Summary Report of EPA's Federal
Managers' Financial Integrity Act
Program
-------
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON, D.C. 20460
THE ADMINISTRATOR
The President
The White House
Washington, O.C. 20500
Dear Mr. President:
This letter is my annual report to you on the management
integrity programs of the U. S. Environmental Protection Agency
(EPA), required by the Federal Managers' Financial Integrity Act.
I am pleased to report that EPA's management control and
financial systems, taken as a whole, reasonably assure that the
objectives of* the Act have been achieved. EPA's Inspector
General has reviewed the Agency's processes for carrying out the
requirements of the Act. He has concluded that the Agency
implements the Act in a reasonable and prudent manner.
MANAGEMENT INTEGRITY IS A HIGH PERSONAL PRIORITY
EPA is faced increasingly with a long list of statutory
deadlines and requirements, and we seek constantly to improve in
'reaching out to a broad spectrum of the public to protect health
and safety, while recognizing economic realities. This is a
difficult and complex task, but an essential one if the American
people are to receive the environmental protection services they
require.
Ensuring the highest standards of personal, organizational
and systems integrity in EPA is one of my personal priorities.
Through our Senior Council on Management Controls, my top
managers and I ensure 'that this priority is shared with all
management and staff levels of the Agency. We want to encourage
a culture in which potential problems are forthrightly identified
and corrected early; we want our people empowered to be leaders
in prevention.
I sincerely believe that we cannot build a sound long-term
quality approach to environmental protection unless we give
priority attention to management vulnerabilities. EPA is
committed to identifying; preventing and following up on
management vulnerabilities in contracts, facilities and data
management, and we are making a major investment in total quality
management to make this happen.
Printed on Recycled Paper
-------
MAJOR MANAGEMENT CONTROL AND FINANCIAL SYSTEMS ACCOMPLISHMENTS
Some of EPA's notable accomplishments for FY 1991 include:
EPA's Senior Council on Management Controls: EPA's Senior
Council continues to operate very effectively in heightening
management attention to emerging issues and the correction of
material weaknesses. Its activities —
• Keep EPA's senior managers alert to potential problems
identified by the Office of the Inspector General (OIG) and
the General Accounting Office (GAO), as well as concerns of
the Office' of Management and Budget (OMB) ;
• Provide to the Agency strategies and guidance for the
internal control and audit management programs; and
• Increase awareness and discussions of management controls at
senior managers' conferences.
Improved Program Effectiveness; EPA continues to promote the
processes of the Federal Managers' Financial Integrity Act
(FMFIA) as a management tool. Program effectiveness has been
improved through increased training, and a number of offices have
established work groups to improve their management control
programs.
Linking Management Controls with Other Agency Processes;
Achieving the President's vision of effective environmental
protection requires new approaches to hoW we develop our budget.
We are now examining the Agency's statutory mandates across all
of our offices in an effort to integrate programmatic activities
to achieve the greatest environmental payoffs. EPA's budget
proposal now focuses on several key priority themes, which cross
traditional program and environmental media boundaries. We will
initiate selected cross-program vulnerability assessments in our
1992 management control processes.
Using Total Quality Management (TQM) Concepts in Implementing
FMFIA: EPA believes that the philosophies of TQM are directly
applicable to our FMFIA processes. For example, one manager used
a "Quality Action Team" to prepare and update the FMFIA
description of activities. This manager now uses the
descriptions as the branch's standard operating procedures,
because of their completeness and accuracy.
Validating Effectiveness of Corrective Actions: Managers are now
required to verify the effectiveness of their corrective actions
to remedy weaknesses. EPA has a management information system
that tracks the progress of corrective actions, including the
final step of verifying the effectiveness of the actions that
have been taken to cure the weakness.
-------
Rotational Assignments in the Management Integrity Program;
EPA's rotational assignment program has resulted-in improved
understanding of the management control and audit management
programs by participating offices.
Office-Specific Accomplishments; Several offices improved their
own management integrity efforts.
• Our Office of Solid Waste and Emergency Response established
several TQM/FMFIA work groups to improve and simplify
various office processes.
• The Office of Research and Development established- its' own
Council on Management Controls, modeled after the Agency's
Senior Council on Management Controls.
• EPA's Region III Office developed an Automated Management
Control Plan and distributed it to the other Regions and
Headquarters Offices. Response has been highly favorable,
and many have elected to use this more efficient approach.
These and other accomplishments reflect the seriousness and
consideration with which EPA managers regard our management
control program.
AREAS RECEIVING PARTICULAR MANAGEMENT ATTENTION BY EPA
Procurement-Related Issues;
Superfund Operations Reorganization - A plan for the
reorganization of EPA's Superfund/RCRA Procurement
Operations has been prepared. This reorganization is
intended to serve the changing needs of the Superfund
program and will facilitate EPA's efforts to ensure high
quality contract management in the Regional offices.
Contract Management Improvements - The ARCS review findings
and reports by EPA's Inspector General point to persistent,
widespread problems in EPA's oversight of the large, task
order contracts that are vital to most EPA functions and
sites. A senior management team will review contract
management personnel and practices in all EPA headquarters
and field offices during FY 1992. Our goal is to emphasize
preventative measures to head off a series of.embarrassing
audits and costly corrective actions. Building continuous
improvement into our contracting operations is a top
management priority.
Conflict of Interest - EPA issued Procedures for Documenting
Organizational Conflict of Interest Decisions Prior to
Contract Award on July 23, 1991. A recent Comptroller
General's decision involving an EPA Contracting Officer's
-------
proper decision to exclude a contractor due to a potential
Organizational Conflict of Interest (OCI), provided
clarification of a Contracting Officer's responsibility in
evaluating OCXs. The new procedures, based in part on the
Comptroller General's decision, provide guidance for
Contracting Officers to use in resolving and documenting
potential OCIs prior to contract award. The procedures and
the award upon which the Comptroller General's decision was
based are examples of the more rigorous interpretation and
application of the conflict of interest requirements of the
Federal Acquisition Regulation in EPA, particularly in the
Superfund program.
EPA has published a proposed Conflict of Interest Rule
in the Federal Register which, when finalized, will provide
the Agency with comprehensive and consistent guidelines and
stronger contract clauses to protect the Superfund program
from conflict of interest.
A data base for tracking and researching conflict of
interest actions is being developed. It will serve as a
valuable tool for Contracting Officers throughout the
country to use in making conflict of interest
determinations.
Contract Property - The Office of the Inspector General
reviewed EPA's oversight of contractor property control
systems in January 1991, and found inadequacies. EPA has
revised its Contract Property Administration Program to
comply with the Inspector General's recommendations.
Centralized Contract Management and Administration Efforts
in the Office of Solid Waste and Emergency Response (OSWER)
- OSWER's Technology Innovation Office has centralized its
contract administration efforts to improve efficiency, and
has instituted new control techniques. Elsewhere in OSWER,
similar initiatives are underway to ensure that contract
management and administration responsibilities are carried
out in a prudent manner.
Scientific Misconduct; EPA is cognizant of the national concern
about incidents of scientific misconduct that may affect the
validity of research findings. This issue has potential
management control implications for EPA. We are addressing the
issue through a work group, which will develop policies and
guidelines to ensure the integrity of the scientific information
that affects our programs.
Contract Laboratory Program; EPA has conducted a major review of
management controls to ensure the integrity of data coming from
laboratories that do work for EPA under contracts. The review
concluded that there are material weaknesses in the management
-------
controls of the program. It is important that data from the
contract laboratories be accurate because of its potential impact
on regulatory policy and enforcement decisions. The issue is
addressed in the material weakness section below.
HIGH RISK AREAS
We have made great strides in strengthening the high risk
areas identified by OMB. Based on our corrective actions to
develop an integrated data base for enforcement activities, EPA
is requesting that the enforcement issue be removed from OMB's
high risk list. The corrective actions have been validated and
proven effective. In addition, OMB has lowered our financial
systems issue from a high to a low priority.
Although EPA has made progress with the Superfund
enforcement issue, OMB has added two new Superfund issues to the
list: Alternative Remedial Contracting System (ARCS) Contract
Management and Accelerated Remedial Clean-up. We have made it an
Agency priority to resolve these high risk issues expeditiously.
These areas are discussed in Enclosure C.
MATERIAL WEAKNESSES AND NONCONFORMANCES
EPA is reporting 16 material weaknesses, seven for the first
time. In order of priority, they are:
1. ARCS Contract Management; Charges made by ARCS contractors
appear excessive; program management costs were high
relative to the charges for site clean-up work; EPA is not
conducting effective administration and oversight; and, EPA
has to improve oversight without overloading ARCS
contractors with administrative paperwork.
2. Accelerating Remedial Cleanup; EPA's clean-up of Superfund
sites has been criticized as too slow. The issues are: 1)
what are EPA's options for accelerating the rate of clean-up
at Superfund sites, and 2) whether the Superfund program
uses realistic assumptions when evaluating and managing
risks at Superfund sites.
3. Federal Facilities; EPA has not had sufficient resources to
perform an adequate level of oversight of other Federal
agencies' environmental compliance and restoration plans and
activities. We recognize that this is a government-wide
challenge that needs improved interagency attention. EPA's
experience with two military bases that are on Superfund's
National Priorities List indicates that EPA's oversight and
assistance role for newly planned DOD base closings will be
more resource intensive than the facilities clean-up work
anticipated earlier.
-------
4. Contract Laboratory Program; The Contract Laboratory
Program is vulnerable to waste and fraud, and does not have
a national tracking system to provide an early
identification of problems and involve top management in
their resolution.
5. Super-fund; EPA's 1989 major review of the Superfund program
(entitled "A Management Review of the Superfund Program,"
also known as the "90-Day Study") identified the Superfund
program as a material weakness.
6. Data Integrity for Pesticides and Toxic Substances; The
effectiveness of the program is weakened by EPA's
inspectors' lack of training in fraud detection in a
laboratory setting; by the advance notice given when
laboratories are to be inspected; and, by the lack of
reporting mechanisms to identify laboratories and the
studies they are conducting on various chemicals.
7. Growing Backlog of Requests for Audits of EPA Contractors;
Almost 90% of EPA's contracting dollars are spent on cost
reimbursable contracts. It is critical that incurred cost
audits of contracts be conducted in a timely manner. There
is a substantial and growing backlog of requests for audits
of EPA contractors, including at least 390 unmet requests
for incurred cost audits.
8. Implementation of Storm Water Permitting Requirements Under
the Clean Water Act; EPA has worked to meet the
requirements and deadlines for storm water permits under the
Clean Water Act amendments of 1987 and has met most of the
NPDES program requirements. However, the Agency has missed
deadlines in the law and is substantially behind in dealing
with unregulated discharges of storm water.
9. Management of Research and Development Extramural Resources;
With increased R&D funding and limited workyears, there is
growing inability to adequately manage our extramural
resources.
10. Research and Development Facilities; The majority of EPA's
R&D laboratories are more than 20 years old and in serious
disrepair. High quality, timely, scientific and technical
information required to meet EPA's goals cannot be generated
in these facilities.
11. Audit Follow-up; The Agency's audit follow-up practices are
not adequate to ensure that corrective actions resulting
from audit recommendations are accurately tracked and
reported.
-------
12. Inadequate Resources for Research and Development: Laboratory
Operating Expenses: The shortage of resources for R&D
laboratory operating expenses has adversely affected
activities essential to operating the labs.
13. Lack of Effectiveness and Productivity in Chemical Testing;
There has been a lack of effectiveness and productivity in
chemical testing. Without sufficient test data on
chemicals, EPA is impeded in taking appropriate regulatory
action.
14. Research and Development Equipment; EPA has no process for
equipment planning, proper forecasting of needs, ensuring
compliance with property management procedures, or planning
for sufficient budgetary support for adequate scientific
equipment. As a result, EPA's scientific and technical
equipment is becoming obsolete faster than it is being
replaced.
15. Weaknesses in Pesticides' Antimicrobial Program; Inadequate
data integrity, systems support, and enforcement follow-up
may exist in the antimicrobial program.
16. Pesticides Disposal Program; State and local actions can
disrupt implementation of the program and management of its
resources.
The Enforcement Data Integration weakness reported last year
as a material weakness has been corrected. EPA now has the
ability to develop enforcement actions and set enforcement
priorities by associating data on compliance and enforcement
activities from the various program offices' data bases.
EPA is reporting five material nonconformances in its
accounting system, the Integrated Financial Management System
(IFMS). These nonconformances, ranked in order of priority, are:
1. Lack of centralized capability to record, bill, and write-
off accounts receivable: IFMS accounts receivable
capabilities are not yet fully implemented.
2. Reconciliation to external Treasury Department reports; The
procedure used to reconcile external Treasury Department
reports is inadequate.
3. Reconciliation between the Personal Property Accountability
System and IFMS; Property management and accounting records
are not subject to adequate controls to assure accurate
data.
-------
8
4. General ledger accounts from the prior accounting system
have not vet been converted to the IFMS: . The ledger
accounts from the prior accounting system have not yet been
entered into the IFMS.
5. More automation of the exchange of information between IFMS
and other administrative systems: Opportunities exist for
more automation of the accounting system with other
administrative systems.
The Lack of Complete Financial Reporting reported last year
as a material nonconformance has been corrected. An ad hoc
reporting system was developed to meet user needs.
CONCLUSION
EPA's management controls are in place, reviewed and
evaluated to reveal strengths and weaknesses. We are pleased
with progress made in securing senior managers' attention to
identifying and disclosing problems early and in building systems
to institutionalize follow-up, correction and prevention of
recurrences. The Agency's administrative, financial and
management control programs are critical to the success of our
environmental protection work. We are committed to improving and
strengthening these programs on a continuing basis.
Sincerely,
Enclosures (5)
A - Statistical Summary of Performance
B - Review Process
C - Progress Report on High Risk Areas
D - Material Weaknesses/Corrective Actions
E - Material Nonconformances/Corrective Actions
-------
U. S. ENVIRONMENTAL PROTECTION AGENCY
STATISTICAL SUMMARY OF PERFORMANCE
FISCAL YEAR 1991
ENCLOSURE A
PAGE 1 OF 4
SECTION 2. INTERNAL CONTROL SYSTEMS
Overall Compliance: Yes X year achieved 1983.
Number of Material Weaknesses;
In year indicated,
number reported
for the first time.
Prior Years: 16
1989 Report: 6
1990 Report: 5
1991 Report: 7
TOTAL: 34
For that year,
number that have
been corrected.
15
2
0
1
18
For that year,
number still
pending.
1
4
5
6
16
The total number of weaknesses corrected in 1991:
Pending Material Weaknesses*;
Category; Program Management
Number: 13
Year
Identified
Target for
Correction
1. ARCS Contract Management ' 1991 TBD
2. Accelerating Remedial Cleanups 1991 FY 1993
3. Federal Facilities 1991 TBD
4. Contract Laboratory Program 1991 TBD
5. Superf und 1989 FY 1992
6. Data Integrity for Pesticides and
Toxic Substances 1991 FY 1992
7. Implementation of Storm Water
Requirements Under the Clean Water Act..1991 FY 1992
8. Audit Follow-up 1989 FY 1992
9. R&D Laboratory Operating Expenses 1990 FY 1995
10. Chemical Testing 1990 FY 1992
11. Pesticides' Antimicrobial Program 1990 FY 1992
12. Pesticides Disposal Program 1990 FY 1992
13. Requests for Audits of Contractors 1991,
.Ongoing
* Due to the OMB format for Enclosure A, these material weaknesses are presented
in priority order within the appropriate category. Please see the narrative
-------
U. S. ENVIRONMENTAL PROTECTION AGENCY
STATISTICAL SUMMARY OF PERFORMANCE
FISCAL YEAR 1991
ENCLOSURE A
PAGE 2 OF 4
portion of the letter for the ranking of material weaknesses.
—Program Execution
—Systems Development & Implementation
—Asset Disposition
—Environmental Impact
—Safety/Health-Related
—Other (Specify)
11 (#1,4,5,6,7,8
9,10,11,12,13)
0
0
0
2 (#2,3)
Category: Functional Management
Number;
Year
Identified
Target for
Correction
14. R&D Extramural Resources.
15. R&D Facilities
16. R&D Scientific Equipment.
—Procurement
—Grant Management
—Personnel & Organizational Management
—ADP Security
—Payment Systems & Cash Management
—Loan Management & Debt Collection
—Property & Inventory Management
—Other
1990 FY 1994
1989 FY 1993
1988 FY 1994
1 (#14)
0
0
0
0
2 (#15,16)
0
TOTAL
16
SECTION 4. FINANCIAL MANAGEMENT SYSTEMS
Compliance Assurance;
Overall Compliance:
o Compliance with financial information
standards
o Compliance with systems functional
standards
No
Year
Achieved
X 1983
(with exceptions as
noted in Enclosure E)
X 1983
(with exceptions as
noted in Enclosure E)
-------
U. S. ENVIRONMENTAL PROTECTION AGENCY
STATISTICAL SUMMARY OF PERFORMANCE
FISCAL YEAR 1991
ENCLOSURE A
PAGE 3 OF 4
Number of Nonconformances;
In year indicated,
number reported
time.
Prior years: 15
1989 report: 3
1990 report: 0
1991 report: 0
TOTAL: 18
For that year,
number that have
been corrected.
12
1
0
0
13
For that year,
number still
pending.
3
2
0
0
The total number of nonconformances corrected in 1991:
Pending Nonconformances;
Name of
System
IFMS
IFMS
IFMS/PPAS
IFMS
IFMS
Type of
Nonconformance
Financial Information
(Data Quality)
Financial Information
(Data Quality)
Financial Information
(Data Quality)
Financial Information
(Data Quality)
System Function
(Effective Interfaces)
Title of
Nonconformance
Regional accounts receivable
recording, documentation,
and collection problems have
impacted the accuracy of the
general ledger accounts
receivable balances.
Comprehensive reconciliation
between Treasury reports and
IFMS needs to be performed.
Reconciliation with property
and accounting records for FY
1989 and 1990 needs to be
performed.
General ledger account
adjustments as a result of the
implementation of IFMS need to
be accomplished.
Opportunities exist for
greater interface between
the accounting system and
other administrative systems.
-------
U. S. ENVIRONMENTAL PROTECTION AGENCY ENCLOSURE A
STATISTICAL SUMMARY OF PERFORMANCE PAGE 4 OF 4
FISCAL YEAR 1991
Number of Section 4 Systems in Operation;
Type of System: 1990 1991
Core Financial System 1 1
Subsidiary systems:
Budget planning/formulation 1 1
Payroll/personnel 1 1
Purchasing/grants 1 1
Property/inventory 1 1
Other (Contract Information/ 3 3
Contract Payment/Document
Control) 0_ 0_
Total 8 8
-------
U. S. ENVIRONMENTAL PROTECTION AGENCY ENCLOSURE B
REVIEW PROCESS PAGE 1 OF 7
FISCAL YEAR 1991
SECTION 2;
Description of Organization and Structure of Review Process: EPA's
FMFIA review process is organized around eleven primary tasks:
1. Issuing annual policy with a list of areas to emphasize and a
planning calendar.
2. Organizing and segmenting the Agency. This entails updating
records, responding to reorganizations and ensuring full
coverage.
3. Updating event-cycle documentation.
4. Assessing each segment's risk. This includes identifying
programs with more susceptibility to waste, fraud or
mismanagement. EPA has a three-year risk assessment cycle.
EPA's most recent Agency-wide vulnerability assessment was
performed in FY 1989. A few offices completed assessments due
to reorganizations in FY 1991. In early FY 1992, EPA will
embark on a new approach in conducting risk assessments. We
will continue to conduct assessments along organizational
lines. Additionally, we will conduct assessments across
organizations and media lines.
5. Developing the Management Control Plan (MCP) to schedule
internal control evaluations [Internal Control Reviews (ICRs)
and Alternative Internal Control Reviews (AICRs)].
6. Evaluating the effectiveness of controls through AICRs and
ICRs. The reviews may include Office of Inspector General
(OIG) and General Accounting Office (GAO) audits, management
reviews, and other internal and external studies.
7. Developing corrective action plans for weaknesses identified
in ICRs and AICRs. .These action plans include milestone dates
for correcting particular weaknesses and validation procedures
that ensure the corrective actions are effective.
8. Implementing corrective actions according to the action plans.
9. Submitting CATS quarterly updates to track and monitor
weaknesses and assure quality.
10. Reviewing and evaluating effectiveness and cost efficiency of
the FMFIA program and reporting the results in the annual
report on controls to the President and Congress.
-------
U. S. ENVIRONMENTAL PROTECTION AGENCY ENCLOSURE B
REVIEW PROCESS PAGE 2 OF 7
FISCAL YEAR 1991
11. Linking FMFIA and budget preparation to identify resources to
correct material weaknesses and high risk areas.
The Assistant Administrator for Administration and Resources
Management, as the Agency's Senior Internal Control Official, is
responsible for oversight of the FMFIA review process. Primary
Organization Heads.. (POHs) are EPA's senior managers who oversee
EPA's major organizational components. They included in FY 1991,
the Deputy Administrator, nine Assistant Administrators, ten
Regional Administrators, the Inspector General and the General
Counsel. Directives and guidance are in place for POHs and their
Internal Control Coordinators (ICCs) to carry out their
responsibilities under FMFIA.
To facilitate complete FMFIA coverage, EPA's assessable unit
segmentation structure parallels the Agency's budget and program
operating structure. Managers of a particular operation are
responsible and accountable for its management controls.
In FY 1991, EPA managers reported that they conducted 48
formal ICRs and 807 AICRs. EPA's MCP shows that 33 ICRs, 808
AICRs, and numerous other reviews are planned for FY 1992.
In FY 1991, we issued improved guidance outlining the criteria
for developing event cycle documentation. This was accentuated
through management controls workshops held in Headquarters and the
Regions.
EPA continues to gain assistance from GAO and OIG in
evaluating the effectiveness of internal controls. Issues raised
in audits are discussed with senior and program managers, and often
are addressed in the POH assurance letters. Several such issues
are reported in this letter as material weaknesses.
Each year, we ask the Inspector General to suggest potential
material weaknesses. In 1991, the IG presented several issues at
the September 12 meeting of the Senior Council on Management
Controls. Representatives from OMB and GAO attended this meeting
and identified -their recommended material weaknesses for EPA
managers to consider. These suggestions are factored into our
FMFIA reporting.
Management initiatives undertaken by EPA in FY 1991 have
improved internal control processes in an already successful FMFIA
program.
D Automated Management Control Plan (AMCP); Our Region III
office automated their Management Control Plan. This data
-------
U. S. ENVIRONMENTAL PROTECTION AGENCY ENCLOSURE B
REVIEW PROCESS PAGE 3 OF 7
FISCAL YEAR 1991
system tracks the internal control evaluations that are
planned and conducted. The data system has been distributed
Agency-wide for testing. Future plans include implementing
the AMCP on an Agency-wide level.
1991 Statistical Data For Review Process;
o Number of assessable units: 239.
o Number of vulnerability assessments:
Planned 239. Conducted 234.
o Number of 1991 Internal Control Reviews:
Planned 44. Conducted 48.
o ' Number of 1991 Alternative Internal Control Reviews:
Planned 686. Conducted 807.
o Percentage of assessable units reviewed in 1991: 76%
Comments on Discrepancy between Reviews Planned Versus Conducted;
EPA revised its plans for conducting reviews based on changing
priorities and funding availability.
SECTION 4;
Description of Organization and Structure of Review Process; The
FY 1991 accounting system evaluation included five OMB Circular A-
127 detailed evaluations and eight guality assurance reviews.
Other reviews and testing provided reasonable assurance that the
Agency's accounting system generally conforms to the principles and
standards developed by the Comptroller General and implemented
through OMB Circular A-127.
EPA's formal quality assurance program provides a balanced
basis for annually reviewing the Agency's accounting system. The
quality assurance program consists of eight assessment tools:
1. Annual review plans prepared by each branch in the Financial
Management Division (FMD) and all Financial Management
Officers (FMOs).
2. In-house transaction testing of each financial management
function on a three-year cycle.
3. Quality Assurance Reviews (QARs) performed at each servicing
finance office on a three-year cycle by FMD.
-------
U. S. ENVIRONMENTAL PROTECTION AGENCY ENCLOSURE B
REVIEW PROCESS PAGE 4 OF 7
FISCAL YEAR 1991
4. Financial Assistance Reviews (FARs) of specific issues and
Management Assistance Reviews (MARs) performed on an ad hoc
basis by FMO.
5. Independent audits by the General Accounting Office and the
Office of Inspector General.
6. Internal Control Reviews performed by independent parties on
a contractual basis when funding is available.
7. Self-assessments and certifications by all FMOs and accounting
system managers.
8. Quarterly tracking of status toward completing corrective
action on internal control weaknesses/nonconformances.
The accounting system review process will continue during FY 1992
as part of our formal Quality Assurance Program.
Provide an Inventory of Agency's Financial Management Systems and
indicate the Total Number of Systems; EPA has one primary
accounting system which is the Integrated Financial Management
System (IFMS). Three subsidiary systems provide substantial
accounting information to IFMS. They are Payroll/Personnel System
(EPAYS), Contract Payment System (CPS), and Automated Document
Control Register (ADCR). In addition, four administrative systems
contain accounting data. These systems are Contract Information
System (CIS), Grants Information, and Control System (GICS),
Personal Property Accountability System (PPAS), and Resources
Management Information System (RMIS). These eight systems
constitute the financial management system for the Agency.
1991 Statistical Data for Reviews Process;
o Number of annual reviews: 0
o Number of detailed cyclical reviews: 13
o Principal review findings: The reviews did not identify any
new material nonconformances for this year. However, they did
identify improvements needed in the regional quality assurance
programs, regional compliance with established accounting
procedures, and minor accounting system nonconformances.
