EPA-350-K-03-001 May 2003
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Ill
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        OFFICE OF INSPECTOR GENERAL
                    Catalyst for Improving the Environment
           Semiannual Report

               to Congress

       October 1, 2002 - March 31, 2003

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                        EPA Inspector General
                         Vision Statement

We are agents of positive change striving for continuous improvement in our Agency's
management and program operations, and in our own offices.
                               Mission

The Inspector General Act of 1978, as amended, requires the Inspector General to:
(1) conduct and supervise audits and investigations relating to programs and operations
of the Agency; (2) provide leadership and coordination, and make recommendations
designed to (a) promote economy, efficiency, and effectiveness, and (b) prevent and
detect fraud and abuse in Agency programs and operations; and (3) fully and currently
inform the Administrator and the Congress about problems and deficiencies identified
by the Office of Inspector General relating to the administration of Agency programs
and operations.
                     Strategic Plan Goals
         1.   Contribute to improved environmental quality and human health.

         2.   Improve EPA's management and program operations.

         3.   Produce timely, quality, and cost-effective products and services that
             meet customer needs.

         4.   Enhance diversity, innovation, teamwork, and competencies.
                     On the cover: Snake River outside Jackson, Wyoming
                     Photo by Tim McCabe, USDA Natural Resources Conservation Service

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f C/i(2rvt/iU    ~w- ^ uring this reporting period, we completed a number of investigations, audits,
                         I   1 and evaluations that demonstrate our commitment to help EPA better deliver
                        J— J cost-effective solutions to pressing environmental problems.

                        Notably, we conducted an audit of Louisiana's National Pollutant Discharge
                        Elimination System, Resource Conservation and Recovery Act, and Title V Air Permit
                        programs. We found that oversight of these important programs was insufficient
                        because Region 6 leadership did not develop and clearly communicate a vision and
                        measurable goals for its oversight of the State, hold Louisiana accountable for meeting
                        commitments, and ensure that environmental data was accurate and reliable for
                        decisionmakers.

                        We also reviewed the State self assessment process.  This process was envisioned by
                        EPA as a tool for directing scarce public resources toward improving environmental
                        results as well as allowing States greater flexibility in achieving those results.
                        However, since the National Environmental Performance Partnership System policy
                        was issued in 1995, EPA and the States have not widely adopted the self assessment
                        concept, and EPA has done little to develop and promote the use of self assessments.
                        As a result, Federal resources may not be directed at the State level to where they
                        would have the most vital environmental impact.

                        Our evaluation of the cleanup actions at the Hanford Superfund site, the largest
                        environmental cleanup project in the country, found that while progress has been
                        made, EPA did not take sufficient action to ensure that timely milestones for interim
                        cleanup actions exist; ensure that cleanup milestones that did exist were achievable;
                        effectively address  insufficient cleanup progress; and take action to address poor
                        performance of the  cleanup remedy for groundwater contaminated with hexavalent
                        chromium.  We recommended that EPA monitor Department of Energy efforts, and
                        take appropriate actions if cleanup progress is not achieved.

                        A joint investigation conducted by the EPA and Nuclear Regulatory Commission
                        Offices of Inspector General disclosed that a major government contractor billed
                        government contracts in excess of actual costs incurred. EPA and 17 other Federal
                        agencies were affected by the overcharging, and the investigation resulted in a
                        settlement agreement estimated at $391 million. Further, in February 2003, an
                        investigation of a New York University professor resulted in a guilty plea, sentence,
                        and fine for theft of Federal funds provided by EPA grants. In November 2002, an
                        EPA employee and relative were convicted of conspiracy to defraud the United States
                        and receipt of stolen government property.

                        As always, the Office of Inspector General is pursuing its quest to provide EPA,
                        Congress, and the public with the oversight and assistance necessary to help ensure
                        continued environmental improvements.
                                                                                  >>~fi:*>*j
                                                                        i L. TiMey
                                                               v   Inspector General

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                                    Profile of Activities and Results
                                              October 1, 2002 to March 31, 2003
                      Audit Operations
                      OIG-Managed Reviews
  (Reviews Performed by EPA, Independent Public Accountants, and
                          State Auditors)
                                                   October 1,2002 to
                                                     March 31,2003
                                                   (dollars in millions)
Questioned Costs *
 -Total
 - Federal

Recommended Efficiencies *
 - Federal

Costs Disallowed to be Recovered
 - Federal

Costs Disallowed as Cost Efficiency
 - Federal

Reports Issued - OIG-Managed Reviews
 - EPA Reviews Performed by OIG
 - EPA Reviews Performed by
    Independent Public Accountants
 - EPA Reviews Performed by
    State Auditors
 Total

Reports Resolved
 (Agreement by Agency officials to
 take satisfactory corrective actions)***
                         Investigative
                          Operations
Fines and Recoveries
(including civil) ****

Investigations Opened

Investigations Closed

Indictments of Persons or Firms

Convictions of Persons or Firms

Administrative Actions Against
EPA Employees / Firms

Civil Fines/Settlements
   $2.0
   $1.8
  $72.5


   $1.4


     $0


     21

      0

    _0
     21



     52
$368M

     65

     45

     16

      9


     17

      2
                                 Audit Operations
                                     Other Reviews
                      (Reviews Performed by Another Federal Agency
                              or Single Audit Act Auditors)
                                                              October 1, 2002 to
                                                                March 31,2003
                                                             (dollars in millions)
Questioned Costs *
 - Total
 - Federal

Recommended Efficiencies *
 - Federal

Costs Disallowed to be Recovered
 - Federal

Costs Disallowed as Cost Efficiency
 - Federal

Reports Issued - Other Reviews
 - EPA Reviews Performed by
    Another Federal Agency
 - Single Audit Act Reviews
 Total

Agency Recoveries
 Recoveries from Audit Resolutions
 of Current and Prior Periods
 (cash collections or offsets to
 future payments) * * (not available at publication deadline)
$2.1
$2.1
 $0
$7.3
 $0
126
 91
217
                                                                         $M
                               Fraud Detection and
                              Prevention Operations
Hotline Complaints Received

Hotline Complaints Addressed

Hotline Complaints Referred

Legislative and Regulatory Items Reviewed
325

279

 46

 32
        Questioned Costs and Recommended Efficiencies, which are from our Inspector General Operations Reporting System, are subject to change pending
        further review in audit resolution process.
        Information on recoveries from audit resolution is provided from EPA Financial Management Division and is unaudited.
        Reports Resolved are subject to change pending further review.
        Total includes actions resulting from joint investigations.

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Table  of Contents
              Goal 1: Contribute to Improved Environmental Quality and
              Human Health  	  1

              Goal 2: Improve EPA's Management and Program Operations	  7

              Goal 3: Produce Timely,  Quality and Cost-Effective Products
              and Services That Meet Customer Needs	  21

              Audit Report Resolution and Summary of Investigative Results
              Status Report on Perpetual Inventory of Reports in Resolution Process    	  25
              Status of Management Decisions on Inspector General Reports	  26
              Inspector General Issued Reports With Questioned Costs	  26
              Inspector General Issued Reports With Recommendations that Funds Be
               Put to Better Use  	  27
              Summary of Investigative Results	  28

              Appendices
              Appendix 1- Reports Issued	  29
              Appendix 2- Reports Issued Without Management Decisions (Available upon request)
                     Printed with vegetable oil based inks on 100% recycled paper (minimum 50% postconsumer)

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                         (m)
                         The work of the OIG is designed to assist EPA in achieving its
                         environmental goals, thus contributing to environmental
                         improvements.  The following illustrates results achieved under
                         this OIG goal.
EPA Region 6
Needs to Improve
Oversight of
Louisiana's
Environmental
Programs	
EPA Region 6's oversight of the Louisiana Department of Environmental Quality
(Louisiana) was insufficient and, as a result, could not assure the public that
Louisiana was adequately protecting human health and the environment.

Region 6 oversight must improve to ensure the effectiveness of Louisiana's
implementation of the National Pollutant Discharge Elimination System water
program, Resource Conservation and Recovery Act program, and Title V air
program. Oversight was insufficient because Region 6 leadership:
(1) did not develop and clearly communicate a vision and measurable goals for its
oversight of the State or emphasize the importance of consistently conducting
oversight, (2) did not hold Louisiana accountable for meeting goals and
commitments, and (3) did not ensure that data of poor quality was corrected so that it
could be relied upon to make sound decisions. As a result, the  working relationship
between the Region and Louisiana was not cohesive, and the Region was unable to
fully assure the public that Louisiana was operating programs effectively.

