&EPA
United States	Office of the Inspector General	August 2001
Environmental Protection	1200 Pennsylvania Ave., N.W. (2460)
Agency	Washington, D C. 20460
EPA's Office of the
Inspector General
Annual
Superfund Report
to the Congress
for Fiscal 2000

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ANNUAL
SUPERFUND REPORT
TO THE CONGRESS
FOR FISCAL 2000
August 2001
US EPA Region 4 Library
SNAFC 9T25
61 Forsyth Street S.W.
Atlanta, GA. 30303
Required by
Section 11 l(k) of the
Comprehensive Environmental Response, Compensation,
and Liability Act of 1980 (CERCLA),
as amended by the Superfund Amendments and
Reauthorization Act of 1986 (SARA)
OFFICE OF THE INSPECTOR GENERAL
U.S. ENVIRONMENTAL PROTECTION AGENCY

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EPA Office of the Inspector General Annual Superfund Report to the Congress for Fiscal 2000	iii
TABLE OF CONTENTS
PURPOSE 	 1
BACKGROUND 	 2
ASSISTANCE TO EPA MANAGEMENT	 3
HAZARDOUS SUBSTANCE SUPERFUND	 5
EPA Earns Unqualified Opinion on Financial Statements 	 5
ASSISTANCE AGREEMENTS 		 6
Ohio Needed to Improve Administration of Superfund Cooperative Agreement	 6
EPA Did Not Deobligate Unliquidated Obligations for IAGs Timely 	 6
REMEDIAL INVESTIGATIONS/FEASIBILITY STUDIES	 8
RESPONSE CLAIMS	 9
INTERNAL AUDITS AND SPECIAL REVIEWS 		11
Brownfields Initiative to Revitalize Urban Areas Had Progressed		11
EPA Planned Additional Tests to Increase Public Confidence in Cleanup		11
National Remedy Review Board Saves Millions in Cleanup Costs 		12
EPA Protected Public Despite Difficulties in Managing Abex Site Cleanup		12
INVESTIGATIVE ACTIVITY	 14
EXHIBIT: FISCAL 2000 SUPERFUND REPORTS	 17
APPENDIX: ABBREVIATIONS	 22
The complete text of selected reviews is available through the EPA OIG
internet home page, http: II www.epa.gov/oigearth

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EPA Office of the Inspector General Annual Superfund Report to the Congress for Fiscal 2000
i
FOREWORD
This report covers fiscal 2000 activities of the
Environmental Protection Agency (EPA) Office
of the Inspector General (OIG), and is our 14th
Annual Superfund Report to the Congress. The
Superfund Amendments and Reauthorization Act
of 1986 (SARA) requires the OIG to audit the
Superfund program annually and to report to
Congress annually on these audits.
In addition to reviewing Agency performance, we
also take a proactive role to help EPA prevent
future problems. During fiscal 2000, we assisted
EPA management in a number of ways. We
conducted a joint review with two other Agency
offices on the management of Superfund
collections and receivables. This review
identified good practices, as well as areas for
improvement for both EPA regions and
Headquarters. The joint team also worked with
the Department of Justice, which has collection
responsibilities, to reconcile EPA and Justice
records and improve coordination between the
two agencies.
As an outgrowth of a site visit for an audit, we
alerted EPA management that storm damage at
the Ramapo Landfill site in New York had not
been repaired after more than a year. We made
suggestions to the Office of Chief Financial
Officer to improve a draft model for estimating
grant accruals at the end of the fiscal year. We
also provided comments to this Office as it
developed policy on Reporting and Tracking
Superfund Accounts Receivable.
In our fiscal 2000 audit of the Hazardous
Substance Superfund financial statements, we
issued an unqualified opinion on the statements,
but there continued to be some areas in which
further improvements were needed. EPA's
financial systems and methodologies were still
not able to fully and reliably account for costs by
strategic goals. EPA also needed to improve
reconciliation of intra-governmental transactions
and security of its core financial systems.
In following up our 1998 audit on Brownfields,
we found EPA had taken significant steps to
implement the recommendations we had made.
We did find some areas where further
improvements, would be helpful. The
Brownfields Cleanup Revolving Loan Fund grant
program pilots have been slow to make loans, and
EPA needed to provide additional flexibility in
that program. Quarterly reports on site
assessment pilots were not always timely.
Finally, EPA needed to better document its site
assessment pilot process. The program provided
a corrective action plan to provide these
improvements.
We reviewed the question at the Lowry Landfill
site in Colorado of whether groundwater was
contaminated with radionuclides from the site.
While Region 8 had made mistakes in how it had
handled some public presentations about site
conditions, it had taken meaningful steps to
improve its communications with the public. The
Region had retained an independent party to
conduct additional groundwater tests to resolve
public concerns and make sure the Lowry cleanup
will adequately protect human health and the
environment.
We reviewed the work of the National Remedy
Review Board, which was created as one of the
Superfund reforms EPA initiated in 1995. The
Board was generally effective in performing
comprehensive reviews of high-cost remedies and
providing advice that fostered consistency in
regional remedial decisions. The estimated cost
savings from its decisions, totaling $68 million at
the time of our review, appeared realistic and
sometimes conservative.
Senator Charles Robb asked us to review some
aspects of the cleanup of the Abex site in
Portsmouth, Virginia. Region 3 had inadvertently
omitted a portion of the contaminated soil
needing cleanup in its cleanup plan, but
discovered the error before cleanup was
scheduled. There were delays in testing duct
work in apartments near the site for lead
contamination which appeared to be related to
EPA's lack of experience in cleaning duct work.
As we recommended, the Region shared the
lessons it learned in this process so that other
regions could benefit from its experience.
Our Superfund investigative efforts continued to
produce fines, restitutions, recoveries, and
convictions for fraud and other improper actions
of EPA contractors. False claims and fraud in the
analyzing of samples from Superfund sites
continued to be the primary bases for indictments
and convictions related to Superfund work. The
major false claims cases completed in fiscal 2000
provided large settlements benefitting other
Federal agencies as well as EPA.

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EPA Office of the Inspector General Annual Superfund Report to the Congress for Fiscal 2000
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The Administration proposed in its fiscal 1998
budget to eliminate the requirement to issue this
report, along with the specific annual audits the
report is required to summarize. This report is
largely duplicative of our semiannual reports.
Elimination of the specific audit requirements,
outlined in the Purpose section of this report
(page 1), would allow us to focus our audit efforts
each year on those areas where they can be most
productive. We encourage the Congress to take
this action.
We will continue to help the Agency implement
Superfund more effectively and efficiently
through program evaluations, audits,
investigations, fraud prevention, and cooperative
efforts with EPA management.
"^u».u,L^A l*-"
Nikki L. Tinsley
Inspector General

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EPA Office of the Inspector General Annual Superfund Report to the Congress for Fiscal 2000	iii
TABLE OF CONTENTS
PURPOSE 	 1
BACKGROUND 	 2
ASSISTANCE TO EPA MANAGEMENT	 3
HAZARDOUS SUBSTANCE SUPERFUND	 5
EPA Earns Unqualified Opinion on Financial Statements 	 5
ASSISTANCE AGREEMENTS 		 6
Ohio Needed to Improve Administration of Superfund Cooperative Agreement	 6
EPA Did Not Deobligate Unliquidated Obligations for Interagency Agreements Timely	 6
REMEDIAL INVESTIGATIONS/FEASIBILITY STUDIES	 8
RESPONSE CLAIMS		 9
INTERNAL AUDITS AND SPECIAL REVIEWS 		11
Brownfields Initiative to Revitalize Urban Areas Had Progressed		11
EPA Planned Additional Tests to Increase Public Confidence in Cleanup		11
The National Remedy Review Board Projects $68 Million Cost Savings 		12
EPA Protected Public Despite Difficulties in Managing Abex Site Cleanup		12
INVESTIGATIVE ACTIVITY	 	 14
EXHIBIT: FISCAL 2000 SUPERFUND REPORTS 	 17
APPENDIX: ABBREVIATIONS 	 22
The complete text of selected reviews is available through the EPA OIG
internet home page, http: // www.epa.gov/oigearth