-------
U. S. ENVIRONMENTAL PROTECTION AGENCY ENCLOSURE B
REVIEW PROCESS PAGE 5 OF 7
FISCAL YEAR 1991
OVERALL
Description of the Agency System for Tracking Reviews. Weaknesses.
and Corrective Actions: Agency-wide, EPA managers use the
Management Control Plan to schedule reviews and the Corrective
Action Tracking System (CATS) to track weaknesses identified in
internal control evaluations. This system tracks and monitors the
status of weaknesses reported in the annual assurance letters as
well as other, less significant weaknesses. Internal Control
Coordinators (ICCs) from each primary organization provide
quarterly status reports for the system on -the corrective actions
taken. Weaknesses identified in audit reports are tracked in the
Agency's Management Audit Tracking System (MATS).
Some of EPA's primary organizations have separate tracking
systems to help monitor their progress. For example, the EPA
office responsible for correcting the Superfund material weakness
uses its Superfund Management Review Progress Report, specifically
related to progress in correcting that material weakness. Relevant
reviews, along with recommendations and associated responses, are
summarized in the Superfund Reports Information System. Other
offices have tracking systems for management of controlled items
within those offices.
Additionally, senior management uses the Agency's Strategic
Targeted' Activities for Results System (STARS) to provide early
warning on potentially troubling national/regional trends and
vulnerability. STARS is also used to determine where targets are
met or exceeded in hopes of isolating successful strategies for
duplication elsewhere in the Agency.
Description of the Process for Validating Corrective Actions;
EPA's validation ensures that corrective actions were successful in
eliminating weaknesses. The Agency now requires the final
milestone in corrective action plans to be a validation action.
Various validation activities used by EPA managers include: review
processes, audits, surveys, and follow-up interviews.
i
EPA's directive on Internal Control requires POHs to carefully
review their operations to ensure that corrective actions taken for
each internal control weakness were sufficient to solve the
problems identified and to preclude future occurrences of these or
similar problems. If the actions appear insufficient, POHs are
asked to modify their corrective actions. We highlight the
importance of validation through the accountabi1itv of the ICC, the
responsibility of the POH, and the oversight, monitoring and
guidance of the Agency senior-management official.
-------
U. S. ENVIRONMENTAL PROTECTION AGENCY ENCLOSURE B
REVIEW PROCESS PAGE 6 OF 7
FISCAL YEAR 1991
The ICCs and POHs complete Quality Control Evaluation Reports
(QCER) as part of their annual assurance letters. This is an
integral part of the Agency's quality control and assurance program
each year. Each QCER examines various aspects of internal
controls. Results of the QCER are used to evaluate EPA's overall
program and identify areas for improvement.
The ICCs review all QCERs completed by their managers,
validate existing risk assessment ratings, review MCPs, consolidate
sub-assurance letters, and consolidate and sign QCERs. ICCs
perform this work to ensure the accuracy, reasonableness, and
reliability of the data.
Description of the Agency's Training in Management Controls; In
FY 1991, we offered more training than in previous years and
developed a management controls workshop for managers. EPA
Internal Control Coordinators arranged training for their managers
on EPA's FMFIA process and their management control
responsibilities. There were 542 managers in 16 offices throughout
EPA trained in management controls for FY 1991. Most offices
reported that they plan to arrange additional training in 1992.
Some offices arranged for the Headquarters Resource Management
Division (RMD) — which oversees EPA's implementation of FMFIA —
to conduct specialized management controls workshops. To
"personalize" the workshops and enhance their effectiveness, RMD
worked closely with those offices' Internal Control Coordinators to
determine what their managers needed. The workshops usually
included:
• An overall explanation of EPA's FMFIA process and objectives;
• An explanation of each document required in the FMFIA process,
such as the risk assessment, event cycle documentation, and
Management Control Plan;
• Managers self-assessment of internal control documents and on-
the-spot development of documents for future use.
In addition to receiving training from within EPA, some
managers received outside training. There were three outside
training courses attended by EPA managers. One well-received
course was Internal Controls given by the Federal Bureau of
Investigations. Another course attended by EPA managers was given
by the Association of Certified Fraud Examiners entitled
Introduction to Fraud Examination. The third course entitled
Evaluating and Reporting on Internal Control Systems was given by
the. Department of Agriculture.
-------
U. S. ENVIRONMENTAL PROTECTION AGENCY ENCLOSURE B
REVIEW PROCESS PAGE 7 OF 7
FISCAL YEAR 1991
Another form of training is our rotational assignment program
for Internal Control and Audit Follow-up Coordinators. These
coordinators — fronr EPA's various program and regional offices -
- work with EPA staff overseeing the Agency's FMFIA and audit
management programs. In FY 1991, several Internal control
Coordinators participated in this program. Region Ill's
coordinator assisted in preparing for the November meeting of the
Senior Council on Management Controls and also helped in writing
the Agency assurance letter. The Region IX coordinator reviewed
the Agency's new cross-media approach to conducting vulnerability
assessments. Region X's coordinator reviewed'the annual guidance
and segmentation and annual work plan calls.
Description of the Agency's Actions to Ensure Accountability for
Results in Identifying and Correcting Material Weaknesses and Non-
conformances; All members of EPA's Senior Executive Service are
required to have an element for management controls and their FMFIA
responsibilities in their performance standards. The same is true
for all Performance Management and Recognition System managers.
Additionally, the Agency requires all General Schedule employees
with specific FMFIA responsibilities — such as Internal Control
Coordinators — to have an element for controls in their
performance standards.
As discussed earlier, EPA's Senior Council on Management
Controls plays a big role in the oversight of correcting weaknesses
and nonconformances. At several Council meetings this.year, senior
managers were asked to provide a status report on their corrective
actions and steps to validate the effectiveness of the actions.
Because of the Senior Council presence, managers have become more
aware of their responsibilities in EPA's management control
program.
-------
U. S. ENVIRONMENTAL PROTECTION AGENCY ENCLOSURE C
PROGRESS REPORT ON HIGH RISK AREAS PAGE- 1 OF 18
FISCAL YEAR 1991
HIGH RISK AREA: Alternative Remedial Contracting System (ARCS)
Contract Management
This high risk area is also reported as a material weakness
in Enclosure D.
Over the past several months, the EPA has been subjected to
serious criticism for its management of the Superfund program.
EPA has been accused of allowing certain Superfund contractors to
spend an inordinate amount of public funds on activities other
than the direct cleanup of contaminated sites. In response to
these allegations, the EPA Administrator established a Task Force
comprised of senior EPA managers and analysts from EPA
Headquarters and Regional offices. The Task Force is addressing
whether or not these allegations of waste are fair and accurate;
if EPA is taking the necessary steps to assure that any problems
are corrected; if oversight of ARCS contractors is adequate and
if improvements are necessary in this area; and if ARCS is still
an appropriate approach to Superfund contracting.
Principal Staff Contact;
Name: Paul Nadeau
Title: .Acting Director, Hazardous Site Control Division
Agency/Office: EPA/OSWER/OERR/HSCD
Telephone Number: (202) 308-8313
Appropriation: Superfund 68/20X8145/TFAY9A
Pace of Corrective Action;
Year Identified; 1991
How Identified; Superfund Management Task Force
Targeted Correction Date in Last Year's Report; Not
Applicable.
Current Target Date; 09/30/92
Strategy; The strategy for corrective action will follow the
Task Force Implementation Plan which was .not issued as of
September 30, 1991. Details of the corrective action measures
will be included in the Corrective Action Tracking System (CATS).
Critical Milestones;
A. Completed Actions/Events: Since the ARCS Report has
just been issued and an implementation plan has not been
prepared, there are no specific milestones at this time.
Results Indicators; OERR identified a series of issues and
recommendations that are grouped into six categories: (1) Program
-------
U. S. ENVIRONMENTAL PROTECTION AGENCY ' ENCLOSURE C
PROGRESS REPORT ON HIGH RISK AREAS PAGE 2 OF 18
FISCAL YEAR 1991
Management, (2) ARCS Capacity and Utilization, (3) ARCS Contract
Controls, (4) ARCS Financial Audits, (5) Award Fee Process, and
(6) EPA Management Process.
An implementation plan will be developed during the first
quarter of FY 1992 to further identify areas of vulnerability and
to establish mechanisms to evaluate progress in addressing the
areas of vulnerability.
-------
U. S. ENVIRONMENTAL PROTECTION AGENCY ENCLOSURE C
PROGRESS REPORT ON HIGH RISK AREAS PAGE 3 OF 18
FISCAL YEAR 1991
HIGH RISK AREA: Accelerating Remedial Cleanups (Programmatic)
The programmatic weakness for this high risk area is also
reported as a material weakness in Enclosure D.
In June 1991, a 30-Day Task Force was convened by the
Assistant Administrator of OSWER, in response to key questions
posed by the Administrator. The primary question is "What are
EPA's options for accelerating the rate of cleanups at Superfund
sites?" The approach of this task force was to apply TQM
principles in looking at all phases of Superfund site management
to determine how the pace of cleanup could be accelerated. The
corrective actions describe the plans OSWER will implement to
accelerate the pace of remedial cleanups.
Principal Staff Contact;
Name: Paul Nadeau
Title: Acting Director, Hazardous Site Control Division
Agency/Office: EPA/OSWER/OERR/HSCD
Telephone Number: (202) 308-8313
Appropriation; Superfund 68/20X8145/TFAY9A
Pace of Corrective Action;
Year Identified: 1991
How Identified: Superfund 30 Day Study Task Force Report
Targeted Correction Date in Last Year's Report: new issue
Current Target Date; 09/30/92
Strategy; The corrective action plans outlined in this report
are based on the Implementation Plan issued by the Task Force.
Implementation of corrective actions will be facilitated via a
senior management task force chaired by the Deputy Assistant
Administrator, OSWER with Deputy Regional Administrators from
each Region. The DAA of OSWER will meet with the Regions,
individually and in groups, shortly. Issues specific to the
Regions will receive a high level of attention. Regions have
already been asked for an assessment of where Superfund resources
might be added to have the most impact on the speed of site
cleanups.
Critical Milestones COMPLETION DATE
ORIGINAL CURRENT ACTUAL
PLAN PLAN
A. Completed Actions/Events; There are several corrective
action plans to correct this weakness. See Enclosure D for
details of these plans.
-------
U. S. ENVIRONMENTAL PROTECTION AGENCY
PROGRESS REPORT ON HIGH RISK AREAS
FISCAL YEAR 1991
ENCLOSURE C
PAGE 4 OF 18
Critical Milestones
ORIGINAL
PLAN
-COMPLETION DATE-
CURRENT
PLAN
ACTUAL
B. Planned Actions/Events (short-term - next 12 months):
Enclosure D for detailed corrective action plans.
Segregate Federal Facilities 12/31/91
Communications Strategy 11/30/91
Publish NPL #12 with new
language 12/31/91
Set Aggressive Cleanup targets 09/30/93
Meet with Regions 12/31/91
Dev. plan and reallocation
strategy 01/31/92
Standardize the Planning Process 06/30/92
Analysis of options 02/28/92
Prioritize approaches 06/30/92
Expand Measures of Success 06/30/92
Draft Strategy 03/31/92
See
C. Planned Actions/Events (longer-term);
detailed corrective action plans.
See Enclosure D for
Expand Flexibility of Contracts 09/30/93
Develop options 03/31/92
Evaluate effects of pilots 09/01/93
Elevate Issues Causing Delays 09/30/93
Prepare strategy 12/31/91
Monitor progress 12/31/91
Results Indicators; OERR has developed Corrective Action Plans
to address the following weaknesses identified in the 30-Day
internal study of the Superfund program.
— Set aggressive cleanup targets
Standardize remedial planning 'and remedy selection
Expand flexibility of design/construction contracts
— Elevate issues causing site-specific delays
— Expand Superfund's measures of success
Assessment of Progress: See Enclosure D.
-------
U. S. ENVIRONMENTAL PROTECTION AGENCY ENCLOSURE C
PROGRESS REPORT ON HIGH RISK AREAS PAGE 5 OF 18
FISCAL YEAR 1991
HIGH RISK AREA; Accelerated Remedial Cleanups (Enforcement)
The enforcement weakness for this high risk area is also
reported as a material weakness in Enclosure D.
In June 1991, a 30-Day Task Force was convened by the
Assistant Administrator of OSWER. Its mission was to respond to
key questions posed by the Administrator. The primary question
is "What are EPA's options for accelerating the rate of cleanups
at Superfund sites?" The approach of this task force was to
apply TQM principles in looking at all phases of Superfund site
management to determine how the pace of cleanup could be
accelerated. The corrective actions outlined in this Annua-1
Assurance Letter describe the plans Superfund will implement to
accelerate the pace of remedial cleanups.
Principal Staff Contact;
Name: Sally- Mansbach
Title: Director, CERCLA Enforcement Division
Agency/Office: EPA/OSWER/OWPE
Telephone Number: FTS 308-8404
Appropriation; Superfund Trust Fund
Pace of Corrective Action;
Year Identified; 1991
How Identified; Superfund 30 Day Task Force Report
Targeted Correction Date in Last Year's Report: new issue
Current Target Date: 9/30/92
Strategy: OWPE is following the implementation plan developed by
the Superfund 30-day Study Task Force. The plan includes a
detailed listing of the milestones to implement the
recommendations outlined in the study.
Critical Milestones
A. Completed Actions/Events; None
B. Planned Actions/Events fFY 19921; Elevate Site-Specific
Issues (EPA/DOJ issues): see Enclosure D.
Accelerate Private Party Cleanups (Begin Remedial Design
before entry of Consent Decree): see Enclosure D.
-------
U. S. ENVIRONMENTAL PROTECTION AGENCY ENCLOSURE C
PROGRESS REPORT ON HIGH RISK AREAS PAGE 6 OF 18
FISCAL YEAR 1991
Results Indicators:
- Increased numbers of early settlements with de minimis PRPs in
order to minimize delays in settlements with other contributors
for overall site remedy.
- An increase in PRP remedial design starts at or prior to
consent decree lodging. This is currently optional language in
the model RD/RA consent decree. Making this mandatory language
is now under consideration.
- Innovative agreements which show effective negotiations with
other collateral PRPs, thereby minimizing delays in the overall
settlement process.
- Remedial Pipeline trends as evaluated through the STARS system
to ensure continuous management improvement.
- Effective compliance monitoring and enforcement follow-up.
Assessment of Progress! Because of the recent release of the 30-
Day Study, limited progress has been achieved to date with the
real measures of success expected during FY 92. Those items
which have occurred to date are as follows:
- EPA conducted both the municipal and de minimis conferences to
devise effective ways to get these types of collateral PRPs
through the enforcement process as quickly as possible and to
minimize delays in the overall site settlement process.
- EPA established STARS measures to evaluate trends in Remedial
Pipeline duration and to encourage continuous improvement with
respect to pipeline management.
-------
U. S. ENVIRONMENTAL PROTECTION AGENCY ENCLOSURE C
PROGRESS REPORT ON HIGH RISK AREAS PAGE 7 OF 18
FISCAL YEAR 1991
HIGH RISK AREA: The 90-Day Study (Programmatic)
In FY 1989, EPA identified all of Superfund as a high risk
area based on the "Superfund Management Review" (also known as
the 90 Day Study). The recommendations outlined in this report
led to the corrective action plans associated with one material
weakness—the Superfund Program—which EPA reported in the
FY 1989 FMFIA report.
A FY 1989 review of this $8.5 billion program indicated that
EPA had to set fair and realistic goals and put controls in place
to assure the program's integrity. Fifty recommendations for
improvement were made. The agency believes full implementation of
the recommendations will help to restore public confidence in the
program.
Principal Staff Contact:
Name: • Clem L. Rastatter
Title: Director, Office of Program Management
Agency/Office: EPA/OSWER/OERR/OPM
Telephone Number: (202) 260-2441
Appropriation: Superfund; 68/20X8145/TFAY9A."
Pace of Corrective Action;
Year Identified: 1989
How Identified;Internal Report "A Management Review of
the Superfund Program".
Targeted Correction Date in Last Year's Report;
September 30, 1991
Current Target Date; December 31, 1991
Reason for Change in Date; Although much progress has been
made, certain workplans required adjustments through the
year. Enclosure D Workplans detail specific explanation
for any workplan that has slipped.
Strategy; In FY 1989, at the Administrator's request, a major
review of the Superfund program (entitled "A Management Review of
the Superfund Program" and known as the "90-Day Study") was
completed. The study led us to declare one material weakness,
the Superfund program. This weakness met OMB's criteria for
"materiality". The Administrator required corrective action
workplans for all offices that had a role in implementing the
study's recommendations. EPA's corrective actions for this high
risk issue are included in Enclosure D.
OERR maintains an automated Milestone Tracking System (MTS)
that can provide detailed planned corrective actions for each of
these weaknesses and the relevant action officials. During FY
-------
U. S. ENVIRONMENTAL PROTECTION AGENCY ENCLOSURE C
PROGRESS REPORT ON HIGH RISK AREAS PAGE 8 OF 18
FISCAL YEAR 1991
1991, OERR worked on 15 90-Day Study corrective action workplans
as part of the FY 1991 material weakness corrective action
process. Since last year, OERR completed 13 of these workplans,
with each workplan consisting of multiple corrective actions. Of
the remaining workplans, both will be completed in FY 1992.
Critical Milestones COMPLETION DATE
ORIGINAL CURRENT ACTUAL
PLAN PLAN
See Enclosure D for detailed corrective action plans.
A. Completed Actions/Events; 13 Corrective Action Workplans
were completed in FY 1991. For a listing and specific details,
see Enclosure D.
B. Planned Actions/Events (short-term - next 12 months!: Two
workplans from the 90-Day Study will be completed by 12/31/91:
NPL Listing Consistency 12/31/91
TAG Application Process 10/31/91
«
See Enclosure for details of these corrective action plans.
Results Indicators; OERR has established several mechanisms to
evaluate progress in addressing areas of vulnerability. These
include: (1) annual review of Records of Decision and subsequent
meetings with Regional staff/management to discuss results and
needed areas of improvement, (2) annual regional reviews have
been revised to ensure that senior OSWER managers focus attention
on areas of vulnerability, (3) assessments of contract management
and operations are designed to evaluate and 'provide corrective
measures to areas of vulnerability, and (4) strategic program
issues are identified by OERR and independent analysis is
undertaken to determine if program implementation is
accomplishing the intended results. Options for improvements are
presented to management as needed..
Assessment of Progress; Summary Information Highlights
- Fifteen 90-Day Study Workplans were active in FY 1991. 13
plans were completed in FY 1989 and FY 1990.
- Eight workplans involved the development of major program
guidance/training sessions/technical manuals/technology
transfer/documents and catalogues.
- Seven workplans involved the development of short sheets and
fact sheets, many of which focused on community relations issues.
-------
U. S. ENVIRONMENTAL PROTECTION AGENCY ENCLOSURE C
PROGRESS REPORT ON HIGH RISK AREAS PAGE 9 OF 18
FISCAL YEAR 1991
- Five workplans resulted in the development of other products
such as support on OSW soil and debris regulations, Environmental
Indicators report, a new jargon matrix, and conducting removal
assessments at each NPL site and removal actions to eliminate
immediate threats.
See Enclosure D for more detailed information on each
corrective action workplan.
-------
U. S. ENVIRONMENTAL PROTECTION AGENCY ENCLOSURE C
PROGRESS REPORT ON HIGH RISK AREAS PAGE 10 OF 18
FISCAL YEAR 1991
•
HIGH RISK AREA: The 90-Day Study (Enforcement)
In FY 1989, EPA identified all of Superfund as a high risk
area based on the "Superfund Management Review" (also known as
the 90 Day Study). The recommendations outlined in this report
led to the corrective action plans associated with one material
weakness—the Superfund Program—which EPA reported in the
FY 1989 FMFIA report.
A FY 1989 review of the $8.5 billion Superfund program
indicated that EPA had to set fair and realistic goals and put
controls in place to assure the program's integrity. Fifty
recommendations for improvement were made. T.he Agency believes
full implementation of the recommendations will help to restore
public confidence in the program.
Principal Staff Contact:
Name: Sally Mansbach
Title: Director, CERCLA Enforcement Division
Agency/Office: EPA/OSWER/OWPE
Telephone Number: FTS 398-8404
Appropriation; Superfund Trust Fund
Pace of Corrective Action;
Year Identified; 1989
How Identified; Internal Report "A Management Review of
the Superfund Program".
Targeted Correction Date in Last Year's Report;
September 30, 1991
Current Target Date; December 31, 1991
Reason for Change in Date; Milestones vary in complexity
Strategy; The Superfund Implementation Program was based on the
90-day Superfund Management Review (SMR) and set forth a
comprehensive long-term strategy for the Superfund Program. The
basic elements of the strategy are to: (1) control acute threats
immediately, (2) deal with the worst sites and worst problems
first, (3) carefully monitor/maintain sites over the long term,
(4) emphasize enforcement to induce private-party cleanup, (5)
seek new technologies for more effective cleanup, (6) improve the
efficiency of program operations, and (7) encourage full
participation of communities.
Critical Milestones; OWPE had the lead on approximately 23 major
SMR projects, involving 50 major milestones.
13 major projects (57%) completed
38 milestones (76%) completed
-------
U. S. ENVIRONMENTAL PROTECTION AGENCY ENCLOSURE C
PROGRESS REPORT ON HIGH RISK AREAS PAGE 11 OF 18
FISCAL YEAR 1991
The most critical concerns for Superfund Enforcement were:
- more aggressive use of enforcement tools;
- review of remedy selection to ensure that remedies at
sites where responsible parties (RPs) perform the RI/FS or
express a willingness to perform the remedy are as protective and
permanent as those developed exclusively by the Agency; and
- strengthening of the Cost Recovery Program.
A. Completed Actions/Events; see Enclosure D, Work Plans
#90002, 90008 and 90019.
B. Planned Actions/Events (FY 1992); see Enclosure D, Work
Plans #90010, 90011 and 90013.
Results Indicators;
- Increased use of Unilateral Administrative Orders for RO/RA.
- Requirement established for Headquarters consultation with the
Region when not issuing a UAO prior to Fund-financing Remedial
Design.
- Finalization of the Site Management Planning Guidance.
- A National Workgroup on CERCLA Enforcement Compliance
Monitoring established including the drafting of a directive
outlining minimum compliance tracking requirements.
- Continued use of treble damage authorities under CERCLA.
- Increased number of settlements of all types, particularly
those for RD/RA.
- Increased use of de minimis provisions of SARA.
- Response/Enforcement Integrated Timeline established.
- Strategic performance evaluation measures established to
evaluate trends in pipeline duration and resulted in improvements
and/or weaknesses.
- The Cost Recovery Rule developed and planned for submission to
OMB.
- Increased funding flexibility for remedial pipeline events,
particularly in the area of Regional Case Budget management.
-------
U. S. ENVIRONMENTAL PROTECTION AGENCY ENCLOSURE C
PROGRESS REPORT ON HIGH RISK AREAS PAGE 12 OF 18
FISCAL YEAR 1991
- Increased number of cost recovery referrals.
Assessment of Progress;
Unilateral Administrative Orders have increased as follows:
FY 1988 FY 1989 FY 1990 FY 1991
RD/RA 13 28 44 46
- The total number of treble damage cases filed since the
passage of SARA in 1986 has been 15.
-The statistics for settlements/compliant UAOs for RO/RA are as
follows:
FY 1988 FY 1989 FY 1990 FY 1991
Settlements: 30 49 60 71
UAOs in Compliance: 6 23 37 27
Total: 36 72 97 98
- To date, there have been 35 de minimis settlements and there
are an additional 17 pending.
- To date, there have been only 10 mixed funding/preauthorization
settlements. However, due to the success of the Enforcement-
First initiative, including use of UAOs, there has been little
need to pursue greater use of mixed funding settlements.
- Since SARA, referrals have increased through FY 1989, and then
stabilized, primarily due to the increase in the rate of
settlements to conduct work in all phases of the remedial
pipeline. Performance is as follows:
FY 1987 FY 1988 FY 1989 FY 1990 FY 1991
37 56 83 79 72
-------
U. S. ENVIRONMENTAL PROTECTION AGENCY ENCLOSURE C
PROGRESS REPORT ON HIGH RISK AREAS PAGE 13 OF 18
FISCAL YEAR 1991
•
HIGH RISK AREA: Financial Systems
GAO, OIG and in-house management reviews have reported
nonconformances and deficiencies in EPA financial systems.
Installation' of the new Integrated Financial Management System
(IFMS) has led to delays in rectifying the systems' problems.
Specific problems include a lack of flexibility in the accounts
receivable module for interest calculations and insufficient
general ledger controls.
Principal Staff Contact;
Name: Sallyanne Harper
Title: Director, Financial Management Division
Agency/Office: US EPA, Office of the Comptroller
Telephone Number: (202) 260-5097
Appropriation: All Appropriations
Pace of Corrective Action;
Year Identified: 1989
Original Targeted Correction Date; September 1990
Targeted Correction Date in Last Year's Report; June 1993
Current Target Date; June 1993
Strategy; A corrective action plan has been developed that
addresses the issue. Milestones are used to ensure progress is
monitored. Revisions are made to the corrective action plan when
additional information or problems are identified.
Critical Milestones COMPLETION DATE
ORIGINAL CURRENT ACTUAL
PLAN PLAN
A. Completed Actions/Events;
Accounts Receivable: Issued 2/90 2/90
policies and procedures to track
enforcement actions.
General Ledger: Automatically 4/90 4/90
performed month-end and
year-end closing and roll
over of account balances.
-------
U. S. ENVIRONMENTAL PROTECTION AGENCY ENCLOSURE C
PROGRESS REPORT ON HIGH RISK AREAS PAGE 14 OF 18
FISCAL YEAR 1991
Critical Milestones COMPLETION DATE
ORIGINAL CURRENT ACTUAL
PLAN PLAN
A. Completed Actions/Events (Continued);
Accounts Receivable:
Implemented IFMS feature to 5/90 5/90
automatically calculate interest,
penalties and handling charges.