Region 6 leadership had not defined what constitutes a successful oversight
program, and had not developed the means for measuring the value of its oversight
and linked that to environmental outcomes.  Region 6 also did not conduct
independent evaluations to assess the effectiveness of its oversight.  Effective
oversight should enable EPA to proactively identify problems with  State programs
and help Louisiana improve its environmental programs to protect human health and
the environment.

We recommended that the EPA Region 6 Administrator take corrective actions to
improve oversight of Louisiana, including developing and communicating a clear
vision and measurable goals for oversight, holding Louisiana accountable for the
results of its programs through stronger grant commitments, and working with the
State to identify and correct inaccuracies in key databases.  Further, we
recommended the Region develop and implement a systematic process to gather and
evaluate feedback from its State partners, and conduct independent evaluations of
oversight.

We issued our final report (2003-P-00005) on February 3, 2003. In responding to
the report, EPA Region 6 acknowledged that its state oversight programs can benefit
from improvements, and agreed with  a number of our recommendations. The
Region also disagreed with several aspects of our findings, and will provide a formal
response by May 5, 2003.
                                                            PAGE 1 -OCTOBER 1,2002 THROUGH MARCH 31,2003

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  EPA Needs to More
  Actively Promote
  State Self
  Assessment of
  Environmental
  Programs	
EPA and states had not widely adopted the self assessment concept as a tool for
program assessment. In fact, EPA had done little to develop and promote reliance on
the use of self assessments by states.  Many states were not performing self
assessments, their content varied, and they had little impact on environmental
performance agreements. As a result, Federal resources may not be directed at the
state level to where they would have the most vital environmental impact.

Since the National Environmental Performance Partnership System policy was
issued in 1995, EPA had not taken a leadership role in defining or re-defining the
purpose of the self assessment, what should be included, and how it should be used,
nor had EPA issued any additional guidance or training on self assessments.
According to officials in states conducting self assessments, the self assessment had
little impact on the negotiation of the environmental performance agreements and
the allocation of Federal funds. State and EPA regional officials stated that the
negotiation process was dominated by EPA priorities as opposed to state identified
environmental problems and priorities.  Some regional staff stated that the self
assessment was used as a reference for state accomplishments and outputs, was not
very timely for negotiation of the performance agreements, and it will be of little
value until EPA reaches a consensus on (a) what will be in the self assessment,
(b) how it should be conducted, and (c) how the results will be used.

We recommended that the Associate Administrator for Congressional and
Intergovernmental Relations clarify the purpose of self assessments and how they
are to be used by EPA and states, and to work with other EPA offices and states to
gain  their acceptance and involvement with the self assessment concept.

We issued our final report (2003-P-00004) on December 27, 2002. In response to
our draft report, the Associate Administrator for Congressional and
Intergovernmental Relations generally agreed with all of our findings and
recommendations.  The Associate Administrator also indicated that EPA will
continue discussions about advancing performance partnership agreements with
states. The self assessment process may be overtaken by a joint evaluation process
which would provide information similar to the self assessment and would improve
joint planning and priority setting. In responding to the final report, EPA agreed to
develop guidance for the joint evaluation process.
  Improving
  Nationwide
  Effectiveness of
  Pump-an d- Treat
  Remedies Needs
  Sustained and
  Focused Action
EPA's Nationwide Pump-and-Treat Optimization project identified
241 recommendations to improve effectiveness and reduce costs at Superfund-
financed groundwater pump-and-treat systems. If implemented, these
recommendations could result in a 36-percent reduction in annual Superfund costs
for evaluated sites. Although about half of the 241 recommendations have been
fully implemented or are in progress, it is not clear that EPA has established a
milestone for completing this project, implementing all the recommendations, and
accounting for the associated environmental and cost savings benefits.  EPA needs to
sustain its progress and develop focused plans to track the effectiveness of this
nationwide project.
http://www.epa.gov/oig/ - PAGE '<

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                          Groundwater contamination is present at the majority of Superfund and Resource
                          Conservation and Recovery Act corrective action sites.  Pump-and-treat remedies are
                          the most common groundwater cleanup remedies used at Superfund National
                          Priorities List (NPL) sites and are also most commonly used to remediate methyl
                          tertiary-butyl ether (MtBE), a pollutant associated with leaks or spills from
                          underground storage tanks.  There are over 700 pump-and-treat systems operating at
                          NPL sites nationwide, 88 of which are financed by the Superfund program.

                          Collectively, Phases I and II of this nationwide project identified the 241
                          recommendations for improvements to about 17 of the 20 Superfund-fmanced
                          pump-and-treat systems evaluated, while also collecting cost and performance
                          information for all 88 Superfund-fmanced systems. The project also identified
                          important ways that existing systems can be managed more effectively. Information
                          obtained from EPA Regions and States generally indicated the optimization project
                          was valuable and useful, and identified savings opportunities. Regions disagreed
                          with less than 10 percent of the recommendations, while others were deferred.

                          Phase III of the project is ongoing and generally involves project tracking and
                          capturing progress toward implementing recommendations.  There is no current
                          scheduled end date, milestone, or focused plan of action associated with completion
                          of Phase III, although EPA's initial plans indicate Phase III was scheduled for
                          completion by the end of fiscal 2002.  EPA needs to set priorities for which sites or
                          recommendations are most critical to track, establish a time line for tracking actions,
                          and establish credible metrics to measure environmental and cost benefit outcomes.
                          In the long term, it will be difficult to  determine the environmental and cost benefits
                          of optimization projects if accurate and meaningful information on the results they
                          produce has not been collected or analyzed.

                          We issued our final report (2003-P-00006) on March 27, 2003.
Region 10 Needs to
Improve Oversight
ofHanford
Superfund Site
Our review of the adequacy of EPA Region 10's oversight of Department of Energy
Superfund cleanup actions at the Hanford 100-K Area Superfund Site has resulted in
EPA's agreement to improve oversight at the site.

The Hanford site, located in southeastern Washington State, encompasses about
586 square miles and has been identified as the largest environmental cleanup
project in the world. The potential environmental and human health risks associated
with contamination at the Hanford site are extreme. Approximately 3.7 million
pounds of used nuclear fuel are stored in unlined concrete basins at the Hanford 100-
K Area site. The Columbia River, which is over 1,000 miles long, runs directly
through the Hanford site for about 50 miles. The spent nuclear fuel storage basins
are less than a half-mile from the river and in earlier years one of the basins had
leaked.
                                                              PAGE 3 - OCTOBER 1, 2002 THROUGH MARCH 31, 2003

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                           We found that despite some important cleanup progress, EPA Region 10 did not:

                               Take sufficient action to ensure that timely milestones for interim cleanup
                               actions at the area existed.

                           •   Ensure that cleanup milestones that did exist were achievable.

                           •   Effectively address insufficient cleanup progress.

                           •   Take sufficient action to address poor performance of the remedy used to clean
                               up groundwater contaminated with hexavalent chromium.

                           Also, EPA Region 10 could not demonstrate that they had obtained sufficient
                           information to conclude that contaminated groundwater in the reactor section of the
                           100-K Area did not require an interim cleanup action. Further, in consultation with
                           an independent expert, we  found that the existing groundwater monitoring and
                           sampling system in the Hanford 100-K area was inadequate to determine whether
                           hazardous pollutants could be affecting the environment.

                           We recommended that Region  10 monitor Department of Energy efforts to
                           successfully complete remediation requirements and take appropriate actions as
                           needed if requirements are not met; evaluate performance of the upgraded pump-
                           and-treat system; require a formal assessment on the need for an interim remedial
                           action in the area's reactor section; and have the Department of Energy improve its
                           groundwater monitoring system.  We noted that enforcement actions should be
                           pursued as appropriate. The Agency generally accepted our findings and
                           recommendations.

                           We issued our final report  (2003-P-00002) on November 4, 2002. The Region
                           generally concurred with the recommendations, with one exception. The Region did
                           not agree with our recommendation to improve the groundwater monitoring system
                           for the reactor section of the 100-K Area.  However, the Region stated that an
                           independent assessment of groundwater monitoring needs for the 100-K Area would
                           be conducted by the United States Geological Survey.
http://www.epa.gov/oig/ - PAGE 4

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Pilot Study on
Science to Support
Rulemaking
Provides
Observations
We studied major environmental regulations and made observations regarding the
use and sources of science supporting the rules.

Developing regulations, also known as rules, is a cornerstone of EPA's mission. By
statute and executive order, they are to be based on the best reasonably obtainable
scientific, technical, economic, and other information. By identifying the science
that was critical to rules promulgated by EPA in the past, we hoped to determine
whether better research planning, application of science to rules, and explanation of
the role of science in rules could achieve improvements in the science behind future
environmental regulations.