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EPA Office of the Inspector General Annual Superfund Report to the Congress for Fiscal 2000
1
PURPOSE
We provide this report pursuant to section
11 l (k) of the Comprehensive Environmental
Response, Compensation, and Liability Act of
1980 (CERCLA), as amended. The Superfund
Amendments and Reauthorization Act of 1986
(SARA) amended that section of CERCLA to
add several annual requirements for the
Inspector General of each Federal agency
carrying out CERCLA authorities. These
requirements include four audit areas and an
annual report to Congress about the required
audit work. This report covers fiscal 2000 OIG
Superfund activities. We discuss the required
four audit areas below.
This report summarizes our work in the
mandated audit areas. We also provide a
broader picture of our Superfund efforts by
summarizing other significant Superfund audit
work, assistance to EPA management, and
Superfund investigative work.
Trust Fund
CERCLA requires . . an annual audit of all
payments, obligations, reimbursements, or other
uses of the Fund in the prior fiscal year. . .
We now meet this requirement through the
financial statement audit required by the
Government Management Reform Act.
Claims
CERCLA requires an annual audit to assure ". . .
that claims are being appropriately and
expeditiously considered . . . . " Since SARA
did not include natural resource damage claims
as allowable Fund expenditures, the only claims
provided in CERCLA, as amended, are response
claims.
Cooperative Agreements
CERCLA requires audits . . of a sample of
agreements with States (in accordance with the
provisions of the Single Audit Act) carrying out
response actions under this title . . . . " We
perform financial and compliance audits of
cooperative agreements with States and political
subdivisions. Some of our audits also review
program performance.
Remedial Investigations/Feasibility
Studies
CERCLA requires our ". . . examination of
remedial investigations and feasibility studies
prepared for remedial actions . . . ." We discuss
our approach to this requirement in a chapter of
this report.

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EPA Office of the Inspector General Annual Superfund Report to the Congress for Fiscal 2000
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BACKGROUND
The Comprehensive Environmental Response,
Compensation, and Liability Act of 1980
(CERCLA), Public Law 96-510, enacted on
December 11, 1980, established the "Superfund"
program. The purpose of the Superfund program
is to protect public health and the environment
from the release, or threat of release, of hazardous
substances from abandoned hazardous waste sites
and other sources where other Federal laws do not
require response. CERCLA established a
Hazardous Substance Response Trust Fund to
provide funding for responses ranging from
control of emergencies to permanent remedies at
uncontrolled sites. CERCLA authorized a $ 1.6
billion program financed by a five-year
environmental tax on industry and some general
revenues. CERCLA requires EPA to seek
response, or payment for response, from those
responsible for the problem, including property
owners, generators, and transporters.
The Superfund Amendments and Reauthorization
Act of 1986 (SARA), Public Law 99-499, enacted
October 17, 1986, revised and expanded
CERCLA. SARA reinstituted the environmental
tax and expanded the taxing mechanism available
for a five-year period. It authorized an $8.5
billion program for the 1987-1991 period. It
renamed the Trust Fund the Hazardous Substance
Superfund. The Budget Reconciliation Act of
1990 reauthorized the program for three
additional years and extended the taxing
mechanism for four additional years. Congress
has continued to fund Superfund after expiration
of the authorization and the taxing mechanism.
The basic regulatory blueprint for the Superfund
program is the National Oil and Hazardous
Substances Contingency Plan (NCP), 40 CFR Part
300. The NCP was first published in 1968 as part
of the Federal Water Pollution Control Plan, and
EPA has substantially revised it three times to
meet CERCLA requirements. The NCP lays out
two broad categories of response: removals and
remedial response. Removals are relatively short-
term responses and modify an earlier program
under the Clean Water Act. Remedial response is
. long-term planning and action to provide
permanent remedies for serious abandoned or
uncontrolled hazardous waste sites.
CERCLA recognized that the Federal
Government can only assume responsibility for
remedial response at a limited number of sites
representing the greatest public threat. Therefore,
EPA must maintain a National Priorities List
(NPL), updated at least annually. The NPL
consists primarily of sites ranked based on a
standard scoring system, which evaluates their
threat to public health and the environment. In
addition, CERCLA allows each State to designate
its highest priority site, without regard to the
ranking system.
CERCLA section 104(c)(3) does not allow EPA
to fund remedial actions unless the State in which
the release occurs enters into a contract or
cooperative agreement with EPA to provide
certain assurances, including cost sharing. At
most sites, the State must pay 10 percent of the
costs of remedial action. EPA may fund 100
percent of site assessment activities (preliminary
assessments, site inspections), remedial planning
(remedial investigations, feasibility studies,
remedial designs), and removals. For facilities
operated by a State or political subdivision at the
time of disposal of hazardous substances, the
State must pay 50 percent of all response costs,
including removals and remedial planning
previously conducted.
CERCLA sections 104(c)(3) and 104(d) authorize
EPA to enter into cooperative agreements with
States or political subdivisions to take, or to
participate in, any necessary actions provided
under CERCLA. A cooperative agreement serves
to delineate EPA and State responsibilities for
actions to be taken at the site, obtains required
assurances, and commits Federal funds. EPA
uses cooperative agreements to encourage State
participation in the full range of Superfund
activities - site assessment, remedial, removal,
and enforcement.

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EPA Office of the Inspector General Annual Superfund Report to the Congress for Fiscal 2000
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ASSISTANCE TO EPA MANAGEMENT
Besides performing audits and investigations, the
OIG responds to EPA management requests for
review of vulnerable program areas and OIG
input in the development of regulations, manuals,
directives, guidance, and procurements. These
are efforts to prevent problems that might later
result in negative audit findings or investigative
results, or to respond to prior audit findings. The
OIG reviews and comments on draft documents
prepared by Agency offices. OIG staff also
participates in conferences and EPA work groups
to provide input. The OIG continued such efforts
in fiscal 2000 in assistance to EPA management
both in work specifically focused on Superfund
and in crosscutting work affecting Superfund.
We summarize below some of our Superfund-
related activities assisting management.
Management of Superfund Collections
and Receivables
OIG staff worked on a team with staff from the
Office of Site Remediation Enforcement in the
Office of Enforcement and Compliance
Assurance and from the Financial Management
Division to improve management of Superfund
collections and receivables. When we began this
effort, EPA had more than half a billion dollars in
Superfund accounts receivable that had been
delinquent for longer than 120days. The joint
team visited three EPA regions to identify both
good practices as well as areas needing
improvement. The team also worked with the
Department of Justice, which has collection
responsibilities, to reconcile EPA and Justice
records and improve coordination between the
two Federal agencies. In addition, the team
•identified areas in which EPA Headquarters
offices could provide better guidance and support.
Initiation of Damage Repair at Ramapo
Superfund Site After OIG Site Visit
A site visit by EPA OIG auditors at the Ramapo
Landfill, a Superfund site in Ramapo, New York,
disclosed storm damage had remained unrepaired
for close to a year. Two down chutes had been
damaged by August 1999 rainstorms and the
September 1999 Tropical Storm Floyd. The
geocomposite cover along the down chutes was
exposed down to the rubber impermeable
membrane, with a two-foot-square opening in one
section. A December 1999 EPA Five-Year
Review report had noted the damage and
indicated that the Town intended to repair it in the
spring of 2000. However, due to funding
problems, the Town had not repaired the damage
at the time of our July 18, 2000 site visit, and did
not expect to begin construction for at least two
months. While the conditions did not pose an
imminent danger to public health or the
environment, the potential for substantial
compromise of the integrity of the landfill cap and
subsequent health risk existed as long as the
conditions remained unrepaired.
On August 1, 2000, the OIG issued an advisory
memorandum urging temporary measures be
taken to protect the site until the permanent repair
could be undertaken. On September 26, 2000,
Region 2 responded to our memorandum with an
update in the status of cap repair work at the
Ramapo Landfill site. The Region reported that
the Town had awarded an engineering and
construction contract for redesign of the landfill's
surface drainage system and repair of the landfill
cap. The Region indicated that construction was
underway.
Lowry Landfill
We worked closely with Region 8 to implement
recommendations in our Region 8 Lowry Landfill
Groundwater Treatment Decision Has Been the
Subject of Public Criticism and Negative
Publicity report, issued on February 29, 2000.
Region 8 consulted with us regarding the
recommended role of the United States
Geological Survey in determining the amount and
level of radionuclides at the Lowry Landfill.
Development of Model for Grant
Accruals
The Office of the Chief Financial Officer (OCFO)
engaged a major international accounting firm to
assist them in developing an approach to provide
grant accrual information for the EPA year end
financial statements. It is necessary to have an
accurate grant accrual estimate to meet
accounting standards and earn a clean opinion on
EPA's financial statements, including the
Superfund Trust Fund Financial Statements.
The firm developed a proposed mathematical
model using historical data to meet OCFO's
needs. The OIG analyzed the approach provided
by the OCFO and expert contractor and concluded

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EPA Office of the Inspector General Annual Superfund Report to the Congress for Fiscal 2000
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that the approach was flawed, and that it would
inevitably result in the EPA receiving a qualified
opinion on their fiscal 2000 financial statements.
The grant accrual projection that the model
provided would have understated the true accrual
by a material amount.
The OIG recommended a potential solution to the
flaw in the model. OCFO considered our
recommendation and adopted our proposed
solution.
Agency Oversight Costs under
Superfund Unilateral Administrative
Orders
In response to prior audit recommendations,
OCFO specifically addressed the tracking of
demands for Agency oversight costs incurred
under Superfund Unilateral Administrative Orders
(UAOs) by issuing policy on Reporting and
Tracking Superfund Accounts Receivable in
January 2000. The guidance clarified the
difference between administrative orders and
UAOs, and described when amounts due under
these documents should either be recorded as
accounts receivable or tracked within the
Agency's Integrated Financial Management
System. During the development of this
guidance, the OIG commented on drafts to ensure
our audit concerns were adequately addressed.

