the Federal Acquisition
Regulation (FAR) and the provisions of the TAT Users' Manual
by improperly using contractor staff for personal services.
According to the FAR, personal services occur when
contractor personnel appear, in effect, to be Government
employees. We found that Region 3 directed professional
level contractor personnel to work in the RRC, under EPA
supervision, doing routine administrative tasks, which makes
them appear to be EPA employees. Region 3 officials
informed us that due to a shortage of EPA administrative
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support personnel, they used contractor staff to assist in
the operations of the RRC. We believe that the use of
contractor personnel to work in the RRC performing
administrative tasks under the direct supervision of EPA
constituted prohibited personal services.
4. Technical Direction Needs Improvement
Region 3 needs to improve its technical direction of
the TAT contractor. The principal mechanism for directing
the contractor is by issuance of a Technical Direction
Document (TDD). The TDD should provide the contractor with
a clear understanding of the services that are required. In
our review of the administration of TDDs we found several
problems, including: (1) inadequate preparation, (2)
delayed processing, and (3) insufficient direction. We
believe that these deficiencies stem from the fact that the
DPO was not available on a full-time basis to properly issue
and manage technical direction. Similar deficiencies were
cited in both an OIG survey report, dated April 18, 1984,
and the results of a review of Region 3 by EPA Headquarters
Emergency Response Division, dated October 29, 1984. The
absence of clear, complete work authorizations, impedes
efficient management of the contractor by the region. Also,
EPA may not be in a position to hold the contractor
accountable or establish a record of the tasks it directed
the contractor to perform. A future consequence of
incomplete TDDs is that the Agency may not have complete
records to recover cleanup costs under Superfund.
5. Improved Evaluation Procedures Needed
Evaluation procedures need to be followed to ensure
that the award fees paid to the contractor are justified.
For the first two rating periods ending September 30, 1987,
the contractor received over 80 percent of the maximum award
fee available ($59,152 of $73,480) for demonstrated
performance in Region 3. Our review disclosed that Region 3
did not: (1) substantiate evaluations as to how and why a
rating was meritorious or deficient, and (2) ensure that
Acknowledgement of Completion/Performance Observation
Reports were submitted within ten days of the task being
completed. We believe these conditions occurred because the
region did not place a high priority on these evaluations.
Lack of sufficient support for contractor ratings and late
submission of Acknowledgement of Completion Reports were
also noted in a management review performed by Headquarters
Emergency Response Division in 1984. We believe that these
problems demonstrated that Region 3 did not adequately
perform the evaluation process in order to justify the award
fee paid.
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6. Unqualified TAT Personnel Assigned to EPA
The contractor did not always provide personnel who
possessed the necessary education and experience as required
by the contract. We examined the resumes of all 40
contractor personnel who were assigned to Region 3. Our
review identified four employees who did not possess the
required qualifications. Consequently, EPA was overbilled
approximately $14,414 for these unqualified contractor
personnel and did not receive the experienced technical
assistance needed to respond to removal and prevention
activities.
7. Procedures for Special Projects Should Be Followed
Region 3 did not follow procedures to properly
administer and manage the issuance of TDDs for special
projects. These TDDs should be utilized to provide EPA,
during emergency removal activities, with specialized
resources not routinely available from the contractor. Our
review for the nine month period ending September 30, 1987,
encompassed 22 TDDs with estimated costs of $130,461. This
review disclosed the following: (1) the procurement of
services not allowed by the contract, and (2) a lack of
proper review and authorization. We believe that this
condition resulted because of the lack of adequate oversight
and control by the DPO. Improvement in the areas cited
above is essential to ensure that only authorized purchases
are made and proper approval is obtained in accordance with
prescribed procedures.
Recommendations
We recommended that EPA:
;
o Discontinue the use of professional level contract
personnel to perform administrative duties, and utilize
them to perform essential tasks requiring their
expertise.
o Aggressively monitor and track TAT project performance,
including periodic site visits to the contractor and
maintaining complete and accurate records and logs.
o Require the contractor to provide accurate management
reports.
o Ensure that sufficient documentation is available for
regions to verify the accuracy of contractor's
invoices. Consider modifying the contract to require
the provision of additional supporting documentation.
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o Discontinue use of the TAT contractor personnel for
personal services and establish procedures to preclude
such future use.
o Improve overall technical direction provided to the
contractor by appointing a full-time DPO and directing
the DPO to ensure that work authorizations are clear
and complete.
o Ensure that evaluations are properly supported to
provide substantive comments which substantiate the
ratings given.
o Direct the DPO to ensure that Acknowledgement of
Completion/Performance Observation Reports are prepared
within ten days of task completion, and follow up with
the contractor if they are not received in that
timeframe.
o Obtain and review resumes from the contractor, and if
necessary, amend the contract and Users' Manual to
include a review requirement.
o Determine whether any overcharges resulted from the
contractor billing for services performed by
unqualified contractor personnel and recover any
overcharges.
o Ensure that the contractor does not proceed with work
on a special project until a TDD is issued and all
required approvals are obtained.
Agency Response
In its response to the final report, the Agency agreed
to take the following corrective actions:
o Phase out use of the TAT in the Regional Response
Center.
o Upgrade the computerized TDD tracking system to help in
making the appropriate review and cost comparison.
Under the revised system, a weekly or bi-weekly summary
of the costs and hours on TDDs will be sent to regional
users. The region is asked to review these carefully,
and notify the DPO and the contractor of any
discrepancies.
o Continue to perform periodic reviews at the TAT office
and document these to show areas reviewed and the
results.