We observed that science played an important role since the rules included in this
study depended on hundreds of scientific documents. However, the role of science
often was not presented in a manner consistent with the conventions of
communicating scientific information, and it was unclear what science was critical
and why.

Second, we observed that although critical science originated from a variety of
sources, research performed under contract to EPA and the regulated community by
private sector firms was the most common source. Grants and cooperative
agreements accounted for about 8 percent of the work.

Finally, we observed that critical science supporting the rules often was not
independently peer reviewed. Consequently, the quality of the science remains
unknown. Based on our observations we suggested that EPA ensure that science in
rulemaking is presented in a way that is apparent and consistent with the conventions
of science.  We also noted that information technology could be better used to ensure
that the Administrator, Congress, and the public could determine that the science
behind rulemaking is adequate.  Further, the critical science behind EPA's rules
should be independently peer reviewed.

Generally, the comments from Agency officials were supportive of the suggestions,
although they identified some concerns about the details of their implementation.
EPA's Science Advisor has committed to a review of the Agency's progress in
implementing its Peer Review policy during the coming  year, and to ensuring that
Agency decisions are based on sound science.  Because of the commitments made
by Agency management in their comments, we believe the report's observations may
serve as a baseline against which the Agency can chart progress.
                                                             PAGE 5 - OCTOBER 1, 2002 THROUGH MARCH 31, 2003

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  Laboratory
  President Sentenced\
  to
  18 months
On October 16, 2002, Terian Koester, President, Quality Water Analysis Laboratory,
Inc. (QWAL), Pittsburg, Kansas, was sentenced to serve 18 months in prison,
followed by 2 years probation, and ordered to pay a $2,000 fine, a $200 special
assessment, and $18 in restitution. This sentence followed a guilty plea by Koester
on July 2, 2002, in the U.S. District Court, District Court of Kansas, to one count of
making false  statements under the Clean Water Act and one count of mail fraud.
                            Koester's guilty plea concluded an investigation into allegations that QWAL
                            provided fraudulent analytical data and test results to its customers, some of whom
                            were wastewater treatment facilities. Specifically, it was alleged that QWAL
                            concealed that analytical equipment was not properly calibrated, failed to follow
                            required testing protocols, and created fictitious data when analytical equipment was
                            inoperable. The wastewater treatment facilities in turn reported the fraudulent data
                            and test results to the EPA under the National Pollutant Discharge Elimination
                            System (NPDES).  Under the NPDES program, facilities use laboratories such as
                            QWAL to perform testing to ensure their facilities meet water quality standards
                            under the Clean Water Act.  By falsifying test results, the public is exposed to poor
                            water quality and public health risks.

                            This investigation was conducted jointly by the EPA OIG and EPA Criminal
                            Investigation Division.
http://www.epa.gov/oig/ - PAGE 6

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Goal 2: Improve EPA's Management and Program Operations
                        The OIG assesses EPA's management and program operations to
                        identify best practices, areas for improvement, and cooperative
                        solutions to problems. The OIG's work is designed to promote
                        efficiency and effectiveness within EPA.  The following illustrates
                        results achieved under this OIG goal.
EPA Must
Emphasize
Importance of
Pre-Award Reviews
for Assistance
Agreements	
In recent years, more than half of the EPA's annual budget is awarded to
organizations outside the Agency through assistance agreements.  EPA project
officers play a key role in assuring the proper expenditure of these funds. It is the
project officer's responsibility to be involved up front in the negotiation of the work
plan. EPA identified critical duties project officers should perform when conducting
a programmatic and technical review and communicated these responsibilities
through training. An effective and complete programmatic and technical review
should result in a work plan that contains expected outputs and outcomes, links those
outputs and outcomes to funding, and identifies target dates and milestones.

We analyzed project officer files for 116 assistance agreements awarded by the
Offices of Water and Air and Radiation in Headquarters and the regions.  We selected
the assistance agreements from a pool of $ 1 billion, which represents 25 percent of
the $4 billion awarded in fiscal 2001. As shown below, we found that project officers
were not always conducting complete programmatic and technical reviews.
Required Step
Link proposed project to the Agency mission
Assess probability of project success
Determine reasonableness of proposed costs
Negotiate outcomes
Include milestones and deliverables in work plans
Implement new work plan regulations
Frequency
Performed
81%
69%
21%
58%
76%
4%
                                                         PAGE 7 - OCTOBER 1, 2002 THROUGH MARCH 31, 2003

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                           Although EPA communicated responsibilities, Agency leadership had not
                           emphasized the importance of project officer duties, nor held project officers
                           accountable for conducting complete programmatic and technical reviews. EPA had
                           not identified the skills and abilities needed for a project officer, nor defined them in
                           performance agreements.

                           It is crucial that Agency management create an environment that considers the
                           management of assistance agreements and the project officer function vital to the
                           accomplishment of the Agency's mission. Without complete programmatic and
                           technical reviews, there is limited assurance that EPA knows what it is buying and
                           that assistance agreement projects will achieve the desired environmental benefits.

                           We recommended that the Assistant Administrator for the Office of Administration
                           and Resources  Management identify skills project officers need to perform pre-award
                           reviews, and evaluate and modify their training to ensure staff have the needed skills.
                           The Project Officer Manual and refresher training course need to reflect the
                           requirements, as well as instructions on how to implement them. We also
                           recommended that a uniform performance standard be developed that clearly
                           communicates key project officer responsibilities critical to accomplishing EPA's
                           mission and include the critical job element in  project officers' performance
                           standards.  In response to our draft report, EPA agreed with our recommendations and
                           developed actions that have been incorporated into the Agency's Grant Management
                           Strategic Plan and Tactical Action Plan.  In addition to the actions recommended in
                           the report, EPA is developing a grants management training program for managers
                           and supervisors that will emphasize their role in providing direction and guidance to
                           project officers. EPA will also issue guidance  on measuring and incorporating
                           environmental outcomes into grants work plans.

                           We issued our final report (2003-P-00007) on March 31, 2003.  A response to the
                           final report is due on June 30, 2003.
 Central States Air
 Resource Agencies
 Association
 Misspent EPA
 Funds
We questioned more than $1.6 million claimed by the Central States Air Resource
Agencies Association (CenSARA) under two grants received from EPA because
CenSARA either did not adequately support the claimed costs or did not spend the
money in accordance with Federal laws and regulations.

EPA provided CenSARA with two grants totaling more than $3.2 million. The first
grant was used to establish CenSARA as a Regional Multi-State Organization to
promote the exchange of information between its States and other interested parties
related to the control of air pollution. The second grant was to establish the
infrastructure for a Regional Planning Body to enable the States and Indian tribes to
address regional haze issues.

We questioned costs claimed because CenSARA: (1) could not reconcile total
program outlays claimed for each grant with the general ledger;  (2) did not maintain
an adequate labor distribution system to track labor efforts spent on each project or
final cost objective; (3) improperly charged all indirect type costs - such as rent,
office supplies, and depreciation - to one EPA assistance agreement, and did not
http://www.epa.gov/oig/ - PAGE 8

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                         develop proper indirect cost rates; and (4) did not competitively procure equipment
                         and services or perform cost or price analysis for purchases.

                         We recommended that EPA recover all funds that were not spent in accordance with
                         Federal rules^uspend work under the current agreements, make no new awards to
                         CenSARA until it can demonstrate that its accounting practices are consistent with
                         Federal requirements, and require CenSARA to modify its financial management and
                         procurement systems to meet Federal requirements. EPA Region 6 agreed with a
                         number of our findings and has taken steps to ensure that CenSARA comes into
                         regulatory compliance. Upon receipt of the draft report, the Region responded by
                         reclassifying CenSARA as a "high-risk grantee," restricting their funding and placing
                         them on a reimbursement method of payment. A recent on-site review revealed that
                         appropriate systems are now in place and changes have been made to correct
                         problems with their general ledger, labor distribution, and indirect costs.  CenSARA's
                         activities for procuring equipment and services have been curtailed or eliminated to
                         prevent future problems.  The Region is planning another on-site review in the next
                         quarter to ensure the grantee continues to comply fully with all regulations. We
                         issued the final report (2003-1-00087) on March 31, 2003. A response is due from
                         the Region by July 30, 2003.
Greater Use of
Performan ce-Based
Service Contracts
Could Increase
Savings	
EPA has made limited use of Performance-Based Service Contracting (PBSC), an
acquisition methodology in which the Government pays for results rather than effort
or process. Office of Management and Budget (OMB) and EPA studies have shown
that PBSC saves money and improves contractor performance. For example, with
OMB's assistance, EPA studied PBSC within the Superfund program.  Most projects
saved money, with one project lowering costs by 30-35 percent while improving the
quality of work.