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EPA Office of the Inspector General Annual Superfund Report to the Congress for Fiscal 2000
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HAZARDOUS SUBSTANCE SUPERFUND
The Government Management Reform Act
requires Federal agencies to prepare annual
audited financial statements. The requirement for
audited financial statements was enacted to help
bring about improvements in agencies' financial
management practices, systems and controls so
that timely, reliable information is available for
managing Federal programs. One of the major
entities covered by these financial statements is
the Hazardous Substance Superfund Trust Fund.
The EPA OIG's requirement to audit EPA's
financial statements also meets our CERCLA
audit requirement to annually audit the Superfund
Trust Fund, which we previously referred to as
our Trust Fund audit. The following summary of
our fiscal 2000 financial statement audit relates to
all findings resulting from our audit of EPA's
financial statements, including the Hazardous
Substance Superfund.
EPA Earns Unqualified Opinion
on Financial Statements
EPA earned an unqualified opinion on its fiscal
2000 financial statements. This is a major
accomplishment for the Agency. Nonetheless, the
Agency needs to further improve its financial
statement preparation processes to ensure
accuracy, timeliness, and better day-to-day
management. In evaluating EPA's internal
controls, we noted certain matters that we
consider to be reportable conditions, but none are
believed to be a material weaknesses which would
prevent the presentation of reliable financial
statement amounts.
We did not identify any instances of
noncompliance with laws and regulations that
would result in material misstatements to the
audited financial statements. However, we did
note EPA was not in substantial compliance with
Statement of Federal Financial Accounting
Standards No. 4 that requires EPA to determine
the full costs of its activities, regularly
accumulate and report cost of activities, and use
appropriate costing methodologies. We also
noted noncompliance related to reconciliation of
intra-governmental transactions and financial
system security.
EPA continues to make progress with completing
Federal Financial Management Improvement Act
remediation plan actions. EPA made significant
improvements in the financial statement
preparation process, financial system security
plan, and federal trading partner information.
In response to our draft report, the Agency
concurred with most of our recommendations and
indicated it had completed or planned a number of
corrective actions. However, the Agency
disagreed with our conclusions that the process for
preparing financial statements was a reportable
condition and that there was noncompliance with
the managerial cost accounting standard. We
issued the final report (2001-1-00107) on
February 28, 2001.
In its July 5, 2001, response to our final report, the
Agency reported further progress in implementing
corrective actions. It also continued to disagree
with us on the issues noted in the paragraph
above, although it is taking some corrective
actions relative to those issues. We will continue
to work toward ultimate resolution of these issues.

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EPA Office of the Inspector General Annual Superfund Report to the Congress for Fiscal 2000
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ASSISTANCE
In fiscal 2000, we issued two reports reviewing
cooperative agreements with states, and a report
on deobligation oflnteragency Agreement
(IAG) funds.
We summarize the more significant of the
cooperative agreement reports and the IAG
deobligations report below.
Ohio Needed to Improve
Administration of Superfund
Cooperative Agreement
The Ohio Environmental Protection Agency
(Ohio) needed to improve its financial and
program results reporting and its procedures for
drawing down cash under a consolidated
Superfund cooperative agreement that provided
$5.5 million in federal funding.
On September 30, 1997, EPA Region 5 awarded
Ohio a consolidated cooperative agreement for
several different types of general and site-
specific Superfund activities. The agreement, as
amended, authorized federal assistance of
$5,528,747 and required State matching costs of
$192,732 through June 30, 2001. Although in
general Ohio was meeting the objectives of the
cooperative agreement, we found that:
•	Ohio had not met its 10 percent cost
sharing requirement for core activities in
fiscal years 1998 and 1999. As of
September 30, 1999, Ohio had under-
matched core activity expenses by more
than $76,000.
•	Ohio's cash draw downs exceeded the
Federal share of expenses under the
cooperative agreement. As a result, Ohio
frequently carried excess cash balances at
the end of the month and occasionally did
not request enough funds to cover
expenses, resulting in a negative cash
balance at the end of the month.
•	Ohio had not submitted accurate or timely
Financial Status Reports. As a result,
Region 5 was not aware of the financial
status of the program or the misstatement
of Federal and State expenses.
AGREEMENTS
• Ohio had not always identified the site-
specific activity performed in its fiscal year
1999 progress reports. As a result, Region
5 may not be able to recover more than
$45,000 of Ohio's payroll costs from
responsible parties because the specific
tasks were not always identified.
We recommended that the Regional
Administrator for Region 5: (1) clarify reporting
requirements for Ohio, (2) ensure that Ohio
reconciles and confirms its cost sharing
requirements, (3) require Ohio to develop an
effective method for determining cash needs,
and (4) require Ohio to ensure that employees
provide the description of the work required to
support cost recovery efforts. The Regional
Administrator and Ohio agreed to work together
to resolve the issues and implement
recommendations. We issued the final report
(2000-P-00020) on September 15, 2000.
Because the Region's proposed actions in
response to the draft report would address the
findings and recommendations in our report, we
closed the final report upon issuance.
EPA Did Not Deobligate
Unliquidated Obligations for
(AGs Timely 	
EPA spends millions of dollars each year to
obtain goods or services from other Federal
agencies through I AGs, much of it in connection
with the Superfund program. In December
1998, EPA had $1.29 billion in open obligations
for IAGs. We found unliquidated obligations
for IAGs were not deobligated in a timely
manner because the responsible agency officials
had not placed sufficient emphasis on oversight
of these funds. The deobligation process is
critical to EPA's efforts to maximize the use of
funds. Although the Agency has policies and
procedures governing the responsibilities for
oversight of IAGs, and for deobligating funds,
Agency officials did not consistently follow the
procedures. This resulted in IAG funds
remaining obligated to projects which were
either completed or canceled. Of the $4.7
million in unliquidated obligations reviewed, we
identified $2.3 million (49 percent) which
should have been deobligated and used for other
purposes, or which may have expired.

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EPA Office of the Inspector General Annual Superfund Report to the Congress for Fiscal 2000
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We determined that: (1) funds from inactive
lAGs had not been timely deobligated, (2)
interaction among Agency offices to deobligate
IAG funds needed improvement, (3) the
unliquidated review process could be
strengthened, (4) Region 7 and Region 2 were
proactive in deobligating IAG funds, and (5) the
new IAG Close-Out Policy was a key factor in
more IAG funds being deobligated. We
concluded that Agency officials responsible for
IAG funds control need to exercise better
oversight of unliquidated obligations, and
consistently implement their IAG policies and
procedures.
We recommended that EPA deobligate $2.3
million in unliquidated obligations no longer
valid, and review all IAGs inactive for 18
months or more to determine if funds should be
deobligated. We also recommended the
reinforcement of responsibilities for the ongoing
review of IAG funds. To enhance EPA's review
process, we recommended that the annual
unliquidated obligation report be prepared in a
format showing the age of the outstanding
unliquidated balances.
We issued the final report (2000-P-00004) to the
Assistant Administrator for Administration and
Resources Management and the Chief Financial
Officer on December 10, 1999. In response to
our report, the Agency agreed to actions to
address the issues we raised although with some
alternative approaches to our recommendations.