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o Review the invoice procedures on TAT and other
contracts to identify a better mechanism for DPOs to
verify reasonableness of contractor vouchered costs.
o Include more detailed statements of work in TDDs.
o Appoint a full-time DPO to administer the contract.
o Remind EPA personnel of the need for additional
comments supporting the numerical performance ratings.
o Reiterate to the contractor its responsibility to
submit timely Acknowledgement of Completion/Performance
Observation Reports. All necessary EPA personnel will
be advised of their responsibility for prompt
evaluation.
o Develop a mechanism to review other than key personnel
on the TAT contract.
o Discuss the instances of overcharges for unqualified
personnel with the DPO and the contractor, and take
appropriate action.
o Develop specific guidelines on the preparation of
special project TDDs and make provisions for alternates
to approve the TDDs during absences of the DPO.
D. RESOLUTION OF SUPERFUND CONTRACT AUDIT REPORTS
Scope and Objectives
We evaluated EPA's Procurement and Contracts Management
Division (PCMD) resolution of ten audit reports that
addressed costs claimed and questioned under emergency
cleanup services contracts. The ten audit reports were
selected from a universe of 25 audit reports issued between
October 1, 1985 and June 15, 1987. Our audit objectives
were to:
1. determine whether contracting officers made appropriate
decisions to resolve issues addressed in the audit
reports;
2. identify the areas of disagreement between the auditors
and contracting officers concerning questioned or set-
aside costs; and
3. reconcile differences between the auditors and
contracting officers.
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We audited costs claimed for "notice to proceed"
contracts where EPA authorized a contractor to begin work
before negotiating a detailed contract, and for delivery
orders under emergency response cleanup services (ERGS)
contracts. These audits were to determine the allowability
of costs claimed, verify the quantities billed and determine
contractor compliance with contract terms.
Findings
1. More Communication Needed Between Contracting Officers
and Auditors
Contracting officers accepted $134,789 of questioned
and set-aside costs based on additional supporting
documentation provided by the contractor, but not made
available to the auditors during their field work. Although
auditors were in the best position to determine if this
information adequately supported questioned or set-aside
costs, contracting officers often relied on this information
without obtaining feedback from the auditors on the adequacy
and accuracy of the documentation. Also, contracting
officers ignored cost information provided by the auditors
in arriving at a fair and reasonable price for provisional
rate equipment. Auditors did not receive 12 of the 18 pre-
negotiations memorandums in our sample before final
negotiations were held with the contractor. More
communication between contracting officers and auditors
would have ensured that contracting officers and auditors
agreed on the resolution of questioned and set-aside costs,
and that contracting officers entered negotiations in the
best possible negotiation position.
2. Negotiation Memorandums Need To Be Written More
Carefully and Completely
Twelve of the 18 post-negotiation memorandums we
reviewed were either incomplete or contained errors. As a
result, the negotiation memorandums did not adequately
document the results of negotiations. The primary purpose
of a negotiation memorandum is to document how the
contracting officer determined or negotiated the final cost
of a delivery order or contract. These memorandums may be
used in cost recovery cases or as a precedent in future
contract negotiations. Therefore, memorandums should be
carefully written so that readers can clearly understand how
the final cost was negotiated. Problems with negotiation
memorandums were partly caused by PCMD hurrying to complete
the negotiations for several audit reports before the end of
fiscal 1987.
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3. Improvements in EPA Contractor's Accounting System Not
Made in a Timely Manner
The Agency paid one EPA contractor $141,082 for
handling and general and administrative expenses without
assuring that the amount was fair and reasonable. Auditors
questioned or set-aside these costs because the contractor's
accounting system could not support the costs. PCMD was not
aggressive in requiring the contractor to improve its
accounting system even though they were aware of
deficiencies in the system since November 1983. Despite
these deficiencies, PCMD continued to make awards to the
contractor, and as of September 30, 1987, the Agency had
more than $72 million obligated against open contracts with
the contractor. The contractor recently made improvements
in its accounting system.
4. Contractors Took Advantage of Ambiguous Contract
Clauses
The Agency paid $42,047 more for labor under ten
delivery orders and one notice to proceed contract than they
would have been required to pay had the contracts been
better worded. Contractors billed the Agency at labor rates
that exceeded the straight time rate even though they did
not pay their employees the overtime or holiday premium.
Auditors questioned the difference between the premium rate
billed to the Agency and the rate paid to the employees.
However, the Agency's legal counsel decided that since the
contract language was ambiguous the contractors did not have
to pay the premiums as a precondition to billing the Agency
at the premium rates. PCMD personnel told us that since
they cannot recover the premium costs, they are asking
contractors to pay the applicable employees and to submit
certifications that employees were paid.
Recommendations
We recommended that EPA:
o Encourage the contracting officers to (a) discuss with
the auditors differences between the audit
recommendations and PCMD's pre-negotiation position;
and (b) obtain feedback from the auditors on additional
supporting documentation provided by the contractor.
o Develop a negotiation memorandum format that will
assist contracting officers in presenting the results
of negotiations in a clear and orderly manner.
o Expand the Quality Assurance Staff's annual contract
review to include a special review of a sample of
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negotiation memorandums. The special review should
concentrate on determining if the negotiation
memorandums are accurate and clearly explain the
rationale for resolving questioned and set-aside costs.
o Require contracting officers to obtain documentation to
support a sample of the certifications made by each
contractor that employees were paid overtime premiums
before they accept the costs for the overtime premiums.
Agency Response
In its response to the final audit report, EPA agreed
with all the recommendations and proposed the following
corrective actions:
1. PCMD will issue a memorandum to contracting officers
strongly encouraging more dialogue with auditors on
significant differences between the prenegotiation
position and the auditor's recommendations.
2. A revised negotiation summary format was prepared and
incorporated into the PCMD Acquisition Handbook on
October 24, 1988. The PCMD Quality Assurance Staff
will evaluate the results of the use of the new format
for any major deficiencies.
3. PCMD will obtain the recommended documentation in
support of the overtime premiums paid. More recent
ERCS contracts contain a requirement that the
contractor actually pay employees overtime premiums.
