1 .ed Stu..,--, Environmeriidl Protection Agency Office of the Inspector General November 1984 401 M Street, SW Washington DC 20460 Office of the Inspector General Semiannual Report April 1, 1984 through September 30,1984 Helping the Environmental Protection Dollar Go Further ------- Foreword Last year when I was confirmed by the Senate as the Inspector General of the Environmental Protection Agency. I outlined several goals I intended to achieve. Together with an expanded staff and the cooperation of Agency management and the Congress, I am pleased that we have made significant progress in achieving these goals while becoming a recognized and independent force in the Agency. My first goal was to improve the operation of the Office of Investigations and promote the fullest possible compliance with Federal laws and regulations. To help achieve this goal we installed a new supervisory management team and recruited 70 percent of our total special agent staff this fiscal year. We have adopted new policies and procedures to ensure professional investigative work and have had a major impact on the Agency by investigating sewer rehabilitation, fraud, and bid-rigging schemes. My second goal was to develop a thorough internal audit program. We implemented an internal and management audit program for the first time by devoting about 30 percent of our resources to examining many critical areas which had never been tested in EPA before. In addition, we adopted new audit policies, procedures, and quality reviews to assure that our audits consistently meet high standards. My third goal was to initiate a program to prevent fraud, waste, and mismanagement. Progress in this area has been very visible. We have established an employee awareness program that is explaining our role as an independent financial and operational overseer and encouraging the reporting of wrongdoing to the OIG hotline. This year we participated with the Administrator in creating the Committee on Integrity and Management Improvement to initiate Agency- wide participation in preventing and detecting fraud, waste, and mismanagement. In addition, we aquired the personnel security function and brought it current by reducing the case backlog and improving operating procedures to assure the integrity of EPA employees. Agency concern for a strong and independent Office of Inspector General has been expressed by supporting the addition of severely needed staff. However, travel is the lifeblood of an auditing and investigating force and travel resources have not kept pace with new staffing levels. Without adequate travel funding, many necessary audits and investigations cannot be performed. In recognition of this situation, Agency management is actively working with us to resolve this problem. The work of the Office of Inspector General is being recognized and supported by the Administrator and top Agency management. This is most obvious in the outstanding work the Agency has done to resolve audit reports, especially those over six months old. By resolving audit reports, Agency management has implemented many improvements and recovered significant amounts of funds. We look forward to continue working with a responsive and supportive Agency management staff. John C. Martin Inspector General ------- Contents Executive Summary 1 Profile of Activities and Results 3 Establishment of the OIG in EPA—its Role and Authority 4 Organization and Staffing 4 Purpose and Requirements of the OIG Semiannual Report 6 Section 1—Significant Problems, Abuses and Recommendations 7 Summary of Audit Activities and Results 7 Agency Management 8 Construction Grants 10 Superfund 13 Section 2—Audit Resolution 15 Audit Followup 15 Previously Reported Items—Action Not Completed 16 Section 3—Prosecutive Actions 17 Summary of Investigative Activities 17 Description of Selected Prosecutive Actions 17 Description of Selected Administrative Actions 18 Section 4—Fraud Prevention and Resource Management 19 Review of Proposed Legislation and Regulations 19 Efforts to Prevent Bid Rigging 20 Suspension and Debarment Activities 21 Committee on Integrity and Management Improvement 22 Personnel Security Program 22 Employee and Public Awareness Activities 23 Hotline Activities 23 Cooperative Efforts 23 Delegations of Authority 24 Travel Fund Limitation 24 Training 25 Section 5—Delinquent Debts 25 Appendix—List of Audit Reports Issued 26 ------- Executive Summary Section 1—Significant Problems, Abuses and Recommendations 1. EPA Regional Offices Awarded Grants To States That Did Not Meet Financial Requirements Three EPA Regional Offices awarded about $38 million of Clean Water Act grants to six State agencies without assurance that grant financial requirements were met. In addition, the six agencies did not accomplish a significant portion of their grant objectives (page 8). 2. EPA Unable to Resolve Delinquent Debts Promptly EPA’s Claims Office did not always resolve delinquent debts promptly, and many records were inaccurate and insufficient for effective management of the debt resolution function (page 8). 3. Regional Laboratory Did Not Control Resources The EPA Regional Office in Denver, Colorado, did not exercise adequate controls over its Environmental Services Division )ESD) laboratory to properly protect or use scientific resources, valuable materials, and storage of toxic substances (page 9). 4. Better Management Is Necessary To Determine Whether Facilities Are Needed And Properly Sized Ineffective project monitoring and incomplete or inaccurate project information resulted in wastewater treatment plants in Hawaii that are oversized and underutilized (page 9) 5. Disregard For Standards Of Conduct Employees at EPA’s Research Triangle Park (RTP), North Carolina. disregarded the Agency’s Standards of Conduct by attending parties and luncheons given by contractors, promoting commercial sales to other employees, and soliciting gifts from contractors (page 10), 6. Grantee Claims $13.7 Million For Treatment Plant That Wasn’t Fully Operational The City and County of Honolulu, Hawaii, claimed $13.7 million for the Honouliuli Wastewater Disposal System that had several component deficiencies which prevented its full operation and use at the time of audit (page 11). 7. EPA Should Not Fund $16.5 Million Project Until Deficiencies Are Corrected Lee County, Florida, invested $16.5 million into wastewater facilities that do not conform with approved plans and specifications (page 11). 8. Grantee Neglects Wastewater Treatment System The East Leflore County Water and Sewer District, Greenwood, Missssippi, had three of five commissioner positions vacant and seemed unable to adequately oversee operations and provide managerial controls. In addition, there was a very low level of utilization of the system in two specific areas of the district at the time of audit (page 11). 9. Grantee Bills EPA For Elaborate And Unnecessary Administrative Facilities At Treatment Plant The City of Austin, Texas, claimed $234,000 for an elaborate oversized lobby and an unnecessary civic room in the administrative building of a wastewater treatment plant. In addition, $617,853 of other costs claimed were questioned because the costs were duplicate claims, unsupported, or otherwise specifically ineligible (page 12). 10. Grantee Claims Over $700,000 Of Ineligible Costs The Lower Lackawanna Valley, Pennsylvania, Sanitary Authority claimed ineligible costs totailrng $708,000 for unallowable equipment rentals and by awarding a contract prior to obtaining the necessary right-of-way (page 12). 11. Grantee Overstates Claims By $646,000 The Metropolitan Sanitary District of Greater Chicago claimed $646,000 of engineering costs which were not supported by accounting records (page 13). 12. Over $6 Million Identified for Recovery In Cleanup At Love Canal Over $6 million was identified for recovery from liable parties under the Comprehensive Environmental Response, Compensation, and Liability Act of 1980 for the costs of cleaning up hazardous substances at Love Canal, New York (page 13). 13. Improvements Needed To Safeguard Superfund Operational and accounting deficiencies in EPA’s Superfund immediate removal action program increased the program’s susceptibility for incurring unnecessary costs and premature depletion of the Trust Fund (page 14). 14. State Agency Claims Ineligible Expenses in Excess of $1 Million The State of Minnesota claimed costs totalling $1,084,558 related to the Reilly Tar hazardous waste site that were not allowable under the Compre- hensive Environmental Response, Compensation, and Liability Act of 1980 (CERCLA) (page 14). ------- Section 2— Audit Resolution Agency management has devoted increased attention to audit follow-up by: stressing the need for timely resolution of audits at meetings with Agency officials, including the status of unresolved audits in the strategic planning and management system, and by issuing an EPA directive to assist managers in using audits as a management tool. This increased effort has successfully stimulated the resolution of audit reports, especially those over six months old, reversing a previous trend. Agency officials sustained $47.1 million of questioned costs and recovered $24.2 million from audit resolutions of audits from current and previous periods (page 15). Section 3— Prosecutive Actions During this period we concentrated much of our effort on closing outstanding investigation cases. We closed 249 cases to reduce our inventory by 11 percent. We also increased our emphasis on long-term major impact initiatives this period that will yield significant results in future periods. A new supervisory management team initiated the use of new techniques to identify indicators of possible wrongdoing. The OlG has performed investigations resulting in the prosecution of one contractor for false billings on an EPA contract, and of another contractor for misrepresentation as a minority business enterprise to illegally obtain subcontracts on EPA projects. In addition, investigations of employee and contractor misconduct resulted in 25 administrative disciplinary actions (page 17>. Section 4— Fraud Prevention and Resource Management Review of Proposed Legislation and Regulations Prior to this semiannual reporting period, the Office of Inspector General was only provided the opportunity to review and to make recommendations on a limited number of selected items. With the cooperation of Agency management, in April 1984 the OlG was afforded the opportunity to review, comment and make recommendations on all legislative and regulatory items within the Agency. As a result, the number of items reviewed by the OIG has increased from 34 last semiannual reporting period to 193 this period (page 19). Actions to Prevent Bid Rigging During audit and investigative reviews conducted in one region over the past three years numerous anti-trust violations were identified and an environment where bid rigging may be a “way of life” for many contractors. We have initiated an anti bid rigging program and suggested several ways the Agency can take more aggressive steps in attacking the bid-rigging problem. These are training of EPA and State officers, requiring certifications of noncollusive bidding, and requiring the retention and analysis of bid records (page 20). Committee on Integrity and Management Improvement With the participation of Agency management, the Committee has undertaken projects in three significant areas: quality assurance/quality control, Agency permits and employee awareness. The quality assurance/quality control group is reviewing ways to strengthen Agency procedures to minimize the possibility of fraudulent or unreliable research results. The permits group is addressing the various permit issuance processes within EPA to determine if generic permits might offer improvements in program effectiveness. A standing committee was established on Employee Awareness in an effort to increase employee participation in the Agency’s management improvement efforts (page 22). Personnel Security Program Makes Rapid Progress The Personnel Security Program has made significant improvements and progress in reducing the case backlog and ensuring that employment of personnel complies with Agency regulations and national security requirements. During this reporting period the review of personnel investigations identified integrity violations resulting in the removal of three employees, the reprimand of one employee, and the repayment of a defaulted student loan by another (page 22). Hotline Activities The OIG hotline center received 75 new complaints (a 50 percent increase over the last semiannual reporting period>, and processed and closed 75 cases during this reporting period. Of the 75 cases closed, 62 were not valid and did not require action while 13 cases resulted in environmental or administrative corrective action (page 23). Travel Fund Limitation Impedes Audit and Investigative Operations Most of our audits and investigations are conducted at contractor or grantee sites, not at EPA facilities. It is mandatory that our auditors and investigators travel to perform their work. White staffing levels have increased, no additional travel resources have been provided resulting in a severe shortage. Because of this shortage we were forced to assign work based on location rather than priority in fiscal 1984. We are working with Agency management to solve this problem, but if it is not resolved soon, we will be unable to perform much needed work and fraud, waste, and abuse may go undetected (page 24) 2 ------- Profile of Activities and Results Audit Operations Amount Total April 1, 1984 Fiscal 1984 to September 30, 1984 • Questioned Costs* $64 Million $1 13 Million (expenditures which are not allowable) • Set-A side Costs* $134 Million $242 Million (expenditures which are insufficiently supported to determine their allowability) • Sustained Costs for Recovery and Savings $46.7 Million $63.1 Million (costs which EPA management agrees are ineligible and is committed to recover or offset against future payments) • Cost Efficiencies or Deobligations $.4 Million 51 .8 Million (funds made available by implementing recommendations in OlG internal and management audits) • Recoveries from Audit Resolutions of Current and Prior $24.2 Milton $37.4 Million Periods (cash collections or offsets to future grants) • EPA Audits Performed by the 010 140 363 • EPA Audits Performed by Another Federal Agency, 648 1.268 State Auditors, or Independent Public Accountants • Audit Reports Resolved 504 1,382 (agreement by Agency officials to take satisfactory corrective action) Investigative Operations • Fines and Recoveries $91,227 $629,860 • Investigations Opened 212 261 • Investigations Closed 249 338 • Investigations Pending (9,30184) 278 - • Indictments/Convictions of Persons or Firms 9 25 • Administrative Actions Taken Against EPA Employees 25 39 Fraud Detection and Prevention Operations • Debarments, Suspensions, Voluntary Exclusions, and 22 61 Settlement Agreements (actions to deny persons or firms from participating in EPA programs or operations because of misconduct or poor performance) • Hotline Complaints Received 75 126 • Hotline Complaints Processed and Closed 75 141 • Proposed Legislative Items Reviewed 97 103 • Proposed Regulatory Items Reviewed 96 124 Questioned and set-aside costs are subject to reduction pending further review in the audit resolution process. ------- The Inspector General Act of 1978 (P.L. 95-452) created the Office of Inspector General to consolidate existing investigative and audit resources in independent organizations headed by Inspectors General. EPA established its Office of Inspector General (OIG) in January 1980. As an Agency with a massive public works budget. EPA is vulnerable to various kinds of financial abuses. The OIG’s role is to review EPA’s financial transactions, program and administrative activities, investigate allegations or evidence of possible criminal and civil violations, and promote economic, efficient, and effective operations within the Agency. The OIG is also responsible for reviewing EPA regulations and legislation. The EPA Inspector General reports directly to the Administrator and the Congress and has the authority to: • Initiate and carry out independent and objective audits and investigations, • Issue subpoenas fr evidence and information, • Obtain access to any materials in the Agency, • Report serious or flagrant problems to Congress, • Select and appoint OIG employees, and The Office of Inspector General functions through three major offices, each headed by an Assistant Inspector General: Office of Audit. Office of Investigation, and Office of Management and Technical Assessment. Nationally, there are six Divisional Inspectors General for Audit and five Divisional Inspectors General for Investigations who direct staffs of auditors and investigators and who report to the appropriate Assistant Inspector General in Headquarters. Field Total • Enter into contracts. The Inspector General is appointed by, and can be removed only by. the President. This independence protects the OIG from interference and allows it to function as the Agency’s fiscal and operational watchdog. Establishment of Organization the OIG in EPA—Its and Staffing Role and Authority Staffing Distribution—Fiscal 84 Ceiling Office Headquarters Inspector General 4 - 4 Audit 26 133 159 Investigations 8 44 52 Management and Technical Assessment 21 - 21 Total 59 177 236 ------- Office of Inspector General - Who’s Who Headquarters Ernest E. Bradley Ill Assistant Inspector General Kenneth A. Konz Deputy James 0. Rauch Director Anna M. Virbick Director Roscoe R. Davis Assistant Inspector General John C. Jones Director Edwin N. Canady Director Divisional Inspectors General Region 4, 6 b 7 Leslie M. Bule, Audit James F. Johnson, Investigation (Acting) Boston Nsw York Region 1 & 2 Sanford Wolfe, Audit Robert M. Bymes, Investigation Region 3 Paul R. Gandolfo, Audit Keith G. Logan, Investigations Headquarters Steven A. McNamara, Internal Audit John C. Martin Donald E. Kirkendall John E. Barden Assistant Inspector General Region 5 & 7 (Investigation) Anthony C. Carrollo, Audit Deirdre M. Tanaka. Investigations RegIon 7 (Audit). 