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EPA Office of the Inspector General Annual Superfund Report to the Congress for Fiscal 2000
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REMEDIAL INVESTIGATIONS/FEASIBILITY STUDIES
We explained in last year's Report that we had
refocused our attention to Superfund site
characterization and remedy selection. In that
reporting period, we undertook in-depth reviews
of the reliability of site-specific analytical data as
a basis for sound site remediation decisions.
The remedial investigation/feasibility study
activity at Superfund sites is highly data
dependent, [f analytical data quality is
inadequate, even strict adherence to Agency rules
and guidance in carrying out the remedial
investigation/feasibility study process will not
assure sound decision making.
In fiscal 1999 we initiated assessment of instances
of possible misrepresentation of analytical data
produced in both Agency and contractor
laboratories. We continued those assessments in
fiscal 2000.
We also completed acquisition and testing of an
automated analytical data processing system that
enables us to review analytical data sets for
indications of improper manual manipulation of
noncompliant analytical results to achieve
method-specified or contract-specified quality.
We are using this tool in support of ongoing
investigations of suspected laboratory fraud, and
it is also available for assessing analytical data
quality on an ongoing basis.
We believe that our resources are better used in
seeking to assure data of known quality to support
Superfund remedial decision making than in site-
specific retrospective reviews of the remedial
planning process.

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EPA Office of the Inspector General Annual Superfund Report to the Congress for Fiscal 2000
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RESPONSE CLAIMS
Section I 1 1(a)(2) of CERCLA, as amended by
SARA, authorizes EPA to pay any claim for
response costs incurred by "any other person" as a
result of carrying out the NCP. Additionally,
section 122(b)(1) of CERCLA, as amended by
SARA, authorizes the President to reimburse
Potentially Responsible Parties (PRPs) for
"certain costs of actions under the agreement that
the parties have agreed to perform but which the
President has agreed to finance." The President
delegated this authority to the EPA Administrator
under Executive Order 12580, January 26, 1987,
who further delegated it to EPA's Office of Solid
Waste and Emergency Response. Authority for
decisions regarding claims against the Fund is
currently delegated to the Director, Office of
Emergency and Remedial Response.
PRPs are required to enter into a Preauthorized
Decision Document (PDD) with EPA to cover
work for which some costs will be reimbursed.
The PDD specifies the work to be performed, the
portion of the cost that EPA will reimburse, and
the procedures through which the PRPs can make
claims for reimbursement.
During fiscal 2000, we issued four memorandums
concerning our reviews of response claims. Our
response claim reviews are not audits, but rather
follow instructions in the Agency's claims
guidance for the claims adjuster.
Parker Landfill Site
We reviewed claimed costs of $4,156,800 for
work performed to clean up the Parker Landfill
site in Lyndon, Vermont. Under the PDD for the
site, the claimant cleaning up the site is entitled to
submit claims covering 47 per cent of eligible
costs, not to exceed a total of $3,015,432. This
was the first claim submitted, and was for costs
incurred from August 5, 1997 through
December 31, 1999.
In our memorandum of August 21, 2000 (2000-S-
00005), we recommended that the claim be paid
except for $302,590 ($142,217 EPA share) in
ineligible, unsupported, and unreasonable costs.
We questioned $277,439 as ineligible because the
costs were incurred prior to the PDD date. We
also questioned $18,001 as unsupported because
there was no documentation that it had been paid.
In addition, we questioned $7,150 as
unreasonable because it was a cost estimate which
the claimant mistook for an invoice. We also
made recommendations for improvements in the
claimant's cost accounting procedures.
EPA allowed the costs questioned as ineligible
because the claimant had been expressly told that
pre-PDD costs would be covered in this case.
EPA disallowed the costs we questioned as
unsupported and unreasonable
LCP Chemicals Site
We reviewed claimed costs of $6,323,041 for
work performed to clean up the LCP Chemicals
site in Brunswick, Georgia. Under the PDD for
the site, the three claimants cleaning up the site
are entitled to submit claims covering 34.5 per
cent of eligible costs, not to exceed a total of
$1,700,000.
In our memorandum of November 3, 1999, we
questioned $138,801 in claimed costs as
unsupported because we found no documentation
that this amount was actually paid. Because the
EPA portion of the accepted claimed costs still
exceeded the PDD ceiling, we recommended
acceptance of the claimed amount of $ 1,700,000.
Harvey & Knotts Drum Site
We reviewed a claim of $ 1,1 82,206 for work
performed to clean up the Harvey & Knotts Drum
site in Kirkwood, Delaware. Under the PDD for
the site, the claimant cleaning up the site is
entitled to submit claims covering one-third of
eligible costs, not to exceed a total of $3,086,000.
In our memorandum of July 6, 2000 (2000-M-
00018), we questioned $48,000 of the claimed
$3,550,167 total costs ($16,000 EPA share)
because they were double billed. The claimant
concurred with this finding. We recommended
the claimant be awarded the balance of
$1,166,206.
C & D Recycling Site
We reviewed claimed costs of $5,735,213.99 for
work performed to clean up the C & D Recycling
site in Foster Township, Luzerne County,
Pennsylvania. Under the PDD for the site, the
claimant cleaning up the site was entitled to
submit claims not to exceed a total of $3,000,000.
During our review, we identified additional costs

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EPA Office of the Inspector General Annual Superfund Report to the Congress for Fiscal 2000
10
totaling $1,482,476.88. However, this has no
effect on the amount to be paid because of the
$3,000,000 cap. In our memorandum of May 17,
2000 (2000-M-00013), we recommended the
claimant be paid the requested $3,000,000 cap
amount.

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EPA Office of the Inspector General Annual Superfund Report to the Congress for Fiscal 2000
11
INTERNAL AUDITS AND SPECIAL REVIEWS
In addition to reviews required by CERCLA, as
amended, we conduct other reviews of EPA's
management of the Superfund program. We
summarize below some particularly significant
reviews of EPA management completed in fiscal
2000 not summarized elsewhere in this Report.
Brownfields Initiative to
Revitalize Urban Areas Had
Progressed	
EPA had taken significant steps to implement
recommendations in our original March 1998
report. For example, the Brownfields pilot
proposals were more focused on site assessment
than before. Also, site assessment pilots were
providing better quarterly reports to EPA.
However, the loan program had been slow to
make loans, and better reporting and
documentation were needed in certain areas
relating to site assessment pilots. The purpose of
the Brownfields Initiative is to restore
contaminated industrial and commercial facilities
to productive use. The following areas needed
improvement:
•	The Brownfields Cleanup Revolving Loan
Fund (BCRLF) grant program pilots had
been slow to make loans. As of June 30,
2000, only about $1 million of $43 million
available had been lent, and only one
cleanup had been completed. The Fund
needed additional flexibility and time before
its success can be fairly evaluated.
•	Site assessment pilots needed to improve on
the timeliness of their quarterly reports to
EPA.
•	The site assessment pilot selection process
needed to be better documented. In general,
the strength of regional quality assurance
programs varied.
We recommended that EPA complete
implementing our prior recommendations, revise
and better document the results of the assessment
pilot selection process, evaluate regional
implementation of quality assurance guidelines,
and clarify pilot reporting requirements. The
Agency's response to our draft report included
corrective actions that, when completed, will
address the recommendations. We issued the
final report (2000-P-00027) on September 29,
2000. As of August 2001, the Agency reported
that the BCRLF pilots had made nine loans for a
total of $2.66 million, with additional loans in
process.
EPA Planned Additional Tests to
Increase Public Confidence in
Cleanup
Region 8 was confident that the risk from
radionuclides at the Lowry Landfill site is low,
and that early warning systems and effective
monitoring to detect radionuclides throughout the
treatment process should ensure protection. We
found no apparent credible evidence that
man-made radionuclides were illegally disposed
at the Lowry site. Region 8 had taken steps,
including hiring an independent party to conduct
additional groundwater tests, to assure the Lowry
cleanup plan adequately protects human health
and the environment and help allay public
concerns.
From the mid-1960s until 1980, the City and
County of Denver operated an industrial liquid
waste and municipal solid waste landfill at the
Lowry Landfill site. More than 130 million
gallons of liquid waste were disposed of at the
site. Over time the liquid seeped through the soil
and mixed with groundwater. Some members of
the public criticized the way Region 8 addressed
the question of whether radionuclides (materials
that exhibit radioactive decay) were in the
groundwater at the Lowry site and challenged
whether the Lowry cleanup plan adequately
protected human health and the environment.
Radionuclides can cause potential health effects
in humans by directly damaging sensitive
biological tissue.
Region 8 did not effectively manage four public
presentations we evaluated in which members of
the public, concerned about radionuclides,
challenged the Region's decision to send Lowry
groundwater offsite to public wastewater
treatment facilities. Region 8's mistakes in the
handling of the presentations increased public
criticism and negative publicity about its offsite
treatment decision. We found Region 8 had taken
meaningful steps to more effectively
communicate with the public and better manage
situations when the public challenges its cleanup