Implemented IFMS feature to 5/90 5/90
automatically generate demand
and billing letters.
All EPA Regions started 5/90 5/90
implementing improved procedures
for establishing accounts receivable.
Issue final policies and 1/91 11/90
procedures on billings and
receivables.
First quarterly reports on 9/90 1/91
implementation due.
Start first round of on-site 10/90 2/91
verification reviews.
Implement IFMS features to 10/90 3/91
perform on-line write-off of
uncollectible accounts.
Complete implementation of 12/90 6/91
improved procedures in all regions.
Complete first round of on-site 6/91 7/91
verification reviews.
Financial Reporting:
Modified existing report formats 7/90 7/90
based on user comments, issued
seven new reports on budget and
construction grants, and published
clear instructions to assist
report users.
-------
U. S. ENVIRONMENTAL PROTECTION AGENCY ENCLOSURE C
PROGRESS REPORT ON HIGH RISK AREAS PAGE 15 OF 18
FISCAL YEAR 1991
Critical Milestones COMPLETION DATE
ORIGINAL CURRENT ACTUAL
PLAN PLAN
A. Completed Actions/Events (Continued);
Complete IFMS Management and 12/90 3/91
prototype testing of the IFMS
Management and Accounting
Reporting System.
Train users in Management and 5/91 7/91
Accounting Reporting System.
Implement Management and 5/91 7/91
Accounting Reporting System
Agency-wide.
General Ledger:
Install edit verify data entries. 6/91 6/91
B. Planned Actions/Events (short term - next 12 months).
Accounts Receivable: Complete 6/92 6/92
second round of on-site
verification reviews.
C. Planned Actions/Events (longer term)
General Ledger:
Reconcile general ledger data. 2/92 10/92
Update policies and procedures 3/92 10/92
for recording transactions in IFMS.
Accounts Receivable: Complete 6/93 6/93
third round of on-site
verification reviews.
Corrective actions consist of improvements to automated
financial system reporting, general ledger and accounts
receivable capabilities. Specifically, the following actions
were completed in FY 1991: (1) implemented the Management and
Accounting Reporting System (MARS); (2) installed general ledger
data edit checks to verify data entries; (3) implemented enhanced
system features to perform on-line write-off of uncollectible
accounts; and (4) issued new accounts receivable directives,
-------
U. S. ENVIRONMENTAL PROTECTION AGENCY ENCLOSURE C
PROGRESS REPORT ON HIGH RISK AREAS PAGE 16 OF 18
FISCAL YEAR 1991
implemented strengthened procedures throughout EPA, and began on-
site reviews of EPA Regions to verify that past problems were
corrected.
During FY 1992, general ledger data will be fully reconciled
and financial system procedures will be updated.
During FY 1993, we will complete on-site reviews and follow-
up reviews to verify that accounts receivable are promptly
recorded in the Agency's financial system. EPA anticipates this
action may enable OMB to remove EPA's financial system from OMB's
high risk list.
Results Indicators:
1. Accounts Receivable: Matching program and accounting
records of accounts receivable. Increased recording and
collection of accounts receivable.
2. Financial Reporting: Ready availability of financial
information in formats that meet user requirements. Discontinued
reliance on ad hoc reporting capabilities of former system.
3. General Ledger: Ability to rely on cumulative trial
balances.
Assessment of Progress; EPA's progress toward enhancing the
Integrated Financial Management System was been delayed. Our
progress has been delayed because we want to ensure that the
software meetS our requirements prior to implementation.
However, we have successfully implemented the ad hoc reporting
system (Management and Accounting Reporting System) needed by EPA
users and met several other milestones. For example, the
Accounts Receivable Task Force (ARTF) has completed their first
round of visits to regional finance offices. The purpose of the
ARTF is to ensure compliance with accounts receivable policies
and procedures. Corrective actions have been developed by the
finance offices in response to problems identified by the ARTF,
These action plans are being monitored by the Financial
Management Division.
We fully expect that the remaining milestones will be
accomplished.
-------
U. S. ENVIRONMENTAL PROTECTION AGENCY ENCLOSURE C
PROGRESS REPORT ON HIGH RISK AREAS PAGE 17 OF 18
FISCAL YEAR 1991
HIGH RISK AREA; Data Integration
OE was hampered in its ability to develop enforcement
actions, set enforcement priorities and target enforcement,
respond to crises and conduct program oversight because of the
inability to associate data on compliance and enforcement
activities from various program offices data bases.
Principal Staff Contact;
Name: Gerald A. Bryan
Title: Director, Office of Compliance Analysis and Program
Operations
Agency/Office: U.S. EPA, Office of Enforcement
Telephone Number: 260-4140
Appropriation; 6800200
Pace of Corrective Action;
Year Identified; FY 1989
How Identified: IG Audit
Targeted Correction Date in Last Year/s Report; 12/90
Current Target Date; Completed February 21, 1991
Reason for Change in Date; Delays occurred in the initial
development of IDEA because of the inability to quickly resolve
with the National Computer Center (NCC) how direct access to the
data systems running in ADABAS would be provided. As a result,
several of the milestone dates were achieved two months later
than originally planned. "
-------
U. S. ENVIRONMENTAL PROTECTION AGENCY ENCLOSURE C
PROGRESS REPORT ON HIGH RISK AREAS PAGE 18 OF 18
FISCAL YEAR 1991
Critical Milestones
-—COMPLETION DATE
ORIGINAL CURRENT ACTUAL
PLAN PLAN
1. Form Workgroup to
develop linking mechanism,
resource requirements and
schedule for implementation 11-01-89
2. Define linking approach
and systems to be linked 11-21-89
3. Develop resource
requirements and construct
a strategy for implementa-
tion, including a project
plan (review projected
milestones and revise
as appropriate) 01-26-90
4. Modify systems where
necessary to accommodate
link ID number 09-30-90
5. Complete update of
systems with link ID
number for current
records 12-31-90
6. Develop automated ID
number assignment proce-
dures and programs 12-31-90
7. Final implementation
of linkage capability
including ongoing
operations and maintenance 12-31-90
11-89
11-89
3-2-90
9-30-90
1-91
2-21-91
2-21-91
Validation; Validation of the effectiveness of.the corrective
action tied to the use of the capability. All headquarters and
regional offices have been trained on the use of IDEA and
currently several offices are incorporating analysis using IDEA
in enforcement screening, enforcement targeting, and strategic
planning. Procedures have been developed requiring that before
individuals can use IDEA and gain access to enforcement sensitive
data, authorization must be granted at the DRA
level. Additional procedures are being developed to provide
access to nonsensitive data.
-------
U.S. ENVIRONMENTAL PROTECTION AGENCY
MATERIAL WEAKNESS/CORRECTIVE ACTIONS
FISCAL YEAR 1991
ENCLOSURE D
PAGE 1 OF 97
PART ONE: SUMMARY/TABLE
Title
ARCS Contract
Management
Accelerating
Remedial Cleanup
Federal Facilities
Contract Laboratory
Program
Superfund
Data Integrity for
Pesticides and
Toxic Substances
Requests for Audits
Storm Water
Managing R&O
Extramural Resources
R&D Laboratory
Facilities
Audit Follow-Up
R&D Laboratory
Operating Expenses
Chemical Testing
R&D Scientific
Equipment
Antimicrobial
Program
Pesticides Disposal
Enforcement Data
Integration
First
Reported
1991
1991
1991
1991
1989
1991
1991
1991
1990
1989
1989
1990
1990
1988
1990
1990
1990 FMFIA
Report Target
for Correction
n/a
n/a
n/a
n/a
1991
n/a
n/a
n/a
1992
1991
1991
1993
1992
1994
1992
1992
Current
Target for
Correction
To Be
Determined
1993
1993
To Be
Determined
1991
1992
Ongoing
1992
1994
1993
1991
1995
1992
1994
1992
1992
Page
2
4
21
24
26
66
68
70
72
76
80
83
87
90
92
94
1989
1991
Complete
96
-------
U. S. ENVIRONMENTAL PROTECTION AGENCY ENCLOSURE D
MATERIAL WEAKNESS/CORRECTIVE ACTIONS PAGE 2 OF 97
FISCAL YEAR 1991
PART TWO: DESCRIPTION OF UNCORRECTED MATERIAL WEAKNESSES
CATS Tracking Number:
Assessable Unit/AU t: OERR/HSCD/1902
Title of Material Weakness: ARCS Contract Management
Description of Material Weakness and Its Impact on Agency
Operations; Weaknesses identified through the Administrator's
Task Force on ARCS Contract Management. EPA has been subjected to
serious criticism for its management of the Superfund program. EPA
has been accused of allowing certain Superfund contractors to spend
public funds on activities other than the direct site cleanup of
Superfund sites.
Workolan #\ 01222
Functional Category in Statistical Summary: Environmental Impact
Appropriation/Program Element: Superfund; 68/20X8145/TFAY9A
Administrative Activity/Program Activity; Program Activity
Year Identified: 1991
Source of Discovery; Superfund Management Task Force
Original Target Correction Date: 09/30/92
Current Target Date; 09/30/92
Critical Milestones in Planned Corrective Action;
A. Completed Actions/Events;
M/S # MILESTONE TITLE ORIG PLAN ACTUAL
M 001 Participate in Task 09/20/91 09/20/91 09/20/91
Force
B. Planned Actions/Events (Short-Term - Next 12 Months):
M/S # MILESTONE TITLE ORIG PLAN ACTUAL
M 002 Task Force Issues 10/02/91 10/02/91 10/02/91
Report
-------
U. S. ENVIRONMENTAL PROTECTION AGENCY
MATERIAL WEAKNESS/CORRECTIVE ACTIONS
FISCAL YEAR 1991
ENCLOSURE D
PAGE 3 OF 97
M/S # MILESTONE TITLE
M 003 Draft HSCD
Implementation Plan
M 001 Verification of
Completion
ORIG PLAN ACTUAL
11/15/91 11/15/91 / /
09/30/92 09/30/92 / /
Validation Process to be Used; HSCD staff will conduct on-site
review of Regional ARCS project management process.
Corrective Action Plan Status Updates;
o September 30. 1991. Status Update; The Superfund Task Force
(Dunne Workgroup) has reviewed the ARCS program and issued a
report. This report included a discussion of ARCS areas of
vulnerability. Because of the recent issuance of this report, a
more specific workplan of corrective action is not available at
this time. The first quarter CATS report will contain more
detailed information.
-------
U. S. ENVIRONMENTAL PROTECTION AGENCY ENCLOSURE D
MATERIAL WEAKNESS/CORRECTIVE ACTIONS PAGE 4 OF 97
FISCAL YEAR 1991
CATS Tracking Number:
Assessable Unit/AU f: OERR/HSED/1902
Title of Material Weakness; Accelerating Remedial Cleanups:
Segregate Federal Facilities from the NPL
Description of Material Weakness and Its Impact on Aaencv
Operations; More effectively segregate Federal facilities on the
NPL. EPA is required to place Federal facilities on the NPL,
although cleanup at those sites is not EPA's responsibility.
Because the NPL is the most commonly used measure of EPA progress,
it would be appropriate to more clearly distinguish between Federal
facilities and sites for which EPA has responsibility.
Workplan #: To Be Determined
Functional Category in Statistical Summary; Environmental Impact
Appropriation/Program Element; Superfund; 68/20X8145/TFAY9A
Administrative Activity/Program Activity; Program Activity
Year Identified; 1991
Source of Discovery; The Superfund 30 Day Study Task Force
Original Target Correction Date; 1993
Current Target Date: 1993
Critical Milestones in Planned Corrective Action:
A. Completed Actions/Events:
M/S # MILESTONE TITLE ORIG PLAN ACTUAL
M 001 Review Of Options by 09/30/91 09/30/91 09/30/91
AA
B. Planned Actions/Events (Short Term; next 12 months)
M/S # MILESTONE TITLE ORIG PLAN ACTUAL
-------
U. S. ENVIRONMENTAL PROTECTION AGENCY
MATERIAL WEAKNESS/CORRECTIVE ACTIONS
FISCAL YEAR 1991
ENCLOSURE D
PAGE 5 OF 97
M 002 Draft Preamble
Language for Fed.
Register
10/31/91 10/31/91
M 003 Dev. Communications 11/30/91 11/30/91 / /
Strategy
M 004 Publish Proposed NPL 12/31/91 12/31/91 / /
#12 With New Language
M 005 Verification of
Completion
12/31/91 12/31/91
Validation Process to be Used; To be determined.
Corrective Action Plan Status Updates:
o September 30. 1991 Status Update; Report was just published
October 1, 1991.
-------
U. S. ENVIRONMENTAL PROTECTION AGENCY ENCLOSURE D
MATERIAL WEAKNESS/CORRECTIVE ACTIONS PAGE 6 OF 97
FISCAL YEAR 1991
CATS Tracking Number;
Assessable Unit/AU #: OERR/HSCD/1902
**
Title of Material Weakness: Accelerating Remedial Cleanups: Set
Aggressive Cleanup Targets
Description of Material Weakness and Its Impact on Agency
Operations: Set aggressive cleanup targets. EPA will more
aggressively pursue site completion as a target of performance.
The Agency will establish national and Regional targets for FY 92
and FY 93 as well as goals for the year 2000. Those targets will
represent an increase in site completions of over 100% by the end
of 1992; over 200% by the end of 1993 (200 sites); and a ten-fold
increase by the year 2000 (650 sites).
Workplan #: To Be Determined
Functional Category in Statistical Summary; Environmental Impact
Appropriation/Program Element; Superfund; 68/20X8145/TFAY9A
Administrative Activity/Program Activity; Program Activity
Year Identified; 1991
Source of Discovery; The Superfund 30 Day Study Task Force
Original Target Correction Date; 1993
Current Target Date; 1993
Critical Milestones in Planned Corrective Action:
A. Completed Actions/Events;
M/S # MILESTONE TITLE ORIG PLAN ACTUAL
M 002 Establish -Workgroup 09/30/91 09/30/91 09/25/91
-------
U. S. ENVIRONMENTAL PROTECTION AGENCY ENCLOSURE D
MATERIAL WEAKNESS/CORRECTIVE ACTIONS PAGE 7 OF 97
FISCAL YEAR 1991
B. Planned Actions/Events (Short-Term - Next 12 Months)
M/S # MILESTONE TITLE ORIG PLAN ACTUAIT
M 001 Formally Establish 09/30/91 10/15/91 / /
Targets
M 003 Meet With Regions 12/31/91 12/31/91 / /
M 004 Establish Tracking 12/31/91 12/31/91 / /
System
M 005 Dev. Plan and 01/31/92 01/31/92 / /
Reallocation Strategy
C. Planned Actions/Events (Longer Term);
M/S # MILESTONE TITLE ORIG PLAN ACTUAL
M 006 Elevate Site-Spec. / / / / / /
Issues
M 007 Verification of 09/30/93 09/30/93 / /
Completion
Validation Process to be Used; To be determined.
Corrective Action Plan Status Updates;
o September 30. 1991 Status Update; Report was just published
October 1, 1991.
-------
U. S. ENVIRONMENTAL PROTECTION AGENCY ENCLOSURE D
MATERIAL WEAKNESS/CORRECTIVE ACTIONS PAGE 8 OF 97
FISCAL YEAR 1991
CATS Tracking Number;
Assessable Unit/AU f: OERR/HSCD/1902 .
Title of Material Weakness: Accelerating Remedial Cleanups:
Standardize the Remedial Planning Process
Description of Material Weakness and Its Impact on Agency
Operations; EPA would standardize the remedial planning process,
to the extent possible given the variety of site conditions. Three
types of standardization are proposed: presumptive remedy
selection; development of soil cleanup levels; and development of
technology-based standards.
Workplan if: To be determined
Functional Category in Statistical Summary; Environmental Impact
Appropriation/Program Element: Superfund; 68/20X8145/TFAY9A
Administrative Activity/Program Activity; Program Activity
Year Identified; 1991
Source of Discovery; The Superfund 30 Day Study Task Force
Original Target Correction Date: 1993
Current Target Date; 1993
Critical Milestones in Planned Corrective Action:
A. Completed Actions/Events: None
B. Planned Actions/Events (Short-Term - Next 12 Months);
M/S # MILESTONE TITLE ORIG PLAN ACTUAL
M 001 Establish Workgroup 11/30/91 11/30/91 / /
M 002 Analysis of Options 02/28/92 02/28/92 / /
M 003 Determine Resource 05/31/92 05/31/92 / /
Implications
M 094 Prioritize Approaches 06/30/92 06/30/92 / /
M 005 Verification of 06/30/92 06/30/92 / /
Completion
-------
U. S. ENVIRONMENTAL PROTECTION AGENCY ENCLOSURE D
MATERIAL WEAKNESS/CORRECTIVE ACTIONS PAGE 9 OF 97
FISCAL YEAR 1991
Validation Process to be Used; To Be Determined
Corrective Action Plan Status Updates:
o September 30. 1991 Status Update; Report was just published
October 1, 1991.
-------
U. S. ENVIRONMENTAL PROTECTION AGENCY ENCLOSURE D
MATERIAL WEAKNESS/CORRECTIVE ACTIONS PAGE 10 OF 97
FISCAL YEAR 1991
CATS Tracking Number;
Assessable Unit/AU *; OERR/HSCD/1902
Title of Material Weakness; Accelerating Remedial Cleanups:
Expand Flexibility of Design/Construction Contracts
•
Description of Material Weakness and Its Impact on Agency
Operations; Expand flexibility of design/construction contracts.
This project will develop and pilot methods to accelerate the pace
of remedial actions by proceeding directly with on-site cleanup
activities following the ROD. Methods to limit the design effort
and cost reimbursement remedial action contracting will be
examined.
Workplan #: To Be Determined
Functional Category in Statistical Summary; Environmental Impact
Appropriation/Program Element; Superfund; 68/20X8145/TFAY9A
Administrative Activity/Program Activity; Program Activity
Year Identified; 1991
Source of Discovery; The Superfund 30 Day Study Task Force
Original Target Correction Date; 1993
Current Target Date; 1993
Critical Milestones in Planned Corrective Action;
A. Completed Actions/Events;
M/S # MILESTONE TITLE ORIG PLAN ACTUAL
B. Planned Actions/Events (Short-Term - Next 12 Months);
M/S # MILESTONE TITLE ORIG PLAN ACTUAL
M 001 Establish Workgroup 11/30/91 11/30/91 / /
M 002 Screen RD Candidates 01/31/92 01/31/92 / /
M/S # MILESTONE TITLE ORIG PLAN ACTUAL
-------
U. S. ENVIRONMENTAL PROTECTION AGENCY ENCLOSURE D
MATERIAL WEAKNESS/CORRECTIVE ACTIONS PAGE 11 OF 97
FISCAL YEAR 1991
M 003 Develop 03/31/92 03/31/92 / /
Design/Construction
Options
M 004 Initiate Work at Sites 04/30/92 04/30/92 / /
C. Planned Actions/Events (Longer Term);
M/S # MILESTONE TITLE ORIG PLAN ACTUAL
Evaluate Effects of 09/01/93 09/01/93 / /
M 005 Pilots
M 006 Verification of 09/30/93 09/30/93 / /
Completion
Validation Process to be Used: To Be Determined
Corrective Action Plan Status Updates;
o September 30. 1991 Status Update; Report was just published
October 1, 1991.
-------
U. S. ENVIRONMENTAL PROTECTION AGENCY ENCLOSURE D
MATERIAL WEAKNESS/CORRECTIVE ACTIONS PAGE 12 OF 97
FISCAL YEAR 1991
CATS Tracking Number;
Assessable Unit/AU ti OERR/HSCD/1902
Title of Material Weakness; Accelerating Remedial Cleanups:
Elevate Issues Causing Delays
Description of Material Weakness -and Its Impact on Agency
Operations; Elevate issues causing site-specific delays. The Task
Force recommended more aggressive action to elevate and resolve
State/EPA issues that delay progress at individual sites.
Workplan #\ To be determined
Functional Category in Statistical Summary; Environmental Impact
Appropriation/Program Element; Superfund; 68/20X8145/TFAY9A
Administrative Activity/Program Activity; Program Activity
Year Identified; 1991
Source of Discovery; The.Superfund 30 Day Study Task Force
Original Target Correction Date;
Current Target Date;
Critical Milestones in Planned Corrective Action;
A. Completed Actions/Events;
M/S # MILESTONE TITLE ORIG PLAN ACTUAL
B. Planned Actions/Events (Short-Term - Next 12 Months) ;
M/S # MILESTONE TITLE ORIG PLAN ACTUAL
M 001 Brief AA for State 11/30/91 11/30/91 / /
Forum
M 002 Prepare Communication 12/31/91 12/31/91 / /
Strategy
-------
U. S. ENVIRONMENTAL PROTECTION AGENCY ENCLOSURE D
MATERIAL WEAKNESS/CORRECTIVE ACTIONS PAGE 13 OF 97
FISCAL YEAR 1991
C. Planned Actions/Events (Longer Term);
M/S # MILESTONE TITLE ORIG PLAN ACTUAL
M 003 Monitor Site Progress 12/31/91 12/31/91 / /
M 004 Include Issues in / / / / / /
Quarterly DAA Reports
M 005 Verification of 09/30/93 09/30/93 / /
Completion
Validation Process to be Used: To be determined.
Corrective Action Plan Status Updates:
o September 30. 1991 Status Update; Report was just published
October 1, 1991.
-------
U. S. ENVIRONMENTAL PROTECTION AGENCY ENCLOSURE D
MATERIAL WEAKNESS/CORRECTIVE ACTIONS PAGE 14 OF 97
FISCAL YEAR 1991
CATS Tracking Number;
Assessable Unit/AU *; OERR/OPM/1911
Title of Material Weakness: Accelerating Remedial Cleanups:
Expand Superfund's Measures of Success
Description of Material Weakness and Its Impact on Agency
Operations;. Expand Superfund's measures of success. This workplan
involves developing a strategy to increase public awareness of
Superfund accomplishments. This will be done by broadening the
scope of public information and outreach to encompass all aspects
of the program. OERR and OWPE will work together to develop a
communication plan to focus on Superfund program accomplishments.
Both offices will work with OSWER communication staff, OCPA, and
Regional offices to integrate the strategy.
Workplan #; To be determined
Functional Category in Statistical Summary; Environmental Impact
Appropriation/Program Element; Superfund; 68/20X8145/TFAY9A
Administrative Activity/Program Activity; Program Activity
Year Identified; 1991
Source of Discovery; The Superfund 30 Day Study Task Force
Original Target Correction Date; 1993
Current Target Date; 1993
Critical Milestones in Planned Corrective Action;
A. Completed Actions/Events;
M/.S # MILESTONE TITLE ORIG PLAN ACTUAL
i
B. Planned Actions/Events (Short-Term - Next 12 Months):
M/S # MILESTONE TITLE ORIG PLAN ACTUAL
M 001 Release Environmental 10/30/91 10/30/91 / /
Indicators Report
M 002 Establish Cross-Org. 11/31/91 11/31/91 / /
Team
-------
U. S. ENVIRONMENTAL PROTECTION AGENCY ENCLOSURE D
MATERIAL WEAKNESS/CORRECTIVE ACTIONS PAGE 15 OF 97
FISCAL YEAR 1991
M 003 Develop Draft Strategy 03/30/92 03/31/92 / /
M 004 Conduct FOCUS Groups 05/31/92 05/31/92
M 005 Begin Implementation 06/30/92 06/30/92 / /
of Strategy
M 006 Verification of / / / / / /
Completion
Validation Process to be Used: To be determined
Corrective Action Plan Status Updates:
o September 30. 1991 Status Update: Report was just published
October 1, 1991.
-------
U. S. ENVIRONMENTAL PROTECTION AGENCY ENCLOSURE D
MATERIAL WEAKNESS/CORRECTIVE ACTIONS PAGE 16 OF 97
FISCAL YEAR 1991
CATS Tracking Number:
Title of Material Weakness; Elevate site-specific issues (EPA/DOJ
issues):
Description of Uncorrected Material Weaknesses; The Superfund 30-
day Study Task Force issued its report, which recommended various
ways to accelerate hazardous waste site cleanup, on July 19, 1991.
An implementation plan, which outlined specific options and
milestones, was released on October 1, 1991. The specific
recommendations and milestones that apply directly to OWPE are as
follows:
Description of Material Weakness and Its Impact on Agency
Operations; The Task Force recommended more aggressive action to
elevate and resolve DOJ/EPA issues that delay progress at
individual sites.
Functional Category in Statistical Summary; Program Management
Appropriation/Program Element: Superfund Trust Fund
Administrative Activity/Program Activity: Environmental impact
Year Identified; 1991
Source of Discovery; 30-day Study
Original Target Correction Date; 9-30-92
Current Target Date; 9-30-92
Critical Milestones in Corrective Action;
Schedule meetings between senior managers at DOJ and EPA Oct. 91
Schedule a meeting between DOJ, States and EPA Oct. 91
to discuss issue-resolution
A. Completed Actions/Events:
Schedule a meeting between mid-level managers at DOJ Sep. 91
and EPA to discuss the issue-resolution initiative
B. Planned Actions/Events fFY 19921;
Use regular conference calls and Branch Chiefs' Ongoing
meetings to identify case-specific EPA-DOJ issues;
and have OWPE's settlement expediter review issues
-------
U. S. ENVIRONMENTAL PROTECTION AGENCY ENCLOSURE D
MATERIAL WEAKNESS/CORRECTIVE ACTIONS PAGE 17 OF 97
FISCAL YEAR 1991
Elevate issues, as appropriate, to the monthly EPA-DOJ Ongoing
meeting for resolution
Include DOJ/EPA issues in quarterly progress reports to Ongoing
DAA, OSWER
Validation Process to be Used; Once issues are elevated and
resolved, fewer moratorium extension requests should be made to
Headquarters. The number of settlements that had been languishing
would be increased, and this data would be revealed in CERCLIS. At
intervals of 6, 9 and 12 months, the Regions-would be surveyed to
ask which long-term disputes had not been elevated, and whether the
DOJ/EPA meetings are achieving their purpose.