8, 9, 10 Truman A. Beeler, Audit Jonathan P. Sweeney, Investigation ------- Purpose and Requirements of the Office of Inspector General Semiannual Report The Inspector General Act of 1978 (P.L. 95-452 requires the Inspector General to keep the Administrator and Congress fully and currently informed about problems and deficiencies in the Agency’s operations and the necessity for and progress of corrective action. The Act further specifies that semiannual reports will be provided to the Administrator by each April 30, and October 31. and io Congress 30 days later. Source The Administrator may transmit comments to Congress along with the report, but may not change any part of the report. The specific reporting requirements prescribed in the Inspector General Act of 1978 are listed below. Also, included are additional requirements resulting from Senate Report No. 96-829 on the Supplemental Appropriations and Rescission Act of 1980 (P.L. 96-304 Section INSPECTOR GENERAL ACT Section 4(aX2) - Review of Legislation and Regulations Section 5(aXl) - Significant Problems, Abuses, and Deficiencies Section 5(a)(2) - Recommendations with Respect to Significant Problems, Abuses and Deficiencies Section 5(a)(3) - Prior Significant Recommendations Not Yet Implemented Section 5(a)(4 - Matters Referred to Prosecutive Authorities Section 5(a) 5) and 6 b)f ) - Summary of Instances Where Information was Refused Section 5(a)(6) - Listing of Audit Reports SENATE REPORT NO. 96-829 Senate Report Page 11, Resolution of Audits Senate Report Page 12, Delinquent Debts 4 2 3 * Appendix 2 5 There were no instances where information or assistance requested by the Inspector General was refused during this reporting period. Accordingly, we have nothing to report concerning sections 5(a)(5) and 6(b)(2) of the Inspector General Act of 1978. 6 ------- Section 1 Significant Problems, Abuses and Recommendations As required by section 5(a)(1) and (2) of the Inspector General Act of 1978, this section identifies significant problems, abuses, and deficiencies relating to the Agency’s programs and operations along with recommendations for the current period. The findings described in this section resulted from audits performed or supervised by the Office of Audit and reviews conducted by the the Office of Investigations. Because these represent some of our most significant findings, they should not be considered representative of the overall adequacy of EPA management. This section is divided into four areas: Summary of Audit Activity and Results; Agency Management; Construction Grants; and Superfund. Summary of Audit Activities and Results Questioned and Set Aside Costs by Type of Audit ‘140 -120 -100 ‘80 -60 40 -20 0 Construotion Set Aside Costs Questioned Costs I Other Grants and Contracts Distribution of Audit Reports Issued by Source Distribution of Audit Reports Issued by Type State Auditor 39 Reports Total Audits - 788 Superfund Internal and 10 F aports 1.3% Superfund Independant Public Accountant 3.7% 188 Reports 7 ------- Agency Management The Inspector General Act requires the O/G to initiate reviews and other activities to promote economy and efficiency and to detect and prevent fraud, waste, and mismanagement in EPA pro grams and operations. Internal and management audits are conducted to accomplish these objectives largely by evaluating the economy, efficiency, and effectiveness of operations. The following are the most significant internal and management audit findings and recommendations. EPA Regional Offices Awarded Grants to States That Did Not Meet Financial Requirements Problem Three EPA Regional Offices awarded about $38 million of Clean Water Act grants to six State agencies without assurance that grant financial requirements were met. In addition, the six agencies did not accomplish a significant portion of their grant objectives. We Found That EPA awards grants under the Clean Water Act to control water pollution and administer functions delegated to the States under the construction grants program. To quality for a grant, the Act and its regulations require a state to contribute a portion of its non-Federal funds at least equal to the amount that it spent in specified base years (level of effort). Six of the nine State Agencies receiving about $38 million in grant awards between fiscal 1981 and fiscal 1983 did not provide sufficient State matching funds to earn these grants. This occurred because policies and procedures in Regions 3, 5, and 9 did not have the necessary controls to ensure an effective system for awarding grants. Deficiencies included: • Using incorrect and unsupportable base year amounts. • Improperly comparing planned and actual expenditures to the base year amounts. • Performing limited or no verification of claimed costs. • Awarding grants without the necessary approval for deviations. In addition, the regions did not ensure the States accomplishment of grant award objectives. During the period reviewed, the state agencies only accomplished 56 percent of the measurable tasks reviewed. The degree of accomplishment varied significantly from State to State and from oblective to objective. For example, California issued only 25 percent of its planned water pollution control permits while Illinois accomplished 81 percent of its plan in fiscal 1983. Although the regional offices knew that the State agencies were not meeting grant requirements, they did not institute sanctions to ensure compliance because they preferred to encourage State agency performance through cooperation and persuasion. We Recommended That The Regional Administrators of Regions 3. 5. and 9: • Institute the necessary controls to ensure that financial requirements are met, including a limited financial review of costs claimed; • Recover funds for grants awarded improperly; and • Take action to ensure that State agencies accomplish the work outputs for which the grants were awarded. What Action Was Taken Final audit reports were issued to the Regional Administrators by September 28, 1984. The Regions generally agreed that their procedures for awarding grants and monitoring work outputs need strengthening but their responses to our recommendations to recover funds differed widely. A draft consolidated report summarizing all findings including those from Region 2 whose report was in process at the close of the reporting period, will be issued to the Assistant Administrator for Water and the Assistant Administrator for Administration during the next semiannual reporting period. EPA Unable to Resolve Delinquent Debts Promptly Problem EPA’s Claims Office did not always resolve delinquent debts promptly, and many records were inaccurate and insufficient for effective management of the debt resolution function. Background Delinquent debts are referred to the Claims Office to (1) compromise (partially collect), (2) suspend (postpone) collection action, (3) terminate (write off) the debt, or (4( forward to the Department of Justice for resolution or litigation. The Agency’s accounting records showed that 108 debts amounting to $2.1 million had been referred to the Claims Office as of January 31, 1984 but remained unresolved. Over the past several years, the President and Congress have emphasized that Federal agencies should promptly collect delinquent debts, a sound financial practice. We Found That The Agency’s Claims Office has not always taken prompt action to resolve delinquent debts and many remained unresolved for extended periods. These delays not only damage potential debt collection, but also distort the Agency’s accounting records. Additionally, lack of timely action on debts gives the wrong impression to the public and debtors that the Agency is not concerned with aggressively collecting or otherwise resolving these debts. The Office of General Council (OGC( had not established criteria for taking timely action on debts other than the 6-year time frame allowed under the statute of l:mitations for litigating debts. Senior officials from OGC stated that the Claims Office’s ability to resolve debts promptly has been hindered by competing priorities and limited staff ------- resources. However, this should not relieve the Agency from aggressively pursuing delinquent debts. As of January 31, 1984, 108 debts amounting to $2.1 million has not been resolved, Our review of 36 of these debts disclosed that they had been in the Claims Office for an average of 15 months. We Recommended That The Deputy General Counsel: • Evaluate the Claims Offices workload and priorities and establish procedures to ensure that debt referrals are effectively processed; • Establish a timeliness standard of six months for making final decisions on debt referrals and incorporate such standards in employees’ performance agreements; • Initiate efforts to increase coordination with the Financial Management Division; and • Implement additional controls to ensure better management of debt referrals. What Action Was Taken The Deputy General Counsel in response to the draft report generally agreed with our recommendations stating that actions had been or would be taken to address problems identified during our review. Although our recommendations were focused on the C/aims Office debt responsibilities, senior OGC officials believed that they may also be applicable to improving the management of other Claims Office activities. The audit report was issued to the Deputy General Counsel on August 17, 1984. The formal response to our report is due by November 16, 1984. Regional Laboratory Did Not Control Resources Problem The EPA Regional Office in Denver, Colorado, did not exercise adequate controls over its Environmental Services Division (ESD) laboratory to properly protect or use scientific resources, valuable materials, and storage of toxic substances. We Found That The inadequacy of controls at every level over the Denver Region laboratory compromised its efficient and effective use of resources and the safeguarding of materials. As a result the laboratory could lose its certification under the Safe Drinking Water Act. Specific deficiencies found at the laboratory nuluded: • Some work was performed that did not benefit the regional program and analysis continued long after the need for data was satisfied; • Samples were taken that were unneeded, unwanted, and unused by the regional program offices; • A study was jeopardized by using untrained staff to take samples and not coordinating study requirements with the responsible program division; • The management information system could not identify workload or use of resources; and • Procedures were inadequate to control employees time, precious metals or storage of toxic substances. We Recommended That The Denver Regional Office take immediate actions to control the functions and operations of the Environmental Services Division laboratory by: • Establishing mission statements for the Environmental Services Division and its laboratory giving first priority to Regional program needs; • Installing and maintaining a time distribution system to record hours by project; • Coordinating workload witn regional program divisions to ensure that overall regional program goals and priorities are achieved; • Instituting a system in the laboratory to accumulate and report accurate information on workload accomplishments and resources used; and • Complying with prescribed laboratory procedures for timekeeping, controls over precious metals and alcohol, and storage of toxic substances. What Action Was Taken In responding to our draft report, the Region agreed with most of the recommendations and has initiated corrective actions. The audit report was issued to the Regional Administrator, Region 8, on September 18, 1984. A formal response to the audit report is due by December 18, 1984. Better Management is Necessary to Determine Whether Facilities are Needed and Property Sized Problem Ineffective project monitoring and incomplete or inaccurate project information resulted in wastewater treatment plants in Hawaii that are oversized and underutilized. We Found That Wastewater treatment facilities, constructeed with EPA funds in Hawaii, often operated below planned capacity. All nine EPA funded plants constructed in Hawaii which were in operation over a year as of June 1982, operated below planned capacity. Five of these plants operated at less than half of planned capacity. This significant underutilization indicates that it may not have been necessary to spend the full $86.5 million on these facilities to obtain the same pollution control results. The underutilization occurred partially because of poor internal controls by program management. Program files were often missing data supporting decisions for grants and the applicants ability to fulfill grant requirements. Also, the systems for project managers to monitor grant progress did not provide timely or complete information. We Recommended That Region 9 strengthen internal controls during the grant application and award process by (1) improving documentaton and review procedures including the need for projects, the cost effectiveness of projects, the grantees’ ability to perform, and previous experiences with grantees; and (2) by developing a checklist of procedures for project officers to use in monitoring grant program. What Action Was Taken In response to our draft audit report, Region 9 generally agreed with the need to implement our recommendations. The Region acknowledges that unused capacity exists but believes that the design capacities of the plants were determined according to the best population and economic growth estimates available. The Region indicated that their formal response will detail plans for implementation of our recommendations. The audit report was issued to the Regional Administrator, Region 9, on April 25, 1984. A formal response was due on August25, 1984. Asof September 30, 1984, we have not received a response. 9 ------- Disregard for Standards of Conduct Problem Employees at EPA’s Research Triangle Park (RTP), North Carolina, disregarded the Agency’s Standards of Conduct by attending parties and luncheons given by contractors, promoting commercial sales to other employees, and soliciting gifts from contractors. We Found That Based on complaints to the DIG Hotline and directly to the OlG ’s Office of Investigations and on information reported in news articles, the Office of Investigations conducted a series of inquiries at Research Triangle Park, Norm Carolina, concerning employee compliance with EPA’s Standards of Conduct pursuant to the Code of Federal Regulations. As we interviewed RTP employees and contractor personnel concerning violations of Standards of Conduct, they named other individuals and questioned the propriety of their conduct Thirty RTP employees attended parties or accepted meals and entertainment from one or more contractors, principally Northrop Services, Inc., on a continuing basis from the mid-i 970’s through 1983. For example, a number of employees attended a “victory celebration” cocktail party sponsored by Northrop after it was awarded an EPA contract. EPA employees solicited promotional gifts from various airlines to be given away as door prizes at the RTP employee Christmas party. There was a widespread practice to solicit retail sales for such items as cosmetics and candy on EPA premises during duty hours. No single cause for disregarding the Standards o f Conduct by employees was identified. RTP has ii independent components reporting to Washington. Individual interpretation of EPA policy by the managers of each component has apparently caused conflict of interest regulations to be ignored or liberally construed. The most obvious problem is the appearance of conflict of interest created by the degree of association by RIP personnel with contractors. Employees at various times have worked for one or more contractors, or have children, spouses, and friends working for them, In these instances, it is difficult to separate professional and personal relationships. We Recommended That The Deputy Administrator reissue the EPA’s Standards of Conduct regulations to RTP employees and have the Office of Inspector General and General Counsel brief all RTP employees to ensure that they understand the Standards of Conduct. These briefings should include the following prohibited items: • Accepting meals, entertainment, and party invitations from EPA contractors; • Soliciting or accepting gifts from firms doing business with the Government; • Selling merchandise by employees on EPA premises; and, • Failing to obtain approval of requests for outside employment from Deputy Counselors. In addition, we recommended that the Deputy Administrator have the Office of Inspector General, Office of General Counsel, and Contract Management Staff brief contractors on Agency policy and Federal acquisition regulations. What Action Was Taken A management implications report was issued to the Deputy Administrator on August 3, 1984. In his response to the report, the Deputy Administrator accepted all of our recommendations and asked the Assistant Administrators for Air and Radiation, Research and Development and Administration and Resources Management to work with the Office of Inspector General and the General Counsel in carrying out the recommendations. Standards of Conduct briefings have been scheduled for early in fiscal 1985. Construction Grants EPA’s wastewater treatment works construction grants program is the largest single program the Agency administers. Under the provisions of P.L. 92-500, as amended, the Agency is authorized to make grants covering up to 75 or 85 percent of the eligible costs of constructing wastewater treatment facilities. Through August 1984, $1.3 billion was obligated on 1,618 construction project awards this fiscal year. The construction grants program represents $2.4 billion or 69 percent of EPA’s total fiscal 1984 budget. As of August 1984, EPA had 6,267 active construction grants representing $17.9 billion of Federal obligations. ------- Grantee Claims $13.7 Million for Treatment Plant That Wasn’t Fully Operational Problem The City and County of Honolulu, Hawaii, claimed $13.7 million for the Honouliuli Wastewater Disposal System that had several component deficiencies which prevented its full operation and use at the time of audit. We Found That EPA awarded three grants to the City and County of Honolulu, Hawaii, to construct the headworks and effluent chambers to the Honouliuli treatment plant and two interceptor sewers. At the time of audit, information available disclosed that the treatment plant would operate at only 50 percent of its design capacity because not all sewer areas had been connected to the plant. In addition, neither interceptor was fully operational. All claimed costs not recommended for recovery ($9.6 million Federal share) were referred to Region 9 for determination of eligibility. Included in the grantee’s claim under one of the grants was $609,935 (Federal share) of ineligible costs used for (1) idle chlorination and effluent screening facilities which, if operational, would