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EPA Office of the Inspector General Annual Superfund Report to the Congress for Fiscal 2000
12
decisions.
We recommended that the Regional
Administrator implement the independent party's
recommendations, as appropriate, to ensure
monitoring and early warning systems are
adequate to detect unacceptable levels of
radionuclides in groundwater before it leaves the
site; clearly explain to the public the factors
involved in making site decisions; and carefully
plan for all public meetings.
We issued the final report (2000-P-00007) to the
Region 8 Administrator on February 29, 2000. In
response to the draft report, the Region concurred
with the recommendations in the report and
indicated that it was taking steps to address them.
In response to the final report, the Region
provided an action plan for implementing the
recommendations.
National Remedy Review Board
Saves Millions in Cleanup Costs
Actions by EPA's National Remedy Review
Board (NRRB) will save an estimated $68 million
at Superfund cleanup sites. These savings are
attributable to effective operations and decisions
by the NRRB.
In 1995, EPA created the NRRB as part of a
comprehensive package of reforms to make the
Superfund program faster, fairer and more
efficient. The NRRB is a peer group composed of
20 EPA managers and senior technical experts.
NRRB's goal is to annually review about 10
percent of all proposed cleanup remedies for
Superfund sites. The reviews are generally
limited to proposed high-cost cleanup decisions
that meet specific dollar thresholds to assure that
the proposed remedies are cost efficient and
consistent with current law, regulations, and
guidance. As of December 1998, the NRRB had
reviewed proposed cleanup decisions for 34 sites
with estimated costs of almost $2.9 billion. As of
January 1999, EPA regions had documented
estimated future savings of $68 million based on
NRRB recommendations for seven of the 34 sites.
We found the NRRB was generally effective in
performing comprehensive reviews of high-cost
remedies and providing advice that fostered
consistency in regional remedial decisions. The
estimated savings resulting from the NRRB's
decisions appeared to be realistic and sometimes
conservative. NRRB's requirements for regional
proposal packages and subsequent reviews have
also promoted improved decision-making and
documentation of proposed remedies by regional
staffs. We identified several opportunities for
EPA to improve the NRRB's operations and
offered suggestions for implementing these
improvements.
We issued the final report (2000-P-00005) to the
Assistant Administrator for Solid Waste and
Emergency Response on December 21, 1999.
Since there were no formal recommendations, the
report was closed upon issuance.
EPA Protected Public Despite
Difficulties in Managing Abex
Site Cleanup	
Senator Charles Robb requested that our office
review specific topics related to EPA's cleanup of
the Abex Superfund site in Portsmouth, Virginia.
His office was concerned about the adequacy of
site cleanup and whether Region 3 sufficiently
addressed concerns of the Washington Park
Housing residents about lead in their heating
ducts.
The Region inadvertently omitted a portion of the
contaminated soil in the cleanup plan. However,
this oversight was discovered before the
contaminated area was scheduled for cleanup.
There was an unusual amount of personnel
turnover during the design phase, with three
remedial project managers assigned to this site in
a 14-month period. The Region indicated this
turnover contributed to the misunderstanding of
what area was to be cleaned up. We later
reviewed this issue separately.
Between 1997 and 1999, the Region conducted
lead sampling inside the apartments and did not
find significant amounts of contamination.
However, the Region did find lead at levels of
concern inside the ducts and arranged cleanup.
Because EPA had no prior experience in cleaning
duct work, we did not consider delays in testing to
be intentional.
We recommended the Region inform other EPA
Regions of its experience with testing inside ducts
for lead contaminants. We issued our final
memorandum report (2000-S-00006) to the
Region 3 Administrator on August 31, 2000. In
response to the final report, the Region issued a

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EPA Office of the Inspector General Annual Superfund Report to the Congress for Fiscal 2000	13
memorandum to its site managers on lessons	Headquarters for sharing with other regions,
learned and transmitted that memorandum to

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EPA Office of the Inspector General Annual Superfund Report to the Congress for Fiscal 2000
14
INVESTIGATIVE ACTIVITY
The OIG Office of Investigations (01) continues
to focus its investigative resources on high cost
program and administrative areas. Priority is also
given to environmental programs and employees
when the action under investigation has the
potential to seriously undermine the integrity of
the Agency and/or the public trust in its ability to
carry out its mission to protect public health and
safeguard the environment. Many of our
investigations resulted in successful prosecutions
of companies and individuals who jeopardized
public health and the environment by falsifying
environmental test data and reports that the
Agency, local governments, and individual
customers rely on to assess threats and control
hazardous wastes, toxins, and other contaminants
that pollute our ground water, rivers, and streams.
Major proactive investigative efforts have
covered all stages of the Superfund program, with
a special emphasis on contracting for removals
and remediation. As a result of 01 proactive
efforts in prior years, we continue to initiate
criminal investigations across the nation. We
continue to see a corresponding increase in the
number of civil cases filed as a result of this
investigative activity. Responding to an increase
in investigative referrals, Of continued its
initiative to detect and investigate laboratory
fraud within the environmental community,
involving commercial, contractual, and Agency,
laboratories. Over the last five years, monetary
fines, restitution, and recoveries resulting from
Superfund program investigations totaled more
than $75 million. We expect to see a continued
increase in significant actions as a result of OI's
investigative emphasis on major Agency
contracting.
During fiscal 2000, our Superfund investigative
efforts resulted in 1 conviction, 13 indictments,
and II civil/administrative actions. Monetary
fines, restitution, and recoveries resulting from
investigations totaled $61.9 million. At the end of
fiscal 2000, we had 57 active Superfund
investigations, 33 percent of all active OIG
investigations at EPA.
We give examples of Superfund investigative
activity with results in fiscal 2000 in the
following synopses.
Excess Lease Costs Case Resulted in
$35 Million Settlement
In March 2000, Jacobs Engineering Group, Inc.
(Jacobs), entered into an agreement with the
United States in U.S. District Court, Central
District of California, to settle a civil lawsuit
charging that Jacobs submitted false claims for 15
years by charging excess lease costs to its
government contracts. The original complaint
was filed as a False Claims Act qui tam suit
alleging that Jacobs had knowingly violated a
provision of the Federal Acquisition Regulation
governing sales and leaseback arrangements.
The suit alleged that Jacobs overcharged the EPA;
the Departments of the Air Force, Army, and
Navy; the Department of Energy; and the
National Aeronautics and Space Administration.
According to the complaint, Jacobs sold its
corporate headquarters in 1982 and then entered
into a 15-year leaseback agreement that included
rates in excess of its prior ownership costs,
passing the higher rental costs to the government
in the form of unallowable charges on its
contracts. Jacobs, headquartered in California
and one of the largest global engineering,
architecture, technology, and construction firms,
had performed work for EPA under the
construction grant program. EPA was awarded
$669,674 in damages by the settlement.
This investigation was conducted jointly by the
EPA OIG, the Air Force Office of Special
Investigations, the Naval Criminal Investigative
Service, the Army Criminal Investigation Division
Command, and the Department of Energy OIG,
with the Defense Contract Audit Agency
providing audit support.
Contractor False Claims Settlement
Saved EPA $24.3 Million
Kaiser Group International, Inc., entered into a
settlement with the United States Attorney's
Office under which the government will realize
$24.3 million in contract savings. The agreement,
reached on September 15, 2000, in the Eastern
District of Virginia, settled a federal False Claims
Act case that involved the EPA and 17 other
federal departments/agencies.
The settlement was the culmination of a lengthy
investigation that disclosed that Kaiser (formerly