E. UNANNOUNCED ON-SITE REVIEWS OF REMOVAL ACTIONS
Background
CERCLA authorizes removal actions at hazardous waste
spills and sites, whether or not they are on the National
Priorities List (NPL). In contrast to long-term remedial
response, removals are generally short-term time-critical
actions needed to abate a threat. They are not subject to
the detailed planning process used for remedial actions, and
the work is generally directed on a day-to-day basis by a
Federal official.
The on-scene coordinator (OSC) is the Federal official
designated to coordinate and direct Federal response at a
site. Implementation of removal actions is usually done
under one of a number of Emergency Response Cleanup Services
(ERCS) contracts. The OSC is normally assisted by a
Technical Assistance Team (TAT) contractor to monitor the
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response, develop the workplan and document the cleanup
costs.
The OIG has been performing unannounced on-site audits
of removal actions for several years. During fiscal 1988,
we issued three reports of such audits. The removals
audited were at the Cam-Or site in Westville, Indiana; the
Del Norte County Pesticide Storage Area site in Crescent
City, California; and the Bossert Manufacturing Facility
site in Utica, New York.
Scope and Objectives
These reviews normally include a site visit of 1-3 days
while a removal is in progress. While at the site, auditors
observe conditions, review documentation and interview
personnel. There is usually follow up work at the EPA
regional office to review documentation that is not at the
site and to interview appropriate personnel.
The objectives of each review were to determine:
o Adequacy of the OSC compliance with prescribed
directives and guidance governing removal actions;
o Adequacy of the OSC's controls in monitoring the
cleanup work and on-site spending; and
o Adequacy of the technical assistance provided by the
TAT contractor.
Cam-Or Site
At the Cam-Or site in Westville, Indiana, we found that
OSC guidance, project monitoring and technical assistance
were generally adequate to control and monitor the removal
action. However, some project management procedures need
improvement. TAT employees at this site were used
extensively for recordkeeping duties resulting in higher
than necessary costs to EPA and a reduced level of technical
support. The OSC also approved charges of $19,954 for
components of a water treatment system that were either
never used or had not yet been assembled for use. Site
controls were not always adequate because (1) the OSC did
not record his own presence on the entry and exit logs; and
(2) unauthorized individuals could gain access to the site
through an opening in the fence.
In response to the draft report, EPA Region 5 indicated
it was taking action to correct the conditions noted. The
region agreed that the recordkeeping workload needed to be
decreased for both OSCs and TAT professionals, and assigned
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some Agency positions to administrative support functions.
The region agreed that the OSC should document the
disallowed charges for the non-operational water treatment
system components on the contractor invoice and would
request that the contracting officer not pay the disputed
charges. The region also agreed that the security service
should patrol the site, including the fence opening, and
that entry and exit logs should be completed.
In the final report, we requested EPA Region 5 to
provide documentation to support the completion of the
planned corrective actions. In response, EPA Region 5
provided further information on its actions.
Del Norte County Pesticide Storage Area Site
At the Del Norte County Pesticide Storage Area site in
Crescent City, California, we found that the OSC conducted
the on-site activities in a reasonable manner and generally
in compliance with applicable EPA guidance. However, the
OSC failed to question costs billed directly by the ERGS
contractor which are included in the contractor's indirect
costs. These costs were for small tools, equipment
maintenance items and general office supplies. Region 9 had
not received formal training on the contract and the OSC was
unaware that these costs were not allowable direct charges.
We recommended that EPA Region 9 assure that all
regional OSCs receive training on the ERCS contract
provisions. This training was provided during the first
quarter of fiscal 1988 by the EPA contracting officer.
Bossert Manufacturing Facility Site
At the Bossert Manufacturing Facility site in Utica,
New York, we found that the OSCs generally had complied with
prescribed directives and guidance, and had control in
monitoring the cleanup work and site spending. We also
noted that the TAT contractor provided adequate technical
assistance. However, we found a few areas that needed
improvement:
o The OSC did not attend daily site safety meetings,
although the OSC is responsible for establishing site
safety standards and making determinations on all site
health and safety issues.
o In some instances, EPA Region 2 did not act timely to
certify the ERCS contractor's invoices. In two cases,
we found delays of 15-21 days in OSC certification of
invoices. In one case, there was an additional delay
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of 22 days in transmitting the certified invoice to the
finance office.
o The ERCS contractor did not submit Daily Cost Reports
to the OSC by noon the following workday, as
contractually required, during our on-site visit. TAT
staff reported that such delays were common and caused
difficulties in determining the accuracy of equipment
charges.
o Some labor and transportation costs claimed on Daily
Cost Reports were not supported by site entrance/exit
logs or project logs.
In response to the draft report, EPA Region 2 began
express mailing invoices to OSCs in the field and increased
the use of computers to accelerate the certification of
contractor invoices. In the final report, we recommended
that EPA Region 2: (1) direct that OSCs attend daily site
safety meetings; (2) provide OSCs with administrative
assistance to expedite the processing of invoices; and (3)
reemphasize to OSCs the importance of assuring timely and
accurate Daily Cost Reports.
In response to the final report, EPA Region 2 agreed:
(1) that OSCs need to attend daily site safety meetings; (2)
to evaluate the results of efforts to expedite the
processing of invoices; and (3) that OSCs need to take
action if Daily Cost Reports are delayed extensively or
otherwise reflect poorly on the overall management of the
removal action.
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FINANCIAL AND COMPLIANCE AUDITS
The OIG is responsible for conducting and supervising
independent and objective audits relating to the programs and
operations of Superfund. In order to carry out this
responsibility the OIG performs financial and compliance audits
of EPA contractors and assistance recipients. Each of the Public
Laws authorizing EPA to award assistance agreements and contracts
provides that the Agency shall have the authority to audit and
examine the books and records of the recipients receiving Federal
funds. The provisions regarding audits are also clearly spelled
out in the general provisions of each EPA contract or agreement.
Our primary audit objectives are to determine; (1) whether the
controls exercised by the recipients through their accounting,
procurement, contract administration, and property management
systems are adequate to account for costs claimed; and (2) costs
claimed are reasonable, allowable, and allocable, in accordance
with applicable laws and regulations, to the sponsored project.