Corrective Action Plan Status Updates:
o September 30. 1991. Status Update; On Target
-------
U. S. ENVIRONMENTAL PROTECTION AGENCY ENCLOSURE D
MATERIAL WEAKNESS/CORRECTIVE ACTIONS PAGE 18 OF 97
FISCAL YEAR 1991
CATS Tracking Number;
Title of Material Weakness: Accelerate Private Party Cleanups
Description of Material Weakness and Its Impact on Aaencv
Operations; In order to limit "midstream" private party takeovers,
responsible parties will not be able to assume the lead for a
project while particular phases of work are underway.
Functional Category in Statistical Summary; Program Management
Appropriation/Program Element; Superfund Trust Fund
Administrative Activity/Program Activity; Environmental Impact
Year Identified; 1991
Source of Discovery; 30-day Study
Original Target Correction Date; 9-30-92
Current Target Date; 9-30-92
Critical Milestones in Corrective Action;
Publicly announce the initiative Oct. 91
Draft a memorandum limiting PRP takeovers Oct. 91
Circulate the draft memorandum to the Regions, OE, Oct. 91
OGC and DOJ for comment
Distribute a final policy Nov. 91
A. Completed Actions/Events; none
B. Planned Actions/Events fFY 1992); See critical milestones in
corrective action list above.
Validation Process to be Used; At quarterly intervals after the
guidance had been distributed to the Regions, CERCLIS data should
reveal a change in "lead" for a particular phase of the cleanup
process. Analysis of the* data should show the number of private
party takeovers to be decreasing over time. Regions will be
contacted monthly to identify sites having private party takeover
as issues, and whether it was resolved according to the guidance.
Corrective Action Plan Status Updates;
o September 30. 1991. Status Update; On Target
-------
U. S. ENVIRONMENTAL PROTECTION AGENCY ENCLOSURE D
MATERIAL WEAKNESS/CORRECTIVE ACTIONS PAGE 19 OF 97
FISCAL YEAR 1991
CATS Tracking Number;
Title of Material Weakness: Begin Remedial Design Before Entry of
Consent Decree
Description of Material Weakness and Its Impact on Agency
Operations; One identified source of cleanup delay is the lapse of
time between the time parties enter into a cleanup agreement and
the date the consent is entered. Under this option, the remedial
design would begin prior to entry of the consent decree.
Functional Category in Statistical Summary; Program Management
Appropriation/Program Element; Superfund Trust Fund
Administrative Activity/Program Activity; Program Management
Year Identified; 1991
Source of Discovery; 30-day Study
Original Target Correction Date; 9-30-92
Current Target Date; 9-30-92
Critical Milestones in Corrective Action;
Publicly announce the initiative Oct. 91
Draft a memorandum establishing accelerated remedial Oct. 91
design as a national "bottom line" position
Circulate the draft memorandum to the Regions, OE, Oct. 91
OGC and DOJ for comment
Distribute a final policy Nov. 91
A. Completed Actions/Events; none
B. Planned Actions/Events (FY 19921;
See critical milestones in corrective action list above
Validation Process to be Used; In the past, the remedial
construction work had to wait to begin until the consent decree
between responsible parties and EPA was entered into the court by
DOJ. . . The entry of the decree was further held up by a 30-day
public comment period. If the lag time between receipt of the
consent decree and its filing by DOJ could be eliminated, as well
as the time consumed by the public comment period, construction
-------
U. S. ENVIRONMENTAL PROTECTION AGENCY ENCLOSURE D
MATERIAL WEAKNESS/CORRECTIVE ACTIONS PAGE 20 OF 97
FISCAL YEAR 1991
could be started much sooner. Within a short time of distributing
the final policy on accelerating cleanups, and by not waiting for
these two events, CERCLIS data would show remedial construction
start dates with no entry date for the consent decree, or the
CERCLIS data would show construction start dates preceding consent
decree entry dates. The policy will encourage the Regions to start
the Remedial Design at the time of referral or even earlier.
Within a year, comparisons could be made to previous years.
Corrective Action Plan Status Updates:
o September 30. 1991. Status Update; On Target
-------
U. S. ENVIRONMENTAL PROTECTION AGENCY ENCLOSURE D
MATERIAL WEAKNESS/CORRECTIVE ACTIONS PAGE 21 OF 97
FISCAL YEAR 1991
Title of Material Weakness; Federal Facilities Enforcement
Description of Material Weakness and Its. Impact on Agency
Operations; Government-wide, environmental management (including
cleanup and compliance) programs are being reported as a material
weakness in the FMFIA process. The Department of Energy and the
Department of Defense are the two largest Federal agencies
identifying environmental management programs as a material
weakness. As these agencies take corrective actions that will span
several decades, corrective actions will include compliance with
environmental statutes and regulations that EPA has responsibility
for enforcing. EPA is part of the corrective action process.
However, Federal Facilities for EPA is also a material weakness in
another, different sense than the other Federal agencies.
EPA's Federal Facilities Enforcement program has not had a
sufficient resource base to perform an adequate level of oversight
of other Agencies' environmental compliance and restoration plans
and activities. This is a government-wide challenge that needs
improved interagency attention. EPA is responsible for overseeing
the cleanup of contaminated sites at numerous Federal Facilities,
as well as inspecting facilities for compliance with all
environmental laws and initiating appropriate enforcement for
facilities out of compliance.
There are almost 9,000 environmental projects within the
Federal government totalling about $6.6 billion for FY 1992. The
Federal Facilities resource request for FY 1992 totalled about 272
workyears and $34 million. These resources are a very small
fraction of the total Federal Facilities work involved. In budget
outyears, the resource requirements for Federal Facilities
environmental cleanup and restoration by other Federal agencies
could increase over 100 percent. EPA does not currently have
anywhere near the level of resources that will allow the Agency to
maintain an adequate degree and level of oversight over the other
Federal agencies' environmental activities.
A specific case in point is occurring in FY 1992. When the
Agency and OFFE prepared its FY 1992 budget request, the Federal
DOD Base Closure program was nonexistent. Now as EPA begins FY 92,
initial workload estimates indicate that over 88.9 new,
-------
U. S. ENVIRONMENTAL PROTECTION AGENCY ENCLOSURE D
MATERIAL WEAKNESS/CORRECTIVE ACTIONS PAGE 22 OF 97
FISCAL YEAR 1991
unanticipated workyears will be required for this program during FY
1992. The sheer magnitude, impact, and political realities of the
Base Closure program could easily consume the entire Federal
Facilities resource base during this period.
Another major resource problem is associated with the
Conservation Law Foundation (CLF) decision. The Court ordered EPA
to conduct Preliminary Assessments (PA) by July 1992, and if
necessary, list some 1,200 Federal Facilities which are candidates
for the National Priority List. At present, EPA has no resources
for fulfilling these oversight responsibilities, and the progress
of Federal Facility site clean up will be impeded.
Functional Category in Statistical Summary: Regulatory
Oversight/Program Execution
Appropriation/Program Element; TYPY3A, AYNH3A
Administrative Activity/Program Activity;
Year Identified; 1991
Source of Discovery; Determination by EPA Senior management
Original Target Correction Date; 1993
Current Target Date; 1993
Critical Milestones in Corrective Action:
A. Completed Actions/Events;
B. Planned Actions/Events fFY 19921;
1. FTE Administrative Ceiling relief requested from OMB
in December 1991.
2. Develop strategy for program efficiencies.
3. Develop strategy for streamlining cleanup process.
-------
U. S. ENVIRONMENTAL PROTECTION AGENCY ENCLOSURE D
MATERIAL WEAKNESS/CORRECTIVE ACTIONS PAGE 23 OF 97
FISCAL YEAR 1991
C. Planned Actions/Events (FY 1993 and beyondl:
1. Attempt to reach adequate resource level, both FTE
and extramural dollars, for Federal Facilities program.
Validation Process to be Used; To Be Determined
-------
U. S. ENVIRONMENTAL PROTECTION AGENCY ENCLOSURE D
MATERIAL WEAKNESS/CORRECTIVE ACTIONS PAGE 24 OF 97
FISCAL YEAR 1991
CATS Tracking Number;
Assessable Unit/AU #: OERR/HSED/1901
Title of Material Weakness; Contract Lab Program
Description of Material Weakness and its Impact on Aaencv
Operations; The CLP. was identified as a material weakness
candidate by the OIG, and OERR concurs with the recommendation. A
corrective action plan will be submitted for the first quarter CATS
report.
Work Plan #'. In Progress
Functional Category in Statistical Summary; Program Management
Appropriation/Program Element; Superfund; 68/20X8145/TFAY9A
Administrative Activity/Program Activity; Program Activity
Year Identified; 1991
Source of Discovery; OIG Audit: FMFIA Audit of the CLP (Willis
Greenstreet Report)
Original Target Correction Date; In Progress
Current Target Date; In Progress
Critical Milestones in Planned Corrective Action;
A. Completed Actions/Events: None
-------
U. S. ENVIRONMENTAL PROTECTION AGENCY
MATERIAL WEAKNESS/CORRECTIVE ACTIONS
FISCAL YEAR 1991
ENCLOSURE D
PAGE 25 OF 97
B.
Planned Actions/Events (Short-Term - Next 12 Months);
M/S # MILESTONE TITLE
ORIG
PLAN
11/10/91
11/15/91
11/31/91
ACTUAL
M 001 Recommendations to AOB 11/10/91
from Audit Report
M 002 Strategy Meeting to 11/15/91
Address Needed Actions
M 003 Assignment of 11/31/91
Responsibilities and
Definition of
Completion Dates
Validation Process to be Used; To be determined
Corrective Action Plan Status Updates;
o September 30. 1991 Status Update; Report was still
confidential as of 09/30/91 and will not be released until mid-
October. At that time, a more definite workplan will be prepared
and outlined in Ql CATS update.
-------
U. S. ENVIRONMENTAL PROTECTION AGENCY ENCLOSURE D
MATERIAL WEAKNESS/CORRECTIVE ACTIONS PAGE 26 OF 97
FISCAL YEAR 1991
CATS Tracking Number; 90-lxl
Assessable Unit/AU #: OERR/HSED/1901
Title of Material Weakness; Superfund Program: NPL Listing
Consistency
Description of Material Weakness and Its Impact on Agency
Operations; Senator Lautenberg said- that Regions are not
consistent in scoring sites for listing on the National Priorities
List. EPA agreed to develop guidance and tools for site scoring
and quality assurance using the revised Hazard Ranking System to
ensure that Regions uniformly interpret and score sites for the NPL
under the revised HRS.
Workolan #; 642
Functional Category in Statistical Summary; Program Management
Appropriation/Program Element; Superfund; 68/20X8145/TFAY9A
Administrative Activity/Program Activity; Program Activity
Year Identified; 1989
Source of Discovery; Congressional Hearings on The "Management
Review of the Superfund Program".
Original Target Correction Date; 9/30/90
Targeted Correction Date in Last Year's Report; 9/30/90
Current Target Date; 12/31/91
Reason for Change in Datefs); The tools (including a computer
program with default values) that are programmed to provide the
calculations required by the model cannot be completed until the
rule is approved by OMB. The rule went to OMB for review 5/9/90,
and it has not yet been approved.
Critical Milestones in Planned Corrective Action;
A. Completed Actions/Events; The program .strategy has been
completed, and the computer program has been written and
tested using the version of the rule which was sent to
OMB.
-------
U. S. ENVIRONMENTAL PROTECTION AGENCY ENCLOSURE D
MATERIAL WEAKNESS/CORRECTIVE ACTIONS PAGE 27 OF 97
FISCAL YEAR 1991
M/S # MILESTONE TITLE ORIG PLAN ACTUAL
M 005 Draft PA Guidance 07/31/90 12/31/90 11/28/90
M 006 State Coop. Agr. 09/30/90 02/28/91 04/10/91
Wrkpln/Draft Strat
M 004 Dist. Final Rhrs 05/30/90 10/30/90 01/15/91
Implementation Plan
B. Planned Actions/Events (Short-Term - Next 12 Months):
* Indicates milestones added since last year's letter.
M/S # MILESTONE TITLE ORIG PLAN ACTUAL
M 003* Finalize Computer 04/30/90 10/01/91 / /
Program
M 009* Draft SI Guidance 07/31/90 11/30/91 / /
M 010* Mrs Guidance Manual 12/01/91 12/31/91 / /
M Oil* Verification of 12/31/91 12/31/91 / /
Completion
C. Planned Actions/Events (Longer Term): HRS packages will be
reviewed on a continuous basis to determine whether the tools and
guidance have been effective, and what additional measures are
needed to improve both quality and consistency of NPL packages.
Validation Process to be Used; Continuing review of all data
packages, determining problems, scoring the categories of problems,
comparison with the baseline review. (This is a Division-level TQM
project.)
-------
U. S. ENVIRONMENTAL PROTECTION AGENCY ENCLOSURE D
MATERIAL WEAKNESS/CORRECTIVE ACTIONS PAGE 28 OF 97
FISCAL YEAR 1991
Corrective Action Plan Status Updates:
o September 30. 1991. Status Update; Preliminary Assessment
guidanceand" PreliminaryAssessmentScore were issued as OSWER
directives. A computer assisted directory was developed for the SA
Sources of Information. SI guidance was developed, and a national
workgroup was established to continue to improve the site
evaluation process. Testing for PREScore Algorithm was completed,
and training schedules were developed. HRS Guidance Workgroup was
established and the final draft of Preliminary Resolutions for
Update 11 was completed. Over 5 HRS/Si.te Assessment Orientations,
5 HRS Package Preparation Sessions, and a survey of Regional and
State Training needs were completed. Development of the Site
Assessment Video and PA/SI Training Sessions have begun.
-------
U. S. ENVIRONMENTAL PROTECTION AGENCY ENCLOSURE D
MATERIAL WEAKNESS/CORRECTIVE ACTIONS PAGE 29 OF 97
FISCAL YEAR 1991
CATS Tracking Number; 90-lal6
Assessable Unit/AU #: OERR/HSCD/1902
Title of Material Weakness; Superfund Program: Technical
Assistance Grant (TAG) Application Process & Procurement
Requirements
Description of Material Weakness and Its Impact on Agency
Operations; EPA should simplify the application process and
simplify .the procurement requirements. EPA should address
revamping the TAG application process to give more weight to the
NRDC recommendation of considering health effects from site
contamination that may have been suffered by TAG applicants.
Workplan #: 00592
Functional Category in Statistical Summary; Program Management
Appropriation/Program Element; Superfund/68/20X8145/TFAY9A
Administrative Activity/Program Activity; Program Activity
Year Identified; 1989
Source of Discovery; The "Management Review of the Superfund
Program"
Original Target Correction Date; 09/30/90
Targeted Correction Date in Last Year's Report; 09/30/90
Current Target Date; 10/30/91
Reason for Change in Datefs); More program experience needed to
test impact of final rule
Critical Milestones in Planned Corrective Action;
A. Completed Actions/Events;
M/S # MILESTONE TITLE ORIG PLAN ACTUAL
M 002 Issue Simplified 03/31/90 03/31/90 03/31/90
Materials
M 003 Dev Procurement 04/30/90 04/30/90 04/30/90
Procedures
-------
U. S. ENVIRONMENTAL PROTECTION AGENCY ENCLOSURE D
MATERIAL WEAKNESS/CORRECTIVE ACTIONS PAGE 30 OF 97
FISCAL YEAR 1991
B. Planned Actions/Events (Short-Term - Next 12 Months);
* Indicates milestones added since last year's letter.
M/S # MILESTONE TITLE ORIG PLAN ACTUAL
M 004 Amend Tag Rule W/R/T 09/30/90 10/10/91 / /
Procurement
M 005* Verification of 09/30/91 10/30/91 / /
Completion
Validation Process to be Used: TAG application processes and
prpcurement requirements are simplified in final TAG rule and
applicants successfully follow procedures.
Corrective Action Plan Status Updates;
o September 30. 1991 Status Update; Rule is currently in Red
Border Review (09/12/91). After Red Border, the rule will go to
OMB and then be published in the Federal Register.
-------
U. S. ENVIRONMENTAL PROTECTION AGENCY ENCLOSURE D
MATERIAL WEAKNESS/CORRECTIVE ACTIONS PAGE 31 OF 97
FISCAL YEAR 1991
CATS Tracking Number; 90-1x4
Assessable Unit/AU #: OERR/HSCD/1902
Title of Material Weakness; Superfund Program: Use of Expedited
Cleanup Approaches
Description of Material Weakness and Its Impact on Agency
Operations; Identify methods to streamline the remedial design and
remedial action process. Implement procedures and contract
mechanism through ARCS and USACE to optimize and expedite the RD/RA
process.
Workplan #\ 00706
Functional Category in Statistical Summary; Program Management
Appropriation/Program Element; Superfund/68/20X8145/TFAY9A
Administrative Activity/Program Activity; Program Activity
Year Identified; 1989
Source of Discovery; "The Management Review of the Superfund
Program"
Original Target Correction Date; 5/30/90
Targeted Correction Date in Last Year's Report; 5/30/90
Current Target Date; 10/31/91
Reason for Change in Datefs): Additional milestones added to
evaluate effectiveness of guidance
Critical Milestones in Planned Corrective Action;
A. Completed Actions/Events;
M/S # MILESTONE TITLE ORIG PLAN. ACTUAL
M 004 Finalize and Issue 05/30/90 05/30/90 06/04/90
Guidance
B. Planned Actions/Events (Short-Term - Next 12 Months);
* Indicates milestones added since last year's letter.
M/S # MILESTONE TITLE ORIG PLAN ACTUAL
-------
U. S. ENVIRONMENTAL PROTECTION AGENCY
MATERIAL WEAKNESS/CORRECTIVE ACTIONS
FISCAL YEAR 1991
ENCLOSURE 0
PAGE 32 OF 97
M 009 Evaluate Expedited
Approach
M/S # Milestone Title
M 010* Verification of
Completion
06/28/91 10/31/91 / /
ORIG PLAN . ACTUAL
10/31/91 10/31/91 / /
Validation Process to be Used;
streamline the RO/RA process.
Regions implement guidance to
Corrective Action Plan Status Updates:
o September 30. 1991 Status Update; DCMB is gathering a list of
expedited clean-up approach sites and will write a status report
during the month of October.
-------
U. S. ENVIRONMENTAL PROTECTION AGENCY ENCLOSURE D
MATERIAL WEAKNESS/CORRECTIVE ACTIONS PAGE 33 OF 97
FISCAL YEAR 1991
CATS Tracking Number: 90—1
Title of Material Weakness; Superfund Program: Cost Documentation
Work Plan #: 90010
Description of Material Weakness and its Impact on Agency Operations:
Develop a rulemaking on cost documentation.
Functional Category in Statistical Summary: Program Management
Appropriation/Program Element: Superfund Trust Fund
Administrative Activity/Program Activity: Program Management
Year Identified; 1989
Source of Discovery; Administrator's request for a major review
of the Superfund Program.
Original Target Correction Date; 07/31/91
Targeted Correction Date in Last Year's Report: 07/31/91
Current Target Date; Unknown
Reason for Change in Datefs): Rule withdrawn from OMB by OSWER/AA's office.
Critical Milestones in Corrective Action:
A. Completed Actions/Events:
M/S # MILESTONE TITLE ORIG PLAN ACTUAL
M 004 Red Border Review 04/30/90 04/30/90 07/30/90
B. Planned Actions/Events (Short-Term-Next 12 Months);
M/S # MILESTONE TITLE • ORIG PLAN ACTUAL
M 007 **Final Rule 07/31/91 07/31/91 / /
Validation Process to be Used; Timeliness and success rate in
cost recovery cases.
Corrective Action Plan Status Updates;
o September 30. 1990 Status Update: Milestones for developing a
rulemaking on cost documentation is on schedule.
-------
U. S. ENVIRONMENTAL PROTECTION AGENCY ENCLOSURE D
MATERIAL WEAKNESS/CORRECTIVE ACTIONS PAGE 34 OF 97
FISCAL YEAR 1991
o December 31. 1990 Status Update: Pending OMB review. Anticipate OMB
review completed by 4/1/91. Rule proposal 5/1/91 with final rule out 6/1/91.
o March 31. 1991 Status Update: Still pending OMB review.
o June 30. 1991 Status Update: Still pending OMB review.
o September. 30. 1991 Status Update: Rule withdrawn from OMB by
OSWER AA's office.
-------
U. S. ENVIRONMENTAL PROTECTION AGENCY ENCLOSURE D
MATERIAL WEAKNESS/CORRECTIVE ACTIONS PAGE 35 OF 97
FISCAL YEAR 1991
CATS Tracking Number: 90-1
Title of Material Weakness: Superfund Program: Cost Recovery Goals
Work Plan if: 90011
Description of Material Weakness and its Impact on Agency Operations;
Development of analysis of cost recovery universe, method for projection of
revenues, and internal and external briefing materials.
Functional Category in Statistical Summary; Program Management
Appropriation/Program Element: Superfund Trust Fund
Administrative Activity/Program Activity; Program Management
Year Identified; 1989
Source of Discovery; Administrator's request for a major review
of the Superfund Program.
Original Target Correction Date; 06/30/90
Targeted Correction Date in Last Year's Report; 06/30/90
Current Target Date: 12/31/91
i
Reason for Change in Datefsi; Extensive comments on draft documents. Pending
senior management review and approval.
Critical Milestones in Corrective Action:
A. Completed Actions/Events: Draft study in internal executive review.
B. Planned Actions/Events (Short-Term -Next 12 Months); Release study.
Validation Process to be Used; For internal use only.
Corrective Action Plan Status Updates;
o September 30. 1990 Status Update; Original target correction
date slipped from 06/30/90 to 12/01/90 due to extensive comment on
draft documents.
o December 31. 1990 Status Update; Release date slipped again
from 12/1/90 to 4/1/91 based on extensive executive review
comments.
-------
U. S. ENVIRONMENTAL PROTECTION AGENCY ENCLOSURE D
MATERIAL WEAKNESS/CORRECTIVE ACTIONS PAGE 36 OF 97
FISCAL YEAR 1991
o March 31. 1991 Status Update; Cost Recovery Goals Report
pending senior management review and approval. Presently awaiting
Division Director's approval before forwarding to OWPE Office
Director, OSWER AA and to the Administrator for signature.
o June 30. 1991 Status Update; Still pending review and
approval by Division Director.
o September 30. 1991 Status Update; Still pending review and
approval by Division Director.
-------
U. S. ENVIRONMENTAL PROTECTION AGENCY ENCLOSURE D
MATERIAL WEAKNESS/CORRECTIVE ACTIONS PAGE 37 OF 97
FISCAL YEAR 1991
CATS Tracking Number; 90-1
Title of Material Weakness: Superfund Program: Case/Site
management planning
Work Plan t: 90013
Description of- Material Weakness and its Impact on Agency
Operations: Develop site management process and tools for RP
search, RI/FS, RD/RA, litigation.
Functional Category in Statistical Summary; Program Management
Appropriation/Program Element: Superfund Trust Fund
Administrative Activity/Program Activity; Program Management
Year Identified: 1989
Source of Discovery: Administrator's request for a major review
of the Superfund Program.
Original Target Correction Date; 06/30/90
Targeted Correction Date in Last Year's Report; 06/30/90
Current Target Date; 12/31/91
Reason for Change in Date(si: Site Management Plan finalized
7/27/91. However, in response to GAO criticism regarding the lack
of documentation of enforcement strategies, the Plan has not been
distributed pending the OWPE Office Director's decision to make
minor revisions.
Critical Milestones in Corrective Action:
A. Completed .Actions/Events;
M/S # MILESTONE TITLE ORIG . PLAN ACTUAL
M 003 Regional Comments Resolved 03/30/90 03/30/90 05/30/90
B. Planned Actions/Events (Short-Term -Next 12 Months);
Draft Site Management Plan — 02/28/91
Final Site Management Plan — 06/30/91
Validation Process to be Used; Regional evaluation of Site
Management Plan. Usefulness — 6 months - 1 year after
implementation.
-------
U. S. ENVIRONMENTAL PROTECTION AGENCY ENCLOSURE D
MATERIAL WEAKNESS/CORRECTIVE ACTIONS PAGE 38 OF 97
FISCAL YEAR 1991
Corrective Action Plan Status Updates;
o September 30. 1990 Status Update; Original target correctipn
date slipped from 06/30/90 to 06/30/91 due to delays in final
formulation of Agency policy on pre-referral negotiation
procedures.
o December 31. 1990 Status Update; Draft Site Management Plan
date of 11/30/90 slipped to 02/28/91 due to substantial changes in
organization and content of document.
o March 31. 1991 Status Update; Draft Site Management Plan
completed. Pending internal review and comment prior to
transmitting to Regions in mid-May 1991 for their review and
comment.
o June 30. 1991 Status Update; Delay in receiving regional
comments. Additional time needed to incorporate regional comments
and to allow for OERR/ERD review and comment at their request.
o September 30. 1991 Status Update; Plan finalized 7/27/91.
However, in response to the GAO criticism regarding the lack of
documentation of enforcement strategies, the Plan is pending the
Office Director's decision to make minor revisions prior to
distribution.