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EPA Office of the Inspector General Annual Superfund Report to the Congress for Fiscal 2000
15
ICF Kaiser International, Inc.) billed government
contracts for computer center costs in excess of
costs actually incurred. In addition, EPA OIG
questioned costs relating to the allocability,
allowability, and reasonableness of Kaiser's
direct and indirect costs dating back to their fiscal
year ending February 28, 1985, due to
unsatisfactory documentary support.
Under the terms of the settlement agreement, the
government's potential contract savings could
reach $390.1 million pending verification of
unbilled obligated fund balances by the 17 other
federal departments/agencies. In settling the final
rates, EPA to date will realize $23.2 million in
contract savings due to Kaiser's agreement to
relinquish all rights in potential claims in the form
of retainages, rate variances, costs, profits, and
fees accrued or otherwise owed in connection
with services provided under a schedule of
government contracts from March 1, 1985
through December 31, 1999. Additionally, in
settling the alleged false claims associated with
the computer center over billing, Kaiser agreed to
forgo $828,604 in repudiated claims against two
Department of the Navy contracts. This
investigation was conducted jointly by the EPA
OIG and the Nuclear Regulatory Commission
OIG
Three Laboratory Employees
Sentenced for Falsifying Test Results
at a North Carolina Laboratory
Three employees of CompuChem Environmental
Corporation of Cary, North Carolina, were
sentenced in U. S. District Court, Eastern District
of North Carolina, on charges of making a false
statement and aiding and abetting others in the
commission of making a false statement.
On October 29, 2000, Mark Bevan, a laboratory
supervisor, was sentenced to 3 years probation,
100 hours of community service, and ordered to
pay a $1,000 fine. On December 16, 1999,
Richard P. Lemis, a second shift supervisor at the
laboratory, was sentenced to 3 years probation, 75
hours of community service, and ordered to pay
$2,100 in restitution. On December 17, 1999,
Valerie Smith, a chemist, was sentenced to 5
years probation, a period of home confinement
not to exceed 180 consecutive days, 100 hours of
community service, and ordered to pay $1,800 in
restitution.
Bevan, Lemis, and Smith had been charged with
conducting improper gas chromatograph/mass
spectrometer analyses on samples taken from
hazardous waste sites nationwide and falsely
certifying that the analyses complied with all EPA
contract requirements. The EPA relies on the
testing data provided by laboratories participating
in the Contract Laboratory Program to assess
threats to public health and the environment and
to determine where and when remedial action is
needed.
Former Employees of Laboratory
Contractor Charged in 30-Count
Indictment
A vice president and 12 former employees of
Intertek Testing Services Environmental
Laboratories, Inc. (ITS), were indicted in U.S.
District Court on charges of conspiracy, mail
fraud, wire fraud, and presenting false claims
against the United States. The indictments were
handed down on September 21, 2000, in the
Northern District of Texas. ITS was formerly
known as NDRC Laboratories, Inc., and Inchcape
Testing Services Environmental Laboratories, Inc.
Between January 1994 and December 1997, ITS,
a full-service environmental testing laboratory,
generated $35.7 million in gross billings and
performed environmental sample analysis on
more than 59,000 separate environmental projects
involving more than 250,000 samples of air, soil,
liquids, pesticides, explosives, and
nerve/chemical agents. These analyses were
conducted for determining, among other things,
the presence of known or suspected human
cancer-causing contaminants.
The 30-count indictment charges that each of the
13 named defendants was involved in the
conspiracy at some time during the period 1988
through 1997. The alleged conspiracy involved:
•	altering data to make diagnostic instruments
appear to be properly calibrated and within
the quality control limits when they were
not;
•	falsely certifying that the equipment used to
perform the analyses was properly calibrated
and within the quality assurance/quality
control criteria set by their clients and the
EPA;
•	presenting reports of analysis on previously
submitted environmental samples; and
•	representing that ITS analysis of samples

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EPA Office of the Inspector General Annual Superfund Report to the Congress for Fiscal 2000
16
was done in accordance with contract
specifications requiring specific procedures,
quality controls, and assurance methods.
This investigation was conducted jointly by the
EPA OIG, the EPA Criminal Investigations
Division, the Defense Criminal Investigative
Service, the Army Criminal Investigation
Command, and the Air Force Office of Special
Investigations.

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EPA Office of the Inspector General Annual Superfund Report to the Congress for Fiscal 2000	17
Exhibit
Page 1 of 5
FISCAL 2000 SUPERFUND REPORTS
Internal and Management Reports	J
Report No. Description	Date
Review Related to Statutory Requirements (other than IG Act)
2000-P-00002 Superfund Annual Report to Congress Review-Fiscal 1998	10/27/99
Follow-up Reviews
2000-P-00027 Brownfields Initiative to Revitalize Urban Areas	9/29/00
2000-P-00026 Region 5's Billing and Collections of Accounts Receivable	9/28/00
Other Performance Reviews
2000-S-00006 Abex Superfund Site Management	8/31/00
2000-P-00004 Interagency Agreement Deobligations	12/10/99
2000-P-00007 Lowry Landfill Groundwater Treatment Decision	2/22/00
2000-P-00005 National Remedy Review Board Effectiveness	12/21/99
2000-P-00014 Region 2's Collection of Oversight Costs from PRPs	3/29/00
Cooperative Agreement Reports	J
2000-3-00100 Delaware Dept of Natural Resources and Environmental Control 6/14/00
2000-P-00020 Ohio Environmental Protection Agency	9/18/00
Response Claims Reports1	I
2000-M-00013 C & D Recycling Site, Foster Township, Luzerne County, PA	5/17/00
2000-M-00018 Harvey & Knotts Drum site, Kirkwood, Delaware	7/ 6/00
2000-S-00005 Parker Landfill site, Lyndon, Vermont	8/21/00
Contract Reports 	J
Initial Pricing Reviews (Preaward Audits)
2000-2-00033"Ecology & Environment, Inc - Army & Air Force Natl	Guard 9/29/00
2000-2-00014 Ecology & Environment, Inc. - Site Assessment Team -	Region 2 8/18/00
2000-2-00013 Ecology & Environment, Inc - START - Region 4	8/18/00
2000-2-00016 Ecology & Environment, Inc - START - Region 8	9/20/00
2000-2-00015 Malcolm Pirme, Inc. - Site Assessment Team - Region	2 8/25/00
1 Some response claims reviews may be completed with just a memorandum and not a
numbered report.

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EPA Office of the Inspector General Annual Superfund Report to the Congress for Fiscal 2000
18
Exhibit
Page 2 of 5
FISCAL 2000 SUPERFUND REPORTS
Contract Reports (continued)	fc
Report No. Auditee/Description	Date
Incurred Costs
2000-1-00315 Ageiss Environmental. Inc - Fiscal 1997	6/ 7/00
2000-1 -00127 Armstrong Data Services - Fiscal 1996	12/14/99
2000-1-00293 Arthur D Little - Fiscal 1995	5/ 8/00
2000-1-00292 Arthur D. Little - Fiscal 1996	5/ 8/00
2000-1-00063 Bechtel Group, Inc - Fiscal 1996	10/22/99
2000-1-00249 Bechtel Group, Inc. - Fiscal 1996	3/22/00
2000-1-00186 Bechtel Group, Inc - Fiscal 1997	1/24/00
2000-1-00248 Bechtel Group, Inc. - Fiscal 1998	3/16/00
2000-1-00218 Bionetics Corp. - Fiscal 1996	2/ 9/00
2000-1-00136 Black & Veatch - Fiscal 1993 ARCS	12/17/99
2000-1-00139 Black & Veatch Special Projects Corp. - Fiscal 1995	12/17/99
2000-1-00137 Black & Veatch Waste Science - Calendar 1994 ARCS	12/17/99
2000-1-00138 Black & Veatch Waste Science - Calendar 1994 ARCS	12/17/99
2000-1-00038 Booz & Allen - Fiscal 1998	10/12/99
2000-1-00350 Brown & Root Environmental - Fiscal 1997	8/ 4/00
2000-1-00337 CDM Federal Programs Corp - Fiscal 1998	7/10/00
2000-1 -00322 Computer Sciences Corp - Fiscal 1995 and 1996	6/16/00
2000-1 -00006 Development Planning & Research Associates, Inc -Fiscal 1998 10/ 5/99
2000-1-00264 Development Planning & Research Associates, Inc.-Fiscal 1999 4/ 4/00
2000-1-00321 Dyncorp, Inc - Calendar 1997-1998	6/16/00
2000-1-00009 Earth Technology Remediation Service - Fiscal 1997	10/ 5/99
2000-1 -00183 Environmental Management Support - Fiscal 1997-1998	1/12/00
2000-1-00318 Environmental Quality Management, Inc. - 1998	6/ 7/00
2000-1 -00375 Four Seasons Industrial Services - Fiscal 1993	8/25/00
2000-1-00376 Four Seasons Industrial Services - Fiscal 1994	8/25/00
2000-1 -00377 Four Seasons Industrial Services - Fiscal 1995	8/25/00
2000-1-00423 Gannett Fleming Environmental Engineers - Fiscal 1998	9/27/00
2000-1-00310 Griffin Services, Inc - Fiscal 1994-96	5/25/00
2000-1-00351 Halliburton/NUS c/o Brown & Root - Fiscal 1996	8/ 4/00
2000-1-00432 Jacobs Engineering - Fiscal 1996	9/27/00
2000-1-00343 Life Systems - Fiscal 1990-93 Supplemental	7/26/00
2000-1-00158 Lockheed - Fiscal 1991	12/22/99
2000-1-00273 Lockheed Martin Services Group - Fiscal 1997	4/10/00
2000-1 -00008 Marasco Newton Group, Ltd. - Fiscal 1997	10/ 5/99
2000-1-00422 Marasco Newton Group, Ltd - Fiscal 1998	9/27/00
2000-1-00418 Metcalf & Eddy. Inc -Fiscal 1991-95	9/22/00
2000-1-00086 Morrison Knudsen Co - Fiscal 1996	11/23/99
2000-1-00084 Morrison Knudsen Co - Fiscal 1997	11/23/99
2000-1 -00352 Morrison Knudsen Co - Fiscal 1998	8/ 7/00
2000-1	-00212 Northbridge Environmental Management Consultants-Fiscal 1995 2/ 4/00
2001-4-00005	Northbridge Environmental Management Consultants-Fiscal 1996 10/14/99
2000-1-00319 Parsons Engineering Science - Fiscal 1994	6/ 8/00
2000-1-00379 PRC/Tetra Tech Environmental Management, Inc - Fiscal 1998 8/30/00
2000-1-00017 Program Resources, Inc. - Fiscal 1994	10/ 7/99
2000-1-00228 Roy F Weston, Inc -Fiscal 1997	2/17/00
2000-1-00413 Roy F. Weston, Inc - Fiscal 1998	9/18/00
2000-1 -00209 Tetra Tech, Inc - Fiscal 1997	2/ 3/00
2000-1-00415 Tetra Tech, Inc - Fiscal 1998	9/18/00