EPA has generally limited use of PBSC to obtaining commercially available
services, such as janitorial and landscaping work.  Further, EPA awarded non-PBSC
contracts for services previously awarded as performance-based.  Also, many
contracts EPA identified as performance-based were not designed to take advantage
of PBSC's benefits, since the contracts were too prescriptive or did not provide
meaningful incentives or disincentives.

Based on discussions with Agency officials, these  conditions occurred because EPA
did not adequately plan or hold officials accountable for increasing PBSC use, and
there was a general reluctance to shift the responsibility for outcomes to contractors.
As a result, EPA missed opportunities to achieve greater cost savings and improve
contractor performance. Of the  $599 million in PBSC-eligible obligations for the
9-month period ended June 30, 2002, we determined that EPA could have saved as
much as $72.5 million through greater use of PBSC.

Also, the Office of Management and Budget's Federal Procurement Data System
(FPDS) showed nearly 50  percent less PBSC obligations than EPA reported in its
own Integrated Contracts Management System (ICMS). This primarily occurred
because FPDS did not show performance-based task orders issued under non-
performance-based contracts as  PBSC, and because ICMS lacked the capability to
                                                             PAGE 9 - OCTOBER 1, 2002 THROUGH MARCH 31, 2003

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                           provide all data needed in FPDS. As a result, EPA's contracting actions were
                           inaccurately portrayed in the national database used for reporting to Congress, the
                           President, and the public.

                           We recommended that EPA take various actions to increase performance-based
                           contracting, and that the database accuracy be reviewed and ICMS and FPDS data
                           periodically compared. EPA generally agreed with our findings and
                           recommendations to expand PBSC, noted that corrected data was sent to FPDs, and
                           that EPA's current contracts systems do not meet its business needs. According to
                           the Assistant Administrator for Administration and Resources Management (OARM),
                           the systems provide inadequate reporting, cumbersome tracking status, and redundant
                           data entries, which result in extraordinary inefficiencies and errors. OARM hopes to
                           install a secure web-based system which will eliminate duplicate data entry, track
                           actual costs and progress in real  time, and provide a Commercial Off The Shelf
                           application consistent with the President's e-government initiatives.

                           We issued our final report (2003-P-00008) on March 31, 2003.  A response to the
                           final report is due June 30, 2003.
 EPA Needs to
 Develop Statistics
 on Improper
 Contract Payments
Research performed in response to a Senate Committee on Governmental Affairs
request identified a limited number of improper payments to EPA contractors. While
the number of improper contract payments found seemed to be minimal and the
Agency appeared highly focused on providing high quality and accurate contract
payments, we noted the Agency did not keep statistics on improper contract
payments. Such statistics could help identify contractor procedural problems,
emerging fraud scams, or EPA control weaknesses or inefficiencies. In addition,
statistics are important because improper payments can impact a program's ability to
achieve its intended outcome. Statistics could also help the Agency assess the need to
establish a cost recovery audit program. We recommended the Agency develop
statistics to track the extent, magnitude, and possible causes of improper contract
payments, to help ensure sufficient controls are in place.

We continue to encourage the Agency to expand the scope of its efforts to review
improper payments from its current assessment of only the Agency's State Revolving
Fund programs to an assessment of improper payments for all Agency programs and
activities.  If program risks are known and quantified, Agency management can
determine whether the problem is significant enough to require additional controls.

On January 16, 2003, we issued our final report (2003-2-00003) to key officials
within EPA's Office of Acquisition and Resources Management and Office of the
Chief Financial Officer. In responding, both offices concurred with the report's
recommendations.  Management agreed to keep statistics starting in fiscal 2003,  and
to subsequently assess whether EPA needs to establish a cost recovery program.  The
formal response also identified many internal control actions put in place as a result
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                         of our review. Finally, the Agency referred to guidance that OMB is currently
                         preparing to assist Federal agencies in identifying and evaluating programs
                         susceptible to significant improper payments, and stated that it will use this guidance
                         to determine how to best conduct an overall assessment of programs and activities.
EPA Earns
Unqualified
Opinion on
Financial
Statements
EPA earned an unqualified opinion on its fiscal 2002 financial statements.  We noted
several reportable conditions in internal controls and some instances of
noncompliance with laws and regulations. However, none of the issues identified
would result in material misstatement of the financial statements.

We identified seven reportable conditions in internal controls for the following areas:

    Documenting and Approving Journal Vouchers
•   Reconciling Unearned Revenue for State Superfund Contracts
    Reconciling Deferred Payments to the Superfund
•   Integrated Grants Management System Security Planning
    Automated Application Processing Controls for the Integrated Financial
    Management System (IFMS)
    Capitalizing Superfund Contractor-Held Property
•   Improper Recognition of Payments to the Superfund

We did not identify any instances of noncompliance with laws and regulations that
would result in material misstatements to the audited financial statements.  The Office
of Chief Financial Officer (OCFO) has made improvements in cost accounting.
While there are still noncompliances with the Managerial Cost Accounting Standard,
those issues no longer meet the Office of Management and Budget's definition of
substantial noncompliance.

We identified three other Federal Financial Management Improvement Act (FFMIA)
noncompliances:

•   EPA continues to experience difficulties in reconciling some of its intra-
    governmental assets and liabilities due to some Federal entities not performing
    reconciliations. Without proper confirmations from its trading partners, EPA has
    limited assurance that intra-governmental balances are accurate.

    The Agency's Contract Payment System was not in compliance with the Joint
    Financial Management Improvement Act (JFMIP) system requirements. Without
    the current interface controls meeting JFMIP requirements, the system could not
    provide the intended level of assurance regarding the complete and accurate
    transfer of contract payment information into the IFMS general ledger.

•   The fiscal 1999 Remediation Plan to correct some FFMIA issues had not been
    completed.
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                           We also found two other noncompliance issues.  EPA was not in compliance with the
                           requirements of the Food Quality Protection Act of 1996 because the Agency
                           exceeded the limitation on the usage of maintenance fees.  EPA did not prepare the
                           SF 224 "Statement of Transactions" in accordance with the Treasury Financial
                           Manual since it reported  adjusted rather than actual amounts. By reporting adjusted
                           IFMS amounts rather than EPA's actual general ledger amounts, EPA prevented
                           differences from being reported by Treasury on the Statement of Differences (Form
                           6652).

                           In its response to our draft report, OCFO generally concurred with our
                           recommendations and noted the completion or planning  of a number of corrective
                           actions. OCFO believes  that they are complying with the Managerial Cost
                           Accounting Standard by  preparing  quarterly subobjective level reports, taking actions
                           to execute the Agency's plan for expanding cost information, and moving from 10
                           goals to 5 in the new Strategic Plan. We recognize improvements that the Agency
                           has made in the area of cost accounting and believe that  the new plan for expanding
                           cost information will provide managers the cost information they need to manage.
                           However, we do not agree with OCFO that the subobjective level reports provide
                           useful, timely, and full cost information.

                           OCFO also stated that they developed a new process and report for reconciling the
                           Contract Payment System with IFMS. OIG did not review the  new process and
                           report because they were developed after we completed our work.

                           We issued our final report (2003-1-00045) on January 29,  2003. A final response to
                           our report is due by April 30, 2003.
 EPA Acting to
 Protect Critical
 Cyber-Based
 Infrastructures,
 Further Steps
 Needed
Presidential Decision Directive 63, signed in 1998, calls for a national effort to ensure
the security of the nation's critical infrastructures, including those that are cyber-
based. In response to that Directive, we reviewed EPA's implementation activities to
protect its critical cyber-based, or Information Technology (IT), infrastructure, and
found that EPA has undertaken significant activities. However, EPA needs to take
further actions to ensure greater IT infrastructure protection.

Significant implementation activities that EPA has undertaken to protect its critical IT
infrastructure include: addressing vulnerabilities identified during risk assessments;
establishing suitable emergency management procedures; establishing effective
internal and external interagency coordination; and identifying appropriate resource
and organizational  requirements with regard to recruitment and awareness of its
information security program.

However, EPA should address additional areas to provide greater assurance of
protecting its  critical IT infrastructure.  Specifically, EPA should:

    Make sure all sites have required data backup procedures necessary for ensuring
    the availability and  integrity of Agency information resources.
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                         •   Provide sufficient resources to complete planned corrective actions to mitigate
                             vulnerabilities previously identified by the General Accounting Office.
                         •   Establish or revise security plans for IT systems critical to its cyber-based
                             infrastructure so that they meet National Institute of Standards and Technology
                             requirements.
                             Have critical IT components of Agency Continuity of Operations Plans tested
                             under circumstances relative to actual deployment.
                             Establish an effective security training program that identifies appropriate IT
                             security personnel and sets IT-related training requirements for those personnel.