not be used in accordance with the grant’s original intent, and (2) unallowable administrative and technical service costs. We Recommended That The Regional Administrator: • Disallow and recover the ineligible costs claimed, • Review the balance of costs for eligibility, and • Not close the grant until a written technical confirmation that the facilities are fully operational is received. What Action Was Taken The audit report was issued to the Regional Administrator, Region 9, on July 12, 1984. A response to the audit report is due on October 10, 1984. EPA Should Not Fund $16.5 Million Project Until Deficiencies Are Corrected Problem Lee County, Florida, invested $16.5 million into wastewater facilities that do not conform with approved plans and specifications. We Found That An EPA grant was awarded for construction of pumping stations, interceptors, and pressure lines to transmit wastewater to an existing treatment plant. The consulting engineer issued a qualified certification of completion of construction. However, the certification was revoked when at the final inspection of the project, despite repeated requests by the grantee and the consulting engineer for correction of performance deficiencies, the contractor did not correct the problems. EPA should not fund $15 million of project costs until the project conforms with approved plans and specifications. In addition, $1 .5 million of costs claimed by the grantee were unsupported, used for items outside the scope of the project, claimed but not paid by the grantee, generated by redesign and the grantee’s delay in obtaining easements, and for other unallowable construction and engineering fees. We Recommended That • EPA disallow and recover the Federal share of $1.5 million of questioned costs; • EPA not participate in the $15 million balance unless the facility conforms with approved plans and specifications; and • EPA review the size of the interceptors to determine if they were improperly designed, and if so reduce funding as necessary. What Action Was Taken In response to the draft audit report, the grantee did not concur with the costs questioned and believes that the audit report cannot be resolved until al/lawsuits are settled. The audit report was issued to the Chief, Facilities Construction Branch, Region 4, on September 4, 1984. A response to the report is due by February 28, 1985. Grantee Neglects Wastewater Treatment System Problem The East Leflore County Water and Sewer District, Greenwood, Mississippi, had three of five commissioner positions vacant and seemed unable to adequately oversee operations and provide managerial controls. In addition, there was a very low level of utilization of the system in two specific areas of the district at the time of audit. We Found That The grantee was in violation of the grant terms which required it to possess an organization with adequate managerial capability to administer the grant and operate the facility. The County Board of Supervisors originally appointed five commissioners when the district was established to manage the operations. However, seven years later, three of the five commissioner positions were vacant. In addition, the district’s administrator, who was overseeing the daily operations, had resigned. One commissioner position was vacant in excess of a year, two were vacant for at least 10 months, and the administrator position was vacant for at least 4 months. With only two commissioners and no administrator, the grantee is in violation of the terms of the grant, which requires the grantee to possess an organization with adequate managerial capacity to operate the facility over its expected life. An engineering evaluation of the system found that about 80 percent of the residences in two areas were not connected to the system. In addition, maintenance was inadequate, metering equipment was not operational, and the construction at one station needed to be justified. Therefore, costs totalling $450,400 were set aside pending corrective action. We Recommended That • EPA and the State require the grantee to fill the vacancies for commissioners and administrator. • EPA require the Federal share, $337,800, related to the engineering problem be returned unless corrective action was made within 90 days. AUDIT PROFILE Audited Costs I diestioned & Set Aside Costs $ MILLIONS p 2 4 8 10 12 14 16 AUDIT PROFILE Audited Costs I Questioned & Set Aside Costs $ MILLIONS 0 4 8 12 16 21 AUDIT PROFILE Audited Costs IOuestloned & Set Aside Costs $ MILLIONS 0.0 0.4 08 1.2 1.6 .2.0 11 ------- What Action Was Taken A copy of the draft report was provided to the grantee for review and comment on January 16, 1984. The grantee did not reply, nor did it request a time extension. Therefore, we recommended that EPA require the grantee to return the Federal share related to the above problems. EPA and State officials are working with the grantee in an attempt to resolve all problems. The State issued an administrative order on August 29, 1984, which required the grantee to establish a plan to connect 100 percent of the unsewered residences or businesses by February 22 1985. The audit report was issued to the Chief, Facilities Construction Branch, Region 4, on April 10, 1984. A response is due by October 10, 1984. Grantee Bills EPA for Elaborate and Unnecessary Administrative Facilities at Treatment Plant Problem The City of Austin, Texas, claimed $234,000 for an elaborate oversized lobby and an unnecessary civic room in the administrative building of a wastewater treatment plant. In addition, $617,853 of other costs claimed were questioned because the costs were duplicate claims, unsupported, or otherwise specifically ineligible. We Found That EPA awarded a $31.2 million construction grant to the City of Austin, Texas, for the Walnut Creek wastewater treatment plant. An engineering evaluation of the aesthetic features and landscaping of the administration building identified excessive space and elaborate design and materials that were paid for as part of the treatment facility grant. This excessive space and elaborate design included a 1,200-square-foot lobby with full-length glass windows, native stone trim, and a sunken sitting area with a contemporary design fountain. In addition, the administration building contained a 1,200-square-foot civic meeting room. The audit report questioned $78,000, one-half the cost of the lobby, and $156,000 for the entire meeting room because the expenditure of grant funds for such purposes was unnecessary and not in the best interest of EPA or the grantee to abate water pollution. The other questioned costs primarily consisted of $237,000 for claiming a duplicate reimbursement, $103,000 for unsupported indirect costs, $50,000 for a retainer fee which is specifically ineligible, and $227,000 in other ineligible engineering fees. We Recommended That EPA not fund the Federal share (55 percent) of $851,853 questioned costs. What Action Was Taken The audit report was issued to the Assistant Regional Administrator, Region 6, on April 2 1984. The City of Austin responded to the audit report by registering a formal dispute of questioned costs on July 7, 1984. Region 6 and the Office of Inspector General are formulating the position EPA will take relative to all disputed items. Our primary concern will be to insure that elaborate and unnecessary facilities are not funded through the EPA grant. Grantee Claimed Over $700,000 of Ineligible Costs AUDIT PROFILE Costs I ] Questioned & Set Aside Costs S MILLIONS 0 2 4 6 8 10 12 Problem The Lower Lackawanna Valley, Pennsylvania, Sanitary Authority claimed ineligible costs totalling $708,000 for unallowable equipment rentals and by awarding a contract prior to obtaining the necessary right-of-way. We Found That The grantee awarded a contract to install manholes prior to obtaining the necessary right-of-way. By the time right-of-way were obtained, the contractor lost a subcontractor and could not supply manholes at the low bid price. The additional cost for manholes and associated interest expenses of $319,000 is not allowed under Federal regulations. The contractor also claimed $221,000 of ineligible costs based on rental rates for ------- equipment that was, in fact, owned by the contractor. Equipment costs claimed must be actually incurred by the contractor. Other questioned costs included ineligible overhead and interest claims. In addition, $1 55,000 of costs contained in an arbitration award for project inspection fees and increased contractor costs were referred to EPA for review. We Recommended That EPA not participate in the Federal share of questioned costs ($335,000) and resolve the eligibility of the $155,000 of costs identified. What Action Was Taken The audit report was issued to the Regional Administrator, Region 3, on May 10, 1984. A response to the report was received on September 14, 1984. The Regional Administrator sustained the $785,000 of costs. As a result, EPA requested the grantee to repay approximately $50,000, which represented the difference between allowable costs and EPA payments made. Grantee Overstates Claim by $646,000 Problem The Metropolitan Sanitary District of Greater Chicago claimed $646,000 of engineering costs which were not supported by accounting records. We Found That The grantee maintained an accounting system which failed to comply with EPA requirements for a grant to design a wastewater treatment facility. The grantee’s engineering firm for the project billed EPA, through the grantee, $646,000 for costs that could not be supported including $581 ,300 of sub- contract costs and $64,700 for fringe benefits. The grantee’s engineering firm did not retain the accounting records applicable to identify specific costs claimed by its subcontractors or the rate used to determine fringe benefit costs. As a result of these problems, all nonsupportable were questioned. We Recommended That The Regional Administrator, Region 5, disallow and recover the $349,648 Federal share of costs questioned. What Action Was Taken In response to our draft audit report, the grantee disagreed with our findings. The audit report was issued to the Regional Administrator, Region 5, on September 28, 1984. A response to the report is due from Region 5 by December 28, 1984. Superfund Program The Super! und Program was created by the Comprehensive Environmental Response, Compensation, and Liability Act of 1980 (CERCLA). The act provides a $1.6 billion trust fund for removal and remedial actions, liability, compensation, cleanup, and emergency response for hazardous substances released into the environment and uncontrolled and abandoned waste sites. The parties responsible for the hazardous substances are liable for cleaning up the site themselves or reimbursing the Government to do so. States in which there is a release of hazardous materials may qualify for assistance from the Superfund by agreeing to pay 10 percent of the costs of remedial actions, or 50 percent if the source of the hazard was owned by the State or local government. Costs claimed by the State from Super! und must be clearly eligible and supported. Over $6 Million Identified for Recovery in Cleanup at Love Canal Problem Over $6 million was identified for recovery from liable parties under the Comprehensive Environmental Response, Compensation, and Liability Act of 1980 for the costs of cleaning up hazardous substances at Love Canal, New York. Background Between 1942 and 1952, Hooker Electrochemical Corporation, now Occidental Chemical Corporation, disposed of over 21,000 tons of various chemicals into the Love Canal, Niagara Falls, New York. The chemicals have migrated into the surrounding environment and have been found in concentrations far in excess of acceptable health and environmental risk levels. Under CERCLA the Federal Government is authorized to initiate legal proceedings against parties who have released hazardous substances into the environment to recover cleanup expenses. EPA requested the OIG to conduct and coordinate audits of expenses related to agreements, contracts, and grants involved in remedial actions at Love Canal. We Found That In an audit of two EPA cooperative agreements with the New York State Department of Environmental Conservation (NYSDEC), we found that NYSDEC and its contractors had incurred $4.4 million in recoverable cleanup costs. In addition, other costs claimed included $1 ,21 1,000 exceeding budget line items and $185,000 AUDIT PROFILE Audited Costs Questioned & Set Aside Costs $ MILLIONS 0 2 4 6 8 10 12 AUDIT PROFILE Audited Costs ] Questioned & Set Aside Costs $ MILLIONS 0 iP 20 30 40 13 ------- for costs incurred for subconsultant work not having written approval. If all costs are eventually supported, the total recoverable costs under these two agreements could total $6.1 million. In the audit, we also questioned costs of $306,000 claimed by NYSDEC. These costs included $110,000 for amounts withheld from contractor billings by NYSDEC pending satisfactory contract completion and $98,000 for unliquidated obligations claimed by NYSDEC for which payment had not been made. We Recommended That EPA require NYSDEC to: • Comply with 40 CFR 30.610 which requires that prior written EPA approval for rebudgeting; • Evaluate the eligibility of (1) costs incurred prior to CERCLA budget period, (2) supply costs not included in the budget, and (3) costs claimed that exceed budgeted line items; and • Delete from the Financial Status Report’s actual expenditures line item: (1) amounts claimed that were withheld from contractor payments and (2) unliquidated obligations, until the amounts are paid. What Action Was Taken The audit report was issued to the Director, Grants Administration Division, on June 27, 1984. A response to the audit report is due by October 25, 1984. Improvements Needed to Safeguard Superfund Problem Operational and accounting deficiencies in EPA’s Superfund immediate removal action program increased the program’s susceptibility for incurring unnecessary costs and premature depletion of the Trust Fund, We Found That EPA has accomplished some improvements in the management and performance of the Superfund immediate removal action program. However, a number of major deficiencies identified in previous audit reports were still present during this reporting period. On scene coordinators at hazardous substance removal sites did not meet their responsibilities consistently from region to region, or adequately monitor contractor’s performance and related invoices to enssure that EPA paid for only necessary and acceptable work. EPA’s accounting system did not identify or accumulate all costs associated with removal actions, and could preclude the Agency from recovering appropriate costs from responsible parties. For example, $146,315 in personnel compensation and contract costs incurred at one site in Region 3 were not recorded as site specific. The approval process to authorize cleanup actions when an exemption to statutory limits is required results in costly delays and needs to be expedited. In one case, delays cost the Agency an additional $160,000. We Recommended That The Assistant Administrator for Solid Waste and Emergency Response: • Ensure an authorized Agency representative is on site to monitor the cntractor’s performance and certification of the contractor’s daily reports and invoices; • Establish procedures to ensure that all site-specific costs (contract, personnel) are recorded as such in the financial management system; • Transfer fund authority and the requirement for enforcement releases to the regions; and • Request the Administrator to discontinue requirements for approval of exemptions to statutory limits by Headquarters offices not directly in the chain of command and rely on regional offices for legal and financial reviews. What Action Was Taken A final audit report was issued to the Assistant Administrator for Solid Waste and Emergency Response on June 21, 1984. We received a response to the audit report on October 2, 1984. The Assistant Administrator generally agreed to take action on all recommendations. Corrective actions have been completed in some areas, and time frames for completion have been provided for other areas where action is still underway. The Assistant Administrator’s response and planned actions are generally responsive to our recommendations. OIG views immediate removal actions as an area susceptible to abuse. Accordingly, in addition to the audit reported above, we are continuing to make unannounced visits to sites where immediate removals are underway to evalute financial controls. We anticipate issuing a consolidated report on these additional site visits to Headquarters in December 1984. State Agency Claims Ineligible Expenses in Excess of $1 Million II Problem The State of Minnesota claimed costs totalling $1,084,558 related to the Reilly Tar hazardous waste site that were not allowable under the Comprehensive Environmental Response, Compensation, and Liability Act of 1980 (CERCLA). We Found That CERCLA permits States to receive credit toward their cost-sharing requirements for cleaning up hazardous waste sites. This credit is for documented, direct, out-of-pocket, non-Federal funds expended or obligated for eligible actions between January 1, 1978, and December 11, 1980. The total ineligible costs of $1,084,558 include the construction of a street, salaries, insurance, and other costs; amounts used by the State as a matching share to obtain funds from another Federal agency; and funds not obligated by the cutoff date. We Recommended That EPA credit the State of Minnesota with only $272,945 of the $1,357,503 claimed for the Reilly Tar site during the period January 1, 1978, to December 11, 1980, with the difference of $1,084,558 being disallowed. What Action Was Taken The audit report was issued to the Regional Administrator, Region 5, on June 13, 1984. As of September 30, 1984, we had not received a response to the report that was due on September 13, 1984. AUDIT PROFILE Audited Costs Ouestioned & Set Aside Costs $ MILLIONS 00 02 04 0.6 08 10 1.2 14 14 ------- Section 2 Audit Resolution As required by the Inspector General Act, this section describes significant problems and recommendations identified in previous semiannual reports which remain unresolved. Also, as required by the Supplemental Appropriations and Rescission Acts of 1980 and 1981, this section includes a summary of unresolved audits and a list of officials responsible for resolving audit findings over six months old. EPA top management officials and the Office of Inspector General have stressed the need for timely resolution of audits. This attention to audit resolution is beginning to yield noticeable results in numbers of audit reports resolved; dollars sustained, saved, and recovered; and management improvements. The number of audit reports in our followup system has declined 20 percent, from 560 reports at beginning of this reporting period to 446 reports as of September 30, 1984. During this penod, EPA management resolved 504 audits and sustained $47.1 million of questioned costs, including $46.7 million for recovery and $0.4 million of cost reductions. Also, EPA recovered $24.2 million from audit resolutions of current and prior periods, including $3.8 million in cash and $20.4 million of offsets against billings. Agency Management Increases Emphasis on Audit Resolution To improve the Agency’s responsiveness to audit findings, senior Agency management has devoted increased attention to audit followup by including the status of unresolved audits in the Administrator’s strategic planning and management system to enhance tracking and oversight. In addition, the Deputy Administrator has scheduled audit resolution as a major topic at meetings with top Agency officials and plans to continue doing so in the future. EPA’s audit followup directive has been revised to incorporate the requirements of 0MB Circular A-50. In April 1984, EPA issued Directive 2750, “Management of EPA Audit Reports and Followup Actions.” Its principal objective is to assist managers in using audits as a management tool. In general, this system: • Clarifies responsibilities of Agency officials for audit followup; • Establishes definitive time frames for the prompt resolution of audits; • Provides ample opportunity for auditees to submit information pertaining to a disputed finding; and • Uses an Audit Resolution Board to resolve disagreements between our office and program officials on our audit findings and recommendations. Followup on Audit Findings As reported in the prior semiannual reporting period, EPA management has successfully stimulated efforts to resolve audit reports. Since March 31, 1984, the number of unresolved audit reports over six months old has decreased significantly reversing the previous trend. Unresolved Audits over Six Months have Decreased Significantly EPA’s unresolved audit findings over six months old have decreased for the first time in a reporting period since March 31 1982. These improved audit resolution statistics indicate a step in the right direction. However, Agency management needs to continue placing strong emphasis on prompt resolution of audit findings and recommendations. By doing so, EPA officials will be ensuring that the intent of Congress is carried out and the Agency will be recovering funds, avoiding costs, and improving its operations. 