While the OIG is responsible for all audits of EPA contracts
and assistance agreements, we can elect to have the audits
performed by in-house staff, independent public accounting firms,
or another Federal, State or local audit agency. During fiscal
1988, our Superfund financial and compliance audits were
performed as follows:
Audits Performed by OIG Staff 4
Audits Performed by Independent Public Accountants 9
Audits Performed by Another Federal Agency 58
A listing of all Superfund audit reports issued by the OIG
during fiscal 1988 is contained in exhibit III.
During fiscal 1988, our audits of Superfund contracts,
cooperative agreements, and interagency agreements resulted in
the following questioned and set-aside costs:
o Contracts
Total Costs Audited $1,903,989,641
Total Costs Accepted $1,602,296,556
Total Costs Questioned $ 68,408,526
Total Costs Set-Aside3 $ 233,284,559
Questioned costs are costs that are unallowable under the
provisions of applicable laws, regulations, or policies.
3 Set-aside costs are costs that cannot be accepted without
additional information or evaluations and approvals by
responsible Agency officials.
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o Cooperative Agreements
Total Costs Audited $ 11,762,333
Total Costs Accepted $ 10,885,515
Total Costs Questioned4 $ 769,764
Total Costs Set-Aside5 $ 107,054
o Interaaency Agreements
Total Costs Audited $ 15,873,249
Total Costs Accepted $ 15,148,720
Total Costs Questioned6 $ 43,440
Total Costs Set-Aside7 $ 681,089
Audits of contracts and assistance agreements have played a
major role not only in yielding financial benefits to the Agency,
but also in improving Agency management. With the increased size
of the program and as more sites are actually cleaned up, we
expect to devote significant resources to auditing EPA
contractors and agreement recipients. These audits also play an
integral part in supporting EPA's cost recovery actions.
4 Questioned costs are costs that are unallowable under the
provisions of applicable laws, regulations, or policies.
5 Set-aside costs are costs that cannot be accepted without
additional information or evaluations and approvals by
responsible Agency officials.
6 Questioned costs are costs that are unallowable under the
provisions of applicable laws, regulations, or policies.
7 Set-aside costs are costs that cannot be accepted without
additional information or evaluations and approvals by
responsible Agency officials.
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ASSISTANCE TO EPA MANAGEMENT
In addition to performing audits and investigations, the
Office of Inspector General (OIG) responds to EPA management
requests for OIG input in the development of regulations,
manuals, directives, guidance and procurements. These are
proactive efforts to prevent problems that would be reflected in
later negative audit findings or investigative results. The OIG
reviews and comments on draft documents prepared by Agency
offices. In some instances, we designate an OIG staff person to
attend meetings of an EPA work group to provide input. Fiscal
1988 was an active year for OIG preventive assistance to EPA
management in the Superfund area.
Technical Assistance Grants
The EPA Administrator requested that the OIG work closely
with the Superfund office in its efforts to develop the technical
assistance grants program to groups of persons affected by
Superfund sites. Because these grants will be awarded to small
groups without grants experience or much administrative
structure, the Administrator recognized that this program
presented special management challenges. In response to this
request, in fiscal 1988 the OIG continued to participate in work
group meetings and review draft program documents, including the
regulation itself.
Cooperative Agreements
As the cooperative agreements section of this report
indicates, we have been conducting Superfund cooperative
agreement audits for several years and have frequently found
significant deficiencies. For some time, Agency management has
involved the OIG in the development of guidance to improve
management of cooperative agreements.* In fiscal 1988, the Agency
developed a regulation on Cooperative Agreements and Superfund
State Contracts for Superfund Response Actions, published in
fiscal 1989. The OIG assisted this effort through active
participation in workgroup meetings and review of drafts. In
addition, OIG staff made a presentation and led workshops at a
conference on State Administration of Superfund Response
Agreements sponsored by EPA and the Association of State and
Territorial Waste Management Officials.
Coordination with Other Agencies
Since EPA was given the responsibility of managing the
Hazardous Substance Superfund (Trust Fund), EPA's OIG took on the
task of informing the Federal OIG community (as well as
appropriate audit organizations) of the mandated audit
requirements. The Superfund Amendments and Reauthorization Act
of 1986 requires "... the Inspector General of each department,
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agency or instrumentality of the United States which is carrying
out any authority. . ." (emphasis added) under SARA to conduct an
annual audit of uses of the Superfund. In July 1987, we formed a
work group comprised of representatives from a number of OIGs or
audit officials of those Federal departments or agencies which
have been given significant Fund-financed responsibilities by
statute or Executive Order 12580. The objectives of our work
group are to:
o clarify the statutory requirement;
o coordinate schedules and reports under the mandatory
annual audit requirement;
o discuss funding mechanisms for the mandatory audit
work; and
o discuss program areas of concerns or audit findings.
The objectives are carried out through meetings held three
or four times a year with the full work group as well as
individual contacts as needed.
We continue to work with other OIG's and audit officials to
resolve Superfund accounting and control problems. We
coordinated these activities with administrative and program
offices at EPA to ensure that an effective audit product would
result. Through our work group contacts, we played a key role in
getting recordkeeping and accounting guidance out to other
Federal agencies who receive Trust Fund monies. We organized and
participated in an audit results panel discussion held during a
nationwide conference on Superfund interagency agreements and
cooperative agreements. The intention of this panel discussion
was to increase awareness of the OIG's role in controlling and
managing Superfund expenditures by all Federal agencies. Through
these activities we hoped to ensure consistent audit coverage as
well as better accountability and control over Trust Fund
spending.
Superfund Orientation Course
As Superfund spending increases and the program continues to
expand and develop, the OIG has recognized a need to ensure that
its auditors and investigators who review Superfund have a good
understanding of the program. Therefore, we have developed a
special orientation course explaining the key aspects of the
Superfund program, including:
o Superfund and related legislation and regulations;
o the removal, remedial and enforcement components of the
Superfund program;
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o organizational structure and functions of EPA offices
delegated specific Superfund responsibilities; and
o the OIG's role and responsibilities concerning
Superfund and the type of Superfund audits the OIG
performs.