                         We issued our final report (2003-P-00009) to the Assistant Administrator for
                         Environmental Information on March 27, 2003.  The Assistant Administrator agreed
                         with most of the findings and recommendations, and indicated the results of our audit
                         will help improve the security of the Agency's IT assets. A response to the final
                         report is due by June 27, 2003.
EPA Employee and
Two Relatives
Convicted of
Receipt of Stolen
Government
Property	
On November 7, 2002, Luther Mellen, Branch Chief, EPA, Architecture,
Engineering, and Real Estate Branch, and Philip C. Burroughs, his stepson, were
found guilty by a federal jury in U.S. District Court, District of Columbia, on charges
of conspiracy to defraud the United States and receipt of stolen government property.
Burroughs was also found guilty of theft of government property. Jeffrey Morgan,
Mellen's nephew, was found guilty of receipt of stolen government property.
Sentencing dates have not been scheduled.

During the trial, the government's evidence demonstrated that Elizabeth C. Mellen,
wife of Luther Mellen, was a Telecommunications Specialist with the Department of
Education.  In that position, she managed a contract with the former Bell Atlantic
Federal Systems. Mrs. Mellen, who previously pled guilty to theft of government
property and conspiracy to defraud the government, was responsible for ordering
telecommunications goods and services from Bell Atlantic, paid for by the
Department of Education. From early 1990 to December 1999, Mrs. Mellen used her
official position and ordered more than $300,000 worth of computers, printers,
cellular phones, and cameras for her personal use. Mrs. Mellen ordered a computer
for the house she and Luther Mellen shared; a laptop computer for her stepson at the
request of Luther Mellen; and large quantities of electronic equipment which she kept
for herself and gave to various family members and friends, including her son, Philip
Burroughs, and her nephew, Jeffrey Morgan.

This investigation was conducted jointly by the Federal Bureau of Investigation, the
Department of Education OIG, and the EPA OIG.
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 NYU Professor
 Sentenced to 2
 Years Probation for
 Theft of Federal
 Funds
On February 25, 2003, Richard Schlesinger, professor of environmental medicine,
New York University (NYU), School of Medicine, was sentenced in U.S. District
Court, Southern District of New York, to 2 years probation and was ordered to pay a
$5,000 fine and a $25 special assessment.  This sentencing is a result of Schlesinger's
November 12, 2002, guilty plea to a criminal information charging him with a
misdemeanor count of theft of federal funds in connection with submitting fraudulent
reimbursement requests.

From December 1997 to July 2001, Schlesinger submitted approximately 81
fraudulent reimbursement requests to NYU with an aggregate value of $22,090.
These reimbursement requests were paid from moneys provided by federal grants
funded by the EPA.  Schlesinger allegedly used the illegally obtained federal funds to
support his hobby of stamp collecting.

This investigation was conducted by the EPA OIG.
 Owners of
 Reproduction
 Company Pay
 $200,000 for Anti-
 Kickback Violations
On December 13 and 20, 2002, respectively, Thomas M. Costas and Robert J. Strom,
owners and operators of Action Reprographics, Inc., New York, New York, each
agreed to pay $100,000 to the government in a civil settlement with the United States
Attorney's Office, District of New Jersey. Additionally, on March 20, 2003, Costas
and Strom were criminally indicted by a Federal grand jury for conspiracy and
income tax fraud.

In the civil case, the United States alleged that Costas and Strom provided kickbacks
to an employee of Ebasco Services, Inc., for the purpose of obtaining favorable
treatment in the award of subcontracts for reproduction services. Ebasco Services
was a major government contractor, providing power generation, environmental
remediation, hazardous waste processing, and construction services to numerous
government agencies, including the EPA, the Department of Defense, and the
Department of Energy. Several former employees of Ebasco Services were
previously convicted of violations of the Anti-Kickback Act of 1986 and with filing
false income tax returns.

This investigation was conducted jointly by the Defense Criminal Investigative
Service, the National Aeronautics and Space Administration OIG, the U.S. Postal
Service OIG, and the EPA OIG.
 Contractor
 Settlement Valued
 at $391 Million
During this reporting period, a final estimate of the value of the September 2000
settlement agreement between ICF Kaiser International, Inc., and the United States
Attorney's Office, Eastern District of Virginia, was computed.  Based upon the
documentation provided by ICF and their representations during the settlement
negotiations, the total value of the settlement was placed at $391,061,944. Since the
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                         date of the settlement agreement, various government agencies have verified that
                         $25,030,858 in funds have been deobligated or retained. The value of government
                         contracts awaiting closeout is $366,031,086. Under the terms of the settlement
                         agreement, ICF agreed to waive these cost claims, which in turn allowed
                         the government to deobligate retained funds and avoid contract closing costs.

                         The settlement agreement was the culmination of a lengthy investigation that
                         disclosed that ICF may have billed government contracts for computer center costs in
                         excess of the costs actually incurred. The EPA and 17 other federal
                         departments/agencies were affected by this settlement.

                         This investigation was conducted jointly by the EPA OIG and the Nuclear Regulatory
                         Commission OIG.
Convictions and
Sentencings Made
in Software Piracy
Case
On December 13, 2002, Ruth Lawton was sentenced to 3 years probation and ordered
to pay a $2,000 fine and a $100 special assessment. This sentencing followed a
September 24, 2002, criminal information filed against Lawton in U.S. District Court,
District of Nevada, charging her with copyright infringement. On that same day,
Lawton entered a guilty plea to the information, acknowledging that she downloaded
more than $2,500 worth of copyrighted software onto her home computer for the
purpose of private financial gain, without the authorization of the copyright holders.

On September 27, 2002, a misdemeanor criminal information was filed in U.S.
District Court, District of Nevada charging Eric Rosenquist with misdemeanor
violations of copyright infringement.  On November 21, 2002, Rosenquist entered
into a plea agreement in which he admitted that he illegally downloaded a digital
copy of Microsoft Money 202 Deluxe on his home computer. On March 21, 2003,
Rosenquist was sentenced to serve 3 years probation, perform 140 hours of
community service, and was ordered to pay a $500 fine and a $25 assessment fee.

On October 15, 2002, Lukasz Doupal pled guilty to a criminal information in U.S.
District Court, District of Nevada, charging him with misprision of a felony,  a
misdemeanor. In the plea agreement, Doupal admitted that he became aware of and
had knowledge of the actual commission of violations of federal criminal copyright
laws by the members of a software piracy group.   Doupal is currently awaiting
sentencing.

This investigation, known as "Operation Bandwidth," is being worked in close
coordination with the United States Attorney, Las Vegas, Nevada, and has resulted in
multiple indictments, informations, and convictions. A 2-year long undercover
operation by federal law enforcement officers from the Federal Bureau of
Investigation, the Defense Criminal Investigative Service, and the EPA OIG focused
on several members of a software piracy group know as the "Rogue Warriorz"
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                          (RWG), a secretive underground organization dedicated to the illegal reproduction
                          and distribution of copyrighted software, movies, and games over the Internet. At
                          least 18 members of the group were hackers who had illegally accessed EPA
                          computer systems to further the reproduction and distribution scheme.  The total retail
                          value of the pirated software was estimated to exceeded $1,000,000.

                          The investigation was conducted jointly by the Federal Bureau of Investigation, the
                          Defense Criminal Investigative Service, and the EPA OIG.
 Electrical
 Contractor Refunds
 $27,828 for
 Over billing of Costs
On October 24, 2002, Philips Brothers Electrical Contractors, Inc., Glenmore,
Pennsylvania, entered into an agreement with the EPA Suspension and Debarment
Division to resolve the EPA's claim that Philips Brothers had sought payment from
the EPA for sales tax not incurred.

Philips Brothers was awarded a contract for electrical construction work on the York
City Sewer Authority (YCSA) Wastewater Treatment Plant.  This project was funded
under an EPA grant awarded to YCSA. Although the basic contract under the grant
was fixed price, Philips Brothers invoiced the YCSA project for expenses incurred on
change order construction work. Some of the supplies purchased for the change order
work were free from Pennsylvania sales tax because of the nature of the public
contracting work performed. On four requests for payment,  Philips Brothers sought
payment for sales tax on these supplies when no sales tax had been paid.  The
refunded amount of $27,828 was divided between the EPA and the YCSA.

This investigation was conducted by the EPA OIG.
 EPA Employee
 Terminated in
 Connection with
 Theft of a
 Government
 Purchase Card
On October 31, 2002, Diane Williams, an Administrative Technician in EPA
Region 5, Chicago, Illinois, was terminated from her EPA position. This action
followed Williams' September 5, 2002, sentencing in the Circuit Court of Cook
County, Illinois, to 1 year of supervised release and 10 days of community service.