-------
U. S. ENVIRONMENTAL PROTECTION AGENCY ENCLOSURE D
MATERIAL WEAKNESS/CORRECTIVE ACTIONS PAGE 39 OF 97
FISCAL YEAR 1991
CATS Tracking Number: 90-1R
Assessable Unit/AU #: OERR\ERD\1900
Title of Material Weakness; Superfund Program: Removal Assessments at NPL
Sites, Phase I
Description of Material Weakness and Its Impact on Agency Operations; The
Superfund Management Review identified the need to perform removal assessments
at each NPL site.
Workplan #\ 607
Functional Category in Statistical Summary; program Management
Appropriation/Program Element: Superfund; 68/20X8145/TFAY9A
ftffrninistrative Activitv/Prociram Activity; program Activity
Year Identified; FY 1989
Source of Discovery; The "Management Review of the Superfund Program"
Original Target Correction Date; 9/30/90
Targeted Correction Date in Tr^^t1 Yg>ai*/s Report: 9/90
Actual Completion Date; 10/19/90
Corrective Actions Taken; * Indicates milestones added since last year's letter.
M/S # MILESTONE TITLE ORIG PLAN ACTUAL
M 001 Send Memo to Regions 07/06/89 07/06/89 07/06/89
M 002 Regions Submit Assessment Schedule 07/31/89 07/31/89 07/31/89
M 003 Regions Complete Assessments 09/30/89 09/30/89 11/30/89
M 007 Compile NPL Response Action Plan 11/30/89 11/30/89 11/30/89
M 008 Regional Progress Report 03/30/90 03/30/90 03/10/90
M 009 Regional Progress Report 06/29/90 06/29/90 06/19/90
M Oil Start Removals at Unaddressed Sites 09/30/90 09/30/90 08/30/90
M 012 Regions Complete All NPL Assessment 09/30/90 09/30/90 09/27/90
-------
U. S. ENVIRONMENTAL PROTECTION AGENCY ENCLOSURE D
MATERIAL WEAKNESS/CORRECTIVE ACTIONS PAGE 40 OF 97
FISCAL YEAR 1991
M 014 Documentation Memo Fran Regions 09/30/90 09/30/90 10/19/90
M 015* Verification of Completion 09/30/90 09/30/90 10/19/90
Results of Validation Actions; Receipt of Regional documentation letters.
30. 1991 Stat11^ Urx^t11?? Workplan Conplete.
-------
U. S. ENVIRONMENTAL PROTECTION AGENCY ENCLOSURE D
MATERIAL WEAKNESS/CORRECTIVE ACTIONS PAGE 41 OF 97
FISCAL YEAR 1991
CATS Tracking Numb^*; 90—1R (continued)
Assessable Unit/AU #: OERR\ERD\1900
Title of Material Weakness: Superfund Program: Removal Actions at NPL Sites,
Phase II
Description of
Lons; ERD
conducted removal assessments at previously unaddressed sites and stabilized the
sites and/or eliminated dangers at the 23 sites where immediate threats were
identified. The "Management Review of the Superfund Program" identified the need
to render each site safe from immediate hazards to public health and the
environment.
Workolan #: 647
Functional Category in Statistical Summary: Program Management
Appropriation/Program Element; Superfund; 68/20X8145/TFAY9A
A
-------
U. S. ENVIRONMENTAL PROTECTION AGENCY ENCLOSURE D
MATERIAL WEAKNESS/CORRECTIVE ACTIONS PAGE 42 OF 97
FISCAL YEAR 1991
Results of Validation Actions: Response actions have been started at the 23
sites as recorded in CERCLIS.
September 30. 1991 Status Update; Workplan Complete.
-------
U. S. ENVIRONMENTAL PROTECTION AGENCY ENCLOSURE D
MATERIAL WEAKNESS /CORRECTIVE ACTIONS PAGE 43 OF 97
FISCAL YEAR 1991
CATS Tracking Number; 90— Ia7
Assessable Unit/AU #: OERR\KSCD\1902
•
Title of Material Weakness: Super-fund Program: Increase citizen involvement
n of Ma**^*"ial Weakness and Its Impact on Agency Operations; The
Administrator should strongly support increased citizen involvement in Superfund
decisions, by dedicating resources necessary for greater citizen involvement and
accepting occasional delays as a result. Also supports 47. F
Workplan #'. 00582
Functional Category in Statistical Summary:- Program Management
Appropriation/Program Element; Superfund/68/20X8145/TFAY9A
Administrative Activity/Program Activity; Program Activity
Year Identified; 1989
Source of Discovery; The "Management Review of the Superfund Program"
Original Target Correction Date: 12/31/89
Targtetgd Correction Date in fagt Y
-------
U. S. ENVIRONMENTAL PROTECTION AGENCY ENCLOSURE D
MATERIAL WEAKNESS/CORRECTIVE ACTIONS PAGE 44 OF 97
FISCAL YEAR 1991
Results of Validation Actions: Regions document increased citizen involvement
using milestone as a method to measure progress.
September 30. 1991 Status Update: Workplan complete.
-------
U. S. ENVIRONMENTAL PROTECTION AGENCY ENCLOSURE D
MATERIAL WEAKNESS /CORRECTIVE ACTIONS PAGE 45 OF 97
FISCAL YEAR 1991
CATS Tracking Numbly; 90—1x2
Assessable Unit/AU #: OERR\HSCD\1902
Title of Material Weakness; Superfund Program: T.jgfr-ian to Citizens/Change
Actions Where Merited
Description of Material Weakness and Its Impact on Agency Oirations; EPA
managers and staff should listen carefully to what citizens are saying, take the
time necessary to deal with their concerns, change planned actions where citizen
suggestions have merit, and then explain to citizens what EPA has done and why.
WorkDlan i: 00583
Functional Category in Statistical Sumntf*Ty; program Management
Appropriation/Program Element; Superfund/68/20X8145/TFAY9a
Administrative Activity/Program Activity; Program Activity
Year Identified; 1989
Source of Discovery; The "Management Review of the Superfund Program"
Original Target Correction Date; 12/31/90
T^Tn^fcgd Correction Date in fast Y**^**ys Report; 12/31/90
Actual Completion Date; 01/22/91
Corrective Actions Taken;
M/S # MILESTONE TITLE ORIG PLAN ACTUAL
M 003 Report on Training Needs 04/30/90 04/30/90 04/30/90
M 004 Draft "SS" on Techniques 07/31/90 07/31/90 08/14/90
M 005 Wrkpln to meet Trng. Needs 08/31/90 08/31/90 08/30/90
M 006 **FinaI Short Sheet 12/31/90 12/31/90 01/22/91
M 007 Verification of Completion 01/22/91 01/22/91 01/22/91
of Validation Actions; EPA managers and staff "^** techniques in
milestone short 'sheet to improve communications with citizens.
30. 1991 Stat?ig updM"*** Workplan complete.
-------
U. S. ENVIRONMENTAL PROTECTION AGENCY ENCLOSURE D
MATERIAL WEAKNESS/CORRECTIVE ACTIONS PAGE 46 OF 97
FISCAL YEAR 1991
CATS Tracking Number: 90^1311
Assessable Unit/AU #: OERR\HSCD\1902
Title of Material Weakness; Superfund Program: Discuss Site Early/Make Docu.
More Readily Avail.
Description of Material Weakness and Its Impact on Agency Operations; EPA should
discuss site findings and decisions as they are developed, not only at the end
of the feasibility study. While a formal comment period is required only at the
proposed plan stage, EPA should make documents available to citizens and to PRPs
throughout the cleanup process, and be open to continually receiving comments.
EPA should be more aggressive about supplying information to citizens and their
technical advisors. Citizens' access to information should be comparable to that
of PRPs. Neither citizens nor PRPs should have to wait until the end of the
remedial investigation and feasibility study to learn the results of the
studies. EPA should ensure access to information by (1) establishing information
repositories that are convenient to the affected public; (2) completing any
necessary review of documents quickly, so the documents can be released; (3)
placing documents in the administrative record and the information repositories
as soon as possible; and (4) notifying citizens of the availability of that
information through fact sheets and other mailings.
WorkDlan #: 586
Functional Category in Statistical Sunnp'*''^: Program Management
Appropriation/Program Element; Superfund/68/20X8145/TFAY9A
Administrative Activity/Program Activity: Program Activity
Year Identified; 1989
Source of Discovery; The "Management Review of the Superfund Program"
Original Target Correction Date; 10/31/90
Targeted Correction Date in La^t Year's Report: 10/31/90
Actual Completion Date; 11/02/90
-------
U. S. ENVIRONMENTAL PROTECTION AGENCY
MATERIAL WEAKNESS/CORRECTIVE ACTIONS
FISCAL YEAR 1991
ENCLOSURE D
PAGE 47 OF 97
Corrective Actions Taken:
M/S # MILESTONE TITLE
M 004 Conduct Survey
M 005 Report en Survey Results
M 009 Issue Draft SS w/Recanmendations
M 006 **Final SS and Recommendations
M 007 Verification
GRIG .PLAN ACTUAL
05/24/90 05/24/90 05/23/90
06/30/90 06/30/90 06/29/90
07/31/90 07/31/90 08/02/90
10/31/90 10/31/90 11/02/90
11/02/90 11/02/90 11/02/90
of Vali^tion Actions; Regions apply guidance on discussing site
findings early to provide citizens and PRPs access to information.
30. 1991
Workplan complete.
-------
U. S. ENVIRONMENTAL PROTECTION AGENCY ENCLOSURE D
MATERIAL WEAKNESS/CORRECTIVE ACTIONS PAGE 48 OF 97
FISCAL YEAR 1991
CATS Tracking Number: 90—Ial4
Assessable Unit/AU #: OERR\HSCD\1902
Title of Material Weakness; Superfund Program; Problems Staff Turnover Creates
for Community
Description of Material Weakness and Its Impact on Agency Operations; EPA should
be sensitive to the problems that staff turnover create for a community and
should preserve the continuity of staff assignments as much as possible. For
example, these problems should be considered as costs in deciding whether to
rganize. EPA managers should try to keep continuity and site history on the
team if one team member must be replaced. For example, if the site manager is
new, the community relations coordinator probably should not be switched. EPA
should'educate new staff about the site's history, the community's involvement
and concerns, and the importance of these concerns. EPA should communicate staff
changes to the community and demonstrate that their concerns are understood.
WorkPlan i: 590
Functional Category in Statistical Sumntf*'»^t prnep"am Management
Appropriation/Program Element: Superfund/68/20X8145/TFAY9A
Achr" nistrative Activity/Program Activity; Progr*111 Activity
VMIT- THarrt-i fieri! 1989
Source of Disooverv: The "Management Review of the Superfund Program"
Original T^T^get Correction Date; 12/31/90
Targeted Correction Date in Ta«st Year's Report; 12/31/90
Actual Completion Date; 12/19/90
Corrective Actions Taken;
M/S # MILESTONE TITLE GRIG PLAN ACTUAL
M 002 Draft "SS" 05/21/90 05/21/90 05/18/90
M 003 Receive Comments on SS 07/02/90 07/02/90 06/25/90
M 004 **Final "SS11 12/31/90 12/31/90 12/19/90
M 005 Verification of Completion 12/19/90 12/19/90 12/19/90
-------
U. S. ENVIRONMENTAL PROTECTION AGENCY ENCLOSURE D
MATERIAL WEAKNESS/CORRECTIVE ACTIONS PAGE 49 OF 97
FISCAL YEAR 1991
of Validation Actions; Regions follow suggestions' in nemo to minimize
staff turnover and to increase continuity of personnel on teams.
30. 1991 Stat1'^ Update; Workplan complete.
-------
U. S. ENVIRONMENTAL PROTECTION AGENCY ENCLOSURE D
MATERIAL WEAKNESS/CORRECTIVE ACTIONS PAGE 50 OF 97
FISCAL YEAR 1991
CATS Tracking Number: 90-1x3
Assessable Unit/AU #: OERR\HSCD\1902
Title of Material Weakness; Superfund Program: Commitment to Communication
of Mat^yjal Weakrv^^g and I*1*? Impact on Agency Or^rations; Obtain
introduction by Administrator to replace community relations video introduction
by Lee Thomas.
WorkDlan I; 00626
Functional Category in Statistical Summary: Program Management
Appropriation/Program Element; Superfund/68/20X8145/TFAY9A
Administrative Activity /Program Activity: Program Activity
Year Identified; 1989
Source of Discovery; The "Management Review of the Superfund Program"
Original Target Correction Date: 12/31/89
TaTcrefcg|-aTr/s Report: 12/31/89
Actual Completion Date: ' 10/22/90
Reason for Change in Datefs) ; The Administrator has agreed, his time permitting,
to make introductory remarks for a CR training video. HSCD staff is working
closely with the Administrator's staff to develop a schedule. The video is part
of the CR training skills course and provides a useful introduction to CR and SF.
Corrective Actions Taken;
M/S # MILESTONE TITLE ORIG PLAN ACTUAL
M 002 **Complete Training Video W/Admin 12/31/89 09/30/90 10/22/90
M 003 Verification of Completion 10/22/90 10/22/90 10/22/90
of Validation Actions; "Community Relations Video" available to public
30. 1991 Status Update; "Workplan Complete
-------
U. S. ENVIRONMENTAL PROTECTION AGENCY ENCLOSURE D
MATERIAL WEAKNESS/CORRECTIVE ACTIONS PAGE 51 OF 97
FISCAL YEAR 1991
CATS Tracking Numl"|gT'; 90—Ia5
Assessable Unit/AU #: OERR\HSCD\1902
Title of Material Weakness; Superfund Program: Regulatory/policy barriers on
the use of treatment technologies
of RCRA land ban or other rules on use of alternative technologies should be
carefully evaluated to identify technologies that may be precluded by the rules.
OSWER should explore ways to apply these rules that preserve their intent and
spirit without restricting use of viable treatment approaches for Superfund
sites.
Wortolan ti 564
Functional Category in Statistical Summary: Program Management
Appropriation/Program Element; 68/20X8145/TFAY9A
Administrative Activity/Program Activity: Prrrp-am Activity
Year Identified; 1989
Source of Discovery; The "Management Review of the Superfund Program"
Original Target Correction Datg; 09/30/91
Targeted Correction Date in Last Year's Report; 09/30/91
Actual Completion Date; 09/30/91
Reason for Change in Datefs); All activities transferred to workplan 01027.
Corrective Actions Taken;
M/S # MILESTONE TTTLE ORIG PLAN ACTUAL
M 003 Support OSW Soil and Debris Reg 09/30/91 09/30/91 09/30/91
M 004 Verification of Completion 09/30/91 09/30/91 09/30/91
-------
U. S. ENVIRONMENTAL PROTECTION AGENCY ENCLOSURE D
MATERIAL WEAKNESS/CORRECTIVE ACTIONS PAGE 52 OF 97
FISCAL YEAR 1991
Pgsults of Validation Actions; Regions "««» treatability variance to develop
treatment standards for contaminated soil and debris until treatment standards
are promulgated. Evaluation of short-sheets will be done on a case-by-case basis
within the Regions.
September 30. 1991 s*~^*""g Update: Vforkplan Complete
-------
U. S. ENVIRONMENTAL PROTECTION AGENCY ENCLOSURE D
MATERIAL WEAKNESS/CORRECTIVE ACTIONS PAGE 53 OF 97
FISCAL YEAR 1991
CATS Tracking Number; 90-1X
Assessable Unit/AU #: OERR/HSCD/1902
Title of Material Weakness: Superfund Program: Five-Year Review of Sites
of EPA's long term effort to monitor site conditions, EPA will conduct a review
of all sites at least every five years after the initiation of the remedial
action where hazardous substances remain on site. This will ensure that the
remedy at each site is fully protective of human health and the environment. EPA
will also maintain the effectiveness of the remedy over the long-term by promptly
correcting any additional problems that may arise at sites where our monitoring
indicates that further response actions are necessary to protect human health and
the environment. To assure the public that EPA is carefully monitoring and
maintaining each site, EPA will report annually the results of all five-year
reviews that were conducted during the preceding twelve month period. EPA will
also create a "monitoring list" of sites at which it will conduct reviews.
WorkDlan t: 00570
Functional Category in Statistical Suinn^yy; Program Management
Appropriation/Program Element; Superfund/68/20X8145/TFAY9A
Administrative Activity/Program Activity; Program Activity
Year Identified; 1989
Source of Discovery: The "Management Review of the Superfund Program"
Original Target Correction Date; 01/31/91
Targeted Correction Date in Last Year's Report: 03/30/91
Current Target Date: 07/15/91
Critical Milestones in Planned Corrective Action;
AJ Completed Actions/Events;
* Indicates milestones added since last year's letter.
M/S # MILESTONE TITLE GRIG PLAN ACTUAL
M 005 Issue Draft Guidance 01/31/91 01/31/91 11/13/90
-------
U. S. ENVIRONMENTAL PROTECTION AGENCY ENCLOSURE D
MATERIAL WEAKNESS/CORRECTIVE ACTIONS PAGE 54 OF 97
FISCAL YEAR 1991
M/S #
M 006
M 009*
B.
M/S #
M
MILESTONE TITLE
Issue Short
Sheet/Guidance
Issue Short Sheet
Planned Act ions /Events
MILESTONE TITLE
007* Verification of
ORIG
03/30/91
07/15/91
(Short-Term
ORIG
07/15/91
PLAN
04/12/91
07/15/91
- Next 12
PLAN
07/15/91
ACTUAL
05/23/91
08/19/91
Months):
ACTUAL
09/30/91
Completion
Validation Process to be Used; Regions use guidance to conduct 5-year reviews.
Corrective Action Plan Status Updates;
o September 30. 1991. Stat"<* Update; Issuance of the short sheet in August
1991, represented the final milestone for this activity. While HSCD plans to
issue supplementary guidance, follow-up with the Regions on schedule for actual
reviews, and concur in initial Regional reviews, these are merely implementation
steps of the above policy.
-------
U. S. ENVIRONMENTAL PROTECTION AGENCY ENCLOSURE D
MATERIAL WEAKNESS/CORRECTIVE ACTIONS PAGE 55 OF 97
FISCAL YEAR 1991
CATS Tracking Number; 90-1A51
Assessable Unit/AU /; OERR\OPM\1902
Title of Material Weakness; Superfund Program: Timely and accurate
dissemination of information, Phase I
Description of Material Weakness and its Impact on Agency Operations; In
response to weaknesses identified in the 90-day Study with respect to the
programs ability to quickly disseminate consistently formatted and managed
guidance and policy direction to the regional users, a variety of remedies were
proposed and have been completed as planned. These included:
development of a Publications Standard Handbook which presents acceptable
standards for planning, controlling, designing, formatting, obtaining
concurrence, and managing distribution of ALL documents required to
perform the work of the Superfund program.
development and transmittal of the Office Director-level directives that
require usage of same, and
development, testing and utilization of software, including a centrally
managed PC label system to control distribution and an inventory
management software system.
These tools were essential to the development and maintenance of a
controlled system to ensure that all Superfund information is readily available
to the users.
Work Plan *: 00557
Functional Category in Statistical Summary: Program Management
Appropriation/Program Element; Superfund; 68/20X8145/TFAY9A
Administrative Activity/Program Activity; Program Activity
Year Identified: 1989
Source of Discovery; The "Management Review of the Superfund Program"
Original Target Correction Date: 01/31/89
Targeted Correction Date in T^^t Y^^r's Report; 01/31/89
Actual Completion Date; 09/30/91
for dianae in Date: Activity was expanded.
-------
U. S. ENVIRONMENTAL PROTECTION AGENCY ENCLOSURE D
MATERIAL WEAKNESS/ CORRECTIVE ACTIONS PAGE 56 OF 97
FISCAL YEAR 1991
Corrective Actions Taken; *Milestones added since last year's letter.
M/S # MILESTONE TITLE ORIG PLAN ACTUAL
M 001 Establish Workgroup and Hold 1st Mtg. 10/15/89 10/15/89 10/15/89
M 002 Define Mechanism for Automating 11/15/89 11/15/89 11/15/89
M 003 Identify and Formalize Distrib. Sys. 01/30/90 01/30/90 01/30/90
M 004 Develop Draft Formats/Procedures 03/01/90 03/01/90 03/01/90
M 007 Finalize Lists and Agreements 06/30/90 06/30/90 06/30/90
M 006 Test Automated System 05/01/90 07/30/90 07/30/90
M 008 Finalize Format and Procedures 08/15/90 08/15/90 08/15/90
M 009 System in Place and Operational 09/30/90 09/30/90 09/30/90
M 010 Validate and Fine-Tune System 09/30/91 09/30/91 09/30/91
M 011*Verification of Completion 09/30/91 09/30/91 09/30/91
of Valjri^tion Actions; Publications Standard Handbook and associated
document development controls have already cut 3-6 weeks and as much as 20
percent from the costs associated with developing and printing a major guidance
or technical document. More measurable saving is expected in FY 1992 and will
be carefully examined. The centralized PC label system, when fully operational,
is expected to save 2-3 clerical FTEs and will reduce document distribution time
by as much as one week. Validation will occur in FY 1991.
-------
U. S. ENVIRONMENTAL PROTECTION AGENCY
MATERIAL WEAKNESS/CORRECTIVE ACTIONS
FISCAL YEAR 1991
ENCLOSURE D
PAGE 57 OF 97
Title of Material Weakness: Timely and Accurate Dissemination of Information,
Phase II .
Work Plan #\ 00568
mailing list of key constituents; communications plan; and information kit on the
program.
Functional Category in Statistical Summary! Program Management
Appropriation/Program Element: Superfund; 68/20X8145/TFAY9A
Administrative Activity/Program Activity; program Activity
Year Identified: 1989
Source of Discovery; The "Management Review of the Superfund Program"
Original T^Tfet CotiucLion Date: 11/30/89
Correction
in Ta
-------
U. S. ENVIRONMENTAL PROTECTION AGENCY ENCLOSURE D
MATERIAL WEAKNESS/CORRECTIVE ACTIONS -PAGE 58 OF 97
FISCAL YEAR 1991
of Validation Actions; Information Kit is frequently requested,
therefore fills the gap.
September 30. 1991 Status Update: Workplan ocnplete.
-------
U. S. ENVIRONMENTAL PROTECTION AGENCY ENCLOSURE D
MATERIAL WEAKNESS/CORRECTIVE ACTIONS PAGE 59 OF 97
FISCAL YEAR 1991
CATS Tracking Number: 90-1x5
Assessable Unit/AU /; OERR\OPM\1911
of MatpT-Jal Weakness; Superfund Program: Eliminate Jargon from Superfund
Lexicon
Description of Mat^^ial Weakness and jt'-g Impact on Agency Operations: Issue
matrix of alternative terms to be used.
Work Plan *: 00569
Functional Category in Statistical Summary: Program Management
Appropriation/Program Element: Superfund; 68/20XS145/TFAY9A
Administrative Activity /Program Activity; Program Activity
Year Identified: 1989
Source of Discovery; The "Management Review of the Superfund Program"
Original Target Correction Date; 03/31/90
Targeted Correction Date in Tjast Year's Report: 03/31/90
Actual Completion Date; 11/30/90
Reason for Change in Date (si ; Delayed due to need for senior management to sign
off.
Corrective Actions Taken; * Milestones added since last year's letter.
M/S # MILESTONE TITLE ORIG PLAN ACTUAL
M 002* Issue Jargon Matrix 03/31/90 05/31/91 06/04/91
M 005* Verification of Completion 07/04/91 07/04/91 06/10/91
Results of Validation Actions; Office Director has noted the importance of
speaking clearly and writing in an understandable fashion at OERR-wide staff
meetings and in memos to staff. In addition, the staff that reviews
correspondence has been empowered to return responses if they are "jargony".
September 30. 1991 Statiig Tifrfate: Workplan complete.
-------
U. S. ENVIRONMENTAL PROTECTION AGENCY ENCLOSURE D
MATERIAL WEAKNESS /CORRECTIVE ACTIONS PAGE 60 OF 97
FISCAL YEAR 1991
CATS Trading Numly"; 90— 1A26
Assessable Unit/AU if: OERR\OPM\1911
Title of Material Weakness: Superfund Program: Environmental Results Indicators
Description of Mat^'rial Weakness and its Impact on Agency Oty"ations; Inadequate
attention has been paid to developing and communicating a meaningful national
picture of the Superfund program's accomplishments. Moreover, the language that
has been used to discuss progress has not conveyed progress in a way the public
could understand. Ineffective communication of the program's accomplishments
reduced the public credibility of the program, and placed impediments on program
progress due to the need to respond to frequent program criticisms. By October
1, 1989, begin collection of data to report environmental results indicators for:
the number of sites where exposure from air, surface water arid/or ground water
releases of hazardous substances have been controlled; progress towards meeting
the human health and/or ecological goals at sites; the amount of hazardous
materials treated or removed and area of material contained.
WorkDlan #: 00548
Functional Category in Statistical Sumn^yy; Program Management
Appropriation/Program Element: Superfund; 68/20X8145/TFAY9a
Administrative Activity /Program Activity; Program Activity
Year Identified; 1989
Source of Discovery: The "Management Review of the Superfund Program"
Original Target Correction Date; 4/30/90
Targeted Correction Date in Tagt Yef^'s Report; 4/30/90
Ac*"113! Completion Date: 09/15/91
Reason for Change in Date(s) ; Scope of data collection, quality assurance, and
analytic review work was substantially larger than originally planned. Draft
final report has gone through extensive structural and editorial changes which
have significantly delayed its completion.
Critical Milestones in FY 1991 Planned Corrective Action;
A. Completed Actions/Even^'^- * Indicates milestones ackfeicl since last year's
letter.