The orientation course will be given to all OIG employees
and OIG audit services contractor employees who are or will be
involved in Superfund audits. The course will also be offered to
other Federal OIGs and audit organizations who are performing
audits in their respective agencies. The course was designed in
fiscal 1988 and will be offered beginning in fiscal 1989.
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REVIEW OF AGENCY'S SUPERFUND PROGRESS REPORT
Section 301(h) of CERCLA, as amended by SARA, requires that,
"On January 1 of each year the Administrator of the Environmental
Protection Agency shall submit an annual report to Congress of
such Agency on the progress achieved in implementing this Act
during the preceding fiscal year." The provision also requires
seven specific areas to be included in the report. The Inspector
General is required to review this report "... for
reasonableness and accuracy and submit to Congress, as a part of
such report a report on the results of such review."
The first Annual Report was due to Congress on January 1,
1988, covering fiscal 1987 activities. The report was not
submitted to Congress until May 11, 1989. Our review of the
report was submitted on April 6, 1989, to the Administrator
(Audit Report No. E1S4*7-11-0037-9100236). Most of our audit
work for this review was conducted during fiscal 1988.
Some of the areas presented in the Annual Report were
reasonable and accurate. However, the information in other
important areas of the report was not reasonable and accurate,
and some information was not as complete as it could have been.
Program accomplishment figures were frequently inaccurate
because the Agency used Headquarters information systems which
were not reliable to prepare its report. Many of their figures
did not agree with the corresponding information secured from
regional information systems, and significant portions of the
regional claims were not supported by valid source documents. In
addition, the Annual Report showed only delays in the status of
remedial investigation/feasibility studies and remedial actions
which occurred since January 1, 1987, while the statute required
that all delays from previously published schedules for
completion be shown.
The statute required EPA to provide "An estimate of the
amount of resources. . . to complete the implementation of all
duties. . . under this Act." However, EPA only provided fiscal
1987 through fiscal 1989 budget figures. We also did not believe
the level of detail provided in feasibility study descriptions
was adequate to enable the reader to fully understand and
appreciate EPA's decision-making process.
Because some official Agency definitions of terms may differ
from common understandings of them, the reader may believe more
on-site work was done at a greater number of facilities than
actually occurred. For example, the Agency defines the "start"
of some key activities as a financial transaction - when funds
are obligated to perform the activity. On-site work may not
begin until months after the "start" is recorded.
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In addition to the findings summarized above, our audit
report included the following comments on the Annual Report
preparation process:
The process used to prepare the Annual Report was not
fully effective. Although this report was due to
Congress January 1, 1988, the report was not completed
until January 1989. Since this is the first time the
report was prepared, some problems were expected.
However, the problems which we identified in our report
seem to have been much greater than they should have
been.
Part of the reason that the Annual Report encountered
such difficulties is that the report coordinator's
resources were limited. Also, at his grade level (GS-
13), he was not in a position of authority from which
to command action on the part of other organizations
whose input was vital. For example, as of March 1988,
the report coordinator was still uncertain of the
sources and accuracy of many of the accomplishments
figures in the report. Despite our repeated requests
for detailed information over a period of four months,
he was unable to secure the information from the Agency
offices responsible for compiling it. Further, the
coordinator had different figures for the same
accomplishments, depending on which information systems
he used. This should not be the case six months after
the end of the fiscal year, and is a further reflection
on the reliability of the Agency's information systems.
OSWER officials stated that the main information
system, CERCLIS, has been improved for fiscal 1988.
These officials believe that the use of the improved
CERCLIS will enhance the accuracy of the fiscal 1988
Annual Report, as well as decrease its preparation
time. However, this system will also contain
information that is not reliable, unless steps are
taken to ensure that regional input to CERCLIS is
accurate and complete.
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EXHIBIT I
UNITED STATES
ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON, D.C.
HAZARDOUS SUBSTANCE SUPERFUND
SCHEDULE OF OBLIGATIONS (NOTE 1)
FISCAL YEAR ENDED SEPTEMBER 30, 1988
Description Total Accepted Questioned
Personnel Compensation $ 93,138,167 $ 93,138,167 $
Personnel Benefits 15.859.492 15.859.492 -
The accompanying notes are an integral part of this schedule.
Total Personnel Compensa-
tion & Benefits 108.997.659 108.997.659 =
Travel and Transportation
of Persons 9,178,351 9,178,351
Transportation of Things 596,886 596,886
Rent, Communications and
Utilities 18,220,192 18,159,522 60,670
Printing and Reproduction 838,868 838,868
Other Contractual Services 1,084,809,993 1,084,809,858 135
Supplies and Materials 3,105,565 3,102,990 2,575
Equipment 15,275,588 15,247,822 27,766
Land and Structures 35,175 35,175
Grants, Subsidies and
Contributions 221,093,417 221,093,417
Insurance Claims and
Indemnities 139.671 139.671 =
Total Non-Personnel Com-
pensation & Benefits 1.353.293.706 1.353.202.560 91.146
GRAND TOTALS $1,462,291,365 $1,462,200,219 $ 91,146
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EXHIBIT I
(CONTINUED)
UNITED STATES
ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON, D.C.
HAZARDOUS SUBSTANCE SUPERFUND
NOTES TO SCHEDULE OF OBLIGATIONS
FISCAL YEAR ENDED SEPTEMBER 30, 1988
NOTE 1. SUMMARY OF SIGNIFICANT ACCOUNTING POLICIES
The Schedule of Obligations was prepared by the EPA
Financial Management Division based on financial information
contained in the Financial Management System for the fiscal year
ended September 30, 1988. EPA's policy is to prepare this
schedule in accordance with accounting policies and procedures
that are legislatively established and promulgated through
various Federal and EPA policy and procedural standards, which is
a comprehensive basis of accounting other than generally accepted
accounting principles. This schedule is not intended to present
either the financial position or the financial results of
operations in conformity with generally accepted accounting
principles.