The EPA investigation found that Williams knowingly stole a government purchase
card from another EPA employee and activated the card.  Williams proceeded to
make purchases of a personal nature, including lamps, cigarettes, and a television set.
In addition, she attempted to extract $500 from an automated teller machine.

This investigation was conducted jointly by the EPA OIG and the Federal Protective
Service.
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Grantee repays
$5,000 to the EPA
On December 17, 2002, and January 23, 2003, respectively, Mark Patrick, Chief
Financial Officer, and David Schmidt, Executive Director, Global Rivers and
Environmental Education Network (GREEN), Ann Arbor, Michigan, agreed to be
held jointly and severally liable for repayment of $5,000 in grant funds to the EPA.
This agreement was reached with the EPA Suspension and Debarment Division.

GREEN had applied for and received an EPA grant in the amount of $25,000 to
conduct training and assistance at Washington Middle School in Seattle, Washington.
This grant was amended to include conducting a student exchange program between
Chief Sealth High School in Seattle, Washington, and a high school in Chongquing,
China. Patrick submitted an invoice under the grant for $5,000 to the EPA knowing
that GREEN was going out of business.

The invoice included the costs of the grant amendment for the student exchange
portion, despite the fact that the student exchange had not taken place at the time the
voucher was invoiced.  The original invoice was not paid and Schmidt resubmitted
the invoice to the EPA after GREEN had commenced dissolution action. The
resubmitted invoice was paid by the EPA.

This investigation was conducted by the EPA OIG.
EPA's Annual
Report Show
Improvements,
More Still Needed
for Public
Accountability
We reviewed EPA's Annual Report for Fiscal 2002 and commented that this report
continues to improve upon previous Agency Reports, especially in the first time use
of specific information references and citations to improve data quality and
transparency. However, there are still several critical areas that continue to need
improvement. Below is a summary of several significant issues and suggestions we
identified that could improve the quality and value of this report to the public:

• •  Cross-goal references are needed throughout this report since many of the goals,
    actions and measures overlap, to offer a greater picture of cross media interaction
    and dependencies;
• •  Better linkages between goals, actions and APGs are needed to demonstrate
    logical relationships and translation to outcomes measures of public benefit.
• •  Self assessment and judgements about how well a program performed or how
    much progress it made should be eliminated in favor of a straight forward
    discussion of what worked and why; and what did not and why not.
• •  Better discussion is needed of EPA's relative contribution compared to other
    federal and state agencies. The term "other federal partners" is used consistently
    throughout this report, however, only occasionally are they identified and their
    relationship to EPA explained.
• •  Many  of the accomplishments reported as results are really projections of future
    expectations. These connections are important to know, but should not be used to
    imply  completed results.
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                              The sections entitled Program Evaluations, should include references to OIG and
                              GAO audit and evaluation reports, as long as these reports have national program
                              implications.
                              There is a lack of attention to the Major Management Challenges in Section I.
                              Also, applicable management challenges should be discussed in each Goal
                              chapter, with citations to Section III;
 EPA Regional
 Super fund
 Ombudsmen
 Program Needs
 Structure
EPA does not have a management system in place to ensure its Regional Superfund
Ombudsmen are accountable for fulfilling their responsibilities. The Regional
Superfund Ombudsman function is generally a collateral duty within the Superfund
program. As a result, there is a perceived lack of independence and impartiality.
Further, a lack of guidance has caused uncertainty over the function.

The American Bar Association identifies a core characteristic of an Ombudsman as
having the ability to conduct inquiries and investigations in an impartial manner.
Another core characteristic is being independent. However, two General Accounting
Office (GAO) reports (dated July 2001 and October 2002) noted concerns about the
independence and  impartiality of both EPA's National Ombudsman and Regional
Superfund Ombudsmen.

To correct the independence and impartiality issues raised by GAO, EPA moved the
National Ombudsman function from EPA's Office of Solid Waste and Emergency
Response to the EPA  OIG. However, EPA has not yet addressed GAO's concerns
regarding the Regional Superfund Ombudsmen.  The continued alignment of the
Regional Superfund Ombudsmen with the Superfund program indicates a lack of
independence and  impartiality.  Specifically, 7 of the 10 Regional Superfund
Ombudsmen are located in the Superfund program and receive their annual
evaluations from managers within that program.  In 5 of the 7 regions aligned with
the Superfund program, the Regional Ombudsmen duties are collateral duties, with
the estimated time spent on Regional Ombudsmen duties ranging from 5 to 20
percent. None of the Regional Superfund Ombudsmen with collateral duties maintain
time records specific to their Ombudsmen duties, and Ombudsmen duties are often
performed in conjunction with other Superfund program responsibilities.

While it is not practical for EPA to meet independence and impartiality standards for
Regional Ombudsmen, due to the limited time spent on Ombudsman duties, these
Regional Ombudsmen believe they can be effective in resolving stakeholder
complaints at a local level and assisting in alleviating site disputes. Therefore, we
recommended that the Assistant Administrator for the Office of Solid Waste and
Emergency Response change the title of the Regional Superfund Ombudsmen to
better reflect their  role, and develop clear and consistent guidance on their duties.
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                         We issued our final report (2003-S-00004) on March 13, 2003. The Office of Solid
                         Waste and Emergency Response agreed with the recommendations and indicated they
                         will immediately begin work on developing specific milestones to implement the
                         recommendations.  A response to the final report is due June 13, 2003.
OIGOmbudsman/
Hotline Activity
Subsequent to the transfer of the national ombudsman function to the OIG, we
recently established an Office of Congressional and Public Liaison (OCPL) to
consolidate the OIG's congressional, media and public liaison activities into a single
organization.  A major element of the public liaison activities of the office are the
activities of the ombudsman and hotline coordinator.  The information received in
OCPL is used to identify potential areas for OIG review, analysis, and
recommendations for Agency program improvement. OCPL also receives
complaints, allegations, concerns and inquiries regarding Agency programs and
operations which and are researched, evaluated and addressed.

For the six month reporting period ending March 31,  2003, the hotline received 325
inquiries or complaints, addressed 279, and referred 46. Matters that did not warrant
OIG action will be used to identify trends or patterns  of potentially vulnerable areas
for possible future OIG work.

We plan to close ten ombudsman cases within the next reporting period.
Additionally, we are performing fieldwork for the Stauffer Chemical, FL and Bunker
Hill/Coeur d'Alene, ID cases and will recommend additional fieldwork for the
Escambia, FL case. We are also contracting with technical experts to assist us in the
review of ombudsman  selected cases.
Review of
Legislation and
Regulations
Section 4(a)(2) of the Inspector General Act of 1978, as amended, directs OIGs to
review existing and proposed legislation and regulations relating to agency programs
and operations to determine the effect on economy and efficiency and the prevention
and detection of fraud and abuse.  During the reporting period, we reviewed 32
regulatory items. The most significant items are discussed below.

OMB Guidance on Implementing a Recovery Audit Program

We provided comments to the Office of Management and Budget (OMB) on
implementation of the new recovery audit requirements for agencies in the fiscal 2002
Defense Authorization Act (PL 107-107; 31 USC sec 3561-3567).  In accordance
with the Inspector General Act of 1978, it is the Inspector General's statutory
responsibility to conduct, supervise, and coordinate any audits it deems appropriate.
OMB's new recovery audit requirements state that "agency heads should coordinate
with the agency Inspector General." We are concerned that the new guidance could
result in an OIG's independence being limited or subordinated and overall authority
compromised. We recommended revising the OMB guidance to clearly describe the
Inspector General's authority.
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                           Revised OMB Circular A-76. Performance of Commercial Activities

                           We also provided comments to OMB on a proposed revision of OMB Circular A-76
                           related to making Government services subject to competition. We believe the basic
                           premise of the proposed revision - namely, that all activities should be considered
                           commercial in nature unless deemed to be inherently governmental - is critically
                           flawed. We recognize that many Federal functions and services can be performed
                           less expensively by competitive contract and that those functions and services should
                           be contracted out.  However, we believe that making a blanket generalization that
                           agencies shall presume all activities are commercial in nature unless justified as
                           inherently governmental is inconsistent with the very purpose of establishing a
                           dedicated workforce of public servants committed to good government as opposed to
                           corporate profits. Furthermore,  Federal employees are subject to specific and
                           rigorous standards of conduct generally unmatched by the private sector.