-------
U. S. ENVIRONMENTAL PROTECTION AGENCY ENCLOSURE D
MATERIAL WEAKNESS/CORRECTIVE ACTIONS PAGE 61 OF 97
FISCAL YEAR 1991
M/S # MILESTONE TTTLE ORIG PLAN ACTUAL
M 021 Complete Regional Quality Assurance 04/27/90 04/30/90 06/28/90
M 028 Contaminant Groupings 05/18/90 05/18/90 05/18/90
M 026 Meet With Regions on FY 91 Rqmts. 05/24/90 05/24/90 05/24/90
M 029 Groundwater Pump and Treat 05/31/90 05/31/90 06/11/90
M 023 Draft Final Report 06/10/90 06/10/90 06/08/90
M 027 Population Data Analysis 06/10/90 06/10/90 06/05/90
M 024 Communications Strategy 06/20/90 06/20/90 06/20/90
M 020 Work With HSCD on El Data Reporting 07/01/90 07/01/90 07/01/90
M 022 Resolve Issues from QA 05/18/90 07/10/90 07/26/90
M 008 **Final FY 1990 El Report 04/30/90 10/12/90 10/26/90
M 009 Regional El Procedures in Place 07/01/90 11/08/90 11/20/90
M 010 Issue Semi-Annual El Report 11/30/90 04/30/91 / /
M Oil* Verification of Conpletion 09/30/91 09/30/91 09/15/91
of Validation Process; Management has used a variety of CERCLIS data
analyses to validate the accuracy and completeness of the environmental
indicators data that have been collected. Similar analytic techniques will be
used to assess the completeness of El data reporting by the Regions in the coming
year.
Corrective Action Plan St-at^s
o September 30. 1991. Status Update: Data collection for the initial
environmental indicator report was completed in March 1990. Data analysis and
quality assurance proceeded through Summer 1990. The final report was completed
in October 1990 and released by the Administrator in December 1990. Work is
underway to prepare an updated Superfund environmental indicator report with
information through the end of 1990. Current schedule calls for
completion in April 1991.
The FY 1991 report, entitled "Superfund: Reporting Progress Through
Environmental Indicators, FY91 Update" was approved by the Assistant
Administrator and sent to the Deputy Administrator on August 2, 1991. On August
29, 1991, the Assistant Administrator held a brainstorming/strategy session to
-------
U. S. ENVIRONMENTAL PROTECTION AGENCY ENCLOSURE D
MATERIAL WEAKNESS/CORRECTIVE ACTIONS PAGE 62 OF 97
FISCAL YEAR 1991
discuss the El messages and how best to make them known to the public. It was
decided that fact sheets of El progress should be developed and made available
to many offices within the Agency, with the hope that Superfund progress would
be incorporated into other Agency papers and briefings. No formal announcement
of this second El report is expected. Future reports will be issued on an annual
basis. This completes the workplan.
-------
U. S. ENVIRONMENTAL PROTECTION AGENCY ENCLOSURE D
MATERIAL WEAKNESS/CORRECTIVE ACTIONS PAGE 63 OF 97
FISCAL YEAR 1991
CATS Tracking Number; 90-1
Title of Material Weakness; Superfund Program; Settlement Tools - Provide
training
Work Plan *; 90002
Description of Material Weakness and its Impact on Agency Operations: Establish
clearinghouse of information on use of settlement tools, and develop case-method
training for RPMs and regional attorneys.
Functional Category in Statistical Summary; Program Management
Apptopriation/Program Element; Superfund Trust Fund
Administrative Activity/Program Activity; Program Management
Year Identified; 1989
Source of Discovery; The Administrator's request for a major review of the
Superfund Program.
Original Target Correction Date; 09/30/90
Targeted Correction Pat** fo Ta^t Year's Report; 09/30/90
Actual Completion Date; 12/30/90
•
Reason for Change in Date(s); Travel restrictions on regional training and
extensive comment/revision of training materials.
Corrective Actions Taken; Course developed; pilot test in Wash., .DC on 8/15-
16/90
Settlement Tools training course completed 12/3/90 and incorporated into
the Superfund Academy.
Regional offerings — 10/90 - 3/91
Repeated offerings of course as needed
Results of Validation Actions; 1) Student evaluations (short/long term); 2)
improvement in program performance.
-------
U. S. ENVIRONMENTAL PROTECTION AGENCY ENCLOSURE D
MATERIAL WEAKNESS/CORRECTIVE ACTIONS PAGE 64 OF 97
FISCAL YEAR 1991
CATS Tracking NuiP^|0'r: 90—1
Title of Material Weakness: Superfund Program: Info. Release to Potentially
Responsible Parties
Work Plan #: 90008
Description of Material Weakness and its Impact on Agency Operations: Prepare
directive on importance of releasing information; develop guidance, databases and
other resources; develop policy statement; and follow with a practical memorandum
on systems for information release.
Functional Category in Statistical Summary; Program Management
Appropriation/Proqr?«n Figment: Superfund Trust Fund
Af^ipi nistrative Activity/Proc|t'am Activity: Piyyji'*"* Management
Year Identified; 1989
Source of Discovery; The Administrator's request for a major review of the
Superfund Program.
Original Target Correction Date: 06/30/90
T^yxreted Correction Date in I^gf- Y^^r's Report: 06/30/90
Actual Completion Date; 02/28/91
Reason for Change in Date f si ; Expansion of types of models available for use
required more time for compilation.
Corrective Actions Taken: Waste-in Guidance signed and transmitted to Regions
02/22/91.
Specific guidance and models on waste-in lists and volumetric rankings.
of valjffotion Actions: Regional Comment — Responses from Regions 1, 3,
5, 6, and 9 have been positive thus far on usefulness of guidance. No formal
feedback system other than regional reviews contemplated at this time.
-------
U. S. ENVIRONMENTAL PROTECTION AGENCY ENCLOSURE D
MATERIAL WEAKNESS/CORRECTIVE ACTIONS PAGE 65 OF 97
FISCAL YEAR 1991
CATS Tracking Number: 90—1
Title of Material Weakness: Superfund Program: Responsible Party Search
Enhancement
Work Plan t: 90019
Description of Material Weakness and its Impact on Agency Operations: Establish
national criteria for re-doing RP searches.
Functional Category in Statistical Summary; Program Management
Appropriation/ Program Element; Superfund Trust Fund
Administrative Activity /Program Activity; Program Activity
Year Identified; 1989
Source of Discovery: Administrator's request for a major review of the Superfund
Program.
Original Target Correction Date: 09/30/90
Targeted Correction Date in Last Year's Report: 09/30/90
Actual Completion Date; 06/01/91
Reason for Change in Date (si ; March 1991 Regional/Headquarters agreement to
update the 12/28/89 guidance. This 12/89 guidance was too resource intensive on
Regions.
Corrective Actions Taken; Memo to Regions establishing ground rules on 12/28/89.
Follow-up meetings with individual Regions.
Criteria established. FY 91 Strategy was issued by 3/1/91. Meetings with
Regions were held on 3/25/91.
'g of Valifrfotion Actions; Evaluation of quality of PRP search. A recently
concluded series of PRP search audits revealed a better quality of PRP searches
from the contractors and better oversight by Regional offices.
-------
U. S. ENVIRONMENTAL PROTECTION AGENCY ENCLOSURE D
MATERIAL WEAKNESS/CORRECTIVE ACTIONS PAGE 66 OF 97
FISCAL YEAR 1991
Title of Material Weakness: Data Integrity for Pesticides and Toxic Substances
of Material Weakness and Its Impact on Agency Operations: Office of
Compliance Monitoring (CCM) has determined that its laboratory data integrity
program constitutes a material weakness. Several factors have been identified
by management that require corrective actions. For instance, inspectors lack
training in fraud detection in a laboratory setting. Currently, CCM cannot offer
its inspectors this specialized training because there is no known Federal entity
or contractor with the required expertise. The OIG is conducting a survey of
laboratories, industry, and Federal agencies to determine if there is any
expertise which could be utilized to train OCM's inspectors. The findings of
this survey should become available in FY 92 when the OIG publishes its final
report of the Good Laboratory Practice Program review.
The effectiveness of the program is weakened by the advance notice that
laboratories are given (2-weeks) prior to an inspection. COM plans to revise on
a pilot basis the notification procedures within the first quarter of FY 92.
The program also lacks the means to identify laboratories based on the
specified studies that they are contracted to conduct. CCM is reviewing the need
to prepare a new regulation for periodic reporting of this information.
Currently, the identification of the authorizing laboratory is required to be on
its published studies. There is, however, no mechanism to funnel this
information on completed studies and studies- in-process to CCM. The reporting
requirement will not only require the identification of the laboratories and the
studies they are conducting, but also the identification of the chemicals
associated with the studies. This will enable better oversight and management
of the studies done by the laboratories.
This program is further exacerbated by the fact that there is no
consistency in the training of Headquarters, Regional, and NEIC inspectors. CCM
is already planning a major training program in September, 1992. This training
will incorporate new information and techniques based on the results and
recommendations presented in the OIG's final GLP report, and the revised
Enforcement Response Policy (ERP) for the FIFRA GLP regulations.
Functional Category in Statistical Surnn^rv: Program Execution
Appropriation/Program Element: Pesticides Enforcement
Administrative Activity /Program Activity: Program Activity
Year Identified: 1991
Source of Discovery; AICR
Original Target Correction Date; 1992
-------
U. S. ENVIRONMENTAL PROTECTION AGENCY ENCLOSURE D
MATERIAL WEAKNESS/CORRECTIVE ACTIONS PAGE 67 OF 97
FISCAL YEAR 1991
Date: 1992
(""'"i'tical Milggtorv^s in Corrective Action;
A. Completed Actions/Events; OCM has taken action on the recommendations
presented in the OIG's special review of the GLP Program disraisspd earlier in
this report. For instance, OCM was instrumental in preparing the Agency's
proposed legislation that would recognize GLP . violations as FIFRA violations.
Also, an interim Enforcement Response Policy (ERP) for the FIFRA GLP regulations
was completed in September 1991. This policy provided guidance for determining
whether to assess a GLP violation under FIFRA section 12 (a) (2) (Q) as a high,
middle, or low level violation. OCM has requested additional resources in the
President's FY 1993 budget to expand its coverage of the regulated community as
recommended by the OIG. OCM has also completed the initial planning in the
development of a corrective action plan as outlined below.
B. Planned Act ions /Events (FY 19921 ;
Initiate, on a pilot basis, a revision of the
inspection notification procedures ............... 12/91
Implement a revised neutral administrative scheme
for laboratory selection procedures .............. 2/92
Initiate an inspector training program which
incorporates results/recommendations of OIG and
IF a source is found, fraud detection in a
laboratory setting ............................... 9/92
C. Planned Actions/Events (FY 1993 and beyond) : OCM will expand its coverage
of the regulated community when it conducts laboratory inspections and data
audits.
Validation Process to be Used; Management will verify completion and
effectiveness of the above corrective actions based on evaluations of the
training programs and the performance of the inspectors.
-------
U. S. ENVIRONMENTAL PROTECTION AGENCY ENCLOSURE D
MATERIAL WEAKNESS/CORRECTIVE ACTIONS PAGE 68 OF 97
FISCAL YEAR 1991
Title of Material Weakness: Growing Backlog of Requests for Audits of EPA
Contractors
have shown potentially millions of dollars in questioned costs and major internal
control weaknesses with accounting and time keeping systems. At present, the
limited number of contract incurred cost audits and system reviews does not
represent adequate audit coverage of EPA contracts. Almost 90 percent of EPA's
contracting dollars are spent on cost reimbursable contracts. This type of
contract provides few incentives for contractors to control costs. The
responsibility and associated risk rests, with the Government and places the
Government in the position of assuming a proportionately ' greater risk.
Therefore; it is critical that incurred cost audits of contracts be conducted in
a timely manner. In addition, there is a substantial and growing backlog of
requests for audits of EPA contractors, including at least 390 unmet requests for
incurred costs audits. The lack of timely contract audit coverage leaves the
Agency vulnerable.
The OIG cannot currently provide strony oversight to the Agency's contract
funds and cannot fulfill the Agency's demands for contract audits. Audits of the
Agency's contractors are needed to provide the Agency's contracting officials
with information necessary to effectively: (1) award a contract, (2) substantiate
the claims submitted for payment, (3) determine compliance with legal and
administrative conditions, and (4) identify potential indicators of fraud,
illegal acts or irregularities. The OIG has identified in the current and future
budget requests, the level of additional resources needed to meet the Agency's
demand for contract audits.
Functional Category in Statistical Sumn^yy; Procurement
Appropriation/Program Element; 6810112/S&E N3AS5A and Superfund NWAY5A
Year Identified; Fiscal 1989 and 1991
Source of Discovery; Fiscal 1989 and 1991 FMFIA Review Process and the ongoing
review by the Office of Audit's Contract Task Force.
Current Target Date; Ongoing
in Corrective Action;
A. Completed Actions/Events; To provide additional audit coverage, the OIG
has several initiatives underway, including, formally assuming cognizance for
12 major EPA contractors, hiring auditors with extensive financial auditing
experience and implementing an expanded contract audit strategy including 'closer
coordination with the Defense Contract Audit Agency. However, OIG non-Superfund
resources have not kept pace with EPA's increased contract workload. Funding for
audits of non-Superfund contracts was substantially reduced; therefore, only high
-------
U. S. ENVIRONMENTAL PROTECTION AGENCY ENCLOSURE D
MATERIAL WEAKNESS /CORRECTIVE ACTIONS PAGE 69 OF 97
FISCAL YEAR 1991
priority assignments (preaward audits) could be performed. Accordingly, we have
requested additional resources for contract audit work in the fiscal 1992 & 1993
budgets.
B. Planned Actions/Events (FY 1992) ; We will request additional resources for
contract audits in the fiscal 1994 budget.
C. Planned Actions/Events (FY 1993 and beyond) ; Justify to the Office of
Management and Budget and the Congress the need for additional resources to
provide coverage of the Agency's contracts. A request for additional resources
has been considered in the current and future budget submissions.
to be Used; To compare the budget request, the actual
resources received, and the Agency's demand for contract audits.
Correct ive Action Plan Sta^1*18 Udat
o September 30. 1991. S^tr^s Update; ppqiiggt^d additional contract resources
in the fiscal 1992 and 1993 budgets.
-------
U. S. ENVIRONMENTAL PROTECTION AGENCY ENCLOSURE D
MATERIAL WEAKNESS/CORRECTIVE ACTIONS PAGE 70 OF 97
FISCAL YEAR 1991
Title of Material Weakness; Implementation of Storm Water Permitting
Requirements Under the Clean Water Act.
Description of Material Weakness and Its Impact on Agency Operations; The Clean
Water Act amendments of 1987 included requirements and deadlines for storm water
permits under the NPDES program (deadlines and requirements for EPA application
regulations, submission of applications by the regulated community, issuance of
permits, study and reports on unregulated universe of storm water discharges, and
development of regulatory approach for unregulated universe (moratorium
sources) ) . EPA has worked to meet these requirements, but has missed deadlines
in the law and is substantially behind in dealing with the moratorium of
unregulated discharges of storm water (the moratorium on coverage of this
universe by the NPDES program expires in October 1992) . Storm water permitting
requirements (before dealing with the moratorium sources) will more than triple
the universe of NPDES dischargers. All of the above create potential material
weakness in the NPDES program (and other water programs) due to the magnitude of
the universe to be regulated and the resource burden associated with such an
increase in the universe.
Functional Cat^^ory in Statistical Sumn«ry; program Management:— Program
Execution.
Auoropi iation/Program Element; Salaries and Expenses and Abatement and Control
appropriations; Permit Issuance, Section 106 Grants, and Construction Grants
Appropriation; Section 104 (b) (3) Grants program elements.
Administrative Activity/Program Activity;
Identified; 1991
Source of Discovery; Informal assessment of progress in meeting 1987 CWA
requirements for storm water; also, implementation issues raised at Headquarters,
regional and state levels.
Original Target Correction Date: Not applicable. This is a newly identified
material weakness.
Current Target Date; No date yet. Will be developed as part of corrective
action plan.
for Change in Datefs) ;
Critical Milestones in Corrective Action: Not applicable.
A. Completed Act ions/ Events T
B. Planned Actions/Events fFY 1992) ; 1/15/92 .Complete corrective action
plan.
-------
U. S. ENVIRONMENTAL PROTECTION AGENCY ENCLOSURE D
MATERIAL WEAKNESS/CORRECTIVE ACTIONS PAGE 71 OF 97
FISCAL YEAR 1991
C. Planned Actions/Events (FY 1993 and beyond); To be developed as part, of
the corrective action plan.
Validation Process to be Used; The validation process management will use to
verify completion and effectiveness of the corrective actions will be developed
as part of the corrective action plan.
-------
U. S. ENVIRONMENTAL PROTECTION AGENCY ENCLOSURE D
MATERIAL WEAKNESS/CORRECTIVE ACTIONS PAGE 72 OF 97
FISCAL YEAR 1991
of Ma^Tial Weakrv^y! Management of R&D Extramural Resources
Description of Material Wgaknggs and Its Impact on Agency Operations: Almost 70%
of ORD's total research budget is used to fund extramural activities, i.e.,
contracts, grants, cooperative agreements and interagency agreements. With
increases in R&D funding and limitations on FTEs, increasing demands and strains
are being placed on our ability to adequately manage our extramural resources and
related instruments such as contracts, research grants, cooperative agreements,
and interagency agreements. The growing disparity between program size and human
resources creates a material weakness in extramural management with a
vulnerability for potential fraud, waste, and mismanagement of federal funds.
Functional Cateqorigs in Statistical Sumnvyryj Procurement and Grants Management.
Appropriation/Program Element; Environmental Protection Agency-Salaries and
Expense, Research and Development, and Superfund Appropriations.
Administrative Activity/Program Activity; Administrative Activity.
Identified; FY 1990
Source of Discovery; ORD conducted a comprehensive assessment of its work force
during the latter part of FY 1989. This analysis was conducted in response to
a request from Congressman Scheuer, chairman of the House Sub-Committee on
Natural Resources, Agriculture Research and Environment, to assess the skills and
talents required to accomplish ORD's scientific mission. One of the five
strategic areas of importance the work force study addressed was "Is that portion
of the work force charged with "extramural" management adequate and appropriate
to the mission?"
The results of the work force analysis along with the expressed concerns
from the Inspector General prompted ORD to conduct an assessment of extramural
management. A questionnaire was developed to assess the adequacy of procedures
and resources for each extramural management instrument. Each ORD assessable
unit completed the set of questionnaires. According to the work force study and
the subsequent lab questionnaire, ORD allocates approximately 300-400 FTEs to
extramural activities which translates to 16%-22% of ORD's work force managing
nearly 70% of ORD's resources. The reports have indicated a definite weakness
in several areas. The highest rated problems were identified as:
o adequacy of extramural management training;
o sufficient number of people to perform contract
management;
o conduct of inspections of contractor work at site;
o adequacy of contract administration files;
-------
U. S. ENVIRONMENTAL PROTECTION AGENCY ENCLOSURE D
MATERIAL WEAKNESS /CORRECTIVE ACTIONS PAGE 73 OF 97
FISCAL YEAR 1991
o performance of yearly inventories of government furnished property;
o monitoring expenditures to determine if they are reasonable in terms
of the work performed; and
o monitoring expenditures to ensure individual ceilings are not
These data are considered a base line for use by an ORD/Agency task force
to achieve process improvements, establish adequate training, establish
management controls and identification of resource shortages. This task force
will use a TQ# approach and is expected to visit each ORD laboratory in FY 1992 .
Original Target Correction Date: June 1992
Targeted Correction Date in T>st Year's Report: June 1992
Current Target Date; 1994
Critical Milestones in Corrective Action:
1. Complete analysis of data gathered by questionnaires on extramural
management instruments and issue report.
Planned Completion Date: December 1990
Completed: December 1990
2. Complete data collection and analysis of work force '90 data.
Planned Completion Date: March 1991
Completed:
3 . Develop event cycle documentation for each extramural management instrument
to be included in each assessable unit's documentation for FY 1991.
Planned Completion Date: March 1991
Completed: August 1991
4 . Identify additional manpower required to adequately manage ORD's extramural
resources.
Planned Completion Date: May 1991
Completed: May 1991
5. Integrate identified requirements into the budget and planning process for
FY 1993.
Planned Completion Date: May 1991
Completed: June 1991
-------
U. S. ENVIRONMENTAL PROTECTION AGENCY ENCLOSURE D
MATERIAL WEAKNESS/CORRECTIVE ACTIONS PAGE 74 OF 97
FISCAL YEAR 1991
6. Develop schedule of training for personnel with extramural management
responsibilities.
Planned Completion Date: September 1991
Revised Completion Date: June 1992
7. Develop policy and procedures for extramural management activities within
ORD.
Planned Completion Date: December 1991
8. Conduct on-site reviews and analysis of the management of ORD's extramural
resources.
Planned Completion Date: June 1992
A. Completed Actions/Events; Briefly describe actions taken since the last
njport to OMB.
Corrective Action milestones 1 through 5 completed.
ORD established a Senior Council on Management Controls that has focused
on providing guidance on correcting extramural management issues.
B. Planned Actions/Events (Short-Term - Next 12 Months);
1. Corrective Action Milestones 6 through 8 to be completed within the next
12 months'.
2. Request Agency approval to establish a Senior level Acquisition Manager to
provide oversight and guidance for extramural activities.
3. In January 1992, begin an on-site review of each laboratory's extramural
management processes and controls and develop corrective action plans where
necessary.
C. Planned Actions/Events (Longer Term); Maintain a Senior level of
management oversight of extramural activities throughout ORD and provide a
proactive approach in identifying and correcting problems.
Validation Process to be Used; An on-site review of each laboratory's extramural
management processes will be conducted to ensure appropriate controls and
control techniques are in place and are effective. These reviews will be
conducted jointly with the Contracts Management Divisions in FTP and Cincinnati.
ORD has established a Senior level Council on Management Controls that will
advise and oversee the extramural management review process.
-------
U. S. ENVIRONMENTAL PROTECTION AGENCY ENCLOSURE D
MATERIAL WEAKNESS/CORRECTIVE ACTIONS PAGE 75 OF 97
FISCAL YEAR 1991
Corrective Action Plan Stat"?
30. 1991. Status
1. ORD assigned a Senior level position to serve as an Acquisition Manager to
oversee ORD's extramural program.
2. ORD Senior Managers were briefed on the findings of the studies that were
conducted and documented during FY 1991.
3. ORD and the Contracts Management Divisions in FTP and Cincinnati have
agreed to a joint review, using a TCpI approach, of ORD's extramural management
program.
-------
U. S. ENVIRONMENTAL PROTECTION AGENCY ENCLOSURE D
MATERIAL WEAKNESS/CORRECTIVE ACTIONS PAGE 76 OF 97
FISCAL YEAR 1991
Title of Material Weakness; ORD Laboratory Buildings and Facilities
Description of Material Weakness and Its Impact on Agency Operations; The Office
of Research and Development is responsible for providing high quality, timely,
scientific and technical information in the service of Agency goals. This
research program is conducted through twelve environmental laboratories across
the country, employing some 2000 people with an annual budget of $380 million.
A majority of these facilities are over 20 years old and are in a serious state
of disrepair. Some labs have been cited for OSHA violations, and for being out
of compliance with other Federal/State regulations. In addition, Congressionally
approved research initiatives are postponed or delayed beyond the time frame
needed because necessary facilities modifications are not funded. Without
adequate facilities to perform the Agency's research, the base on which the
development of policy, guidance, standards, regulations, and the appropriate
tools for implementing pollution abatement strategies is seriously weakened.
Functional Category in Statistical Sumn^Ty; Property and Inventory Management
Appropriation/Program Element; Environmental Protection Agency -Salaries and
Expenses, Research and Development, and Buildings and Facilities Appropriations.
Administrative Activity/Program Activity; Program Activity
Year Identified; FY 1989
Source of Discovery; An effort to coordinate and improve the quality of ORD's
annual buildings and facilities budget submission resulted in an onslaught of
project proposals that painted a dismal picture of the research and developments,
particularly the remote laboratories. A more in-depth review was conducted to
determine the magnitude of the problem. Management visits to various
laboratories resulted in "horror stories" of deficiencies that were impairing
ORD's research program and situations that were potentially harmful to laboratory
staff. In addition, EPA Health and Safety Audits, and Environmental Compliance
Audits identified areas needing immediate attention.
Original Target Correction Date; December 1990
Targeted Correction Date in T;ast Yf^r's Report; December 1990
Qirrent Target Date; June 1993
Reason for Change in Date (si; The targeted date relies on the Agency's effort
to develop a master plan for all EPA facilities. The effort began in FY 1991 and
is scheduled for completion in FY 1993. The master plan will provide Agency-
level base data to be used in establishing funding requirements for facility
improvements to support the Agency's mission.
Critical Milestones in Corrective Action:
-------
U. S. ENVIRONMENTAL PROTECTION AGENCY ENCLOSURE D
MATERIAL WEAKNESS/CORRECTIVE ACTIONS PAGE 77 OF 97
FISCAL YEAR 1991
1. Develop a Facilities Management Plan to collect data to adequately document
ORD's research facility needs.
Planned Completion Date: July 1990
Completion Date: August 1991
2. Develop procedures to systematically link B&F budgeting with ORD and Agency
long-term strategic planning.
Planned Completion Date: October 1990
Revised Completion Date: September 1993
3. Develop prioritization methodology to determine B&F priorities based on
short-term and long-term strategic planning.
Planned Completion Date: January 1990
Completion Date: January 1990
4. Develop Agency level budget initiatives to address critical B&F needs.
Planned Completion Date: Annual Activity
5. Develop systematic methodology to accomplish required repair and improvement
projects to ensure compliance with OSHA and other Federal/State regulations.
Planned Completion Date: December 1990
Completion Date: June 1991
6. Develop Policies and Procedures to direct ORD's B&F activities.
Planned Completion Date: October 1990
Revised Completion Date: June 1992
A. Completed Actions/Events;
Milestone # 1:
1. The Facilities Management Plan was fully implemented in FY 1991.
2. EPA's Environmental Health and Safety Office audited several of the
ORD laboratories for Fire Protection and Life Safety. The audits identified and
quantified health and safety deficiencies that EPA has committed to correcting
using a time-phased approach.