271 * As of October 22, 1984, 34 of the 125 audit reports over six months old had been resolved. Our office has received and is reviewing an additional 40 responses to audit reports over six months old. 15 ------- EPA Contracts Director, Procurement and Contracts Management Division Chief, Durham Cost Advisory Branch EPA Grants Programs Director. Grants Administration Division Regional Administrator Region 1 Regional Administrator Region 2 Regional Administrator Region 3 Regional Administrator Region 4 Regional Administrator Region 5 Regional Administrator Region 6 Regional Administrator Region 8 Regional Administrator Region 9 Previously Reported Items—Corrective Actions Not Taken The Inspector General Act requires that each semiannual report identify problems discussed in previous reports Report Grantee/Contractor Number 10937 West Windsor, New Jersey which remain unresolved. Fifty-one audit reports were discussed in all previous semiannual reports; 41 have been resolved. The 10 audit reports listed below had not been resolved as of September 30, 1984. TOTAL 125 75 50 The numbers in the column represent report responses (1) the OIG has received and is evaluating, (2) to be referred to Audit Resolution Board, and (3) in litigation or requiring special study. Action Officials for Audit Reports Outstanding more than 6 Months as of September 30, 1984 Action Officiel Number No or of Invalid Responses 1 Reports Responses in Process IssuedStatus Date 3 - 3 3 3 - 05/06/81 3 11556 Washington Suburban Sanitary 09/11:81 3 Commission, Maryland 5 5 - 20473 Washington Suburban Sanitary 02 1 1/82 3 Commission, Maryland 34 22 12 30324 Jet Line Services, Inc., 1230.82 2 30672 Massachusetts Department of 022883 2 10 10 - Environmental Quality Engineering 31256 EPA Region 9 Survey of Obligations 06.3083 2 11 - 40573 Santa Rosa, California, 01 /30.84 2 19 19 41141 Lafayette, Tennessee 1 06.13.84 1 40506 Atlanta University Center. Georgia 01 1684 3 6 - 6 41288 IT Corporation, Wilmington, California 2 07 23 84 Report reissued at request of program offices to obtain supplemental data. 2 1 1 2 Report reissued to incorporate the results of a major subcontract audit. 6 4 2 Explanation of Status Codes 7. No response. 26 11 1 5 2. Response being evaluated. 3. Resolution delayed pending required studies or litigation, 16 ------- Section 3—Prosecutive ’ Actions The following is a summary of investigative activities during this reporting period. These include investigations of alleged criminal violations which may result in prosecution and conviction, investigations of alleged violations of agency regulations and policies, and OlG personnel security investigations. The Office of Investigations tracks investigations in the following categories: preliminary and regular investigations, investigations being worked with another agency, and OlG background investigations. Profile of Pending Active Investigations By Category of Investigation Theft or Abuse of Government Property 9% Antitrust 4,7% Other 5.8% Personnel Securty 4.7% Administrative and Privacy Act Violations 4.0 ’o Conflict of Interest 4.7%- Profile of Pending Active Investigations By EPA Office Unit Summary of Investigative Case Activity During this period, we closed 249 investigations to reduce our inventory by 11 percent. At the same time, we increased our emphasis on long-term major impact initiatives. Pending Investigations as of March 31, 1984 New Investigations Opened This Period Investigations Closed This Period Pending Investigations as of September 30, 1984 278 We expect that several of the major projects initiated this period will produce significant resuits in future periods. For example, one of these long-term investigations required two years of work before we reported or it. The Municipal and Industrial Pipe Services, Inc. IMIPSI case uncovered a 10 year, S8 mil: on scheme by the directors of MIPS to defraud the Government on EPA-funded sewer rehabilitation projects. The investigation led to the successful prosecution of the directors of MIP who were fined and received substantial prison terms isee page 23 of the semiannual report for the period ending March 31. 1984). Prosecutive and Administrative 315 Actions 212 In this per!od investigat ve efforts resulted in six indictments and three 249 convictions. Fines and recoveries amounted to $91,227. A total of 25 administrative actions were taken as a result of investigations, broken- down as follows: Suspensions Resignations Reprimands Repayment of Funds Reassignments Demotions Others Total Does not include suspensions ano debarments resulting from the Office of In yes tigations activir es Description of Selected Prosecutive Actions Below i’s a brief descript on of some of the prosecutive actions which occurred during the reporting period. Some of those actions resulted from investigations initiated prior to April 1, 1984. Contractor Pleads Guilty to False Billing An investigation resulted in an $80;000 fine of Meredith Associates, Inc. MAll, ‘A/estport, Connecticut. MIA waived indictment and pled nob contendre to an eigth-count charge of making false 2 statements and causing false statements to be made to EPA for contract reimbursements in 5 violation of 18 USC 1001 and 18 3 USC 2. The investigation stemmed from allegations that the sole source contract was — escaiated by $350,000 above the original estimate of S75,000, and focused on MIA’s billing procedures and the falsification of invoices submitted to EPA. The OIG interviewed several MAI employees who stated that Meredith ordered the overbilling of EPA for services on the contract based on employee timesheets that were altered to reflect more hours than were actually worked. In addition, new timesheets were prepared to reflect an inflated number of hours. An examination of MAI records revealed that inflated hours were carried forward on 16 of MAI’s 25 invoices paid by EPA. Contractor 3° h Misrepresents Itself as a Minority Business Murray Paving Company, Inc., of Whitesboro, New York, pled guilty to a five count charge of mail fraud after fraudulently receiving EPA subcontracts on a 17 ------- sanitary sewer project in Whitestown, New York. The subcontracts w ,ere supposed to go to a minority business enterprise in compliance with Federal funding requirements. Murray Paving Company misrepresented its status as a minority business enterprise to three different prime contractors to obtain the $180000 of subcontracting work. Murray Paving Company is not and never has been a certified minority business enterprise nor did it ever have a legal relationship with a certified minority business enterprise which would qualify it under Federal regulations. As a part of the guilty plea, Murray Paving Company agreed to accept a two-year debarment from work on federally funded contracts, and could be fined up to $5,000 at the October 18, 1984. sentencing. False Claims An EPA employee, Sheila Walker, admitted during an investigation to improperly receiving $4,590 in unemployment benefits. The employee was hired by EPA three weeks after separation from another Federal agency, but collected unemployment compensaticn benefits totalling $4,590 by falsely certifying her unemployment for nine months. Ms. Walker pled guilty to making false statements to obtain unemployment compensation (18 USC 1919). On June 28. 1984, she was placed on three years probation and was ordered to make full restitution. Ms. Walker, who was on temporary appointment, is no longer with EPA. Embezzlement of Government Funds An unannounced audit of an EPA imprest fund by regional staff on March 30. 1984, revealed a $3,342.92 shortage in the fund entrusted to Vertie Lee Rogers, an EPA travel clerk and cashier. During a subsequent investigation by the 01G. Rogers admitted embezzling the money. Rogers resigned from EPA, effective April 6, 1984, and made restitution to the imprest fund in the amount of $3,342.92. Rogers was charged with violating 18 USC 657 (Embezzlement of Government Funds) on September 13, 1984. Vertie Lee Rogers pled guilty to the charge on October 10, 1984. Description of Selected Administrative Actions The 0/C investigates and reports on information, allegations, and indications of possible wrong doing or misconduct by EPA employees and persons or firms acting in an official capacity directly with EPA or through its grantees. In addition, the Senate Report of the Supplemental Appropriations and Rescission Act of 1980 states that appropriate administrative action is expected to be taken in cases where employees have acted improperly. Selected administrative actions taken against EPA employees or those with an official re/a fionship with EPA during the semiannual reporting period in connection with audits and investigations are shown below. Two EPA Program Office Attorneys Violate Standards of Conduct One EPA attorney was suspended for three days and another was reprimanded for violating EPA’s Standards of Conduct by using Agency time and equipment for personal activities. The Office of Inspector General received information from one of the attorneys’ clients who was outraged that these attorneys conducted a private legal practice on Government time. Our investigation revealed that the two program office attorneys worked jointly on a private legal case without Agency approval for outside employment. In addition, they failed to list their outside law practice on their Confidential Statements of Employment and Financial Interests and used EPA telephones, word processing, and photocopying equipment for their private legal work. Employee Embezzles Imprest Fund An unannounced audit of a regional imprest fund by the regional staff on March 30, 1984, revealed a $237 shortage in the cash box of an EPA clerk-typist. During a subsequent investigation by the OIG, the employee admitted embezzling the money to make a deposit on an apartment. The employee resigned from EPA effective April 5, 1984, and made restitution to the imprest fund in the amount of $237. Prosecution was declined. Payroll Abuse A section chief in EPA Headquarters submitted a request to reschedule salary payment (SF 1166) stating that he did not receive three consecutive salary payments totalling $3,086.99, when in fact the three payments were electronically mailed to his credit union account. The employee was relieved of his responsibilities as section chief and was demoted three grade levels. Employee Linked to Leave Violation An EPA Headquarters official combined the same week of annual leave each year and a seven-day golf tournament with two days of work in North Carolina from 1979 to 1983. The two days of work occurred on Thursday and Friday of each year and were followed by a golf tournament beginning on Saturday and extending throughout the next week when the official was on annual leave. EPA regulations rohibtt taking annual leave in conjunction with official travel except in emergency or unique situations. In addition, the employee violated regulations by earning and using compensatory time instead of annual leave while he was at the maximum level of a grade 15. The employee was reprimanded for taking leave in connection with official travel. Additionally, the employee’s annual leave balance was reduced by 102 hours, valued at about $3,038, to repay EPA for the compensatory time. The employee retired while Agency action was still pending. Interest-Free Loan to City Inspector A public works inspector for Portland, Oregon, accepted a $7,500 interest free loan from a contractor on an EPA project. The inspector regularly examined pipe that was manufactured by the contractor, however, the investigation d.d not establish that the inspector approved substandard pipe. The City of Portland informed the OIG that as a result of the investigation, the inspector was suspended for two weeks and ordered to repay the loan in full with interest or be terminated. 18 ------- Section 4 Fraud Prevention and Resource Management This section describes several activities of the Office of Inspector General to promote economy and efficiency and to prevent and detect fraud, waste, and abuse in the administration of EPA programs and operations. This section includes information required by statute, recommended by Senate report, or deemed apropriate by the Inspector General. 2nd Half FY’84 Review of Proposed Legislation and Regulations Section 4(a)(2) of the Inspector General Act of 1978 specifies that it is the duty and responsibility of the Office of Inspector General to review existing and proposed legislation and regulations relating to programs and operations concerning their impact on the economy and efficiency or the prevention and detection of fraud and abuse. Prior to this semiannual reporting period, the Agency did not fully recognize these duties and responsibilities of the Office of Inspector General. As a result, the Office of Inspector General was only provided the opportunity to review and make recommendations on a limited number of selected items. How- ever, with the cooperation of the Offices of Administration and Resources Management, External Affairs, and Policy Planning and Evaluation, the Office of Inspector General, beginning in April 1984, has been afforded the opportunity to review, comment, and make recommendations on all legislative and regulatory items within the Agency. The number of total items reviewed by the Office of Inspector General has increased from 34 (6 legislative and 28 regulatory) last semiannual reporting period to 193 (97 legislative and 96 regulatory) this period. The most significant items reviewed are summarized below: [ I 11 Legislation Regulations H.R. 3282, “The Water Pollution Control Act” We believed that proposed amendments to the Water Pollution Control Act contained provisions which would have seriously curtailed our efforts to prevent waste, fraud, and abuse in the wastewater treatment construction grants program. Section 13 of H.R. 3282 would have amended section 203(a) of the Federal Water Pollution Control Act to provide that once the Administrator approves a grant, EPA will be obligated to pay all costs regardless of audit findings. This would have virtually eliminated our ability to audit construction grants and recommend disallowance of costs. We felt that the public should not be expected to pay for projects or portions of projects not planned, designed, and constructed in accordance with Federal statutes and regulations. Similarly, the public should not be expected to reimburse a grantee for costs which were improperly incurred or unallowable under applicable Federal cost principles. To protect the public interests, we suggested that section 13 be eliminated entirely. Subsequently, the proposed bill was amended to eliminate the exclusion from audit. Additionally, the proposed bill was amended to provide one-quarter of one percent of the construction grants funded each year for the exclusive use of the Inspector General to conduct audits and investigations of the programs. Subsequent to the end of the reporting period the bill was not passed by Congress. EPA Directive, Security Volume, Part I—Physical Security The Inspector General Act of 1978 established the Office of Inspector General as an independent authority responsible for ensuring the integrity of the Agency’s employees and operations by conducting audits, investigations, and evaluations. Although we endorse the mission and activities of the physical security program, this directive does not recognize the statutory role of the Inspector General. This lack of recognition could cause a conflict of authority in the investigation of a possible criminal, civil, or administrative violation, or circumvent the potential involvement of the Inspector General entirely. We strongly believe that the Chief, General Services Branch, should be required to report routinely any instances of possible wrongdoing or criminal, civil, or administrative violations to the Inspector