                           Proposed New EPA Order. Sexual Orientation and Parental Status Discrimination

                           This EPA order is an attempt to  implement an Office of Personnel Management
                           process for handling discrimination complaints based on sexual orientation.  It also
                           adds information on parental status.  We  expressed concern that the proposed new
                           order is sometimes confusing because it does not clearly explain certain processes.
                           Generally, we believe the order  should explain in clearer language: (1) the
                           overlapping authority of different agencies;  (2) what appeal routes an employee has
                           available for assistance; (3) the required timeframes for raising allegations under each
                           of the appeal routes; and (4) what remedies are available. In addition, although
                           neither form of discrimination is appealable to the Equal Employment Opportunity
                           Commission, the policy does not explicitly say so and should.

                           Approval of Draft Records Schedules

                           We did not concur with draft records schedules for EPA's Integrated Grants
                           Management System, Integrated Contracts Management System, and Grants and
                           Other Agreement Oversight. The various disposition instructions/retention periods
                           for electronic software programs, electronic data, and supporting documents are not
                           consistent but should be.  We were also concerned that there would be  an inability to
                           audit/retrieve data if the Agency is keeping incremental backup copies  of inactive
                           databases and the copies have not been modified to work with the latest software
                           release. Having earlier versions of software would enhance the ability  to
                           audit/retrieve the data, especially to ensure the authenticity of electronic/digital
                           signatures.  Further, we do not concur with the proposal to break records related to
                           post award monitoring, evaluation, and oversight for specific grants at the end of the
                           reporting period and destroy them after 7 years (or 30 years for Superfund site-
                           specific records). In our opinion, these records should be maintained for the same
                           period as other records related to the grant.
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Goal 3: Produce Timely, Quality and Cost-Effective Products and Services That
	Meet Customer Needs	

                         The OIG is a customer-driven organization in which customer
                         needs serve as the basis for work planning and the design of OIG
                         products and services. All OIG work is based on anticipated
                         value to Congress and EPA. The following illustrates results
                         achieved under this OIG goal.
 EPA OIG Develops
 Guide for Assessing
 Organ ization al
 Systems	
EPA OIG recently developed a guide, "Assessing Organizational Systems: A User's
Guide," that can be used by both OIG and Agency Program Managers to assess
organizational systems.  Specifically, this guide provides a framework that can be
used to determine the efficiency and effectiveness of a particular program.

Over the past several years, the OIG has provided its staff with a number of training
classes designed to focus attention on applying "Systems" models in our audit and
evaluation projects.  The guide was developed to enable the OIG, as well as others in
the Agency, to effectively apply the principles touched upon during this training.

The guide is broken down into seven sections similar to those in the Malcolm
Baldrige criteria: Leadership, Strategic Planning, Customer/Stakeholder and Market
Focus, Information and Analysis, Human Capital, Process Management, and
Performance Results. Each section contains a set of questions derived from an
integration of our Malcolm Baldrige training, High Performance Organization
training, the President's Management Agenda, the Federal Managers' Financial
Integrity Act, and the Government Performance and Results Act.

These questions are designed to provide a useful tool when assessing an organization
or program. In particular, the guide contains a list of "Vital Few" questions for each
area, which can be used to enable the team to quickly develop an overall picture of an
organizational system before asking more specific questions as needed. The
questions are also designed to help the user identify the root cause of a condition, to
better enable the development of solutions.
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 OIG State
 Revolving Fund
 Activities Meet
 Customer Needs
The OIG's state revolving fund activities continue to meet the needs of Agency and
state revolving fund program managers and staff. The OIG conducts audits in states
that do not perform annual audits. During this reporting period, the OIG completed
five audits of state clean water or drinking water revolving funds.  These audits
provide Agency and state program managers with assurance that the financial
information about the state revolving fund is accurate and reliable.

The OIG also completed an audit guide for the clean water and drinking water state
revolving funds. The guide highlights and explains some of the unique characteristics
of the state revolving funds that state or independent auditors needs to be aware of in
auditing the funds.  State program managers and staff have also found the guide
useful in helping them understand and apply new accounting and financial reporting
requirements. The guide includes sample reports and financial statements that state
managers and independent auditors can refer to in preparing audited financial
statements. The audit guide is available on the OIG's internet web site.
 OIG Issues First
 Multi-Year Plan
The EPA OIG developed and isued its first Multi-Year Plan covering fiscal 2003
through 2005, and is the connecting link between EPA's Strategic Goals and OIG's
Strategic Goals and Annual Work Plans. Constructed, with the input of EPA and
OIG clients and stakeholders, the Multi-Year Plan demonstrates how the concepts,
direction, and priorities established in the OIG Strategic Plan will be cohesively
implemented and arrayed to answer a logical sequence of questions.  We will
specifically apply a variety of professional disciplines through a progression of
assignments in Product Line Tracks, linked to specific EPA programs, operations and
challenges to evaluate the linkage and relationships of the inputs, processes, and
actions that critically influence the successful fulfilment of EPA's Statutory Mission
and Goals. This Multi-Year Plan is designed to increase the depth of our reviews by
performing technical, policy and scientific analysis of complex environmental issues,
while examining the interrelationships of supporting management systems. The
Multi-Year Plan recognizes human capital, partnerships, followup, flexibility,
measurement, and review s of EPA's Program Assessment Rating Tools (PART) as
elements for success through FY 05.  The Multi-Year Plan is available electronically
from  http://www.epa.gov/oig
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 Cross-Walk Between EPA Goals and EPA QIC Multi-Year Plan Through FY 2005
Cleaner Air
      Air
      Chapter 2
 •Particulate Matter: How can EPA maximize the effectiveness of its fine participate matter
  (PM 2.5) ambient monitoring and emissions control strategies?
 • Ozone: How can EPA better execute its ozone reduction strategies?
 •Air Toxics: How can EPA improve the effectiveness of its efforts to assess, monitor, control,
  and reduce the risks from toxics air pollutants to human health & environment?
 •Challenges to Progress: How can EPA maximize the contributions of state and local entities
  in continuing progress toward meeting clean air goals?
Purer Water
      Water
      Chapter 3
 • Safe Drinking Water: How can EPA effectively implement the Safe Drinking Water
  Amendments of 1996?
 •Watershed Protection: How can EPA effectively control, protect and monitor watersheds
  and water quality?
 •Reducing Pollutant Loadings: How can EPA effectively use and improve policy tools to
  reduce water pollutant loadings?
Safer Land
      Land
      Chapter 4
 • Superfund: Is EPA making progress toward effective risk reduction and waste cleanup?
 •Brownfields: Is EPA making progress toward effective risk reduction, cleanup, and restoring
  previously polluted sites to appropriate uses?
 •Resource Conservation & Recovery Act (RCRA): Is EPA making progress toward effective
  waste management, hazardous material management, and risk reduction?
Ecosystems &
Communities

Compliance &
Environmental
Stewardship

     Cross Media
     Chapter 5
• "Homeland Security: How can EPA better execute its Strategic Plan to prevent, prepare for,
  and respond to a terrorist attack to minimize adverse impacts on human health and the
  environment?
• •Environmental Stewardship: Do the States and tribes use high performance concepts to
  deliver environmental and human health protection?
• "Environmental Justice: How well are environmental justice concerns incorporated into EPA
  decisionmaking; Do EPA policies and practices disproportionately contribute adverse impacts
  on human health and the environment in communities of concern?
• "Compliance Assistance & Enforcement: Is the employment of traditional and nontraditional
  enforcement approaches optimized to ensure compliance with environmental rules and
  regulations that are designed to protect human health and the environment?
EPA Management
Support
Infrastructure

     Good
     Government
     Chapter 6
  Financial Management: Does EPA have the people, processes, and systems needed to
  efficiently provide timely accurate, complete and useful financial information for
  decisionmaking and accountability?
  Information Resources Management: Does EPA have systems, processes, and controls in
  place to ensure timely, reliable, and complete information is available to manage EPA's
  programs and report on environmental results?
  Program Management: Does EPA have the system and processes in place to plan, budget
  for, and manage its programs, and human capital needed to carry out its mission?
  Assistance Agreements: Is EPA using assistance agreements to efficiently and effectively
  accomplish its mission?
  Contracts: Is EPA using contracts to efficiently & effectively accomplish its mission?
  Energy Conservation- Green Power: Will EPA's strategies enable it to reduce overall
  energy usage by 20 percent from fiscal 1990 to 2005 and by 25 percent by fiscal 2010?
                                                              PAGE 23 - OCTOBER 1, 2002 THROUGH MARCH 31, 2003

-------
 Scoreboard of Mid-Year Results Compared to FY 2003 Performance Targets
 All results reported are a combination of completed and prospective as of March 31, 2003 unaudited
Annual Performance Goal;
Target, Mid-Year Reported Status
Supporting Measures
Goal 1. Contribute to Environmental Quality and Human Health
 Environmental Improvements/Actions/Changes