Milestone # 2:
1. In FY 1990, ORD requested that the Facilities Management and Services
Division, OARM, provide a master plan for each ORD facility to link physical
plant needs, strategic research needs and B&F budgeting to support ORD and Agency
-------
U. S. ENVIRONMENTAL PROTECTION AGENCY ENCLOSURE D
MATERIAL WEAKNESS/CORRECTIVE ACTIONS PAGE 78 OF 97
FISCAL YEAR 1991
long-term planning. OARM approved this request and expanded it into an Agency-
wide initiative to develop a master plan that includes all Agency facilities.
The effort began in FY 1991.
Milestone # 3:
1. Developed an automated methodology that was used to rank the FY 1992 B&F
budget submission. This methodology has been institutionalized in the ORD B&F
process.
Milestone # 4:
1. ORD annually submits initiatives for the outyear budget submissions to
provide increased resources for repair and upkeep under $75K (our annual needs
exceed $3.5 million), and initiatives for projects over $75K. In 1991, EPA
provided ORD with $200K for minor repair and improvement projects and ORD was
able to divert an additional $500K toward these needs.
Milestone # 5:
1. Provide follow-up to Environmental Compliance Audits on each of the ORD
laboratories to ensure a corrective action plan is prepared that addresses the
appropriate issues and projects requiring B&F resources are included in the
budget request.
Milestone # 6:
1. Prepared draft policy and procedure.
C. Planned Actions/Events;
Milestone # 2:
1. Work with the Agency to complete the master plan and to ensure that ORD's
physical plant needs and research needs are incorporated into the final document
and that the B&F budget requests adequately represent the needs identified.
2. Provide the Agency with critical data necessary to gaining additional B&F
resources for the B&F projects that cost less than $75K as well as for the
projects that cost more than $75K.
3. Work with the Agency to determine the methodology to manage B&F projects
that cost less than $75K.
Milestone # 6:
1. Complete the policies and procedures and submit them for internal review.
-------
U. S. ENVIRONMENTAL PROTECTION AGENCY ENCLOSURE D
MATERIAL WEAKNESS/CORRECTIVE ACTIONS PAGE 79 OF 97
FISCAL YEAR 1991
Budget Implications. If Any: The above corrective action plan provided for the
development and implementation of a facilities management plan. This plan
addresses the total requirements of the research and development laboratories,
identifying needs of both the physical-plant and the research program.
In FY 1991, ORD did not have any authority to fund minor repair and
improvement projects costing $75K and under. In FY 1992, ORD has been given the
authority to fund these projects, but has not been given resources for these
projects. Any funding in FY 1992 will come from the R&D expenses which is
already critically under-funded.
ORD has an average annual need of approximately $3.5M for project: costing
$75K and less. ORD was provided with $700K to fund these projects. The lack of
funding for basic repair and maintenance and for laboratory modification for
research activities is exacerbating previously identified health and safety
problems and unduly delaying critical research projects. In addition, the
Agency's B&F appropriation that covers the greater than $75K projects is not
adequate to mitigate the effects of long-term neglect for the EPA-owned
laboratories. ORD's annual Repair and Improvement request in the B&F submission
averages approximately $12M which is primarily for the EPA-owned laboratories.
Without additional funding the physical condition of the research and development
laboratories will deteriorate even further, greatly impairing EPA's research
program.
Valiciation Pixx'g's'-s ta? be Used: The ffat-a that was generated £tmn the datratvuga
and from the B&F submissions led ORD to request that the Agency provide a master
plan of each ORD facility. The master plan will provide Agency-level validation
of ORD's needs and link these needs to the Agency's B&F request.
Corrective Action Plan Status Updates;
o September 30. 1991. Status Update;
Milestone # 2: The Agency's initiative to develop an Agency-wide master
plan will provide the B&F budgeting link with ORD and Agency long-term strategic
planning. This effort began in FY 1991 and will continue through FY 1993.
Milestone # 6: The draft policies and procedures is under internal ORPM
review.
The remaining milestones have been completed.
-------
U. S. ENVIRONMENTAL PROTECTION AGENCY ENCLOSURE D
MATERIAL WEAKNESS/CORRECTIVE ACTIONS PAGE 80 OF 97
FISCAL YEAR 1991
Title of Material Wgaknggs; Agency-wide Audit Follow—up
Description of Material Weakness and Its Impact on Agency Operations;
EPA offices' compliance with audit management practices are not adequate to
ensure that management's corrective actions taken in response to audit findings
and recommendations are implemented fully.
Inaccurate data entered in the Agency's Management Audit Tracking System
(MATS) by EPA offices results in the reporting of inaccurate information in the
"Semiannual Management Report to Congress," as required by the IG Act Amendments
of 1988. Without strong audit management practices, offices may not be
implementing follow-up actions fully and effectively.
Functional Category in Statistical Sumn«yy; Program ManagumMMfryprngram Execution
Appropriation/Program Element; Environmental Protection Agency/All
Appropriations
ive Activity/Program Activity; Administrative Activity
Identified; 1989
Source of Discovery; 1989 OIG Special Review on Audit Follow-up
TrV'Tfgt'Od OotiBUt.ion Date in Ir*gt Y^^r's Report; 9/90
Current Target Date; 4th qtr FY 1992
Reason for Change in Date f si ; The Resource Management Division made significant
progress in correcting many of the problems in audit follow-up. The central
database was completed and a reporting process put in place which allowed EPA to
meet the reporting requirements of the IG Act Amendments of 1988. However, our
analysis and the 1990 Inspector General Special Review of EPA's Audit Follow-up
indicated that significant additional work was required in EPA offices to correct
the weakness..
Critical Milestones in Corrective Action;
A. Completed Actions/ Events; (actions taken since, the last report to OMB)
1. Develop an audit follow-up on-site review protocol and establish audit
follow-up as a standard item to be included in Management Assistance Reviews.
Beginning date: 3rd qtr FY 1991
Completion date: May 1991
-------
U. S. ENVIRONMENTAL PROTECTION AGENCY ENCLOSURE D
MATERIAL WEAKNESS/CORRECTIVE ACTIONS PAGE 81 OF 97
FISCAL YEAR 1991
2. Modify the existing Management Audit Tracking System (MATS) to expand its
capabilities and enhance its user friendliness.
Beginning date: February 1991
Conpletion date: July 1991
B. Planned Act ions/Events fShort-Term - Next 12 Months);
1. Survey MATS users on their issues and concerns with the system. Build
these concerns into planning process for any future, ongoing MATS enhancement
efforts.
Beginning date: 1st qtr FY 1992
Conpletion date: 4th qtr FY 1992
2. Develop an Audit Quality Assurance program to establish forms, policies and
procedures to ensure the highest quality of data entered into MATS.
Beginning date: May 1991
Completion date: 4th qtr FY 1992 (revised)
3. Develop additional Audit follow-up guidance that will update the EPA orders
and directives on audit management and provide for greater uniformity of audit
follow-up procedures.
Beginning date: 1st qtr FY 1991
Conpletion date: FY 1992 although activities will be ongoing
4. Conduct Quality Assurance reviews in several EPA locations to assess the
accuracy of data entered in MATS.
Beginning date: May 1991
Completion date: FY 1992 although activities will be ongoing
C. Planned Actions/Events (Longer Term): The short-term, planned corrective
actions for FY 1991 and FY 1992 are anticipated to remedy the weakness in FY
1992.
Validation Process to be Used; The Quality Assurance reviews begun in FY 1991
will test transactions, evaluate controls, and result in a written report. These
reports will validate the effectiveness of actions or identify additional actions
needed. In addition, we anticipate that the OIG will perform a Special Review
of Audit Follow-up again in 1992.
-------
U. S. ENVIRONMENTAL PROTECTION AGENCY
MATERIAL WEAKNESS/CORRECTIVE ACTIONS
FISCAL YEAR 1991
ENCLOSURE D
PAGE 82 OF 97
Cor
live Action Plan Status Updates:
Sentemher 30. 1991. Status Undate:
Milestone A-l
Milestone A-2
Milestone B-l
Completed in May 1991
MATS contractor delivered MATS 2.0 on July 15,
1991 with a number of refinements to broaden its
usefulness and reduce the need for shadow
systems.
On-site reviews have identified users' concerns
with MATS. These reviews will continue in FY
1992.
Milestone B-2
Milestone B-3
Milestone B-4
Contractor has completed five site reviews in
preparation for drafting the QA manual. Expected
delivery of the manual is 2nd quarter 1992.
MATS Bulletins are planned for release in the 2nd
quarter 1992. These bulletins will provide
technical updates on audit tracking and follow-
up.
QA reviews have been conducted in several
locations. Reviews have been conducted in FTP
and Regions II, V, VII, and IX.
-------
U. S. ENVIRONMENTAL PROTECTION AGENCY ENCLOSURE D
MATERIAL WEAKNESS/CORRECTIVE ACTIONS PAGE 83 OF 97
FISCAL YEAR 1991
Title of Material Weakiv?gg»; R&D Laboratory Operating Expenses
of Material Weaknggs and Its Impact on Agency Operations; A lade of
sufficient resources for laboratory operating expenses has created a material
weakness in our research programs. The lack of resources could significantly
impair the fulfillment of ORD's laboratory research mission if left unoorrected.
The shortage of resources for laboratory operating expenses has adversely
affected activities such as telecommunications, mail services, janitorial
services, computer operations, warehouse operations, training and the ability to
purchase specialized laboratory supplies for ORD's research projects.
The amount of shortfall to fund laboratory operating expenses increased
over the past several years because a disproportionate share of those dollars
were needed to fund PC&B. In many cases, the shortfall in S&E operating expenses
was partially funded by diverting funds from other high priority programs.
Authority for use of the Research and Development (R&D) appropriation for
the financing of expenses was provided in the FY 1991 Appropriations Act.
Congress also established a ceiling in the R&D account for operating expenses,
however a comprehensive definition of operating expenses was not provided. This
may have resulted in an inconsistent application of the use of the R&D
appropriation for expenses across the ORD community.
Functional Catgcrory in Statistical Sumryyv; prnrp-ayn execution.
Appropriation/Program Element: Environmental Protection Agency-Research and
Development Appropriation, Program Elements CA2H1A for Field and laboratory
Expenses and CA3H1A for Headquarters Expenses. Superfund Appropriation,
Administrative Ceiling
Administrative Activity /Program Activity: Program Activity.
Year Identified; FY 1990, Revised FY 1991
Source of Discovery; The increasing costs for personnel compensation and
benefits (PC&B) over the past several years has eroded the base of available
funds to operate the Research and Development laboratories. This inadequate
purchasing base has resulted in a reduction in the amount of specialized supplies
that scientists are able to purchase. One laboratory reported that supply
dollars are currently only 10% of those needed to conduct planned experiments.
To identify and quantify the problem, ORD conducted a comprehensive review
of laboratory infrastructure and resource needs. Preliminary results indicate
a requirement for resources for laboratory operating expenses far in excess of
currently available or anticipated funds. A recent management review of the
Environmental Monitoring and Assessment Program identified a possible
inconsistency in the use of the R&D appropriation to fund laboratory operating
expenses.
-------
U. S. ENVIRONMENTAL PROTECTION AGENCY ENCLOSURE D
MATERIAL WEAKNESS/CORRECTIVE ACTIONS PAGE 84 OF 97
FISCAL YEAR 1991
Original Target Correction Datei December 1992.
current Target Date; December 1992: Internal ORD management improvement actions.
December 1995: Completion of proposed 5-year phased plan for addressing operating
expense funding shortfall. Will require support from outside ORD.
in Curujctive Action;
1. Complete analysis of data gathered in the comprehensive review of
laboratory operating expenses to include an analysis of direct and indirect cost,
one-time costs, and a shortfall analysis by comparison of data with operating
plans.
Completed Date: November 1990
2. Issue final report on laboratory operating expenses.
Completed Date: December 1990
3. Develop ORD strategies and priorities to address laboratory operation
expense requirements.
Completed Date: April 1991
Milestone Revised:
(a) Develop ORD process for operating expense budgeting to
provide for laboratory input and Office Director review and
prioritization.
Completed date: April 1991
(b) Develop ORD strategies and priorities to address laboratory operating
expense requirement through planning and execution.
Planned completion date: December 1991
# 4 Addition to Milestones:
4 . Develop comprehensive definition of operating expenses and appropriate use
of appropriations.
Planned completion date: December 1991
5. Develop a mechanism to ensure full capture of direct/ indirect research
project costs.
Planned Completion Date: To be determined after
completion of "4." above
-------
U. S. ENVIRONMENTAL PROTECTION AGENCY ENCLOSURE D
MATERIAL WEAKNESS/CORRECTIVE ACTIONS PAGE 85 OF 97
FISCAL YEAR 1991
6. Integrate laboratory operating expense requirements into the ORD planning
and budgeting process.
Planned Completion Date: June 1991
Revised planned completion date: March 1992
7. Develop techniques for analyzing the application and
achievement of plans against utilization
Planned Completion Date: To be determined after
ocnpletion of "5." above
8. Conduct a follow-up review of laboratory operating expense requirements.
Planned Completion Date: December 1992
Critical Milpg|g in OortBtjtive Action;
A. Completed Actions/Events; A comprehensive analysis was conducted of
identified laboratory requirements against available funding. The results of
this analysis indicate a requirement far in excess of available funding.
Identified needs were used to. establish the FY 1992 operating plans, providing
funding for critical needs. The data was also used in developing budget
justifications and issue papers for the FY 1993 submission to the Agency and OMB.
A process was established for the laboratories to have input into the ORD
planning and budget process to identify and prioritize their needs/ allow for
review by ORD Office Directors and overall prioritization for input into the
budget submission.
-------
U. S. ENVIRONMENTAL PROTECTION AGENCY ENCLOSURE D
MATERIAL WEAKNESS/CORRECTIVE ACTIONS PAGE 86 OF 97
FISCAL YEAR 1991
B. Planned Actions/Events (Short-Tenn - Next 12 Months) ; A workshop on
laboratory budgeting is scheduled for October 1991 to develop strategies to
enhance the process and to identify indirect vs direct costs for better
accounting of needs based on the research program vs administrative overhead.
This workshop will also help to refine a definition of operating expenses and
appropriateness of funding mechanisms for laboratory operating expenses.
The FY 1994 process will begin earlier this year to provide timeliness for
input into the budget submission. Strategies and formats will be developed at
the October workshop and will be refined in later working sessions.
C. Planned Actions/Events (Longer Term) : Corrective Action Milestone 6, a
review of the process and its effectiveness is to be completed in December 1992 .
Validation Process to be Used; A follow-up analysis of ORD laboratory operating
expenses will be conducted to assess progress on reducing the deficiency.
Corrective Action Plan Stat"-**
September 30. 1991. Status Update:
Milestone # 1 - Completed November 1990
Milestone # 2 - Completed Dprrp-mbpr 1990
Milestone # 3 -
(a) Completed April 1991
(b) Workshop on Lab Budgeting scheduled for October
1991 to develop strategies for laboratory budgeting.
Milestone # 4 New Milestone added based on identified
need. Workgroup established to develop and obtain
necessary concurrences on definition of operating
expenses. .
Milestone # 5 - Revised date of March 1992. Changes in the
FY 1993 budget process require an earlier submission of needs
to have inpact on actual budget submission.
Milestone # 6 Follow-up review to be done by December
1992.
-------
U. S. ENVIRONMENTAL PROTECTION AGENCY ENCLOSURE D
MATERIAL WEAKNESS/CORRECTIVE ACTIONS PAGE 87 OF 97
FISCAL YEAR 1991
Title of Material Weakness; Lack of effectiveness and productivity in the
Chemical Testing Program.
Description of Ma'***>v'ial Weakrv^gg and It's Impact on Agency Oty-ations:
Perhaps the most fundamental aspect of the Agency's toxic substances regulatory
effort is the need to obtain accurate and reliable data, particularly scientific
data, on chemical substances so that the Agency can, with confidence, make
appropriate regulatory decisions on their manufacture, distribution, use and
disposal. To the degree that chemical test data do not exist and cannot readily
be obtained, the Agency may be prevented from, or at lease impeded in, taking
appropriate regulatory action. For many existing chemicals and most new
chemicals, such data are often not available and must be generated through
chemical testing activities on the part of industry. Where data must be
produced, EPA must encourage or demand the production of such data. In some
cases, industry will voluntarily perform the necessary testing, but in other
cases EPA must take regulatory action to insure that testing takes place and that
test data are generated and provided to the Agency. Section 4 of TSCA given EPA
the authority to require such testing.
Rulemaking in general, and test rules are no exception, is often a slow and
resource-intensive process. While this may, in part, explain the performance to
date of the GTS chemical testing program, the fact remains that GTS has
promulgated only a few section 4 test rules. As a consequence, only a limited
number of the many thousands of chemicals that could or should be tested have
undergone the testing necessary to yield the test data on which further
regulatory rulemaking decisions must be based.
In response to the acknowledged shortcoming of the chemical testing program
as it has operated 'in the past, GTS has instituted a series of corrective
measures to improve the program. These actions emphasize the purpose of the
program as not simply to promulgate test rules, but rather to encourage testing
of all chemicals for which testing is needed by whatever means are at EPA's
disposal. In particular, the program will: encourage voluntary testing on the
part of industry; enlist greater numbers of chemical industry testing efforts,
through the OECD; and implement multi-chemical rules that will more efficiently
and more rapidly put the industry on notice as to the chemicals that the Agency
has an interest in.
Functional Category in Statistical Sumn^'yy; Program Execution
Appropriation/Program Element;
Appropriations: 6810200 and 681/20108
Program Element: JNL2S
Administrative Activity /Program Activity; Program Activity
Year Identified; 1990
-------
U. S. ENVIRONMENTAL PROTECTION AGENCY ENCLOSURE D
MATERIAL WEAKNESS/CORRECTIVE ACTIONS PAGE 88 OF 97
FISCAL YEAR 1991
Source of Discovery: The material weakness came to light through several
different sources over a period of time. They include the GAO audit of the
program, a planned AICR review, the August 15, 1990, meeting of the Agency's
Senior Council on Management Controls; and general discussions internal to GTS
and OPTS. These developments taken together led OTS management to identify the
chemical testing program as a material weakness.
In June 1991, GAO issued a second report, Toxic Substances: EPA's Chemical
Testing Program Has Not Resolved Safety Concerns (RCED-91-136). This report
mmended that EPA establish and implement criteria and a methodology for
determining when chemicals present risks that would trigger implementation of
TSCA regulatory provisions. GAO also recommended that the Agency implement an
information system to track the status of chemicals being tested and identify
ways to make TSCA test results more readily available to other regulatory
agencies, researchers, and other interested parties.
Original Target Correction Date; September 1992
Targeted Correction Date in M^t Y«?arfs Report: September 1992
Current Target Date; September 1992
Critical Milgston^g in Corrective Action:
A. Completed Actions/Events; In March 1991, OTS developed and ia-qic** proposed
generic test rules for obtaining neurotoxicity data, and developmental and
reproductive toxicity data. Work is almost complete on 1) developing and issuing
a proposed .multi-chemical test rule for glycidols; 2) developing and issuing a
proposed multi-chemical test rule for aryl phosphates; and 3) fully implementing
the process for producing, reviewing, publishing and annually updating the Master
Testing List.
B. Planned Act ions /Events fFY 19921 :
Develop and issue proposed multi-chemical
test rule for aryl phosphates ................... 10/91
Issue final generic test rule for obtaining
neurotoxicity data .............................. 11/91
Issue final generic test rule for obtaining
developmental and reproductive toxicity data. . . . 6/92
Issue final multi-chemical test rule for
glyvifold ........................................ 9/92
Material weakness judged to be corrected ........ 9/92
-------
U. S. ENVIRONMENTAL PROTECTION AGENCY ENCLOSURE D
MATERIAL WEAKNESS/CORRECTIVE ACTIONS PAGE 89 OF 97
FISCAL YEAR 1991
C. Planned Actions/Events fFY 1993 and beyond) : Conduct AICR of revised
Chemical Testing Program 12/92.
Validation Process to be Used: OTS will conduct an AICR to evaluate the newly
implemented process, procedures, rules and other features of revisions to the
chemical testing program. The AICR will determine whether these changes and
improvements are functioning in an optimal manner. OTS will judge the success
of correcting the lack of efficiency and productivity in the program by
evaluating whether appropriate processes are in place which we can reasonably
expect will lead, in time, to the anticipated increase in the amount of chemical
testing that is necessary to support an effective TSCA regulatory program.
Corrective Action Plan
o September 30. 1991. Status Update; We have a delay in issuing the multi-
chemical test rule for glycidols because 1) OGC identified numerous issues during
streamlined review that necessitated substantial redrafting of the package; and
2) CMB's review period covered 90-days rather 'than the 15-30 days as planned.
We received substantial new information and technical and policy issues
associated with the multi-chemical test rule for aryl phosphates and the OMB
review period added two months to the original schedule thereby delaying the
issuance.
-------
U. S. ENVIRONMENTAL PROTECTION AGENCY ENCLOSURE D
MATERIAL WEAKNESS/CORRECTIVE ACTIONS PAGE 90 OF 97
FISCAL YEAR 1991
Title of Material Weakness: R&D Scientific and Technical Equipment
Description of Material Weakness and Its Impact on Agency Operations; A large
portion of ORD's scientific/technical equipment is old, technologically
antiquated, and needs to be replaced. The Agency is in danger of not being able
to carry out its research responsibilities required by Federal statutes. EPA has
no plan for equipment planning, conducting proper forecasting, or planning for
sufficient budgetary .support to reach an acceptable state of scientific equipment
in the next five years.
Functional Category in Statistical Summary; Property and Inventory Management.
Appropriation/Program Element: Environmental Protection Agency - Research and
Development and Superfund Appropriations
Administrative Activity/Program Activity: program Activity
Year Identified; FY 1988
Source of Discovery; In FY 1986, ORD experienced an extreme shortage of Salaries
and Expense funds; therefore, sufficient funds were not available in any one
account to allow for the acquisition of major scientific equipment. However, by
pooling a part of ORD's resources to create a capital equipment escrow, some
items of equipment could be purchased. The Assistant Administrator for ORD
established a Capital Equipment Committee to manage these resources. During this
process, a complete inventory of ORD's scientific equipment was conducted. An
analysis of this inventory identified the majority of ORD's scientific equipment
to be antiquated and technologically obsolete.
Original Target Correction Date; March 30, 1990
Targeted Correction Date in Last Year's Report: September 30, 1994
Current Target Date; September 30, 1994
Reason for Change in Datefs) ; The material weakness is a more complex issue than
initially described in FY 1988. The broadened plan for the revised corrective
actions will be implemented over a five-year period based on availability of
resources.
Milgstongs in Corrective Action;
A. Completed Actions/Events; The inventory of ORD's scientific equipment was
updated in April 1990. Based on the current inventory a five-year plan was
developed to replace equipment over 7 years old and to purchase state-of-the-art
equipment for new research initiatives. A budget initiative for the FY 1993
budget submission was prepared requesting resources for the five-year plan to
upgrade ORD's scientific equipment base.
-------
U. S. ENVIRONMENTAL PROTECTION AGENCY ENCLOSURE D
MATERIAL WEAKNESS/CORRECTIVE ACTIONS PAGE 91 OF 97
FISCAL YEAR 1991
B. Planned Actions/Events (Short-Term - Next 12 Months) : Planned actions for
FY 1992 include recertifying that prior years' replacement needs are still un-
met. The inventory will be updated annually arid we will continue to submit
budget initiatives to request resources to meet the plan to upgrade ORD's
scientific equipment.
C. Planrvpd Actions/Event'^ (Longer Term) ;
1. ORD will update the inventory of scientific equipment annually to
determine un-met needs.
2. Based on emerging research initiatives, we will forecast needs for
new equipment.
3 . A review will be conducted of the equipment replacement program and
revisions made as necessary.
4. Budget initiatives will be prepared to seek prior years' un-met
needs and current needs as identified in the five-year plan.
5. A new five-year plan to cover fiscal years 95 through 99 will be
Budget Implications. If Any; The corrective action plan to upgrade ORD's
scientific and technical equipment is dependent upon resources appropriated
through the fruHgoh process.
Validation Process to be Used; A complete analysis of ORD's equipment inventory
and review of the corrective action plan will be conducted each year over the
life of the five-year plan. Revisions will be made as necessary and incorporated
into the budget initiative prepared for the next years' submission.
Corrective Action Plan Status Updates:
o September 30. 1991 Status Update;
1. A budget initiative was submitted in ORD's FY 1993 budget submission-
requesting additional funds for the equipment upgrade.
-------
U. S. ENVIRONMENTAL PROTECTION AGENCY ENCLOSURE D
MATERIAL WEAKNESS/CORRECTIVE ACTIONS PAGE 92 OF 97
FISCAL YEAR 1991
Title of Material Weakness: Antimicrobial Program
Description of Ma*"^Tial Weaknggs and I^-s Impact on Aciency
A GAO audit identified a material weakness in the program's data integrity
assurance process, system support, and enforcement follow-up. OPP has responded
specifically in Congressional hearings to issues raised by GAO.
Functional Category in Statistical Smnrc«'''vi Program Execution
Appropriation/Program Element; Registration
Administrative Activity/Program Activity; Registration
Ygar Identified; 1990
Source of Discovery; GAO Audit
Original Target Correction Date; 1992
Targeted Correction Date in Fast*. year's Report; 1992
Current Target Date; 1992
Critical Mil<*5fr?rv?s in Corrective Action;
A. Completed Act ions/ Events: In September 1990, EPA signed an •Interagency
Agreement with the Food and Drug Administration (FDA) to test samples of suspect
products used on medical instruments and to test products prior to registration
if the registration data appears questionable.