General. The Inspector General should be apprised of the determination to open an investigation, the progress of any such investigation and afforded the prerogative to initiate an independent investigation. Additionally, we believe that the Inspector General should be apprised of all reports of theft with the prerogative for making an independent investigation. H.R. 5640, “The Superfund Expansion and Protection Act of 1984” HR. 5640 would amend the Comprehensive Environmental Response, Compensation and Liability Act of 1980 (CERCLA). Specifically, this bill would revise section 111(k) of CERCLA to include three new reporting requirements for the Office of Inspector General. We believe the requirement to conduct an annual audit of payments, obligations. reimbursements, and other uses of the fund, including a random sample of agreements between EPA and the States, should be revised. Though we are willing to perform this audit, we believe that the term “random sample” is too limiting. Since the total number of cooperative agreements is likely to be quite small initially, a stratified or judgmental sample would allow Legus ation and Regulation Reviews by Semiannual Reporting Period ‘200 160 120 ‘80 ‘40 0 1st Half FY84 ------- us to better identify problem areas. The second provision of the amended section 11(k) would require the lG to prepare an annual report on the status of all remedial and enforcement actions undertaken in the previous fiscal year. We believe that reporting data on remedial and enforcement activities is a program responsibility. Section 9(a) (2) of the Inspector General Act of 1978 prohibits the IG from assuming program operating responsibilities. The third provision would require the IG to estimate the amount of resources the Administrator would require to implement all the provisions of the Act. Again, we believe that this provision is a program function which blurs the independent review function that was intended for the 1G. We believe that the requirement for annual reports on the status of remedial, enforcement actions, and resource requirements might be more appropriately fulfilled by the Administrator. The Office of Inspector General could, in turn, review these reports for accuracy and reasonableness. Elimination of Unnecessary Reports to Congress We specifically disagree with the elimination of certain reporting requirements through the repeal of the Supplemental Appropriations and Recission Act of 1980 [ 31 USC 26(b)] as proposed in title 1, section 101(d), of this draft bill. The Senate report on this Act requires the Inspectors General to report in their semiannual reports to Congress a summary of unresolved audits and a list of officials responsible for resolving audit findings over six months old We firmly believe that this report of accountability is necessary to lever Congressional attention and Agency responsiveness concerning the resolution of deficiencies identified in audit reports. The independent status of the Inspector General report provides a means for the Agency and its officials to be held accountable for implementing recommendations and taking corrective actions. H.R. 4233, “Civilian Travel Expense Amendments Act of 1983” This Act would require the establishment of a flat per diem rate for all Federal travel and would abolish the requirement to present records and receipts for documentation purposes. We believe that the establishment of a flat per diem rate would definitely reduce the administrative costs of processing travel papers. However, if records and receipts are not required from travelers, the potential for fraud and abuse may offset any savings accrued. Though travel fraud and waste occurs under the present law, it is often deterred by the requirement to provide travel expense documentation. To guard against flagrant travel abuses, we believe that at a minimum, documentation for overnight lodging should be required. This would provide authentication of expenses, dates, and locations, and prevent employees from obtaining alternate lodging while remaining eligible for full payment of presumed expenses. Assistance Administration Manual We believe that the Assistance Administration Manual chapter which mandates the awarding of a fair share of EPA financial assistance to small minority and women businesses through subagreements should be revised. Though we support and advocate the awarding of EPA financial assistance to small minority and women businesses, we are concerned that businesses representing themselves as small and disadvantaged actually qualify as such. Currently, this manual chapter does not contain any controls or verification requirements to reduce the Agency’s vulnerability to such misrepresentation. We suggest that businesses represented as small and disadvantaged be required to meet certain verifiable criteria or conditions, and that specific controls be established to verify compliance with those conditions. Violations of those conditions or falsification of representation as a small and disadvantaged business should result in the business being debarred or suspended from participation with EPA. Additionally, any subagreement with a small and disadvantaged business should be contingent upon a verification that such business has not been debarred or suspended from doing business with EPA. As of September 30, 1984, our suggestions for changes to the Assistance Administraion Manual were still being considered through the Agency review and clearance process. S. 2666, a Bill “To Preclude Changes in the Federal Regional Office Structure Except by Statute” We believe that the Federal regional structure should not be mandated by statute. One objective of our Government is to be flexible and responsive to the people it serves. This involves decentralized delivery of Government services based on the nation’s demographic characteristics and changes in its population. The establishment of a statutory regional structure reduces the Government’s flexibility to respond to the country’s demographic needs and changes, and greatly reduces its ability to adjust regional organizations to enhance economic and efficient operation. Actions to Prevent Bid Rigging — an Agencywide Effort Bid rigging by Contractors doing business with the Federal Government is one of he most flagrant, chronic, and concealable forms of fraud against the government. Bid rigging is the preconceived agreement between contractors to illegally influence the awarding or pricing of competitively bid contracts. EPA and its grantees sustain millions of dollars in losses of construction grant program funds. During audit and investigative reviews conducted in one region over the past three years, numerous violations were identified and an environment uncovered where bid rigging may be a ‘way of life” for many Contractors. Criminal penalties on the 17 bid rigging convictions to date include prison sentences of over 16 years and fines of $705000. Additional indictments have been filed, and more are expected. While observations of bid rigging are based primarily on activities in one EPA region, the nature of these activities indicates they are applicable nationwide, and aggressive action is needed to minimize losses in EPA’s construction grants. The OIG has extended its review to other areas of the country and is attempting to involve the Agency in a unified, ongoing effort against bid rigging. 20 ------- In our previous two semiannual reports to Congress, we indicated that the OlD worked jointly with the Antitrust Division of the US. Department of Justice in presenting seminars titled ‘Efforts to Prevent Bid Rigging.” We believe that project was successful in alerting seminar participants to the problem. We believe this served as a starting point in an anti-bid rigging program, and recognized a need to have the Agency take more aggressive steps in attacking the bid rigging problem. Accordingly, we suggested several action areas to Agency officials: • Training EPA and State project officers in the prevention, detection, and reporting of fraud, waste, and abuse for a solid first line of defense; • Requiring all contract bidders to sign affidavits or certifications of noncollusive bidding to emphasize the illegality of the action and to strengthen the Government case against bid rigging; and • Requiring the grantee and consulting engineer to retain all project bid records so critical documentation is available for analysis and prosecution. Program managers have agreed on the desirability of these suggestions and are prepanng an action plan for their implementation. We plan to work closely with Agency management to focus its effort on preventing, detecting, and prosecuting bid rigging. As more knowledge is acquired from our ongoing audit and investigative reviews, additional suggestions will be provided. EPA’s policy is to do business only with contractors, grantees, and persons who are responsible, honest, and who comply with applicable rules and regulations. EPA enforces this policy by suspending or debaring any organization or person for acting improperly, having a history of substandard work, or willfully failing to perform on EPA or other Federally funded activities. Suspensions and debarments deny participation in Agency programs and activities to those who represent a risk of abuse to the Government. The EPA Grants Administration Division operates the suspension and debarment program in EPA, with the OIG providing statutory oversight. Acting by Agency request or by its own authority, the OlG conducts audits, investigations, and engineering studies, obtains documents and seeks prosecutive actions necessary to determine whether there is a cause for a debarment. Active Cases Under Investigation Under Program or Counsel Review Proposed for Debarment Suspended Proposed for Debarment Other Pending Total Actions to Debar or Suspend Persons and Firms • The A.C. Lawrence Leather Company, Danvers, Massachusetts, and five of its officers and employees were convicted variously of storing and disposing hazardous wastes without a permit, filing false statements with EPA that concealed the use of hazardous wastes, and illegally discharging raw waste into the Asheulot River in New Hampshire. In connection with their EPA research grant, they were also convicted of filing false claims and mail fraud. The company and all five officers and employees were debarred from participation in EPA programs for the maximum three yearsl period allowed under EPA regulations. • William A. Croft, Madison, Wisconsin, an assistant professor at the University of Wisconsin, was convicted of converting to his own use the services of three subordinate employees whose salaries were 80 funded under an EPA grant. Subsequently, Mr. Croft was debarred from participation in any EPA project for a three-year period. • Richard Gordon Newman of Pierre, South Dakota, was convicted of embezzling EPA funds during his tenure as executive director of the South Dakota Association of Conservation Districts. Subsequently, he was debarred from participation in EPA programs for three years. • Complaints were received from three employees who had not received their Davis- Bacon wages from Bowers Excavating and Fencing, Inc., Klamath Falls, Oregon, a contractor on an EPA-funded project. After notices of proposed debarment were issued to the contractor and two corporate officers, negotiations were initiated which resulted in a settlement agreement. The contractor agreed to pay the full Davis-Bacon wages, with interest, and to accept an 18-month debarment by EPA for the company and the two involved officers. - Summary of Suspension and Suspension and Debarment Activities Debarment April 1. 1984, - September 30. 1984 Activities ___________ Total Fiscal 1984 Cases Opened Cased Completed Debarments Voluntary Exclusions Settlements Cases Dismissed Cases Closed After Investigation Total 59 85 9 24 9 16 3 20 17 32 39 93 As of 9/30/84 36 26 17 0 21 ------- Bid Rigging— Prosecution Resuks in Debarments As described in our previous two semiannual reports and earlier in this section (Fraud Prevention and Management Improvements), the OIG is continuing its investigation of evidence that EPA contractors are rigging bids on wastewater treatment facilities. As of September 30, 1984, a total of 17 guilty pleas were entered in violations of section 1 of the Sherman Act (15 USC ). Below are examples of persons and or firms that were debarred or suspended from doing business with EPA based upon prosecutive action for bid rigging. • Steve D. Rothrock and his company, Rothrock Construction Company, Murrells Inlet, South Carolina, were debarred from doing business with EPA for three years on May 17, 1984. The debarments followed the conviction of Rothrock and his company for violating section 1 of the Sherman Act (15 USC 1). In the spring of 1983, Rothrock and his company pled guilty to charges that they and coconspirators submitted collusive, noncompetitive bids to the North Carolina Sewer District Commission. The collusive bids were submitted to have one of the conspirators receive an award of S3,647,697 to work on an EPA-funded sewer project. • Frederick M. Young, President, CFW Construction Co., Inc., Fayetteville. Tennessee, reached a settlement with EPA on March 29, 1984, agreeing to be voluntarily excluded from doing business with the Government for one year. Young had previously been suspended for one year on July 19, 1983, pending debarment action. Young’s exclusion was based on his violation of section 1 of the Sherman Act (15 USC 1). On December 17, 1982. Young pled guilty to charges that he and coconspirators submitted collusive, noncompetitives bids on a Chester, South Carolina, Sewer District project funded in part by EPA. The collusive bids were submitted so that CFW would receive an award of $2,077,651 to work on the project. On March 2, 1984, CFW also pled guilty to a charge of submitting collusive, noncompetitive bids on the project. Committee on Integrity and Management Improvement In our last semiannual report we reported the establishment of an Agency Committee on Fraud, Waste, and Mismanagement. By consensus of the Committee, the name was changed to the Committee on Integrity and Management Improvement (CIMI) to promote a more positive image of its goals and objectives, The CIMI will coordinate the Agency’s effort and recommend appropriate action to the Administrator relating to policy, plannning, implementation, and resource requirements necessary to curb fraud, waste, and mismanagement. In addition, however, it will foster and review ways to improve economy and efficiency throughout the Agency. On August 9, 1984, EPA Order 1130.1—Committee on Integrity and Management Improvement was issued to describe the purpose, membership, functions and authority of the Committee. The Committee on Integrity and Management Improvement has undertaken three initial projects: Quality Assurance/Quality Control (QA/QC) EPA relies heavily on highly technical data received from external sources in its regulatory decision making process. The QA/OC working group is reviewing ways to strengthen Agency procedures to minimize the possibility of fraudulent or unreliable research resu)ts and technical data having a significant impact on the regulatory process. Agency Permits The permits working group is addressing the various permit issuance processes within EPA to determine if generic permits (industrywide, etc.) might offer substantial improvements in program effectiveness and efficiency of operations. Particular emphasis will be given to the impacts of permitting on small businesses. Environmental results derived from the permits process will be carefully considered in the analysis. Employee Awareness Subcommittee The CIMI established a standing subcommittee on Employee Awareness. This subcommittee is attempting to increase employee participation in the Agency’s management improvement efforts through a revitalized suggestion program and periodic issuance of Employee Awareness Bulletins. The Awareness Bulletins will be signed to sensitize employees, and in some instances grant and contract recipients, to conditions that have proven to be indicators of abuse or wrongdoing in Agency programs. Personnel Security Program Makes Rapid Progress The Personnel Security Program has made significant improvements and progress in reducing the case backlog and ensuring that employment of personnel complies with Agency regulations and national security reqirements since its transfer to the OIG in October 1983. During this semiannual reporting period the Personnel Security staff has reviewed 247 investigations and has intiated a purge of existing security files. These activities have resulted in the identification of the following conditions and subsequent administrative actions: • An employee was removed from duty after being arrested for theft and possession of heroin. Administrative action had been initiated against the employee for frequent absences without leave prior to the arrest. • Two alien employees were removed from duty for falsifyng their non-citizen status. The Agency is seeking recovery of two years salary from one of the aliens. • An employee had intentionally defaulted on a Federally insured student loan. The employee agreed to accept automatic salary deductions until the loan is fully repaid. • An employee was reprimanded for falsification of employment credentials. The employee falsely claimed to hold a Masters Degree in Public Administration. In addition, the Personnel Security Program initiated further actions to improve and ensure the integrity of Agency personnel and its contractors including: • Coordinating efforts with a program office to conduct limited investigations of contractors who handle privileged information; • Working with contractors to update the Personnnel Security Information System (computerized listing of employees’ security data); and • Working with program offices to help them implement changes in the new Federal Personnel Manual for reclassifying the sensitivity of positions. 