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EPA Office of the Inspector General Annual Superfund Report to the Congress for Fiscal 2000
19
Exhibit
Page 3 of 5
FISCAL 2000 SUPERFUND REPORTS
Contract Reports (Continued)	I
Report No Auditee/Description	Date
Incurred Costs (Continued)
2000-1-00214 Tetra Tech/PRC Environmental Management, Inc. - Fiscal 1996	2/ 4/00
2000-1-00210 Tetra Tech/PRC Environmental Management. Inc - Fiscal 1997	2/ 3/00
2000-1-00385 URS Greiner, Inc - Fiscal 1997	8/30/00
Final (Closeout) Audits
2000-1-00140 Black & Veatch Special Projects Corp. - Fiscal 1995 ARCS	12/17/99
2000-1-00317 Black & Veatch Special Projects Corp. - Fiscal 1996 ARCS	6/ 7/00
2000-1-00389 Black & Veatch Special Projects Corp. - Fiscal 1997 ARCS	9/ 7/00
2000-1-00184 Booz Allen Hamilton - 68-01-7282	1/13/00
2000-1 -00407 CDM Federal Programs Corp - Fiscal 1997 ARCS	9/14/00
2000-1-00193 Dynamac Corp - 68-C8-0058	1/27/00
2000-1-00233 ENSR Consulting & Engineering - 68-02-4548	2/29/00
2000-1-00208 Environmental Management Support - 68-W2-0004	2/ 3/00
2000-1-00237 Environmental Management Support - 68-W1-0016	2/29/00
2000-2-00004 Foster Wheeler Environmental Corp - Fiscal 1996 ARCS	2/ 2/00
2000-1-00014 Peer Consultants, P C - 68-01-7448	10/ 6/99
2000-1-00386 PRC Environmental Management, Inc - Tech. Enforcement Supp. 2 9/ 5/00
2000-1-00263 Research & Evaluation Associates, Inc. - 68-D1-0136	3/29/00
2000-1-00229 Roy F Weston, Inc. - Fiscal 1991-94 ARCS	2/17/00
2000-1-00180 Versar, Inc. - 68-03-3484	1/ 3/00
Internal Controls
2000-1 -00071 Bechtel Group, Inc - 1999	12/28/99
2000-1-00072 Bechtel Group,- Inc. - 1999	12/28/99
2000-1-00073 Bechtel Group, Inc. - 1999	12/28/99
2000-1-00074 Bechtel Group, Inc. - 1999	12/28/99
2000-1-00342 CET Environmental Services. Inc - Fiscal 1999 Floorcheck	7/24/00
2000-S-00003 Environmental Quality Management, Inc. - 1999 Floorcheck	11/ 3/99
2000-4-00060 Guardian Environmental Services - Accounting System Review	9/22/00
2000-1-00332 Jacobs Engineering Group - Billing System Internal Controls	7/ 5/ 00
Cost Accounting Standards
2000-1-00177 Bechtel - Cost Accounting Standards 403, 414 and 418	12/28/99
2000-1-00178 Bechtel - Cost Accounting Standards 403, 414 and 418	12/28/99
2000-1-00179 Bechtel - Cost Accounting Standards 403, 414 and 418	12/28/99
2000-1-00417 Bechtel National - Cost Accounting Standard 408	9/22/00
2000-1 -00255 CH2M Hill, Inc - Cost Accounting Standard 410	3/23/00
2000-1 -00307 Development Planning & Research Associates, Inc. - CAS 404	5/23/00
2000-1-00308 Development Planning & Research Associates, Inc - CAS 409	5/23/00
2000-1 -00338 Development Planning & Research Associates, Inc -Disci St.	7/10/00
2000-1 -00267 Ensercn Corp - Cost Accounting Standard 405	4/ 6/00
2000-1-00196 Foster Wheeler Environmental Corp - CAS 406	2/ 2/00
2000-1-00200 Foster Wheeler Environmental Corp. - CAS 408	2/ 3/00
2000-1-00198 Foster Wheeler Environmental Corp - CAS 410	2/ 2/00
2000-1-00197 Foster Wheeler Environmental Corp - CAS 420	2/ 2/00
2000-1-00159 ICF Kaiser - Initial Disclosure Statement Adequacy Review	12/22/99
2000-1 -00098 ICF Kaiser Consulting Group, Inc. - Disclosure Statement	11/29/99

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EPA Office of the Inspector General Annual Superfund Report to the Congress for Fiscal 2000
20
Exhibit
Page 4 of 5
FISCAL 2000 SUPERFUND REPORTS
Contract Reports (continued)
Report No. Auditee/Descriptiori	Date
Cost Accounting Standards (continued)
2000-1-00221	Industrial Economics. Inc. - Disclosure Statement	2/ 9/00
2000-1-00103	IT Environmental - Cost Accounting Standards 404, 405,	414 12/ 2/99
2000-1-00104	IT Environmental - Cost Accounting Standards 404, 405,	414 12/ 2/99
2000-1-00105	IT Environmental - Cost Accounting Standards 404, 405,	414 12/ 2/99
2000-1-00106	IT Environmental - Cost Accounting Standards 411, 418,	420 12/ 2/99
2000-1-00107	IT Environmental - Cost Accounting Standards 411, 418,	420 12/ 2/99
2000-1-00108	IT Environmental - Cost Accounting Standards 411, 418,	420 12/ 2/99
2000-1 -00109	IT Environmental - Cost Accounting Standards 413, 414,	415 12/ 2/99
2000-1-00110	IT Environmental - Cost Accounting Standards 413, 414,	415 12/ 2/99
2000-1-00111	IT Environmental - Cost Accounting Standards 413, 414,	415 12/ 2/99
2000-1-00101	IT Environmental - Fiscal 1998 Disclosure Statement	12/ 1/99
2000-1-00152	Lockheed Martin Services, Inc. - Cost Accounting Standard 406 12/21/99
Other Contract Audits
2000-1-00306	Analytical Engineering - Accounting System	5/23/00
2000-1 -00083	Bechtel Environmental, Inc. - Disclosure Statement 2/1/99	11/23/99
2000-1 -00175	Bechtel Environmental, Inc - 1999 MAARs	12/28/99
2000-1-00176	Bechtel Environmental, Inc. - 1999 MAARs	12/28/99
2000-1 -00434	Bechtel Environmental, Inc - MAARs 13 & 6	9/28/00
2000-1 -00435	Bechtel Environmental. Inc. - MAARs 13 & 6	9/28/00
2000-1-00436	Bechtel Environmental, Inc. - MAARs 13 & 6	9/28/00
2000-1-00387	Bechtel Environmental. Inc. - Investigation	9/ 6/00
2000-1 -00431	Bechtel Environmental. Inc. - Systems and Infrastructure	9/27/00
2000-1-00334	Black & Veatch Special Projects Corp - Cost Acctg Standards 7/ 5/00
2000-1-00260	Black & Veatch Special Projects Corp - Fiscal 1995 RAC	3/27/00
2000-1-00133	Black & Veatch Special Projects Corp - Fiscal 1997 Disci St 12/15/99
2000-1-00135	Black & Veatch Special Projects Corp - Fiscal 1997 Floorcheck 12/15/99
2000-1-00134	Black & Veatch Special Projects Corp -FY 1997 Purchase	System 12/15/99
2000-1-00430	CDM Federal Programs Corp - Fiscal 1998 ARCS	9/27/00
2000-1-00355	CET Environmental Services, Inc - Review of Invoices	8/10/00
2000-1 -00369	CET Environmental Services, Inc - Review of Invoices	8/24/00
2000-1 -00370	CET Environmental Services, Inc - Review of Invoices	8/24/00
2000-1-00426	CET Environmental Services. Inc - Review of Invoices	9/27/00
2000-1-00428	CET Environmental Services, Inc. - Review of Invoices	9/27/00
2000-1 -00429	CET Environmental Services. Inc - Review of Invoices	9/27/00
2000-2-00018	CET Environmental Services, Inc - Review of Invoices	9/27/00
2000-2-00019	CET Environmental Services, Inc - Review of Invoices	9/27/00
2000-2-00020	CET Environmental Services. Inc - Review of Invoices	9/27/00
2000-2-00021	CET Environmental Services. Inc - Review of Invoices	9/27/00
2000-2-00022	CET Environmental Services. Inc. - Review of Invoices	9/27/00
2000-2-00023	CET Environmental Services, Inc - Review of Invoices	9/27/00
2000-2-00024	CET Environmental Services, Inc. - Review of Invoices	9/27/00
2000-2-00025	CET Environmental Services. Inc - Review of Invoices	9/27/00
2000-2-00026	CET Environmental Services. Inc. - Review of Invoices	9/27/00
2000-2-00027	CET Environmental Services. Inc - Review of Invoices	9/27/00
2000-2-00028	CET Environmental Services, Inc - Review of Invoices	9/27/00
2000-2-00029	CET Environmental Services, Inc. - Review of Invoices	9/27/00
2000-2-00030	CET Environmental Services. Inc - Review of Invoices	9/27/00
2000-2-00031	CET Environmental Services, Inc - Review of Invoices	9/27/00