Obligations, as presented in this Exhibit, were reported by
EPA's Financial Systems Branch in a Superfund Control Totals
Report from information contained in the Financial Management
System "Allotment File" for the current fiscal year
appropriation. The total obligations from this report, amounting
to $1,462,291,365, were reconciled with the totals reported by
EPA to the Office of Management and Budget for the appropriation
68-20X8145 for the period ended September 30, 1988.
Obligations - Nonpayroll
Obligations are amounts of orders placed, contracts awarded,
services received, travel performed and similar transactions
during a given period that will require payments during the same
or future periods. Such amounts include disbursements for which
obligations had not been previously recorded and actual
disbursements to liquidate those obligations. The term
"obligation" includes both obligations that have matured (legal
liabilities) and those that are contingent upon some future
performance, such as providing services or furnishing materials.
Obligations represent funds obligated against the current fiscal
year's appropriation, including carry-over authority for
appropriations from prior years. Obligations are recorded for
budgetary purposes by appropriation at the time they are
incurred.
52
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EXHIBIT I
(CONTINUED!
Obligations - Payroll
Payroll obligations are based upon actual personnel
compensation and benefits recorded monthly in the payroll
subsystem (paymerge file) plus accruals generated at month-end.
Personnel compensation and benefits obligations amounted to
$108,977,659, which, based on EPA policy, were recorded as
obligations for budgetary accounting purposes.
Administrative Expense Ceiling
Funding for the Superfund program is achieved through a
separate annual, no-year appropriation. The legal limitation set
by Congress on the Superfund appropriation requires the Agency to
stay within an administrative expense ceiling. Congressional
intent was to limit intramural expenses to ensure that the
primary function of the Superfund of cleaning up hazardous waste
sites was protected. Agency policy is that the legally binding
administrative expense ceiling placed on the Superfund
appropriation be managed by the Office of the Comptroller through
a distribution of specific ceilings to the individual Responsible
Planning and Implementation Officers.
Public Law 100-202 provided funding to carry out the
Comprehensive Environmental Response, Compensation, and Liability
Act of 1980, with $1,128,000,000 for fiscal 1988, to be derived
from the Hazardous Substance Superfund, consisting of
$888,900,000 as authorized by the Superfund Amendments and
Reauthorization Act of 1986, and $239,100 as a payment from
general revenues to the Hazardous Substance Superfund, with all
of such funds to remain available until expended. The law also
provides no more than $182,400,000, or 16.2 percent of total
funding, to be available for administrative expenses.
Our analysis of the administrative expenses for the year
indicated that the Superfund program obligated $156,352,780, or
10.7 percent of total obligations, for these administrative
expenses, as defined by Agency policy. The Agency defined
administrative expenses to include all object classes in the
Schedule of Obligations except Other Contractual Services, Land
and Structures, and Grants, Subsidies and Contributions. These
amounts are within the dollar limitation set by Congress, and are
85.7 percent of the administrative expense ceiling of
$182,400,000.
53
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EXHIBIT II
UNITED STATES
ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON, D.C.
HAZARDOUS SUBSTANCE SUPERFUND
SCHEDULE OF DISBURSEMENTS (NOTE 1)
FISCAL YEAR ENDED SEPTEMBER 30, 1988
Description Total Accepted Questioned
Personnel Compensation $ 92,327,130 $ 92,291,205 $ 35,925
Personnel Benefits 15.634.232 15.634.232 -
Total Personnel Compensa-
tion & Benefits 107.961.362 107.925.437 35.925
Travel and Transportation
of Persons 8,748,723 8,748,723
Transportation of Things 539,955 539,955
Rent, Communications and
Utilities 17,981,557 17,934,177 47,380
Printing and Reproduction 772,665 772,665
Other Contractual Services 561,475,786 561,475,786
Supplies and Materials 3,139,237 3,113,990 25,247
Equipment 17,392,761 17,383,599 9,162
Land and Structures 3,975 3,975
Grants, Subsidies and
Contributions 72,196,826 72,082,473 114,353
Insurance Claims and
Indemnities 139.326 139.326 -
Total Non-Personnel Com-
pensation & Benefits 682.390.811 682.194.669 196.142
GRAND TOTALS $790,352,173 $790,120,106 $232,067
The accompanying notes are an integral part of this schedule.
54
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EXHIBIT II
(CONTINUED!
UNITED STATES
ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON, D.C.
HAZARDOUS SUBSTANCE SUPERFUND
NOTES TO SCHEDULE OF DISBURSEMENTS
FISCAL YEAR ENDED SEPTEMBER 30, 1988
NOTE 1. SUMMARY OF SIGNIFICANT ACCOUNTING POLICIES
The Schedule of Disbursements was prepared by the EPA
Financial Management Division based on financial information
contained in the Financial Management System for the fiscal year
ended September 30, 1988. EPA's policy is to prepare this
schedule in accordance with accounting policies and procedures
that are legislatively established and promulgated through
various Federal and EPA policy and procedural standards, which is
a comprehensive basis of accounting other than generally accepted
accounting principles. This schedule is not intended to present
either the financial position or the financial results of
operations in conformity with generally accepted accounting
principles.
Disbursements, as presented in this exhibit, were reported
by EPA's Financial Systems Branch in a Special Superfund Audit
Report from information contained in the Financial Management
System Allotment File. The total disbursements from this report,
amounting to $790,352,173, were reconciled with the totals
reported by EPA to the Office of Management and Budget for
appropriations 68-20X8145 and 68-2068145 for the period ended
September 30, 1988.
Disbursements - Nonpayroll
Disbursements represent the amount of cash outlays made to
liquidate obligations. They represent funds disbursed during the
current fiscal year against either prior years' or current year's
appropriations. Nonpayroll disbursements are recorded on the
cash basis of accounting.