22 ------- Employee and Public Awareness Activities A major goal of the Office of Inspector General is to enhance its presence among EPA employees, grantees, firms participating in EPA programs and the public. In this process we are trying to make these groups aware of and instill in them a sense of responsibility to prevent, detect, and report instances of fraud, waste, and abuse. We have found that while most EPA employees. grantees, and contractors are conscientious about the economy, efficiency, and effectiveness of their work, they have little knowledge about the 01G. These groups are often in the best position to detect, prevent, and report fraud, waste, and abuse if they know how to identify and report it. To provide information and encourage participation in fulfilling the objectives of the OlG, we have used a variety of mediums to reach specific segments of the EPA concerned population. Publications To inform different groups about OIG operations we have been working with the EPA Office of Public Affairs to publish articles in several different EPA publications. During this reporting period articles conceming the OIG appeared in the EPA Times, the EPA Management Memo, and the EPA Journal. Articles concerning the OIG were also published in the journals and news- letters of several professional associations and State or local governments. Semiannual Reports Over 1.000 copies of our Semiannual Report to Congress for the period ending March 31, 1984, were distributed to employees, citizens, news services, the Army Corps of Engineers, and State agencies administering EPA programs and projects. The distribution of these reports to news services resulted in publication of additional articles concerning the 01G. We are particularly interested in getting State agencies and grantees more involved in the prevention and detection efforts. Committee on Integrity and Management Improvement This newly created group composed of EPA managers (described separately in this section) has established employee awareness to the vulnerabilities of fraud, waste, and abue as one of its primary concerns. With the OIG serving in an advisory capacity, an employee awareness subcommittee has been formed and is undertaking several projects to heighten employee awareness to specific kinds of fraud and abuse, and encourage employee participation in identifying ways to improve Agency operations. Briefings to Management and Associations The Inspector General, Deputy Inspector General and other managers in the OIG have participated in a vigorous schedule of presentations and briefings to EPA management in Headquarters and in the field. In addition, presentations have been made to many grantees as well as professional and governmental associations. Opportunities for participation and presentations are always welcomed. We have also provided talking papers and information for presentation by the Administrator and Deputy Administrator. EPA Directive To more fully describe the role of the Office of Inspector General in EPA. an EPA directive has been produced, circulated within the Agency for comment, and is scheduled for printing and distribution during November 1984. This directive, The Functions and Activities of the Office of Inspector General, discusses the duties and independent authority of the Office of Inspector General. It particularly describes the relationship of the OIG to EPA and other Federal agencies, departments or offices, and clearly informs employees of their responsibility to prevent, detect, and report instances of fraud, waste, and mismanagement. Hotline Activities During this reporting period some of the effects of the employee and public awareness program and hotline publicity emphasizing the detection and reporting of instances of fraud, waste or mismanagement have been realized through increased activity in the OIG Hotline. The number of hotline complaint cases received and opened increased by 50 percent this reporting period. Also, during this reporting period, access to the EPA’s OIG toll-f ree hotline number has been extented to include Alaska, Hawaii. and Puerto Rico. The OIG Hotline Center received 75 new complaints and completed and closed 75 cases during the reporting period. Of the 75 cases closed, 62 were not valid and did not require action while 13 cases resulted in environmental or administrative corrective action. Cases that do not have immediate validity due to insufficient information may be used to identify trends or patterns of potentially vulnerable areas for future review. The following chart shows the increase in complaints received 80 70 60 50 4 30 20 on the hotline this reporting period. Of the 75 complaints received during the period, 22 were from EPA employees, 48 were from the public, and 5 were referred from the U.S. General Accounting Office. Of the 13 cases cited, 7 resulted in a management implications report, “Responsibility Under EPA’s Standards of Conduct,” issued to officials at Research Triangle Park, North Carolina (see Section I of this report). The remaining 6 cases resulted in corrective actions. Cooperative Efforts for Assistance Cooperation Among Federal Auditors Ensures the Integrity of Other Federal Agency Charges to Superfund EPA entered into interagency agreements with other Federal departments and agencies to obtain support services for Superfund. As of June 1984, obligations under these agreements exceeded $58 million and cumulative payments exceeded $28 million. To ensure the integrity of payments to the other Federal agencies, we requested Federal auditors located within the other agencies to perform financial and compliance audits of Superfund claims made by their agencies. The purpose of these audits is to determine if (1) other Federal agencies are .adequately accounting for and . documenting site specific costs and (2) costs claimed are allowable, allocable, and reasonable. Such detailed accounting is required for EPA to recover Superfund expenditures from liable parties. This project is significant for two reasons: (1) the protection afforded Superfund by having the large amount of claims for these agencies subjected to 23 Hotline Complaints Received by Semiannual Reporting Period 1st Half FY’84 10 0 2nd Half FY’84 ------- audit and (2) the cooperation demonstrated by the various Federal Inspector General organizations in completing the project. We have requested audits on 10 Federal agencies or departments including: Coast Guard Department of Commerce Department of Defense Department of Energy Department of Health and Human Services Department of Interior Department of Justice Federal Emergency Management Agency Internal Revenue Service Library of Congress We have recommended that EPA disallow any questioned costs identified as a result of these audits unless adequate documentation is subsequently received. The questioned costs totalling $30,000 in the Department of Interior and Internal Revenue Service reports have been disallowed by EPA, and over $1 million questioned in the Coast Guard report is still under consideration in the audit resolution process. We will request additional audits as further claims are received from these and other agencies against their interagency agreements. Sewer Rehabilitation Review The Office of Inspector General has initiated contacts with the American Consulting Engineers Council (ACEC) to formulate a feasible and cost-effective approach for reinspection of sewer rehabilitation work funded by EPA. The ACEC is a federation of independent consultant engineering and land surveying firms whose purpose is to develop and follow professional conduct standards consistent with the ideals of the engineering profession. The assistance of the ACEC Research and Management Foundation is being sought as part of the OIG national review of EPA-funded sewer rehabilitation. 24 OIG Acts to Assure Administrative Independence Section 3(a) of the Inspector General Act of 1978 states that the Inspector General shall report to and be under the general supervision of the Administrator or Deputy Administrator. In this regard, the Office of Inspector General is obliged to follow Agency administrative policies and procedures and act only with the authority delegated by the Administator, as long as the authority and independence provided to the OIG by the IG Act is not compromised, diminished or interferred with. During this semiannual reporting period the OlG has worked with Agency management to identify specific Agency administrative Delegations of Authority to recognize the OIG’s independence. Establishment of SES Performance Review Board In accordance with our independent role and to insure that OIG employees are not subjected to performance review by the same agency officials they are required to monitor, we requested that the Administrator exclude the OIG from review of its SES employees by Agency personnel and establish a separate Performance Review Board to review SES performance ratings and bonus nominations for OIG employees. Accordingly, a subcommittee of outside experts from other Inspector General offices throughout the Government was created to perform the regular duties of the PRB members concerning the review of ratings and bonus nominations for lG employees. These outside experts will be accredited as members of the EPA’s PRB, so their work can be transmitted as an appendix to the total PRB report to the Administrator. However, the Performance Review Board still retains the authority to determine the amount of any bonus recommended to be granted, as a part of its overall submission. Other existing Delegations of Authority will be revised to recognize the independence of the 01G. Federal Register This Delegation of Authority will recognize the authority of the OIG to sign and submit certain types of documents for publication in the Federal Register. Security This Delegation of Authority will recognize the transfer of the Personnel Security Program to the Inspector General and its further redelegation to the Assistant Inspector General for Management and Technical Assessment. Travel Fund Limitation Impedes Audit and Investigative Operations Most ot our audits and investigations are conducted at contractor or grantee sites—not at the EPA facilities where our staff is located. It is mandatory that our auditors and investigators travel extensively to perform these audits and investigations. Because of travel fund shortages in fiscal 1984. we were forced to assign work based on whether or not it was close to home instead of on the relative priority of the job. Essential training for auditors and investigators was cancelled and revisions were made to our audit and investigative plans, thus reducing the number of priority audits and investigations to be accomplished. We are working with Agency management to solve this problem. However, travel funds are scarce throughout the Agency and little progress has been made so far. Our travel funds were reduced substantially in the fiscal 1983 budget, and our staffing was increased by 45 full-time equivalents (FTEs) in the fiscal 1984 supplemental budget but, no additional travel money was provided to support those FTEs. In fiscal 1985 staffing was increased by 20 FTEs and Agency management provided a small amount of additional travel funds. The graph below shows the dramatic decreases in travel dollars per FTE in our fiscal 1983 and 1984 budgets, with only slight relief provided in the fiscal 1985 budget. Travel funds provided in the fiscal 1985 budget are at about the same level per FTE as we had in fiscal 1984; we still have a shortage of $212,000. If we do not receive some additional travel funds for fiscal 1985, we will have to continue to neglect important audit and investigative efforts requiring travel and use our auditors and investigators on less important work merely because the jobs do not require travel. Consequently, priority requests from Agency EPA Office of Inspector General (Travel Dollars per FTE) 3.3 ‘ 2.8 2.6 2.5 82 83 84 Fiscal Year ------- Section 5—Delinquent Debts management will not be performed; statutes of limitations will run out on criminal matters not investigated; and fraud, waste, and abuse will go undetected. We will not be able to adequately monitor our independent public accountants to ensure that their work :s complete and in compliance with standards. Preaward. interim, and final construction grant audits which provide large returns of funds to the treasury will not be done. Training Stays Close to Home The Office of Inspector General training program, which sought a new direction by its formalization and expansion in fiscal 1984, was handicapped by a limitation of travel funds. Most training was confined to local offerings while many highly regarded training opportunities were foregone Training priorities this period concentrated on microcomputers, communication skills, and human interaction and relations. We provided 729 staff days of training to 108 staff members. The use of individual development plans was initiated to identify training needs and develop our first annual training plan. The limitation in travel funds resulted in the cancellation of courses in operational auditing, successful audit report wriung, and a number of individual enrollments, especially in microcomputer training. Training was rescheduled whenever possible to reduce travel expenses. The Supplemental Appropriations and Rescission Act of 1980 (P.L. 96-304), requires the Inspector Genetal to report on EPA’s delinquent debts and efforts to improve the collection of such debts. Review of Collection Procedures We reviewed accounts receivable and collection procedures in three of the Agency’s 15 servicing finance offices ISFOsI. Our review disclosed that controls were adequate and aggressive collection actions were generally taken. We also noted that two SFOs had not reconciled their General Ledger to the accounts receivable subsidiary records. The total differences was $834. However, these SFOs indicated that they would correct these discrepancies. Claims Office Actions When SFOs determine that debts are uncollectible, they are forwarded to the EPA Claims Officer for disposition. The Claims Officer may compromise, terminate, or suspend further collection efforts on debts under $20,000. Debts over $20,000 must be forwarded to the General Accounting Office or the Department of Justice for approval of the final resolution of debts. For this reporting period, the Claims Officer 111 terminated 16 debts totaling $363,369; (2) collected on four debts totaling $2,891; (3) compromised on nine debts totaling $1,074,749 for $1,058,630. Further, during this period the Claims Officer did not refer any debts to the General Accounting Office or Department of Justice. As of September 30, 1984, there were 34 accounts receivable valued at $1,320,890 in the Claims Office. Of the $1 .3 million, about $749,000 represents debt amounts between 1 to 2 years old while about $524,000 are over 2 years old. We recently completed a review of the Claims Office efforts to promptly resolve delinquent debts (section 1). Agency Initiatives The Office of Inspector General was requested by the EPA Claims Office, Office of General Counsel, to review financial statements and assess the ability of six debtors to repay their debts of $71,245. We concluded that three debtors had the ability to repay while one did not. We are awaiting additional financial information from one debtor, and our assessment for another debtor is not yet complete. The Financial Management Division (FMD) entered into formal Credit Bureau Agreements with various credit bureaus governing the transmittal of debt information. The FMD also transmitted to all SFOs an advance copy of the Financial Management Manual Chapter 7—Billings. This chapter established EPA’s overall billing policy including assessing penalty and handling charges. Agency Collection Efforts The Financial Management Division provided the following summary of EPA’s collection efforts for the period April 1, 1984, through September 30, 1984, and accounts receivable as of September 30, 1984. These may not be the Agency’s final figures. Although they reflect the Agency’s accounting records as of September 30, they are preclosing figures (i.e., we obtained them before the closing process was completed). $27,531,360 Collections Amounts Written off Interest Assessments Interest Collections Accounts Receivable: Under 90 days old Over 90 days old Interagency agreements Total $38,627,711 $ 187,405 $715,024 $ 236,764 $ 9,380,609 $1 5,483,1301 $ 2, 668, 6212 Almost 81 percent of this amount constitutes receivables which are being appealed. Collection actions are suspended until the appeals process is complete. 