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EPA Office of the Inspector General Annual Superfund Report to the Congress for Fiscal 2000	21
Exhibit
Page 5 of 5
FISCAL 2000 SUPERFUND REPORTS
Report No. Auditee/Description	Date
Other Contract Audits (continued)
2000-1-00254	CH2M Hill, Inc. - Billing System - Fiscal 1998	3/23/00
2000-1-00340	CH2M Hill, Inc - Compensation Review	7/24/00
2000-1 -00235	CH2M Hill, Inc - Disclosure Statement Revision 2a & 2b	2/29/00
2000-1 -00236	CH2M Hill, Inc - Disclosure Statement Revision 3a & 3b	2/29/00
2000-1 -00240	CH2M Hill, Inc - Disclosure Statement Revision 4d & 5e	3/ 6/00
2000-1-00246	CH2M Hill, Inc - Disclosure Statement Revision 6a & 6b	3/16/00
2000-1 -00245	CH2M Hill, Inc - Disclosure Statement Revision 7a & 7b	3/16/00
2000-1-00253	CH2M Hill, Inc - Floorcheck - Fiscal 1999	3/22/00
2000-1 -00234	CH2M Hill, Inc - Purchasing System Review Follow-up	2/29/00
2000-1 -00275	Development Planning & Research Assoc., Inc -Disci St Rev. 7	4/10/00
2000-1-00291	Development Planning & Research Assoc , Inc -Disci St Rev 8	5/ 8/00
2000-1-00276	Development Planning & Research Associates, Inc. - Floorcheck	4/11/00
2000-1-00410	Entropy Environmentalists, Inc. - 68-02-4442	9/15/00
2000-1 -00300	FEV Engine Technology - Accounting System & Internal Controls	5/16/00
2000-1-00201	Foster Wheeler Environmental Corp. - Accounting System	2/ 3/00
2000-1-00199	Foster Wheeler Environmental Corp - Compensation	2/ 3/00
2000-1-00206	Foster Wheeler Environmental Corp. - Financial System	2/ 3/00
2000-1-00207	Foster Wheeler Environmental Corp - Financial System	2/ 3/00
2000-2-00008	Foster Wheeler Environmental Corp - RAC - Fiscal 1998	3/22/00
2000-1 -00202	Foster Wheeler Environmental Corp - Floorcheck	2/ 3/00
2000-1 -00205	Foster Wheeler Environmental Corp -IS Vendor Master File Cont	2/ 3/00
2000-1-00204	Foster Wheeler Environmental Corp /Ebasco-Labor Acctg System	2/ 3/00
2000-1-00102	IT Environmental - Billing System	12/ 1/99
2000-1-00099	IT Environmental - Fiscal 1998 Labor Follow-up	12/ 1/99
2000-1 -00097	IT Environmental - MAAR 6 Floorcheck	11/26/99
2000-1-00284	IT Group, Inc - Disclosure Statement Revision 5	4/26/00
2000-1-00333	Jacobs Engineering Group - Accounting System Controls	7/ 5/00
2000-1-00151	Lockheed Martin Services, Inc - Accounting System	12/21/99
2000-1 -00282	Lockheed Martin Services, Inc. - Disclosure Statement Rev 3	4/26/00
2000-1-00153	Lockheed Martin Services, Inc - Estimating System-Fiscal 1996	12/21/99
2000-1-00068	Morrison Knudsen Co - ARCS Fiscal 1997	10/28/99
2000-1-00257	Roy F Weston, Inc. - 68-03-3482	3/24/00
2000-1-00311	Roy F Weston, Inc - ARCS Closeout - 68-W8-0089 - Fiscal 1993	5/25/00
2000-1 -00258	Roy F Weston, Inc - ARCS Closeout - 68-W9-0046 - Fiscal 1994	3/27/00
2000-1-00230	Roy F Weston, Inc - ARCS Closeout - 68-W9-0022 - Fiscal 1995	2/17/00
2000-1 -00313	Roy F Weston, Inc. - ARCS Closeout - 68-W9-0046 - Fiscal 1995	6/ 7/00
2000-1 -00225	Roy F Weston, Inc - Floorcheck - Fiscal 1995	2/16/00
2000-1 -00226	Roy F Weston, Inc - Floorcheck - Fiscal 1997	2/17/00
2000-1 -00252	Science Applications International Corp. - 68-D2-0157	3/22/00
2000-1-00065	Smith Environmental Tech. - Floorcheck - Fiscal 1996	10/25/99
2000-1-00001	Sverdrup Civil - Floorcheck - Fiscal 1999	10/ 1/99
2000-1-00309	Sverdrup Civil - Floorcheck - Fiscal 2000	5/25/00
2000-1-00055	Sverdrup Corp - ARCS Closeout - 68-W9-0032 - Fiscal 1994	10/14/99
2000-1-00056	Sverdrup Environmental - RAC Closeout - 68-W5-0014 - FY 1997	10/14/99
2000-1-00211	Tetra Tech Env Mgmt., Inc -ARCS Closeout - 68-W8-0084 - FY97	2/ 4/00
2000-1-00242	Tetra Tech Env Mgmt , Inc.-ARCS Closeout - 68-W8-0092-FY88-95	3/ 7/00
2000-1-00213	Tetra Tech Env Mgmt . Inc.-RAC Closeout - 68-W7-0003-FY97-98	2/ 4/00
2000-1 - 00409	URS Operating Service, Inc. - Proposal PR - HQ-99 -17386	9/15/00

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EPA Office of the Inspector General Annual Superfund Report to the Congress for Fiscal 2000
22
APPENDIX: ABBREVIATIONS
Acctg.	Accounting
ARCS	Alternative Remedial Contracting Strategy
BCRLF	Brownfields Cleanup Revolving Loan Fund
CAS	Cost Accounting Standard
CERCLA	Comprehensive Environmental Response, Compensation, and Liability Act of 1980, as
amended
EPA	Environmental Protection Agency
IAG	Interagency Agreement
IG	Inspector General
ITS	Intertek Testing Services
Ltd.	Limited
NCP	National Oil and Hazardous Substances Contingency Plan, 40 CFR Part 300
NPL	National Priorities List
NRRB	National Remedy Review Board
OCFO	Office of the Chief Financial Officer (EPA)
OI	Office of Investigations (EPA OIG)
OIG	Office of the Inspector General
PA	Pennsylvania
PDD	Preauthorized Decision Document
PRC	Planning Research Corporation
PRP	Potentially Responsible Party
RAC	Remedial Action Contract
Rev.	Revision
SARA	Superfund Amendments and Reauthorization Act of 1986
St.	Statement
START	Superfund Technical Assessment and Response Team (EPA contract)
Tech.	Technical or Technology
UAO	Unilateral,Administrative Order

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