Disbursements - Payroll
Personnel compensation and benefits disbursements amounted
to $107,961,362, which represented personnel compensation and
benefits during fiscal 1988 on an accrual basis.
55
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EXHIBIT II
(CONTINUED!
Property and Equipment and Depreciation
EPA's policy is to capitalize property and equipment with a
cost greater than $5,000 and a useful life of two years or
greater. However, disbursements for equipment recorded in this
Exhibit are presented on a cash basis as an operating expense,
without adjustment for capitalized items. No depreciation was
calculated or recorded for purposes of this schedule.
56
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EXHIBIT III
1 OF 5
SUPERFUND AUDIT REPORTS
ISSUED DURING FISCAL 1988
O INTERNAL AND MANAGEMENT AUDITS
Final
Report
Number
89019
80028
81917
80608
80612
80611
80633
80838
81927
81966
81949
81554
80664
80330
89000
Description
RI/FS REVIEW, WHITEHOUSE SITE, FL
FY86 CONSOLIDATED TRUST FUND
FY87 TRUST FUND
REG. 3 FY84 TRUST FUND SUPPL.
REG. 4 FY83 TRUST FUND SUPPL.
REG. 3 FY84 INDIRECT COST RATE
REG. 4 FY83 INDIRECT COST RATE
COOPERATIVE AGREEMENTS CAPPING
REG. 4 SIGNIFICANT REMOVALS
ZONE 1 FIELD INVESTIGATION TEAM
REG. 3 TECHNICAL ASSISTANCE TEAM
CONTRACT AUDIT RESOLUTION
REMOVAL VISIT, BOSSERT SITE, NY
REMOVAL VISIT, CAM-OR SITE, IN
REMOVAL VISIT, DEL NORTE SITE, CA
Audit
Control
Number
E5EH7040293
P5EH7110022
P5EH8110030
P5EH8110035
P5EH7110034
P5EH8110036
P5EH8110034
E5EE8090018
E5EH7040181
E5EH7030273
E5EH7030290
E5EH7110043
E5EH7020217
E5EH7050566
E5E47090225
Date
Report
Issued
9/30/88
10/ 7/87
9/21/88
2/16/88
2/16/88
2/16/88
2/17/88
3/29/88
9/26/88
9/30/88
9/28/88
7/29/88
2/23/88
12/10/87
12/30/87
57
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EXHIBIT III
2 OF 5
SUPERFUND AUDIT REPORTS
ISSUED DURING FISCAL 1988
o COOPERATIVE AGREEMENTS
Final
Report
Number
81914
81968
Auditee
NEW HAMPSHIRE DEPT. ENV. SERVICES
TRUSTEES HEALTH HOSP. BOSTON, MA
Audit
Control
Number
E5BH6010025
E5BG8010110
Date
Report
Issued
9/21/88
9/30/88
58
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EXHIBIT III
3 OF 5
SUPERFUND AUDIT REPORTS
ISSUED DURING FISCAL 1988
o INTERAGENCY AGREEMENTS
Final Audit Date
Report Control Report
Number Auditee Number Issued
80781 ARMY COE-AIDEX SITE, IA M5BG8110040 3/18/88
81533 ARMY COE-CHARLES GEORGE SITE, MA M5BG8110049 7/25/88
81583 INTERNAL REVENUE SERVICE-FY84-87 M5BG8110051 8/ 4/88
80571 NAT'L BUREAU OF STANDARDS, DOC M5BH8110032 2/ 5/88
80803 DEPARTMENT OF TRANSPORTATION M5BH8110027 3/22/88
59
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EXHIBIT III
4 OF 5
SUPERFUND AUDIT REPORTS
ISSUED DURING FISCAL 1988
o CONTRACT AUDITS
Final
Report
Number Auditee
81563 A.T. KEARNEY INC., IL
81609 A.T. KEARNEY INC., IL
81653 ACUREX CORP., CA
81651 BAKER/TSA INC., PA
81652 BAKER/TSA INC., PA
81634 BATTELLE MEMORIAL INSTITUTE, OH
81816 BECHTEL ENVIRONMENTAL INC., CA
81455 BMI, OH
81525 BMI, OH
81608 CAMP, DRESSER & MCKEE, VA
80465 DONOHUE AND ASSOCIATES, WI
81422 DPRA INC., MN (FORMERLY POPE-REID)
81607 EARTH TECHNOLOGY CORP., VA
80343 ENGINEERS INT'L, IL
81479 ENV. TOXICOLOGY INT'L INC., WA
81424 FLUOR DANIEL INC., TX
81456 GARD INC., IL
81435 GEO/RESOURCE CONSULTANTS INC., CA
81436 GEO/RESOURCE CONSULTANTS INC., CA
81437 GEO/RESOURCE CONSULTANTS INC., CA
81712 GOVERNMENT FINANCE RESEARCH, IL
81483 HARDING LAWSON ASSOCIATES, CA
81711 HARZA ENVIRONMENTAL SERVICES, IL
81564 HARZA ENVIRONMENTAL SERVICES, IL
81421 HAVENS AND EMERSON, OH
81230 HAZTECH CORP., GA-PEAK OIL SITE
80836 HAZTECH CORP., GA-GEN. REF. SITE
81541 HAZTECH CORP., GA
81423 HDR ENGINEERING INC., MN
80298 HUBBLER, ROTH & CLARK, MI
81514 IT CORP., NM
81507 JACOBS ENGINEERING GROUP, CA
81551 JACOBS ENGINEERING GROUP, CA
81857 JACOBS ENGINEERING GROUP, CA
81447 K.W. BROWN & ASSOCIATES, TX
81448 K.W. BROWN & ASSOCIATES, TX
81568 KELLOGG CORP., CO
80299 LIFE SYSTEMS INC., OH
81626 MAECORP INC., IL
81425 MCCLELLAND ENGINEERS, TX
Audit
Control
Number
D9AT8050519
D9AT8050520
D9AT8090217
D9AT8050539
D9AT8050540
D9AT8050538
D9AT8090332