2 This amount is for debts owed EPA by other Federal agencies. Since these debts do not have an impact on the U.S. Treasury, we have not included them in the regular accounts receivable figures. However, it is still important to note that these debts impact the Agency’s budget. Approximately 95 percent of the total in this category is under 90 days old. 25 ------- Appendix - Audit Reports Issued The Inspector General Act Requires the identification of each audit report completed or issued by the OIG during the reporting period. The following listing categorizes audit reports by type and region. Auditee Final Report Issued 1. INTERNAL & MANAGEMENT AUDITS E1AM4OIOO1Q-41189 FOURTH QUARTER SPENDING REG 06 2784 TOTAL OF REGION 01 = 1 T1DS4020040-41i88 REG 2 OPEN DUMPS & LANDFILLS NY 06 2784 TOTAL OF REGION 02 = 1 E1HW3030326-41615 LEVEL OF EFFORT 106 & 235g GRANTS 09 2784 TOTAL OF REGION 03 = EIZW4OSOI 35-41 582 LEVEL OF EFFORT 06 & 205g GRANTS 09 2554 TOTAL OF REGION 05 = 1 E1ZM4O601771583 IMPREST FUND REGION 4 TX 092584 TOTAL OF REGION 06 1 2. CONSTRUCTiON GRANT AUDITS Auditee Final Report Issued E1ZM4080005-41553 REGION 8 LABORATORY COLORADO 09 1884 TOTAL OF REGION 08 = E16W2090257-40951 REGION 9 ADMIN OF CONSTR GRANTS 042584 E17M4090118-41348 REGION 9 TRA\ EL OPERATION CA 07 31 84 E1HW40S0097 41623 LEVEL OF EFFORT 106 & 205g GRANTS 092884 TOTAL OF REGION 09 = 3 E1ZM4110024-41432 CLAIMS OFFICE DEL DEBT ACTVY 08 1784 TOTAL OF HEADQUARTERS 1 TOTAL INTERNAL & MANAGEMENT AUDITS 10 E2CW30201 28-40862 £20 W402013 1-4 1296 P2BW1 020020-40940 P2CW3020105-41 150 P2CW30201 29-41486 OCEAN TOWNSHP NJ NEW WINDSOR NY PASSA C VALLEY SEWERAGE COM N TOWN OF POUGHKEEPSIE NY CUMBERLAND COUNTY VA NJ 040554 P2CW4020016-41603 072384 P2CW4020017-4 1605 04 2384 P2C W4Q2 0073-4 16 06 06 1484 P2CW3020107-41607 083184 P2CW4020 123-41614 TOTAL OF REGION 02 10 Audit Control Number Audit Control Number HAWAII E2CW4010027-40923 MADAWASKA ME 04 1984 S2CW30101280865 ATTLEBORO 040584 E2CW4010086-40994 SOUTH ESSEX SEWERAGE DIST M Q5 0 84 S2CW3O1 01 50-40878 AMHERST 04 1054 E2CW4010097-41081 MERIDEN CT 052484 S2CW3010163-40879 METRO DIST COMM - FRS MA 04 1084 P2CW3010173-40844 MILTON 0402 34 52CW3010149-40881 HARDWICK MA 04 108-1 P2CW3010187-80877 JAMESTOWN RI 04 1034 S2CW3010161-41380 WEYMOUTH 080684 P2CW3010074-40880 WARNER VLLAGE FIRE DISTR!CT N 04 1084 S2CW3010164-41 588 WILBRAHAM 092684 P2CW3010198-41604 KILLINGLY CT 092684 S2CW3010165-41601 MALDEN MA 09258-2 S2BW3010127-40864 ATTLEBORO MA 040554 TOTAL OF REGION 01 = 15 MARION T OF NY N CHAUTAUQUA LAKE SD N BELV DERE TOWN OF NJ V OF MONTICELLO-THOMPSON NY GUILDERLAND T NY 092584 09 26 84 092684 09 26 84 0927 84 E2CW20300101 595 KENT COUNTY LEV COURT-DE 09 2 84 P2CW3030275-41 192 LANSDALE-PA 06 28 84 P2CW30301620905 WASHINGTON COUNTY SAN DIST-MD 041884 P2CW3030280-41193 NORTH CORNWALL TWP-PA 062884 P2cw3o3o173-4oBos WSSC-MD 041884 P2CW303Q176-41249 JANE LEW WATER COMMISSION LW 0711 84 P2CW3030167-40907 ALTAVISTA TOWN-LA 04 1834 P2CW3030329-41250 HOWARD COUNTY DEPT OF WV-MD 07 11 8-1 P2CW3030178-40934 AUGUSTA COUNTY-VA 042354 P2CW3030182-41 251 ALLEGANY COUNTY-MD 07 11 84 P2Cw3o3o328-4o935 CHARLESTON CITY-WV 042383 P2CW3 030207-41273 CHARLESTON-WV 07 1784 P2CW3030330-40936 CHARLESTON CTY-Vv\ 042384 P2CW3030365-41315 ALLENTOWN-PA 072584 P2CW3030282-40943 BETHEL BOROUGH-PA 042484 P2CW3030284-41 362 WSSC-MD 080284 P2CW3030274-40944 MCCANDLE SS-PA 0424 84 P2CW3030349-41 363 WSSC-MD 0802 84 P2CW3030384-40945 LARKSVILLE-PA 042484 P2CW3030225-41 364 ANNE ARUNDEL COUNTY-MD 080284 P2CW3030366-40946 MECHANiCSBURG-PA 092884 P2CW30302161 377 BEN WOOD CITY-LW 080683 P2CW3030268-41013 SHIRLEY TOWNSHIP-PA 05 1334 P2CW3030283-41378 WSSC-MD 080684 P2CW3030385-41014 NEWPORT TOWNSHIP-PA 05 1084 P2CW30301831 379 WSSC-MD 080684 P2CW303026 1015 PENN TOWN MUNICIPAL AUTH-PA 05 1384 P2CW3030185-41410 DERRY TOWNSHIP-PA 08 1484 P2CW30301151016 LOWER LACKAWANNA-PA 051084 P2CW3030224-41424 HARPERS FERRY BOLIVAR PSD-WL 081684 P2CW3030266-41030 CHAMBERSBURG BOROUGH-PA 05 1434 P2CW3030146-41433 BALTIMORE CITY-MD 082084 p2cw3o3o383 - 41o31 LITITZ SEWER AUTHORITY-PA 05 1484 P2CW30301 79-41 434 HAMPTON RDS SANITATION DIST VA 0820 84 P2CW3030273-41032 TREDYFFRIN-PA 05 1484 P2CW30301811513 WSSC-MD 090684 P2CW3030195-41 181 BLACKSBURG VP SAN AUTH-VA 062784 P2CW2030539-41 563 BLUEFIELD SANITARY BOARD-WV 092084 P2CW3030350-41 182 WSSC-MD 062784 P2CW3030267-41584 CAMBRIDGE-MD 09 2684 P2CW3030243-41 183 ROMNEY CITY-Wv 0627 84 P2CW3030353-41589 CARLISLE BOROUGH-PA 09 2084 P2CW3030352-41 190 CRANBERRY TOWNSHIP-PA 062583 P2CW3030262-41616 BALTIMORE COUNTY-MD 0927 84 P2CW4030038-41191 CHARLES COUNTY-MD 062884 P2CW3030276-41617 TOTAL OF REGION 03 = 46 EAST NORRITON PLYMOUTH-PA 092784 E2CW3040181-40883 EAST LEFLORE CO MS 041034 P2CW3040281-41109 JEFFERSON 0000MM AL 060684 E2CW4340042-41045 JACKSONVILLE FL 051884 P2CW3040292-41127 CAMPBELL KENTON CO SD#1 KY 060884 E2cW3040266-41439 ATLANTA GA 082284 P2CW4040004-41 140 PORT ORANGE FL 061384 E2AW4040340-41626 LOUISVILLE KY 09 2884 P2CW4040103-41223 WILSON NC 07 0684 P2CW3040162-40897 MIAMI DADE WATER & SEWER FL 04 1384 P2CW4040109-41224 ALAMANCE CO NC 070684 P2CW3040258-40927 CORBIN UTILITIES COMM KY 042004 P2CW4040077-41270 ELIZ.ABETHTOWN KY 07 1684 P2CW3040279-40928 TALBOTTON GA 04 2084 P2CW404001 1-41350 MIAMI DADE CO WSA FL 0801 84 P2CW3040293-40929 CORDELE GA 042084 P2CW4040045-41 351 MIAMI DADE WSA FL 0801 84 P20\N3040268-40977 NEW HOPE AL 043034 P2CW4040069-41419 PANAMA CITY FL 08 1504 P2BW4040041 -40978 ALEXANDER CITY AL 043084 P2CW4040101-41440 LOGAN VILLE GA 0822 84 P2CW3040297-40983 GWINNETT CO GA 050384 P2CW3040240-4M62 HATTIESBUAG MS 082884 P2CW3040309-40993 MONROEVILLE AL 050484 P2CW4040018-41463 GREENUP COUNTY KY 080684 P2CW3040317-41 008 WiNSTON SALEM CITY CO NC 0507 84 P2BW3040265-41 499 LEE COUNTY FL 090484 P2CW3040219-41019 JEFFERSON COUNTY COMM SSICN AL 05 1084 P2CW4040005-41500 PACE MS 0904-84 P2CW3040298-41020 PRATTVILLE AL 05 1084 P2CW4040084-41558 CLAXEON GA 09 1984 P20W3040299-41021 PRA1TVILLE AL 051084 P2CW3040307-41570 MOBLE WATER & SEWER COMM AL 092484 26 ------- Audit Control Number Auditee Final Report Issued Audit Control Number Auditee Final Report Issued P2CW3040063-41628 S2CW2040336-40882 S2CW3040072-40896 S2CW3040023-40959 E2CW2050296-4091 7 E2CW1 050448-40924 E2CW2050219-40937 E2CW205001 1-40939 E2CW205021 1-40947 E2CW2050095-40952 E2CW205021 7-40953 E2CW4050077-40981 E2CW1 05041 5-40982 E2BW2050154-41 114 E2CW3050432-41 126 E2CW4050245-41 233 E2CW205041 2-41305 E2DW4050289-41 341 E2CW4050304-41 349 E2DW4050309-41 472 E2CW2050515-41482 E2DW4050326-41 510 E2DW4050282-41 541 E2CW20501 90-41579 E2CW4050334-41 580 E2GW4050246-41 596 E2CW1050031-41618 P2CW1 050374-40850 P2CW2050293-40869 P2CW2050636-40870 P2CW2050573-40893 P2CW2050491 -40904 P2CW20501 53-40914 P2CW2050292-4091 5 P2CW2050482-4091 6 P28W2050233-4091 8 P2BW30501 32-40925 P2BW30501 95-40932 P2BW4050046-40933 P2CW2050485-40950 P2CW30501 92-40957 P2CW3050224-40958 P2BW4050099-40968 P2CW1 050411-40976 P2CW1 050299-40984 P2C 1N2050206-40985 P2CW3050257-41 018 P2CW2050191-41 037 P2CW2050421 -41046 E2CW1 0601 01-40846 E2CW306001 7-41267 E2CW3060090-41 269 E2BW4060095-41 484 E2BW2060079-41 629 P2CW30601 78-40851 P2CW30601 89-40852 P2CW30601 94-40853 P2CW2060073-41 074 P2CW30601 40-41202 E2CW207061 5-40903 E2CW2070498-41 076 E2CW2070365-41 147 E2CW2070610-41 176 E2CW3080057-41084 P2CW3080016-41 139 D2CW40901 19-40990 E2CW4090037-41 071 E2CW4090009-41 108 E2CW4090040-41 125 E2CW4090096-41 138 E2CW4090043-41 236 E2CW4090044-41 260 NORTH CHARLESTON SD SC CLARKSVILLE TN COPPERH ILL TN HARTSVILLE TN WILLIAMSPORT OH MSD CHICAGO IL MSD CHICAGO IL MSD CHICAGO IL MSD CHICAGO IL DEERFIELD IL MSD CHICAGO IL ST CLAIR CO (PORT HURON) MI BEAR LAKE MI MASSILLON OH MAHONING CO (YOUNGSTOWN ) OH BUTLER CO (HAMILTON) OH PARMA OH ST CLOUD MN FORSYTH 1WP (GWINN) MI CITY OF CRANDON WI COLUMBUS OH SYLVAN IA OH SHERIDAN TOWNSHIP (FREMONT) MI ELK RIVER MN SWEETSER IN PLEASANT VALLEY(CHILLICOTHE)OH MSD CHICAGO IL GREENFIELD OH MATFHEWS SELMA/LIBERTY IN SANDUSKY OH LAFAYE1TE OH ELDORADO OH DARLINGTON IN DORA & LEIGHTON TWPS MI ADA OH NAPOLEON OH GRATIOT CO (ITHACA) MI MMSD MILWAUKEE WESTERN LAKE SUPERIOR SD MN CLARK CO (SPRINGFIELD) OH LINCOLN IL CRAWFORd MURPHY JOLIET IL MWCC ST PAUL MN MWCC ST PAUL MN HUNTINGTON IN MARION WI HAMPTON 1WP MI AUSTIN CHENEWILLE LA PINE BLUFF/WHITEHALL AR BROWNWOOD TX CPI INC CARLSBAD NM BAYTOWN TX GONZALES LA FRIENDSW000 TX CAMDEN AR SEWARD NEBRASKA WINFIELD KS WICHITA KS TONGANOXIE KS CASPER BOARD OF PUBLIC UTIL WY EUREKA MT TOWN OF J MONTGOMERY PASADENA CA CLAREMONT CA CITY OF NEWMAN CA CITY OF TUOLUMNE COUNTY WATER DIST CA HAWAII CITY OF HI HONOLULU HI CITY & COUNTY OF HONOLULU HI CITY & COUNTY OF 09/28/84 04/10/84 04/13/84 04/25/84 TOTAL OF REGION 04 = 39 TOTAL OF REGION 05 = 90 04/19/84 04/20/84 04/23/84 04/23/84 04/23/84 04/24/84 04/25/84 05/02/84 05/03/84 06/07/84 06/07/84 07/09/84 07/25/84 07/31/84 07/31/84 08/29/84 08/31/84 09/06/84 09/13/84 09/25/84 09/25/84 09/24/84 09/28/84 04/03/84 04/09/84 04/09/84 04/12/84 04/17/84 04/18/84 04/18/84 04/18/84 04/19/84 04/20/84 04/20/84 04/20/84 04/24/84 04/25/84 04/25/84 04/25/84 04/30/84 05/03/84 05/03/84 05/10/84 05/15/84 05/18/84 S2CW2040351 -41 075 S2CW4040187-41 141 S2CW4040070-41 387 P2CW1 050211-41068 P2BW30501 57-41087 P2CW1 050048-41097 P2CW3050223-41 098 P2CW3050098-41 099 P2CW3050255-41 100 P2CW3050212-41101 P6DW4050225-41112 P2CW2050203-41 173 P2CW2050202-41 174 P2CW2050205-41 175 P2CW2050300-41 178 P2BW2050508-41 179 P2CW2050204-41 194 P2BW3050357-41 195 P2CW3050380-41 232 P2CW20501 82-41242 P2DW2050543-41 268 P2BW40501 55-41327 P2CW305041 8-41328 P2CW3050300-41 329 P2DW3050096-41333 P2DW30501 01-41334 P2CW1 050372-41343 P2CW20501 14-41344 P2CW3050228-41 345 P2CW2050507-41 346 P2CW3050194-41 347 P2CW3050081-41368 P2CW30501 00-41412 P2CW2050181 -41480 P2CW20501 07-41481 P2DW30501 12-41483 P2BW3050236-41 492 P2CW3050447-41 493 P2BW2050370-41 495 P2CW3050214-41 520 P2DW3050054-41 551 P2CW2050422-41 581 P2CW20501 22-41612 P2CW2050302-41 613 P2CW4050091-41 619 P2CW3050436-41 620 P2BW4050229-41 621 P2CW205041 6-41622 04/02/84 P2CW30601 14-41211 07/13/84 P2CW30601 32-41212 07/16/84 P2CW4060038-41 213 08/31/84 P2CW3060182-41222 09/28/84 P2CW3060205-41 274 04/03/84 P2CW30601 93—41283 04/03/84 P2CW4060098-41 528 04/03/84 P2CW3060076-41630 05/23/84 P2CW3060077-41631 07/02/84 TOTAL OF REGION 06 = 19 04/24/84 E6DW4070073-41 624 05/24/84 P2CW207061 3-41077 06/14/84 P2CW2070530-41 625 06/25/84 TOTAL OF REGION 07 = 7 P2BW3080046-41 469 05/29/84 06/12/84 TOTAL OF REGION 08 = 3 05/04/84 05/22/84 06/05/84 06/07/84 06/12/84 07/09/84 07/12/84 H2BM40901 81-41448 P2CW2090047-41321 S2CW30901 30-40908 S2CW30901 34-40909 S2CW30901 73-40926 S2CW3090040-40975 S2AW3090251-40991 MORRISTOWN TN LAFAYEUE TN WAVERLY TN SHAWANO LAKE SD (SHAWANO) WI DONAHUE & ASSOC. WI MEDINA CO OH LINCOLN IL CALEDONIA MI BELPRE OH DE KALB SD IL MWCC ST PAUL MN MWCC ST PAUL MN MWCC ST PAUL MN MWCC ST PAUL MN BERRIEN COUNTY BPW MI ANTIGO WI MWCC ST PAUL MN MWCC ST PAUL MN FORCE ACCOUNT ERIE CO (SANDUSKY) OH FARIBAULT MN ALPENA CO MI LYNN KI1TINGER AND NOBLE TRUMBULL CO (WARREN) OH SANDUSKY OH TUSCOLA CO MI MANISTIOUE MI MILLERSBURG IN SAGINAW MI JACKSON CO (FREETOWN) IN NEORSD CLEVELAND OH FAIRFIELD HEART OF THE VALLEY SC WI BAY CITY MI LORRAIN OH SHIPSHEWANA IN LYNN IN FRANK A THOMAS (FY 77) LORAIN OH FRANK A THOMAS (OH CY 78-81) LUCAS CO (HOLLAND) OH COLEMAN WI LUCAS CO (HOLLAND) OH LESLIE MI BERRIEN CO (ST JOSEPH) MI IRON MOUNTAIN MI GRAND RAPIDS MI GRAND RAPIDS (OH FY 78) MI NORTH SHORE SD IL WYNNE AR CLUTE/RICHWOOD TX LUBBOCK TX PASADENA TX HARLINGEN TX HARRIS CO WCID #21 TX CORSICANA TX HARDY AR REDFIELD AR PERU KS OSCEOLA IA HANNIBAL MO MESA CO COUNTY OF DAVIS UNIVERSITY OF CA GARDNERVILLE RANCHOS GID NV SAN FRANCISCO CITY & COUNTY CA SAN FRANCISCO CITY & COUNTY CA WHEATLAND CA CITY OF THOUSAND OAKS CITY OF CA LOS ANGELES CA CITY OF 05/23/84 06/13/84 08/08/84 05/21/84 05/30/84 06/04/84 06/04/84 06/04/84 06/04/84 06/05/84 06/06/84 06/22/84 06/22/84 06/22/84 06/27/84 06/27/84 06/28/84 06/28/84 07/09/84 07/10/84 07/13/84 07/30/84 07/30/84 07/30/84 07/30/84 07/30/84 07/31/84 07/31/84 07/31/84 07/31/84 07/31/84 08/03/84 08/14/84 08/30/84 08/30/84 08/31/84 08/31/84 08/31/84 08/31/84 09/07/84 09/17/84 09/24/84 09/27/84 09/27/84 09/28/84 09/28/84 09/28/84 09/28/84 07/03/84 07/03/84 07/03/84 07/06/84 07/16/84 07/20/84 09/11/84 09/28/84 09/28/84 08/29/84 08/24/84 07/26/84 04/18/84 04/18/84 04/20/84 • 04/30/84 05/04/84 27 ------- Audit Control Number Auditee Final Report Issued Audit Control Number Auditee Final Report Issued S2CW3090025-41 038 S2CW3090244-41 070 S2CW309 0180-4 1083 S2CW4090014-41 133 S2CW3090174-41 142 S2CW3090245-41 149 S2CW30901 72-41166 S2BW3090219-41 292 S2BW3090220-41 293 S2CW4090034-41 322 E2BW2100079-40849 E2CW31 00038-41318 E2DW31 0001 7-41 384 P2CW31 00037-40980 P2CW31 00006-41034 P2CW31 00053-41043 EAST BAY MUD CA WASCO PUD CA S SAN LUIS OBISOP COUNTY CA LAKE COUNTY SANITATION DIST CA SAN FRANCISCO CITY & COUNTY CA LAKE COUNTY CA PLACERVILLE CA CITY OF JAMES M MONTGOMERY CA LOWRY & ASSOCIATES CA RIO DELL CA CITY OF 3. OThER GRANT & CONTRACT AUDITS 05/17/84 S2CW409001 1-41425 05/22/84 S2CW4090020-41 460 05/29/84 S2CW3090250-41 491 06/11/84 S2CW4090102-41 509 06/13/84 S2BW4090134-41517 06/14/84 S2CW409001 0-41550 06/22/84 S2CW3090248-41 562 07/23/84 S2CW3090249-41 565 07/23/84 S2CW3090246-41 586 07/26/84 S2CW4090073-41 627 TOTAL OF REGION 09 = 34 04/03/84 P2CW3100054-41 044 07/25/84 P2CW31 00027-41134 08/06/84 P2CW3100043-41 135 05/01/84 P2CW41 00004-41148 05/14/84 P2CW3100041-41316 05/16/84 P2CW31 00044-41317 TOTAL OF REGION 10 = 12 TOTAL CONSTRUCTION GRANT AUDITS 275 TOTAL OF REGION 01 = 64 TOTAL OF REGION 02 = 21 CONSTRUCTIONEERING NW INC WA MERIDIAN ID CITY OF SNOHOMISH WA COUNTY OF ASOTIN COUNTY WA MONMOUTE OR INDEPENDENCE OR CITY OF 05/07/84 07/19/84 09/26/84 04/11/84 05/11/84 05/11/84 05/11/84 05/11/84 05/11/84 05/11/84 05/21/84 OS/2 1/84 05/21/84 05/21/84 0512 1/84 05/21/84 05/21/84 0512 1/84 05/21/84 0512 1/84 06/12/84 06/12/84 06/20/84 06/20/84 07/05/84 07/05/84 07/05/84 07/11/84 07/11/84 07/11/84 07/11/84 07/11/84 D3AM4O1O1 55-41 279 D3AM4 O1O1 59-41 289 D3AM4O1 01 58-41 290 D3AM4O1O1 57-41 291 D3AW4O1 0162-41332 D3AM4010167-41 397 D3DW4O1 01 69-41417 D3DW4O1 01 70-41 418 D3AM4010171-41 421 D3AM4O1O173-41 452 D3AM4010174-41 453 D3AM4O1 0175-414S4 D3AM4O1 0176-41455 D3DM3O1 0157-41485 D3DM4O1 0178-41487 D3AM4O 1 01 79-4 1 522 D3AA401 0183-41523 D3AM4010187-41 566 D3A4401 0195-41567 D3AM4010199-41 568 D3DW4O1 0092-41602 N3GC4O1O100-40912 N3GC4 O1O1O1-4O913 N3GC4010105-41017 N3GC4O1 0122-41072 N3GC4010123-41073 N3GC401O138-41218 N3GC4O 10 137-4 12 19 N3GC4O1 0160-41335 N3GC4010181-41539 N3GC4O1 01 86-41 40 N3GC4O1 0196-41569 C3EC4O1 0104-40995 C3ES4O1 0139-41278 C3EC4O1 0177-41585 D3AH4O1 0095-40888 D3DM3010141-41 023 D3DW4O1 0107-41024 D3AM4O1 01 08-41 02S D3AM4O1 0109-41026 D3AW4O1O1 10-41027 D3AM4O1O1 11-41028 D3AM4O1O1 12-41050 D3CM4O1O1 13-41051 03CM401O114-41 052 D3AM4010115-41053 D3AM4O1O1 16-41054 D3CM4O1O1 17-41055 D3AM4O1O118-41056 D3CM4O1O1 19-41057 D3CM4O1O12O-41058 D3DM4010121-41 059 D3AM4O10127-41136 D3AM4010126-41 137 D3AM4O1O131-41157 D3CM4010132-41 158 D3DW2O1 0007-41215 D3CM4O 10 140-4 12 16 D3AM4010141-41217 D3DW4O1 0148-41252 D3DW2O1O1 17-41253 D3DW4O1 0147-41254 D3DW4O1 01 49-41 255 D3D W401 01 50-41 256 C3EC40201 63-41385 D3AB40201 06-40871 D3DM4020141-41 092 D3DM40201 58-41257 D3CM4O2O1 75-41423 D3DM40201 79-41468 D3BM40201 89-41488 D3AM4020188-41489 E3AM40201 55-41 330 H3CM40201 59-41258 N3GC40201 15-40941 C3EC40301 66-40874 C3EC40301 77-40969 C3EC4030181-40998 C3EC40301 89-41005 C3EC4030219-41153 C3EC4030252-41 237 C3EC4030298-41 431 C3EC4030304-41 438 C3EC4030343-41 600 D3DM4030161-40845 D3AM40301 62-40860 D3AM40301 63-40861 D3DM4O3O1 64-40872 CHINO BASIN MWD CA LOS ANGELES CA CITY OF RIVERSIDE CA CITY OF RIVERSIDE CITY OF CA KENNEDY/JENKS ENGINEERS OAK VIEW SANITARY DISTRICT CA BAKERSFIELD CA CITY OF LOS ANGELES CA CITY OF LOS ANGELES CA CITY OF LOS ANGELES CA CITY OF INDEPENDENCE OR CITY OF GERVAIS OR CITY OF WINLOCK WA CITY OF KINGSTON-CATALDO SEWER 0 1ST ID FREMONT ID COUNTY OF GRANITE FALLS WA TOWN OF CAMP DRESSER & MCKEE INC MA INDUSTRIAL ECONOMICS INC MA PUTNAM HAYES&BARTLETT INC MA GCA CORP MA SPRINGBORN BIONOMICS INC. ARTHUR D LIULE INC MA FAY SPOFFORDÞDIKE INC MA SEA CONSULTANTS INC MA TRC-ENVIRON CONSULT’ INC CT INDUSTRIAL ECONOMICS INC MA CHARLES RIVER ASSOC INC MA GCA CORP MA STONE & WEBSTER MA DUFRESNE HENRY INC VT EG&G INTL-MA TRC ENVIRON CONSULTANTS INC C GCAITECH DIV MA RILEY STOKER CORP MA CAMBRIDGE SYSTEMATICS INC MA MITRE CORP MA DUBOIS & KING VT STAMFORD CT UNIV OF MASSACF-IUSETrS MA MIDSTATE REGIONAL PLAN CT SO WESTERN RPA CT BERKSHIRE CTY REG’L PLAN COM M PIONEER VALLEY PLAN COMM MA SO EASTERN REG PLAN&ECONDD MA BRIDGEPORT CT MASSPORT MA DEPT OF HEALTH SERVICES CT NEW BRITAIN CT UNIVERSITY OF PUERTO RICO PR NJ DEPT OF ENVIRON PROTECT NJ NJ DEPT OF LAW & PUBLIC SAFE N NJ DEPT OFHIGHER EDUCATION NJ NJ GENERAL FUND NJ SOUTHERN TIER CENTRAL RPDB-NY HAZEN & SAWYER NY GORDIAN ASSOC NJ NJ DEPT OF ENVIRON PROTECTION HAZEN & SAWYER NY BOOZ ALLEN & HAMILTON-MD ROY F WESTON INC-PA MINE SAFETY APPLIANCE CO-PA CLEMENT ASSOC-VA BOOZ ALLEN & HAMILTON INC-MD PEER CONSULTANTS IN-MD AMERICAN MANAGEMENT SYSTEMS-VA DYNAMIC INTERNATIONAL-MD INFORMATICS INC-MD INFORMATION SYSTEMS-MD O’CONNOR MANAGEMENT INC-PA WOODWARD CLYDE CONSULTANTS-NJ BOOZ ALLEN & HAMILTONINC-MD 08/16/84 08/28/84 08/31/84 09/05/84 09/06/84 09/17/84 09/19/84 09/20/84 09/26/84 09/29/84 05/16/84 06/11/84 06/11/84 06/13/84 07/25/84 07/25/84 07/20/84 07/23/84 07/23/84 07/23/84 07/30/84 08/10/84 08/14/84 08/14/84 08/15/84 08/27/84 08/27/84 08/27/84 08/27/84 08/31/84 08/31/84 09/10/84 09/10/84 09/20/84 09/20/84 09/20/84 09/26/84 04/18/84 04/18/84 05/09/84 05/23/84 05/23/84 07/05/84 07/05/84 07/30/84 09/13/84 09/13/84 09/24/84 04/23/84 05/04/84 05/07/84 05/21/84 07/05/84 08/31/84 06/06/84 09/21/84 09/21/84 09/26/84 04/10/84 04/12/84 04/24/84 04/24/84 05/07/84 05/07/84 05/07/84 05/07/84 05/07/84 05/07/84 05/07/84 05/07/84 05/07/84 CT DEPT ENVIRON PROT CT CONN RESOURCES REC. AUTH CT MAINE DEPT OF ENVIR PROTECT ME CAMP DRESSER & MCKEE INC MA CAMP DRESSER & MCKEE MA GREEN INTL AFFILIATES INC MA E GCA COPR MA ABT ASSOCIATES INC MA META SYSTEMS INC MA WCB ARTHUR D LIULE INC MA MARSHALL BARTLETT INC MA WCAB ABT ASSOCIATES INC MA ABT ASSOCIATES INC MA WCAB ENERGY RESOURCES CORP INC MA DYNATREND INC MA FUTURES GROUP INC CT PUTNAM HAYES & BARTLEY INC MA DATA RESOURCES INC MA FACTORY MUTUAL RESEARCH COPR M TEMPLE BARKER & SLOANE INC MA CONSULTING STATISTICIANS MA GCA CORP MA ENVIRONMENTAL RESEARCH TECH M FACTORY MUTUAL RESEARCH CORP M FAY SPOFFORD & THORNDIKE MA PUTNAM HAYES & BARTLETT MA GCA CORPORATION MA FAY SPOFFORDÞDIKE INC MA METCALF & EDDY MA METCALF & EDDY INC MA FAY SPOFFORDÞDIKE INC MA FAY SPOFFORDÞDIKE INC MA INTERSTATE SANITATION COMM NY FRONTIER TECH SERVICES NY BURNS AND ROE NJ BURNS & ROE NJ SYRACUSE RESEARCH CORP NY ECOLOGY & ENVIRONMENT INC NY MECHANICAL TECHNOLOGY-NY CHEM SYSTEMS INC-NY MALCOLM PIRNIE INC NY NJ DEPT OFHEALTH NJ CENTRAL NY REGIONAL P&ID BD NY HARFORD COUNTY-MD ANNE ARUNDEL COUNTY-MD DC DEPT OF ENVIRON SERVICES-DC PRINCE WILLIAM COUNTY-VA SUSSEX COUNTY-DE STATE WATER CONTROL BOARD-VA HOWARD COUNTY-MD FAIRFAX COUNTY-VA BALTIMORE COUNTY-MD SKELLY & LOY-PA CENTEC CORP-VA ICF INCORPORATED-DC CLEMENT ASSOC-VA 08/08/84 04/09/84 05/3 1/84 07/11/84 08/16/84 08/29/84 08/31/84 08/31/84 07/30/84 07/11/84 04/23/84 N3GC40201 20-40942 N3GC40201 27-40992 N3GC40201 33-41007 N3GC40201 38-41064 N3GC4020143-41214 N3GC40201 86-41490 P3CM20201 98-41113 P3CM3020023-41 590 P3DM30201 03-41591 P3CX2O2001 7-41608 04/10/84 04/25/84 05/07/84 05/07/84 06/19/84 07/10/84 08/17/84 08/22/84 09/24/84 04/02/84 04/04/84 04/04/84 04/10/84 D3CM40301 65-40873 D3AM40301 71-40889 D3CM40301 74-40948 D3AM40301 75-40949 D3CM4O3O1 78-40996 D3AM40301 79-40997 D3CM40301 82-40999 D3CM40301 83-41000 D3CM40301 84-41001 D3AM40301 85-41002 D3AM40301 86-41003 D3AM40301 88-41004 D3CM40301 87-41006 28 ------- Audit Control Number Auditee Final Report Issued Audit Control Number Auditee Final Report Issued D3BM4030260-41 012 BIONETICS CORP-VA 07/18/84 D3AM4030284-41 405 VERSAR INC-VA 08/13/84 D3CM4030194-41035 INTERNATIONAL BUSINESS SERV-DC 05/15/84 D3AM4030285-41406 BOOZ ALLEN & I- AMILTON-MD 08/13/84 D3CM40301 95-41036 ROY F WESTON INC-PA 05/15/84 D3CM4030286-41407 SYSTEX INC-MD 08/13/84 D3DM4030202-41 115 MINE SAFETY APPLIANCE CO-PA 06/07/84 D3CM4030287-414 08 SYSTEX INC-MD 08/13/84 D3AM4030203-41 116 SC&A INCORPORATED-VA 06/07/84 D3DM4030288-41 409 GENERAL RESEARCH CORP-VA 08/13/84 D3CM4030206-41 119 HITTMAN ASSOCIATES-MD 06/07/84 D3CM4030292-41426 WAPORA INC-MD 08/17/84 D3AM4030207-41 120 JACA CORP-PA 06/07/84 D3AM4030293-41 427 DYNAMAC CORP-MD 08/17/84 D3CM4030208-41 121 BOOZ ALLEN & HAMILTON-MD 06/07/84 D3AM4030294-41 428 CRC SYSTEMS INt-VA 08/17/84 D3AM4030209-41 122 NUS CORP-Mb 06/07/84 D3AM4030296-41429 ENVIRON CORPORATION-DC 08/17/84 D3CM4030210-41 123 WAPORA INC-MD 06/07/84 D3AM4030297-41430 CLEMENT ASSOCIATES INC-VA 08/17/84 D3AM403021 1-41 124 GENE RAL SOFTWARE CORP-MD 06/07/84 D3AM4030302-41 436 WHITESCARVER ASSOC INC-DC 08/21/84 D3AM4030212-41131 