FDA agreed to conduct efficacy testing for all products bearing sporicidal
claims, except gaseous sterilants. FDA received samples for all products
designated for testing. FDA has completed testing on three products. EPA has
reviewed the data on these products and plans to extend the Interagency Agreement
for an additional year to complete the planned testing.
On January 21, 1991, OPP officially responded to GAO's recommendations.
B. Planned Act ions/ Events (FY 1992) ;
Finalize the strategy for Agency action if
failing data is submitted ....................... 12/91
Develop a comprehensive inspection scheme
to target laboratories testing high volume
disinfectants ................................... 12/91
C. Planned Actions/Events (FY 1993 and beyond) ; Fund proposal » to. conduct
research and development work on the AOAC Sporicidal Test Method. Prepare
-------
U. S. ENVIRONMENTAL PROTECTION AGENCY ENCLOSURE D
MATERIAL WEAKNESS /CORRECTIVE ACTIONS PAGE 93 OF 97
FISCAL YEAR 1991
written guidance for data auditors. Develop an ongoing national disinfectant
strategy.
Validation Process to be Used; Science ASvisory Panel Sub-Panel Review, among
others still to be determined.
Corrective Action Plan Stat"-1*
o September 30. 1991. Status Update; Test Method Research and Development -
A cooperative agreement for statistical support was awarded to Dr. Martin
Hamilton, Montana State University. The agreement for research on the AOAC
sporicidal test is under review within the Grants Office.
Product Testing and Agency Response to Failing Data - The Agency received
failing data on sporicidal claims for two products. The Agency has developed a
•follow-up strategy where OCM will issue a stop sale and civil penalty for every
batch found to fail the screening tests being conducted by FDA. OCM will proceed
with enforcement testing, using the same standards and test procedures required
for the original registration of the product. OCM will issue a stop sale and
civil complaint against the two products concurrent with a public notice/press
release information users of the failure and the enforcement action.
Laboratory Testing Capability - OPP has established its laboratory needs
for antimicrobial product testing and is exploring the availability of facilities
to conduct the various tests used to determine antimicrobial product
effectiveness .
-------
U. S. ENVIRONMENTAL PROTECTION AGENCY ENCLOSURE D
MATERIAL WEAKNESS/CORRECTIVE ACTIONS PAGE 94 OF 97
FISCAL YEAR 1991
Title of Material Weakness: Disposal Program
Description of Material Weakness and Its Impact on Agency Operations: OPP has
a process in place to effectively implement the disposal program and manage the
resources involved. However, the disposal program is subject to the influence
of many factors outside of OPP's control. These outside factors have the
potential to create a material weakness in the program. The full range of these
factors and their potential for impacting the program need to be assessed.
Functional Category in Statistical Summary: Program Execution
Appropriation/Program Element; Disposal
Administrative Activity/Program Activity: Program Activity
Year Identified: 1990
Sriirng nf ni.grrruip'ry; Management Review
Original T^yget Correction Date: 1992
Correction Date in Tast*. VAar/s Report: 1992
Turret Date: 1992
Critical Mil
-------
U. S. ENVIRONMENTAL PROTECTION AGENCY ENCLOSURE D
MATERIAL WEAKNESS /CORRECTIVE ACTIONS PAGE 95 OF 97
FISCAL YEAR 1991
Finalize Report to Congress ..................... 6/92
C. Planned Actions/Events (FY 1993 and beyond) ; Closeout investigation to
verify completed corrective actions.
Validation Process to be Used: Closeout investigation.
Corrective Action Plan Status Updates:
30. 1991. Sfcat"g Update: Phase 1, procedural regulations are in
red border review. OPP is participating in an Inter-agency committee on
hazardous materials listings and is evaluating pesticides listed, and those that
would be listed if the listing criteria were broadened.
-------
U. S. ENVIRONMENTAL PROTECTION AGENCY ENCLOSURE D
MATERIAL WEAKNESS/CORRECTIVE ACTIONS PAGE 96 OF 97
FISCAL YEAR 1991
PART THREE. DESCRIPTION OF CORRECT^ MATERIAL
CATS Tracking Number; 90-1
Title of Material Weakness; Inability to Associate Data on Compliance and
Enforcement Activities From Various Offices' Data Bases.
of Enforcement was seriously hampered in its ability to develop enforcement
actions, set enforcement priorities and target enforcement, respond to crises,
and conduct program oversight because of the inability to associate data on
compliance and enforcement activities from the various program offices data
bases.
Functional Category in Statistical Summary- Program Execution and Systems
Development and Implementation
Appropriation/Program Element; 6820200/AJAH3A
Administrative Activity/Program Activity; Enforcement
Year Identified; FY 1989
Source of Discovery; IG Audit and OE Senior Management
Original Target Correction Date; 12/90
Targeted Correction Date in Last Year/s Rpport; 12/90
Actual Completion Date; 2/21/91
Reason for change in Date; Delays occurred in the initial development of IDEA
because of the inability to quickly resolve with the National Computer Center
(NCC) how direct access to the data systems running in ADABAS would be provided.
As a result, several of the milestone dates were achieved two months later than
originally planned.
Corrective Actions Taken; Validation of the effectiveness of the corrective
action is tied to the use of the capability. All headquarters and regional
offices have been trained on the use of IDEA and currently several offices are
incorporating analysis using IDEA in enforcement screening, enforcement
targeting, and strategic planning. Procedures have been developed requiring that
before individual can use IDEA and gain access to enforcement sensitive data,
authorization must be granted at the DAA or DRA level. Additional procedures are
being developed to provide access to nonsensitive data.
-------
U. S. ENVIRONMENTAL PROTECTION AGENCY ENCLOSURE D
MATERIAL WEAKNESS/CORRECTIVE ACTIONS P.AGE 97 OF 97
FISCAL YEAR 1991
•
Critical Mil«?stongs completion Date
1. Form workgroup to develop linking
mechanism, resource requirements and
schedule for Implementation. 11/89
2. Define linking approach and system
to be linked 11/89
3. Develop resource requirements and
construct a strategy for implementation,
including a project plan (review projected
milestones and revise as appropriate) 3/2/90
4. Modify systems where necessary to
accommodate link ID number. -. . 9/30-90
5. Complete update of systems with link
ID number for current records. 1/91
6. Develop automated ID number assignments
procedures and programs. 2/21/91
7. Final implementation of linkage capability
including ongoing operations and maintenance. 2/21/91
Results of Validation Actions; Validation of the effectiveness of the corrective
action is tied to the use of the capability. All headquarters and regional
offices have been trained on the use of IDEA and currently several offices are
incorporating analysis using IDEA in enforcement screening, enforcement
targeting, and strategic planning. Procedures have been developed requiring that
before individuals can use IDEA and gain access to enforcement sensitive data,
authorization must be granted at the DAA or DRA level. Additional procedures are
being developed to provide access to nonsensitive data. .
-------
U.S ENVIRONMENTAL PROTECTION AGENCY ENCOLSURE E
REVIEW PROCESS PAGE 1 OF 15
FISCAL YEAR 1991
SECTION 4 ASSURANCE AND SUPPORTING DOCUMENTATION
We reviewed our accounting system in use during FY 1991, in
accordance with the Guidelines for Evaluating Financial
Management/Accounting Systems issued by the Office of Management
and Budget (OMB), and based on the principles and standards
developed by the Comptroller General and implemented through OMB
Circular A-127.
We continued our evaluation of all system functions during
this past year as part of an on-going Quality Assurance Program.
The completed evaluations included tests of transactions and
certifications from financial management offices as to the adequacy
of their internal and accounting controls. There is no assurance,
of course, that the system operates at all times in accordance with
the test results. The results of the review described above,
assurance given by Agency officials, and other information provided
indicate that our accounting system, taken as a whole, generally
conforms to the principles and standards developed by the
Comptroller General and implemented through OMB Circular A-127.
Exceptions to overall compliance with applicable principles and
standards are the material nonconformances identified in this
enclosure.
During FY 1991, we continued monitoring, implementing and
enhancing our accounting system, the Integrated Financial
Management System (IFMS). Our implementation is a multi-year
effort, which will result in a modern, efficient, economical and
effective accounting system. As part of this system
implementation, we have identified problems and developed
appropriate action plans to resolve them. We have revised the
implementation dates for different IFMS functions based on our
experiences. We have developed procedures to ensure adequate
testing is performed to meet users' needs prior to implementing the
functions.
At the end of FY 1991, there were five instances of accounting
system material nonconformances that continue to exist. These
nonconformances are accounts receivable; reconciliation to Treasury
reports; property and accounting records reconciliation; general
ledger adjustments; and interfaces between IFMS and other
administrative systems. Further details on these nonconformances,
together with plans and schedules for corrective action are
contained in this enclosure.
-------
U.S ENVIRONMENTAL PROTECTION AGENCY ENCOLSURE E
REVIEW PROCESS PAGE 2 OF 15
FISCAL YEAR 1991
ACCOUNTING SYSTEM COMPONENTS
EPA has one primary accounting system which is the Integrated
Financial Management System (IFMS). Three subsidiary systems
provide substantial accounting information to IFMS. They are
Payroll/Personnel System (EPAYS), Contract Payment System (CPS),
and Automated Document Control Register (AOCR). In addition, four
administrative systems contain accounting data. These systems are
Contract Information System (CIS), Grants Information and Control
System (GICS), Personal Property Accountability System (PPAS), and
Resources Management Information System (RMIS).
-------
U.S ENVIRONMENTAL PROTECTION AGENCY ENCOLSURE E
REVIEW PROCESS PAGE 3 OF 15
FISCAL YEAR 1991
Part 1. Summary of Pending Material Nonconformances
Year
Target for Current
Title (s) of First Correction Target for
nonconformances Reported in FY 1990 Correction Page
Regional accounts receivable recording, documentation, and
collection problems have impacted the accuracy of the general
ledger accounts receivable balances.
1989 1993 1993 4
Comprehensive reconciliation between Treasury reports and IFMS
needs to be performed.
1988 1993 1993 7
Reconciliation with property and accounting records for FY 1989 and
1990 needs to be performed.
1983 1992 1992 9
General ledger accounts adjustments as the result of the
implementation of IFMS need to be accomplished.
1989 1993 1992 11
Opportunities exist for greater interface between the accounting
system and other administrative systems.
1985 1992 1993 13
-------
U.S ENVIRONMENTAL PROTECTION AGENCY ENCOLSURE E
REVIEW PROCESS PAGE 4 OF 15
FISCAL YEAR 1991
Part 2. Description of Non-conformances
Name of System; Integrated Financial Management System
Title of Material Nonconformance; Regional accounts receivable
recording, documentation, and collection problems have impacted the
accuracy of the general ledger accounts receivable balances.
System Type; Core Financial
Functional Category in Statistical Summary; General Ledger Control
Appropriation; All appropriations
Administrative Activity/Program Activity; Administrative
Pace of Corrective Action;
Year Identified; FY 1989
Original Targeted Correction Date; March 1990
Targeted Correction Date in Last Year/s Report; June 1993
Current Target Date; June 1993
Reason for Change in Datefs); Does not apply
Description of Material Nonconformance and Its Impact on Agency
Operations; In FY 1990, we identified several potential unrecorded
accounts receivable in the regional offices. These unrecorded
receivables were the result of program officials not promptly
notifying the servicing finance office of the creation and
disposition of the receivables. Also, inadequate policies and
procedures contributed to the problem. Because of this problem,
the accuracy of the general ledger accounts receivable balances was
questionable.
To correct this deficiency, during FY 1991, we issued new
policies and procedures for accounts receivable. Also, regional
finance offices were required to perform a reconciliation of all
open IFMS receivables. In addition, we created an Agency-wide
Accounts Receivable Task Force (ARTF) that is visiting each region
to identify and resolve problems with accounts receivable. The
ARTF visited four regions in FY 1991. The remaining regions will
be visited in FY 1992 and 1993.
-------
U.S ENVIRONMENTAL PROTECTION AGENCY ENCOLSURE E
REVIEW PROCESS PAGE 5 OF 15
FISCAL YEAR 1991
Source of Discovery of Material Nonconformance; FY 1989
transaction testing, Regional FMFIA Certification, Report of
Assurance from Component System Manager for IFMS, and OIG Audit
Report E1SJF9-05-0274-0100207 Review of Superfund Cost Recovery
Accounts Receivable Establishment and Collection.
Critical Milestones in Corrective Action;
Completion Date
Critical Milestones Original Plan Current Plan
A. Completed actions/events
MILESTONE TITLE
Automated calculation of interest, penalties and
handling. 06/89 03/90 03/90
Demand and Billing Letters.
06/89 03/90 03/90
Issue policy and procedures to track enforcement actions
that result in accounts receivable.
02/90 01/91 11/90
Implement IFMS on-line .write-off of uncollectible
accounts. 06/89 04/91 03/91
First round of on-site verification reviews.
10/90 06/91 07/91
B. Planned actions/events (short term - next 12 months)
Enhance on-line write-off capability.
04/91 03/92
Second round of on-site verification reviews.
06/92 06/92
Provide additional capabilities in the calculation of
interest, penalties, and handling charges.
09/92 09/92
C. Planned actions/events (longer term)
Third round of on-site verification reviews.
06/93 06/93
-------
U.S ENVIRONMENTAL PROTECTION AGENCY ENCOLSURE E
REVIEW PROCESS PAGE 6 OF 15
FISCAL YEAR 1991
Validation Process to be Used; A task force has been created that
will review accounts receivable at each finance office. The task
force visited four regional finance offices in FY 1991.
The Financial Compliance and Quality Assurance Staff will follow-up
on issues raised by the task force during Quality Assurance Reviews
of the regions.
In FY 1991, the OIG conducted a follow-up review of corrective
actions taken since their initial review of accounts receivable.
The OIG concluded that current corrective actions by EPA
appropriately address the issue of accounts receivable.
-------
U.S ENVIRONMENTAL PROTECTION AGENCY ENCOLSURE E
REVIEW PROCESS PAGE 7 OF 15
FISCAL YEAR 1991
Name of System: Integrated Financial Management System
Title of Material Nonconformance; Comprehensive reconciliation
between Treasury reports and IFMS needs to be performed.
System Type; Core Financial
Functional Category in Statistical Summary! Data accuracy,
timeliness, comparability, usefulness
Appropriation; All appropriations
Administrative Activity/Program Activity; Administrative
Pace of Corrective Action;
Year Identified; FY 1988
Original Targeted Correction Date; December 1988
Targeted Correction Date in Last Year/s Report; June 1993
Current Target Date; June 1993
Reason for Change in Date(si; Does not apply
Description of Material Nonconformance and Its Impact on Agency
Operations; During the initial implementation of IFMS, cash
reconciliation reports were not available. Therefore,
reconciliation between the Agency's general ledger and external
Treasury reports could not be accomplished in a timely manner. In
addition, revised procedures for assuring reconciliation of cash
balances were inadequate to address the problem.
During FY 1991, detailed reports needed to perform the cash
reconciliation were produced. Monthly cash reconciliations between
the Agency and Treasury are now being performed.
Source of Discovery of Material Nonconformance; FY 1989 Report of
Assurance from Component System Manager for IFMS.
-------
U.S ENVIRONMENTAL PROTECTION AGENCY ENCOLSURE E
REVIEW PROCESS PAGE 8 OF 15
FISCAL YEAR 1991
Critical Milestones in Corrective Action;
Completion Date
Critical Milestones Original Plan Current Plan Actual
A. Completed actions/events
MILESTONE TITLE
Develop necessary reports to facilitate the Treasury
reconciliation process. 09/89 06/91 06/91
B. Planned actions/events (short term - next 12 months)
None
C. Planned actions/events (longer term)
Perform a comprehensive review of Treasury records and
the Agency's general ledger on 9/30/92 to ensure
reconciliation of balances.
09/89 06/93
Validation Process to be Used; With the availability of detailed
cash reports, the Financial Reports and Analysis Branch (FRAB) has
and will continue to review the monthly cash reconciliations made
by the regional offices. The Financial Compliance and Quality
Assurance Staff (FCQAS) will coordinate with FRAB to identify
regional problems with the cash reconciliation. If required, FCQAS
will review this item as part of their visits to regional financial
management offices.
-------
U.S ENVIRONMENTAL PROTECTION AGENCY ENCOLSURE E
REVIEW PROCESS PAGE 9 OF 15
FISCAL YEAR 1991
Name of System; Integrated Financial Management System/Personal
Property Accountability System
Title of Material Nonconformance; Reconciliation with property and
accounting records for FY 1989 and 1990 needs to be performed.
System .Type; Core Financial Subsidiary System and Personal
Property Accountability System
Functional Category in Statistical Summary; Property
Bureau/Appropriation;' All appropriations
Administrative Activity/Program Activity: Administrative
Pace of Corrective Action;
Year Identified: FY 1983
Original Targeted Correction Date; December 1989
Targeted Correction Date in Last Year's Report; May 1992
Current Target Date; May 1992
Reason for Change in Date(si; Does not apply
Description of Material Nonconformance and Its Impact on Agency
Operations; In the past, property values were recorded in the
Agency's General Ledger accounts based upon the data contained in
the Personal Property Accountability System (PPAS). Procedures for
assuring that all property acquisitions were reflected in the PPAS
have been inadequate. For an interface between the Integrated
Financial Management System (IFMS) and PPAS to operate properly,
the Financial Management Division (FMD) must be assured of the
accuracy of property values maintained in PPAS.
In FY 1991, we initiated revised procedures for capitalization of
property. These procedures require the regional finance offices to
coordinate with the regional property offices to ensure that items
capitalized are in PPAS and the financial data is reconciled.
Further, we have provided items capitalized in FY 1989 and FY 1990
to the system manager for PPAS. The information will be reconciled
with PPAS.
-------
U.S ENVIRONMENTAL PROTECTION AGENCY ENCOLSURE E
REVIEW PROCESS PAGE 10 OF 15
FISCAL YEAR 1991
Source of Discovery of Material Nonconformance: EPA OIG Audit
P5EH7-11-0022-80028 dated October 7, 1987 and GAO Report AFMD 90-
20.
**
Critical Milestones in Corrective Action;
Completion Date
Critical Milestones Original Plan Current Plan
A. Completed actions/events
MILESTONE TITLE
Define requirements to reconcile data between FMS and
PPAS. 03/87 03/87 08/87
Develop a reconciliation process (interim procedure until
new system is implemented).
07/88 07/88 07/88
Implement the reconciliation process (interim procedure
until new system is implemented).
10/88 10/88 12/88
Implement distributed data entry PPAS network and a
national PPAS. 04/88 04/89 06/89
Require comprehensive inventories be conducted in all
accountable areas. 05/89 12/89 05/90
Implement modified reconciliation process that does not
rely totally on PPAS. . 06/91. 06/91 07/91
B. Planned actions/events (short term - next 12 months)
Perform reconciliation based on modified procedures using
FY 1989 and 1990 data. 05/92 05/92
Validation Process to be Used; On a monthly basis, the Financial
Reports and Analysis Branch (FRAB) is reviewing the regional
capitalization reports submitted based on the revised
reconciliation procedures issued. If problems are identified, FRAB
will work with the Financial Compliance and Quality Assurance Staff
to include this item as part of a Quality Assurance Review of a
specific regional financial management office. In addition, we
will request that regional finance offices conduct transaction
testing of property for FY 1992.
-------
U.S ENVIRONMENTAL PROTECTION AGENCY ENCOLSURE E
REVIEW PROCESS PAGE 11 OF 15
FISCAL YEAR 1991
Name of System: Integrated Financial Management System
Title of Material Nonconformance; General ledger account
adjustments as the result of the implementation of IFMS need to be
accomplished.
System Type; Core Financial
Functional Category in Statistical Summary? General Ledger Control
Bureau/Appropriation; All appropriations
Administrative Activity/Program Activity; Administrative
Pace of Corrective Action;
Year Identified; FY 1989
Original Targeted Correction Date; February 1990
Targeted Correction Date in Last Year's Report; February 1992
Current Target Date; October 1992
Reasons for Change in Datefsi; The completion date has been
revised to reflect the extensive work to identify the detailed
corrective actions required.
Description of Mate'rial Nonconformance and Its Impact on Agency
Operations; Although the system has been accurately recording
transactions for FY 1990 and 1991, the validity of certain closing
balances for FY 1989 is questionable. In FY 1989, we converted
our accounting data from our former Financial Management System
(FMS) to IFMS. During this conversion, some transactions were
improperly classified, affecting the closing balances in certain
accounts.
We have identified the differences in the FY 1989 closing balances.
Our next step is to validate and verify the composition of the
differences. Once this task has been completed, we will make the
necessary adjusting entries in IFMS.
-------
U.S ENVIRONMENTAL PROTECTION AGENCY ENCOLSURE E
REVIEW PROCESS PAGE 12 OF 15
FISCAL YEAR 1991
Source of Discovery of Material Nonconformance: FY 1989
transaction testing, Regional FMFIA Certification, and Report of
Assurance from Component System Manager for IFMS.
Critical Milestones in Corrective Action;
Completion Date
Critical Milestones Original Plan Current Plan Actual
A. Completed actions/events
MILESTONE TITLE
Automatically perform month-end and year-end closing and
roll over General Ledger account balances.
01/90 02/92 11/90
Install Enhanced General Ledger edits in IFMS.
03/91 06/91 06/91
B. Planned actions/events (short term - next 12 months)
None
C. Planned actions/events (longer term)
Correct FY 1989 FMS to IFMS conversion errors.
02/92 10/92
Adjust beginning account balances.
02/92 10/92
Adjust and reclassify transactions, as appropriate.
02/92 10/92
Update policies and procedures for recording transactions
in IFMS.
10/90 10/92
Validation Process to be Used; The supporting documentation of the
adjustments will be maintained for review. FCQAS will conduct a
review to ensure adequate documentation has been developed to
support the accuracy of the adjustments.
-------
U.S ENVIRONMENTAL PROTECTION AGENCY ENCOLSURE E
REVIEW PROCESS PAGE 13 OF 15
FISCAL YEAR 1991
Name of System; Integrated Financial Management System
Title of Material Nonconformance; Opportunities exist for greater
interface between the accounting system and other administrative
systems.
System Type; Core Financial
Functional Category in Statistical Summary; Interfaces with
subsidiary/program systems
Bureau/Appropriation; All appropriations.
Administrative Activity/Program Activity: Administrative
Pace of Corrective Action;
Year Identified; FY 1985
Original Targeted Correction Date; June 1990
Targeted Correction Date in Last Year/s Report; September
1993
Current Target Date; September 1993
Reason for Change in Datefsi; Does not apply
Description of Material Nonconformance and Its Impact on Agency
Operations; Data maintained in the accounting system and used by
other key administrative systems could be transferred between the
respective systems more efficiently and effectively. OMB Financial
Management System Objectives require electronic communications
between systems to avoid duplication of data entry. During FY 1991
we continued to work toward developing the necessary electronic
interfaces.
Critical Milestone in Corrective Action;
Completion Date
Critical Milestones Original Plan Current Plan Ar*nai
A. Completed actions/events
MILESTONE TITLE
Install interface (IFMS/GICS).
09/88 06/89 06/89
-------
U.S ENVIRONMENTAL PROTECTION AGENCY ENCOLSURE E
REVIEW PROCESS PAGE 14 OF 15
FISCAL YEAR 1991
Implement a national PPAS.
12/88 06/89 06/89
B. Planned actions/events (short term - next 12 months)
Define requirements for IFMS and PPAS.
01/91 04/92
Detailed Design (IFMS/PPAS).
03/92 03/92
Analyze for further enhancements (IFMS/GICS).
03/92 03/92
C. . Planned actions/events (longer term)
Implementation (IFMS/PPAS).
10/92 10/92
Define requirements (IFMS/GICS).
01/93 01/93
Detailed design (IFMS/GICS).
06/93 06/93
Install new interface (IFMS/GICS).
09/93 09/93
Additional milestones will be added as new systems are developed,
such as the Integrated Contract Management System which will
replace the Contract Information System.
Source of Discovery of Material Nonconformance; This issue was
reconfirmed with the implementation of IFMS in FY 1989 and reported
in the Report of Assurance from Component System Manager for IFMS.
Prior to FY 1989 > EPA had identified this nonconformance as it
related to EPA's Financial Management System which IFMS replaced.
Validation Process to be Used; The Financial Compliance and
Quality Assurance Staff will review this item as part of their work
on IFMS and FMFIA. In addition, we expect that GAO, OIG, and
Superfund auditors to be actively involved with auditing various
portions of IFMS along with other administrative systems.
-------
U.S ENVIRONMENTAL PROTECTION AGENCY ENCOLSURE E
REVIEW PROCESS PAGE 15 OF 15
FISCAL YEAR 1991
Part 3. Material Nonconformances Corrected
Name of System; Integrated Financial Management System
Title of Material Nonconformance; (s) Financial reporting under the
Integrated Financial Management System (IFMS) is incomplete.
System Type; Core Financial
Functional Category in Statistical Summary; Data accuracy
timeliness, comparability, and usefulness
Appropriation; All appropriations
Year Identified; FY 1989
Original Targeted Correction Date; September 1990
Corrective Actions Taken; For the short-term, we relied on ad hoc
reporting capabilities of the former system and developed special
reports. After reviewing the needs of the users, we decided to
develop and implement an ad hoc reporting system called the
Management and Accounting Report System (MARS).
Results of Validation Actions Taken; The Financial Compliance and
Quality Assurance Staff attended training in MARS to ensure that
the system would provide information needed by users. In addition,
we monitored general MARS D-Mail announcements concerning the
issues raised by users. As a last step in our validation, we
reviewed the MARS Hotline Reports for the type of questions and
issues being raised by users. We also contacted users who had
reported errors.
------- |