D9AT8050470
D9AT8050512
D9AT8050527
D9AT8050231
D9AT8050465
D9AT8050537
D9ATS050170
P9AT8100075
D9AT8060169
D9AT8050471
D9AT8090181
D9AT8090182
D9AT8090183
D9AT8050556
D9AT8090191
D9AT8050558
D9AT8050526
D9AT8050464
E9CT8040141
E9CT7040281
P9AT8040255
D9AT8050467
D9AT8050159
D9AT8060188
D9AT8090194
D9AT8090197
D9AT8090333
D9AT8060175
D9ATS060176
P9AT8080099
D9AT8050154
P9AT8050481
D9AT8060168
Date
Report
Issued
8/ 1/88
8/ 5/88
8/12/88
8/12/88
8/12/88
8/10/88
9/ 7/88
7/ 8/88
7/22/88
8/ 5/88
1/20/88
6/29/88
8/ 5/88
12/16/87
7/14/88
6/30/88
7/ 8/88
7/ 6/88
7/ 6/88
7/ 6/88
8/25/88
7/14/88
8/25/88
8/ 1/88
6/29/88
6/ 7/88
3/29/88
7/26/88
6/29/88
12/ 2/87
7/21/88
7/20/88
7/28/88
9/13/88
7/ 6/88
7/ 6/88
8/ 2/88
12/ 3/87
8/ 9/88
6/30/88
60
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EXHIBIT III
5 OF 5
Final
Report
Number
81913
81513
81657
81677
89002
81203
81526
80009
81493
81467
80174
81263
81936
81505
81506
81562
81418
81674
81391
81434
81884
81390
81527
80246
SUPERFUND AUDIT REPORTS
ISSUED DURING FISCAL 1988
o CONTRACT AUDITS (Continued)
Auditee
MED-TOX ASSOCIATES INC., CA
MIDWEST RESEARCH INSTITUTE, MO
MIDWEST RESEARCH INSTITUTE, MO
MORRISON KNUDSEN ENG. INC., ID
OH MATERIALS CORP., OH
OH MATERIALS CORP., OH
PMA INC., MI
PRC ENVIRONMENTAL MANAGEMENT, IL
PTI ENVIRONMENTAL SERVICES, WA
RESEARCH TRIANGLE INSTITUTE, NC
RQAW ASSOCIATES, IN
S&D ENGINEERING SERVICES, NJ
S-CUBED, CA
SCIENCE APPLIC. INT'L CORP.
SCIENCE APPLIC. INT'L CORP.
SCIENCE APPLIC. INT'L CORP.
SOUTHERN RESEARCH INSTITUTE
TERRACON CONSULTANTS EC INC
TETRA TECH INC., CA
TETRA TECH INC., CA
URS CONSULTANTS INC., CA
URS CONSULTANTS INC., CA
WESTON GEOPHYSICAL, PA
WW ENGINEERING & SCIENCE, MI
CA
CA
CA
AL
IA
Audit
Control
Number
D9AT8090340
D9AT8070167
D9AT8070188
D9AT8100094
P9AX7050708
P9AH7050655
D9AT8050510
D9AT7050780
P9AT8100074
H9AT8040332
D9AT8050085
P9AT8020161
D9AT8090345
D9AT8090192
D9ATS090193
D9AT8050525
D9AT8040323
P9AT8070149
D9ATS090177
D9AT8090180
D9AT8090337
D9AT8090178
D9AT8050511
D9AT8050139
Date
Report
Issued
9/20/88
7/21/88
8/15/88
8/22/88
4/13/88
6/ 1/88
7/22/88
10/ 3/87
7/15/88
7/12/88
ll/ 5/87
6/ 9/88
9/27/88
7/20/88
7/20/88
8/ 1/88
6/29/88
8/22/88
6/24/88
7/ 6/88
9/19/88
6/24/88
7/22/88
11/20/87
61
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APPENDIX A: ACRONYMS AND ABBREVIATIONS
BEST
CERCLA
CERCLIS
CFR
COE
DOC
DPO
EDP
EPA
ERCS
FAR
FDER
FICA
FIT
FMS
FTE
I PA
LFK
NCP or National
Contingency Plan
NEIC
Basic Extraction Sludge Treatment
Comprehensive Environmental Response,
Compensation, and Liability Act of 1980, as
amended
Comprehensive Environmental Response,
Compensation, and Liability Information
System, the Superfund management information
system
Code of Federal Regulations
Corps of Engineers
Department of Commerce
Deputy Project Officer
electronic data processing
Environmental Protection Agency
Emergency Response Cleanup Services
Federal Acquisition Regulation, 48 CFR
Chapter 1
Florida Department of Environmental
Regulation
Federal Insurance Contributions Act
Field Investigation Team
EPA's Financial Management System
Full-time equivalent
independent public accounting firm
Lead Free Kids
National Oil and Hazardous Substances
Contingency Plan, 40 CFR Part 300
EPA's National Enforcement Investigations
Center
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NHDES
NPL
O&M
GIG
OSC
PA
PAO
PCB
PCMD
PEB
PPAS
RFP
RI/FS
ROD
RRC
SARA
SI
TAT
TDD
Trust Fund
New Hampshire Department of Environmental
Services
National Priorities List
operation and maintenance
Office of Inspector General
On-Scene Coordinator
Preliminary Assessment
Property Accountable Officer
polychlorinated biphenyl
EPA's Procurement and Contracts Management
Division
Performance Evaluation Board
EPA's Personal Property Accounting System
Request for Proposals
Remedial Investigation/Feasibility Study
Record of Decision
Regional Response Center
Superfund Amendments and Reauthorization Act
of 1986
Site Inspection
Technical Assistance Team
Technical Directive Document or Technical
Direction Document
Hazardous Substance Superfund
63
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