HAGLER BAILLY & CO-DC 06/11/84 D3AM4030303-41437 SYNERGY INC-DC 08/21/84 D3AM403021 3-41132 ENERGETICS INC-MD 06/11/84 D3AM4030305-41445 DYNAMAC CORPORATION-MD 08/23/84 D3AM4030217-41 151 VERSAR INC-VA 06/19/84 D3AM4030307-41465 ICF INCORPORATED-DC 08/28/84 D3CM4030218-41 152 WAPORA INC-MD 06/19/84 D3AM4030308-41 466 VERSAR INC-VA 08/28/84 D3CO4030224-41 196 WAPORA INC-MD 06/28/84 D3AM4030309-41 467 PEAT MARWICK MITCHELL & CO-DC 08/28/84 D3DM4030231-41199 CLEMENT ASSOC INC-VA 07/02/84 D3CM4030310-41477 CLEMENT ASSOC INC-VA 08/30/84 D3AM4030232-41 200 NATIONAL ACADEMY OF SCIENCESDC 07/02/84 D3AM403031 1-41478 ICF TECHNOLOGY-DC 08/30/84 D3CM4030233-41201 WAPORA INC-MD 07/02/84 D3AM4030312-41479 VIAR & COMPANY-VA 08/30/84 D3CM4030234-41 204 WAPORA INC-MD 07/02/84 D3AM403031 9-41505 URBAN INSTITUTE-DC 09/05/84 D3CM4030235-41 205 WAPORA ND-MD 07/02/84 D3AM4030320-41 506 SOBOTKA & COMPANY-DC 09/05/84 D3CM4030236-41 206 WAPORA INC-MD 07/02/84 D3AM4030321-41518 BENDIX FIELD ENG CORP-MD 09106/84 D3AM4030237-41 207 CENTAUR ASSOC-DC 07/02/84 D3AM4030322-41 519 PEER CONSULTANTS-MD 09/06/84 D3CM4030238-41208 GEOMET TECH INC-MD 07/02/84 D3AM4030325-41521 DYNAMAC CORPORATION-MD 09/10/84 D3CM4030239-41 209 WAPORA INC-MD 07/02/84 D3DM4030327-41 529 AMERICAN MANAGEMENT SYSTEM-VA 09/12/84 D3AM4030240-41 234 ENERGY & ENVIRO ANALYSIS-VA 07/09/84 D3CM4030328-41 530 INFORMATICS-MD 09/12/84 D3CM4030241 -41235 SCIENTEX CORP-DC 07/09/84 D3AM4030329-41 531 CENTEC CORP-VA 09/12/84 D3AM4030245-41 241 ENVIRONMENTAL LAW INSTITUTE-DC 07/10/84 D3AM4030330-41 532 ENGINEERING SCIENCE INC-CA 09/12/84 D3AM4030246-41 243 MORCOM SYSTEMS INC-DC 07/11/84 D3AM4030333-41 554 EA ENGINEER-SCIENCE & TECH-MD 09/18/84 03DM4030247-41 244 GKY & ASSOCIATES-VA 07/11/84 D3DM4030334-41 555 ATLANTIC RESEARCH CORP-VA 09/18/84 D3AM4030250-41245 ICF INCORPORATED 07/11/84 D3AM4030335-41 556 HIRT TELECOM CO-VA 09/18/84 D3AM4030251-41246 ICF INCORPORATED 07/11/84 D3AM4030336-41 557 COLUMBUS SERVICES INC-PA 09/18/84 D3CM4030254-41 266 INNOVATIVE SYSTEM RESEARCH-NJ 07/12/84 D3AM4030344-41 577 DDD CO-MD 09/24/84 D3AM4030261-41275 KENDRICK & CO-DC 07/18/84 D3AM4030345-41578 BOOZ ALLEN & HAMILTON INC-MD 09/24/84 D3AM4030262-41 276 CALCULON CORP-PA 07/18/84 D3AM4030340-41 597 COOPERS & LYBRAND 09/24/84 D3CM4030265-41 303 INNOVATIVE SYSTEMS RESEARCH-NJ 07/25/84 D3DM4030341-41 598 COMPUTER SCIENCES CORP-VA 09/24/84 D3BM4030266-41 319 EARTH TECH RESEARCH CORP-MD 07/26/84 D3AM4030342-41 599 PEER CONSULTANTS-MD 09/24/84 D3AM4030267-41 320 CSC-ATD-VA 07/26/84 E3DM20301 50-41542 WSSC-MD 09/13/84 D3CM4030268-41 338 DYNAMAC CORP-MD 07/30/84 E3DM3030372-41 543 DISTRICT OF COLUMBIA-DC 09/14/84 D3AM4030269-41 339 MERIDIAN CORP-VA 07/31/84 H3CM4030204-41 117 GEORGE WASHINGTON UNIVERSITY 06/07/84 D3AM4030270-41340 EARTH TECHNOLOGY CORP-NJ 07/31/84 H3CM4030205-41 118 GEORGE WASHINGTON UNIVERSITY 06/07/84 D3AM4030271-41360 BOOZ ALLEN & HAMILTON INC-MD 08/02/84 N3GC4030167-40875 CAMBRIDGE-MD 04/10/84 D3AM4030273-41 381 INFOTEL BUSINESS SYSTEM-PA 08/06/84 N3GC40301 68-40876 ROANOKE-VA 04/10/84 D3AM4030274-41 382 JWK INTERNATIONAL CORP-VA 08/06/84 N3GC4030242-41 238 WILMINGTON METROPOLITAN-DE 07/10/84 D3AM4030275-41383 EXECUTIVE COMMUNICATIONS-PA 08/06/84 N3GC4030243-41239 REGIONAL PLANNING COUNCIL-MD 07/10/84 D3CM4030278-41 399 ORI INCORPORATED-MD 08/13/84 N3GC4030244-41240 OUEEN ANNE’S COUNTY-MD 07/10/84 D3AM4030279-41400 JRB ASSOCIATES-VA 08/13/84 N3GC4030249-41 247 MONTGOMERY COUNTY-MD 07/11/84 D3AM4030280-41401 ECOLOGICAL ANALYSIS INC-MD 08/13/84 N3GC4030248-41248 CITY OF RICHMOND-VA 07/11/84 D3AM4030281-41 402 JRB ASSOCIATES-VA 08/13/84 N3GC4030272-41 361 HENRICO COUNTY-VA 08/02/84 D3AM4030282-41 403 PEER CONSULTANTS-MD 08/13/84 N3GC4030301 -41435 LEESBURG-VA 08/21/84 D3AM4030283-41404 VIAR AND COMPANY-VA 08/13/84 P3DW1030017-41091 PHILADELPHIA CITY-PA 05/31/84 C3EM4040208-41110 TALLAHASSEE FL 06/06/84 D3AM4040293-41502 SOUTHERN RESEARCH INST AL C3FM4040209-41 111 TALLAHASSEE FL 06/06/84 D3AM4040299-41 527 PRIEDE SEDGWICK INC FL C3EM4040223-41 170 CHARLOTTE NC 06/22/84 D3AM4040305-41 575 SOUTHERN RESEARCH INST AL C3FM4040224-41171 CHARLOTTE NC 06/22/84 D3CM4040314-41576 ENVIRONMENTAL SC & ENGR FL C3EM4040249-41 355 JACKSONVILLE FL 08/01/84 H3CM4040153-40867 UNIV OF NORTH CAROLINA NC C3FM4040250-41356 JACKSONVILLE FL 08/01/84 H3CU4040165-40974 EAST TENN STATE UNIV TN C3EM4040272-41 390 DEKALB CO GA 08/09/84 H3CM4040184-41009 RESEARCH TRIANGLE INSTITUTE NC C3FM4040273-41391 DEKALB CO GA 08/09/84 H3GE4040194-41089 RESEARCHTRIANGLE INST NC C3EM4040270-41 573 ATLANTA GA 09/24/84 H3AM4040219-41129 RESEARCH TRIANGLE INST NC C3FM4040271 -41574 ATLANTA GA 09/24/84 H3AM4040294-41 503 RESEARCH TRIANGLE INST NC D3DM4040151-40855 SOUTHERN RESEARCH INSTITUTE AL 04/03/84 H3AM4040295-41 504 RESEARCH TRIANGLE INST NC D3BM4040152-40856 SOUTHERN RESEARCH INSTITUTE AL 04/03/84 N3GM4040149-40854 NEW HANOVER CO WILMINGTON NC D3AM40401 54-40868 H&R TECHNICAL ASSOC 04/06/84 N3GM40401 47-40866 RALEIGH NC D3DM40401 56-40887 SOUTHERN RESEARCH AL 04/10/84 N3GM40401 57-40895 BOCA RATON FL D3BM4040173-40964 SOUTHERN RESEARCH INST AL 04/25/84 N3GM4040159-40899 FLA DEPT OF AGRI FL IG D3DM4040177-40966 NORTHROP SERVICES NC 04/25/84 N3GM4040160-40900 VOLUSIA COG DAYTONA BCH FL D3DM4040178-40967 NORTHROP SERVICES NC 04/25/84 N3GM4040161-40901 HIGH POINT NC D3AM4040185-41010 ENVIRIONMENTAL SC & ENGR FL 05/07/84 N3GM4040172-40963 BREVARD CO FL D3CM4040216-41128 BRANDON SMITH AND JONES TN 06/08/84 N3GM4040166-40965 SHELBY CO TN D3CM4040220-41130 SOUTHERN RESEARCH INST AL 06/08/84 N3GM4040181-40979 PASCO CO FL D3BM4040230-41 163 SOUTHERN RESEARCH INST AL 06/21/84 N3GM4040192-41085 HUNTSViLLE AL D3DM4040231-41164 SOUTHERN RESEARCH INSTITUTE AL 06/21/84 N3GM4040196-41086 ESCAMBIA CO FL D3CM4040238-41 203 GEORGiA TECH GA 07/02/84 N3GM40401 93-41 088 GULFORD CO NC D3CM4040241-41271 SOUTHERN RESEARCH INST AL 07/16/84 N3GM4040195-41090 MECKLENBURG CO NC D3AM4040248-41272 NORTHROP SERVICES RTP NC 07/16/84 N3GM4040206-41095 KISSIMMEE FL D3AM4040262-41354 BARRY AVIT OR & ASSOC AL 08/01/84 N3GM4040212-41104 DECATUR TN D3AM4040278-41442 ENTROPHY ENVIRONMENTALIST NC 08/22/84 N3GM4040227-41 160 OKALOOSA CO FL D3AM4040287-41443 CONTINENTAL SHELF ASSOC FL 08/22/84 N3GM4040228-41161 ATLANTA REG COM GA D3CM4040289-41464 GEORGIA TECH GA 08/28/84 N3GM4040229-41 162 NORTH CAROLINA ISTATE OF) NE TOTAL OF REGION 03 = 128 29 ------- Audit Control Number Auditee Final Report Issued Audit Control Number Auditee Final Report Issued N3GM4040225-41 167 N3GM4040226-41 168 N3GM4040232-41 169 N3GM4040246-41 230 N3GM4040247-41 231 N3GM4040257-41 286 N3GM4040259-41 287 N3GM4040256-41 294 N3GM4040258-41 295 N3GM4040266-41 374 JOHNSON CITY TN ORANGE CO FL JACKSON MS ALA DEPT PUBLIC HLTH AL SO ALA RPC AL TUSCALOOSA AL PINELLAS CO FL ST PETERSBURG FL EASTCENTRAL FL CRAVEN CO NC 06/22/84 N3GM4040268-41 375 06/22/84 N3GM4040267-41 388 06/22/84 N3GM4040269-41 389 07/06/84 N3GM4040274-41 392 07/06/84 N3GM4040275-41 393 07/20/84 N3GM4040276-41 420 07/20/84 N3GM4040280-41 501 07/23/84 N3GM4040279-41 507 07/23/84 N3GM4040290-41 508 08/03/84 N3GM4040300-41 548 TOTAL OF REGION 04 = 78 POLK CO FL TENN DEPT HLTH & ENVIRON TN ALA DEPT OF EDUCATION AL ALABAMA FORESTRY COMM AL LAKE CITY TN GWINNETT CO GA SAVANNAH GA CHATTANOOGA TN KY NAT RES & ENV PRO. CAB KY TENNESSEE TN C3FC4080045-40986 C3FC4080054-41 221 C3FC4080056-41 282 D3AR4080046-41 063 N3GC4080039-40890 PIKES PEAJ( COG CO PIKES PEAK AREA COUNCIL GOB CO DURANGO CITY OF CO ROGERS & ASSOC SALT LAKE UT COLORADO DEPT OF HEALTH CO TOTAL OF REGION 06 = 37 06/27/84 TOTAL OF REGION 07 = 21 05/04/84 N3GC4080038-4C (891 07/05/84 N3GC4080040-4091 9 07/20/84 N3GC408O042-40920 05/21/84 N3GC4080041 -40921 04/12/84 N3GC4080053-41 145 TOTAL OF REGION 08 = 10 C3EC4050292-41 309 XENIA CY 83 OH 07/25/84 D3AB4050288 -41302 C3FC4050293-41310 XENIA CY 83 OH 07/25/84 D3AB4050303 -41326 C3EC4050294-41 311 NOACA FY 82 & 83 OH 07/25/84 D3AB405031 2-41386 C3FC4050295-4131 2 NOACA FY 82 & 83 OH 07/25/84 D3CB405031 6-41398 C3EC4050296-41313 NIPC FY82 & 83 IL 07/25/84 D3AM4050318 -41411 C3FC4050297-41314 NIPC FY B2 & 83 IL 07/25/84 D3AM4050319 -41422 C3EC4050310-41394 MONTGOMERY CO OH CGHD CY82&83 08/09/84 D3CB4050321 -41446 C3FC405031 1-41395 MONTGOMERY CO OH CGHD CY 82/83 08/09/84 D3AM4050329 -41457 C3EC4050330-41475 NW IN RPC (HIGHLAND) CY 80&81 08/30/84 D3AB4050332 -41473 C3FC4050331-41476 NW IN RPC (HIGHLANDI CY 80&81 08/30/84 D3AB4050333-41474 D3C84050167-40847 UOP PROCESS DIVISION IL 04/03/84 D3AM4050336 -41494 D3DB4050168-40848 GLOBETROTTERS ENGINEERING IL 04/03/84 D3AB4050341 -41533 D3C840501 85-40894 BMI COLUMBUS OH 04/13/84 D3AB4050343-41 552 D3BB4050301 -40911 HNT&B MO 07/30/84 H3CB4050206-4101 1 D3CB4050209-41 065 BMI COLUMBUS OH 05/21/84 N3GC40501 64-40857 D3CB4050210-41066 BMI COLUMBUS OH 05/21/84 N3GC4050165-40858 D3CB4050211-41067 BMI COLUMBUS OH 05/21/84 N3GC4050166-40859 D3BW4050214-41 082 HNT&B FY82 INCURRED COSTS 05/25/84 N3GC4050247-41197 D3CB4050222-41105 MICHIGAN TECH INSTITUTE MI 06/05/84 N3GC4050290 -41307 D3CB4050223-41106 BMI COLUMBUS OH 06/05/84 N3GC4050291 -41308 D3CB4050224-41107 BMI COLUMBUS OH 06/05/84 N3GC4050308-41369 D3DW4050227-41154 CH2M HILL 0/H FY81 OR 06/20/84 N3GC4050314 -41 396 D3DW4050228-41155 CH2M HILL 06/20/84 N3GC4050327 -41458 D3DB4050248-41 198 AUTO TESTING LABS OH 06/29/84 N3GC4050328 -41459 D3AB4050285-41 299 NATIONAL WATER WELL OH 07/24/84 N3GC4050337-41 511 D3AM4050286-41300 GENERAL TELEPHONE OF INDIANA 07/24/84 P3DW4050300 -41342 03AB40502B7-41 301 CUSTOM EDITORIAL PRODUCTIONS 07/24/84 P3BW4050284 -41 564 TOTAL OF REGION 05 = 54 C3EM4060111-40960 TX DEPT OF WATER RESOURCESTX 04/25/84 N3GM4060105 -40884 C3FM4060112-40961 TX DEPT WATER RESOURCES TX 04/25/84 N3GM4060114-40898 C3FM40601 20-40971 SOUTHEAST ARKANSAS RPC 04/27/84 N3GM40601 13-40930 C3EM40601 21-40972 SOUTHEAST ARKANSAS RPC AR 04/27/84 N3GM40601 15-40931 C3EM4060135-41 102 SAN ANTONIO TX 06/05/84 N3GM40601 19-40962 C3FM40601 36-41103 SAN ANTONIO TX 06/05/84 N3GM40601 16-40970 C3EM40601 71-41559 SHREVEPORT LA 09/18/84 N3GM40601 23-40973 C3FM40601 72-41560 SHREVEPORT LA 09/19/84 N3GM40601 34-41093 C3EM4060183-41 561 FAYETTEVILLE AR 09/19/84 N3GM4060147 -41 225 D3AM40601 08-40885 RADIAN CORP TX 04/10/84 N3GM40601 48-41226 D3AM4060109-408B6 RADIAN CORP TX 04/10/84 N3GM4060149-41227 D3CM4060153-41352 SOUTHWEST RESEARCH INST TX 08/01/84 N3GM40601 50-41 228 D3CM4060154-41353 SOUTHWEST RESEARCH INST TX 08/01/84 N3GM4060151-41229 D3AM40601 64-41372 INTRA TECHNOLOGIES TX 08/03/84 N3GM40601 56-41284 D3AM4060170-41441 SCIENCE RESEARCH SYSTEMS LA 08/22/84 N3GM4060155-41285 D3AM4060181-41571 RADIAN CORP TX 09/24/84 N3GM4060162-41370 D3CM40601 84-41572 CREST ENGINEERING OK 09/24/84 N3GM40601 63-41371 E3AM4060097-40863 NATIONAL RURAL WATER ASSOC TX 04/05/84 N3GM4060180 -41 549 H3CU4060138-41 159 HOUSTON UNIV OF TX 06/21/84 C3FC4070114-41264 DEPT OF ENVIRONMENTAL QUAL IA 07/12/84 D3AM4070126 -41413 C3FC4070111-41 265 SENECA CITY OF MO 07/12/84 D3AH4070133 -41 514 C3FC4070120-41323 EL DORADO CITY OF KS 07/26/84 D3AH4070134-41515 C3FC4070132-41471 HUTCHINSON CITY OF KS 08/29/84 N3GC4070107 -41146 C3FC4070140-41535 CHANUTE CITY OF KS 09/12/84 N3GC4070099-41156 C3FC4070143-41538 HAYS CITY OF KS 09/12/84 N3GC4070119 -41280 D3CM4070085-40987 MIDWEST RESEARCH INSTITUTE MO 05/04/84 N3GC4070124-41337 D3CP4070086-4098B MIDWEST RESEARCH INSTITUTE MO 05/04/84 N3GC4070130-41470 D3CM4070087-41 079 MIDWEST RESEARCH INSTITUTE MO 05/24/84 N3GC40701 41-41 536 D3CM4070088-41 080 MIDWEST RESEARCH INSTITUTE MO 05/24/84 N3GC40701 42-41537 D3AM4070096-41184 MIDWEST RESEARCH INSTITUTE MO OB/03/84 08/09/84 08/09/84 08/09/84 08/09/84 08/15/84 09/04/84 09/05/84 09/05/84 09/17/84 07/24/84 07/30/84 08/08/84 08/10/84 08/14/84 08/15/84 08/24/84 08/28/84 08/29/84 08/29/84 08/31/84 09/12/84 09/17/84 05/08/84 04/04/84 04/04/84 04/04/84 06/29/84 07/25/84 07/25/84 08/03/84 08/09/84 08/28/84 08/28/84 09/06/84 07/31/84 09/19/84 04/10/84 04/16/84 04/20/84 04/20/84 04/25/84 04/27/84 04/27/84 06/01/84 07/06/84 07/06/84 07/06/84 07/06/84 07/06/84 07/20/84 07/20/84 08/03/84 08/03/84 09/17/84 08/14/84 09/06/84 09/06/84 06/14/84 06/19/84 07/20/84 07/30/84 08/29/84 09/12/84 09/12/84 04/12/84 04/19/84 04/19/84 04/19/84 06/14/84 BMI 01-I LIFE SYSTEMS INC. OH BMI OH IGT CHICAGO IL AMITY UNLIMITED INC. OH CHAPMAN & ASSOCIATES OH IGT CHICAGO IL COLEJON MECHANICAL CORP OH BABCOCK & WILCOX ALLIANCE OH BABCOCK & WILCOX BARBERTON OH FRED B DEBRA CO. CINCINNATI OH ETA ENGINEERING INC IL OHIO EDISON COMPANY OH U OF MN ST PAUL MN NW MI RPD COMM. MI MIAMI VALLEY RPC COMM. OH METRO COUNCIL OF TWIN CITIES M COLUMBUS ICY 83) OH IL DEPT OF AGRI FY82 & 83 IL BLOOMINGTON CY 82 IN SW IL M&R PC FY 82-83 TRI-COUNTY RPC LANSING CY83 MI MICHIGAN DEPT OF AG FY 81/82 WI DEPT OF AG TRADE/CPFY81/82 MINNESOTA (STATE) (FY 83) ENGINEERING CONSULTANTS INC MI IN STATE BOH INDIANAPOLIS IN SANTE FE NM TEXAS DEPT AGRI TX METROPLAN LITTLE ROCK AR CORPUS CHRISTI TX NEW ORLEANS LA NEW MEXICO HLT & ENVIRONMENT D CAPITAL REGION PL COMM LA FT WORTH TX AUSTIN TX HOUSTON/GALVESTON TX EL PASO TX LUBBOCK TX ARLINGTON TX TEXARKANA TX AMARILLO TX ALBUQUERQUE NM HOUSTON GALVESTON TX SPRINGDALE AR SELLERS & CO KANSAS CITY MO BLACK & VEATCH KANSAS CITY MO MIDWEST RESEARCH INSTITUTE MO LINCOLN CITY OF NE MIDAMERICA REGIONAL COUNCIL MO DEPT OF HEALTH NE EAST-WEST COORDINATING COUN MO DEPT OF HEALTH & ENVIRON KS GEOLOGICAL SURVEY IA JOINT BD OF HEALTH OF KC KS SD DEPARTMENT OF HEALTH SD DENVER REGIONAL COG CO CHEYNNE RIVER SOUIX TRIBE SD BREMERTON CITY OF WA CO ST DEPT OF LABOR & EMP CO 30 ------- Audit Control Number Auditee Final Report Issued Audit Control Number Auditee Final Report Issued 5. SUPERFUND AUDITS TOTAL OF REGION 09 = 48 04/17/84 04/18/84 04/19/84 04/25/84 06/14/84 06/14/84 09/06/84 TOTAL OF REGION 10 = 13 TOTAL OTHER GRANT & CONTRACT AUDITS = 474 E5CCH4O1 0102-41210 E5CH4O1 0103-41376 INLAND POLLUTION CONTROL INC CLEAN HARBORS 07/02/84 E5CH4O1 0133-41547 08/03/84 TOTAL OF REGION 01 = 3 HAZARDOUS WASTE MGMT INC MA 09/14/84 E5BH4020051-41 180 NYSDEC (LOVE CANAL) NY 06/27/84 E5AH40201 54-41331 TOTAL OF REGION 02 = 2 MALCOLM PIRNIE INC NY 07/30/84 05/31/84 E5CM40401 79-41373 06/26/84 TOTAL OF REGION 04 = 3 D5AH4050298-41 324 D5AH4050302-41 325 E5CH3050260-41 078 PRC ENVIRONMENTAL MGMT INC IL LIFE SYSTEMS INC. OH MN PCA 07/26/84 07/30/84 06/13/84 TOTAL OF REGION 05 = 5 07/25/84 09/25/84 E5CH4090047-41 288 IT CORPORATION WILMINGTON CA 07/23/84 TOTAL OF REGION 09 = 1 D5BH41 10052-41298 E5EH41 10009-41033 E5BH41 1 0048-41 049 E5EH2110021-41165 H5CH41 10044-41022 H5BH41 10045-41029 H5CH41 10047-41047 H5CH41 10046-41048 ROY F WESTON INC OERR REVIEW OF CLAIM PROCEDURE INDIANA UNIV FOUNDATION OFFICE EMERG REMEDIAL RESPNSDC RESEARCH TRIANGLE INSTITUTE INDIANA UNIV FOUNDATION INDIANA UNIVERSITY FOUNDATION BIOGENICS INC 06/12/84 05/10/84 05/18/84 06/22/84 05/11/84 05/11/84 05/18/84 05/18/84 TOTAL OF HEADQUARTERS = 15 TOTAL SUPERFUND AUDITS = 29 CENTERS DISEASE CONTROL RESEARCH FOUND STATE U OF NY US COAST GUARD NATIONAL BUREAU OF STANDARDS DEFENSE CONTRACT AUDIT AGENCY NOM AND NBS BROOKHAVEN NATIONAL LAB 05/22/84 06/14/84 04/30/84 04/23/84 07/11/84 07/23/84 08/22/84 D3CM4090094-40989 D3CB40901 20-41039 D3DM4090121-41040 D3DM40901 22-4 1041 D3DM40901 23-41042 D3BM40901 26-41060 D3CM40901 24-41061 D3AH40901 25-41062 D3AM40901 27-4 1096 D3AM4090131-4 1185 D3AM4090132-41 186 D3AM4090133-41 187 D3AR40901 54-41261 D3AB40901 55-41262 D3AM40901 56-41263 D3AM4090161-41357 D3CN40901 62-41358 D3AB40901 63-41359 D3CM40901 64-41365 D3AH40901 65-41366 D3AM40901 66-41367 D3AH40901 75-41414 D3AH40901 76-41415 D3CW40901 77-41416 C3FC41 00051-40892 C3FC41 00052-40910 C3FC41 00053-40922 C3FC41 00058-40955 C3FC4100064-41 143 C3FC4100065-41 144 C3FC4100073-41 512 05/04/84 05/17/84 05/17/84 05/17/84 05/17/84 05/21/84 05/21/84 05/2 1/84 06/01/84 06/27/84 06/27/84 06/27/84 07/12/84 07/12/84 07/12/84 08/01/84 08/01/84 08/01/84 08/02/84 08/02/84 08/02/84 08/14/84 08/14/84 08/14/84 TRW REDONDO CA HAWAII UNIVERSITY OF HI DAMES & MOORE LA CA AIR POLLUTION TECH SD CA STEARNS CONRAD & SCHMIDT CA ROCKWELL INT CANOGA PARK CA BECKMAN INSTRUEMENTS INC CA S-CUBED SAN DIEGO CA ZONGE ENG & RESEARCH ORG AZ ACUREX CORPORATION CA CKY INC REDONDO BEACH CA ENERGY & ENVIRON RESEARCH CA TEKNEKRON RESEARCH INC CA SRI INTERNATIONAL CA ENGINEERING-SCIENCE INC CA ENGINEERING-SCIENCE INC CA DAMES & MOORE LOS ANGELES CA SRI INTERNATIONAL CA ENVIRONERGY CO SAN MATEO CA JACOBS ENGINEERING PASADENA CA ACUREX CORP MT VIEW CA JACOBS ENGINEERING PASADENA CA TETRA TECH INC PASADENA CA DAMES & MOORE LOS ANGELES CA WOODLAND CITY OF WA METROPOLITAN PARK DIST WA BOONEY LAKE CITY OF WA EATONVILLE TOWN OF WA OLYMPIC AIR POLLUTION CTRL WA OREGON DEO OR CASTLE ROCK CITY OF WA D3AB40901 82-41447 D3&A40901 83-41449 D3AW40901 84-41450 D3AM40901 86-41461 D3&A40901 90-41496 D3AB4090191-41497 D3AB40901 92-41498 D3AH40901 94-41524 D3AM40901 95-41525 D3AW4090196-41 526 D3AW4090199-41 544 D3AB4090200-41 545 D3CH4090201 -41546 D3M4090202-41 592 D3CM4090203-41 593 D3CR4090204-41 594 D3AB4090208-41 609 D3AM4090209-41 610 D3M4090210-4161 1 N3GC4090141-41172 N3GC4090142-41 220 N3GC40901 44-41277 N3GC4090185-41451 N3GC4090197-41 534 SYSTEM DEVELOPMENT CORP CA AEROCOMP INC COSTA MESA CA EARTH METRICS BURLINGAME CA EARTH METRICS BURLINGAME CA ROCKWELL INTERNATIONAL CA ENERGY & ENVIRONMENTAL RES CA JONES & STROKES SACRAMENTO CA S-CUBED SAN DIEGO CA MID WEST RESEARCH INSTITUTE MO TETRA TECH INC PASADENA CA ENGINEERING SCIENCE ARCADIA CA JONES & STOKES ASSOC CA SRI INTERNATIONAL CA DAMES & MOORE LOS ANGELES CA SCS ENGINEERS LONG BEACH CA SRI INTERNATIONAL CA WESTEC SERVICES INC CA ENERGY & ENVIRON RESEARCH CA PACIFIC ENVIRON SVCS INC CA SOUTHERN CAL ASSOC OF GOVTS CA DEPT OF CONSER & NAT RES NV KERN COUNTY OF CA COUNCIL OF FRESNO CTY GOVTS CA SACRAMENTO AREA COG CA EARTH TECHNOLOGY CORP WA IDAHO DEPT OF AGRICULTURE ID PUGET SOUND COUNCIL OF GOVTS W MUNI OF METRO SEAITLE WA STATE DEPT OF AGRICULTURE OR YAKIMA COUNTY WA 08/24/84 08/24/84 08/24/84 08/28/84 08/31/84 08/31/84 08/31/84 09/10/84 09/10/84 09/10/84 09/14/84 09/14/84 09/14/84 09/21/84 09/21/84 09/21/84 09/26/84 09/26/84 09/26/84 06/22/84 07/05/84 07/18/84 08/27/84 09/12/84 09/06/84 04/25/84 04/25/84 07/20/84 07/30/84 08/27/84 D3AB4100082-41516 N3GC41 00057-40954 N3GC41 00059-40956 N3GC41 00072-41281 N3GC41 00075-41336 N3GC41 00080-41456 E5CM40401 80-41094 E5EM4040200-41 177 CHEMICAL WASTE MANAGEMENT FL PLASTIFAC GULFPORT MS TRIANGLE RESOURCE ND NC 08/03/84 E5EH4050023-41 304 E5EH4050196-41 587 SF LAB CONTRACTS R5 SF REVIEW OF PLANNING PHASE P H5BH41 10043-41069 H5CH41 10053-41306 O5EH41 10040-40902 O5EH41 10041-40938 O5BH41 10054-41259 05BH41 10056-41297 O5CH41 10059-41444 TOTAL AUDITS = 788 ------- |