 Target 60;  Reported 3 8;
 3  Legislative changes/decisions
 5  Regulatory changes/decisions
24 EPA Policy, process, practices change
 5  Examples of environmental improvement
 1  Best environmental practice implemented
 Environmental Risks Reduced or Eliminated
 Target 20;  Reported 12;
10 Environmental Risks reduced/eliminated
2  Certifications/validations/verifications
 Environmental recommendations, best practices,
 risks identified

 Target 80;  Reported 5 7;
25 Environmental recommendations
 7 Environmental best practices identified
23 Environmental risks identified
 Goal 2. Improve EPA's management, accountability and program operations
 Return on Investment: Potential dollar return
 compared to investment in OIG (in millions)

 Target 150% ; Reported 918% ;
$4.1 Questioned costs
  72.5 Recommended efficiencies, costs saved
$ 368 Fines, recoveries, settlements
 Criminal, Civil & Administrative Actions
 Reducing Risk of Loss/Operational Integrity

 Target 50;  Reported 43;
 9 Criminal Convictions
16 Indictments/informations/comlaints
  2 Civil Judgements/settlements
 17 Administrative actions
 Improvements in Business/Systems/Efficiency

 Target 75;  Reported 28;
16 Policy process, practice, control changes
 1 Corrective action on FMFIA/Mgt Challenge
 3 Best practice implemented
 8 Certifications/validations/verifications
 Recommendation, best practices, risks identified

 Target 155;  Reported 57;
52 Recommendations
 5 Best practices identified
   Risks identified
   FMFIA/ Management Challenges
http://www.epa.gov/oig/ - PAGE 24

-------
Audit Report Resolution
Status Report on Perpetual Inventory of Reports in Resolution Process for Semiannual Period Ending
March 31, 2003
Report Category
A. Reports for which no
management decision was
made by October 1, 2002
B. Reports which were
issued during the reporting
period
C. Reports which were
issued during the reporting
period that required no
resolution
Subtotals (A + B - C)
D. Reports for which a
management decision was
made during the reporting
period
E. Reports for which no
management decision
was made by
March 31, 2003
Reports for which no
management decision was
made within six months of
issuance
No.
of
Reports
85
238
174
149
52
97
46
Report Issuance
(Dollar Value in Thousands)
Questioned
Costs
$55,173
3,965
0
59,138
22,083
37,054
33,423
Recommended
Efficiencies
$3,622
72,516
0
76,138
253
75,885
3,369
Report Resolution Costs Sustained
(Dollar Value in Thousands)
To Be Recovered




$8,781


As Efficiencies




$0


Any difference in number of reports and amounts of questioned costs or recommended efficiencies between this
report and our previous semiannual report results from corrections made to data in our audit tracking system.
                                                                     PAGE 25 - OCTOBER 1,2002 THROUGH MARCH 31,2003

-------
Status of Management
Decisions on IG Reports	

This section presents statistical
information as required by the
Inspector General Act Amendments of
1988 on the status of EPA
management decisions on reports
issued by the OIG involving
monetary recommendations.
As presented, information contained
in Tables 1 and 2 cannot be used to
assess results of reviews performed or
controlled by this office. Many of the
reports were prepared by other
Federal auditors or independent
public accountants. EPA OIG staff
do not manage or control such
assignments.  Auditees frequently
provide additional documentation to
support the allowability of such costs
subsequent to report issuance. We
expect that a high proportion of
unsupported costs may not be
sustained.
Table 1 — Inspector General Issued Reports With Questioned Costs for Semiannual Period Ending
March 31, 2003
Report Category
A. Reports for which no management decision
was made by October 1, 2002**
B. New reports issued during period
Subtotals (A + B)
C. Reports for which a management decision
was made during the reporting period
(i) Dollar value of disallowed costs
(ii) Dollar value of costs not disallowed
D. Reports for which no management decision
was made by March 31, 2003
Reports for which no management decision was
made within six months of issuance
Number of
Reports
35
16
51
11
8
3
40
20
Questioned Costs*
(Dollar Value in Thousands)
$55,173
3,965
59,138
22,083
8,781
13,302
37,054
33,423
Unsupported Costs
(Dollar Value in
Thousands)
$17,340
1,646
18,985
11,245
0
11,245
7,740
6,095
* Questioned costs include the unsupported costs.

** Any difference in number of reports and amounts of questioned costs or recommended efficiencies between this report and our
previous semiannual report results from corrections made to data in our audit tracking system.
http:/Awvw.epa..gov/oig/- PAGE 26

-------
Table 2 — Inspector General Issued Reports With Recommendations That Funds Be Put To
Better Use for Semiannual Period Ending March 31, 2003
Report Category
A. Reports for which no management decision was made by
October 1, 2002
B. Reports which were issued during the reporting period
Subtotals (A + B)
C. Reports for which a management decision was made during the
reporting period
(i) Dollar value of recommendations from reports that were
agreed to by management
(ii) Dollar value of recommendations from reports that were
not agreed to by management
(ill) Dollar value of non-awards or unsuccessful bidders
D. Reports for which no management decision was made by
March 31, 2003
Reports for which no management decision was made within six
months of issuance
Number of
Reports
5
2
7
1
0
1
0
6
4
Dollar Value
(In Thousands)
$3,622
72,516
76,138
253
0
253
0
75,885
3,369
Reports With No Final Action As Of March 31, 2003
Which Are Over 365 Days Past OIG Report Issuance Date
Audits
Programs
Assistance Agreements
Contract Audits
Single Audits
Financial Statement Audits
TOTAL
Total
20
81
19
12
1
133
Percentage
15
61
14
9
1
100
                                                              PAGE 27 - OCTOBER 1,2002 THROUGH MARCH 31,2003

-------
Summary of Investigative Results
Summary Of Investigative
Activities
Pending Investigations as
of September 30, 2002

New Investigations
Opened This Period

Investigations Closed
This Period

Pending Investigations as
of March 31,2003
   181
   65
   45
   201
Prosecutive and
Administrative Actions

In this period, investigative efforts
resulted in 9 convictions and 16
indictments (does not include
indictments obtained in cases in
which we provided investigative
assistance). Fines and recoveries,
including those associated with civil
actions, amounted to $368 million.
Seventeen administrative actions
were taken as a result of
investigations.
Terminations
Restitutions
Reprimands
Suspension &
Debarments
Other
                                          TOTAL
2
3
3

8
1
                      17
                          Profiles of Pending Investigations by Type
           General EPA Programs
              Total Cases = 143
                                   Superfiind
                                Total Cases = 58
                                                      13
              Contract
              Assistance
              Agreement
Employee Integrity
Program Integrity
Other
             Computer Crime
             Unit
 Lab Fraud
http://www.epa.gov/oig/ - PAGE '<

-------
  Appendix  1  -- Reports Issued
        THE INSPECTOR GENERAL ACT REQUIRES A LISTING, SUBDIVIDED ACCORDING TO SUBJECT MATTER, OF EACH REPORT ISSUED BY
THE OFFICE DURING THE REPORTING PERIOD AND FOR EACH REPORT, WHERE APPLICABLE, THE DOLLAR VALUE OF QUESTIONED COSTS
AND THE DOLLAR VALUE OF RECOMMENDATIONS THAT FUNDS BE PUT TO BETTER USE.
                                                                                    Questioned Costs
Report Number
                                 Title
 Final  Report
	Issued	
                                                                                                                 Recommended
                                                                                                                 Efficiencies
Ineligible
 Costs	
Unsupported
  Costs	
Unreasonable (Funds Be  Put
  Costs	To Better Use)
             CLOSED: Final-Prel.  Res. Results on Improper
             Contract Pymnts
             EPA's Controls Over  Social Security Numbers b
             y  Third Parties
             Oversight of Superfund Cleanup Actions  for DO
             E  Handford Site
             Science to support rulemaking - pilot study r
             eport
             State Self-Assessments
             Region 6 Needs to Improve Oversight of  LA's E
             nviron Programs
             Superfund Cleanups of Groundwater
             Assistance Agreements - Awarding
             Contracts - PBSC
             Adequacy of Cyber-based Infrastructure  Implem
             en Activities

                 TOTAL  PERFORMANCE REPORTS = 10
2003-1-00048  Nevada DWSRF  FY 2001                        21-JAN-03
2003-1-00060  Audit of the State  of Nevada CWSRF FY2001 Fin 05-FEB-03
            ancial Stmts
2003-1-00068  Audit of Washington DWSRF FY 2001            21-FEB-03
2003-1-00086  AA 2002 CWSRF New Hampshire                  24-MAR-03
2003-1-00087  CENTRAL STATES AIR  RESOURCE AGENCIES  GRANT AU 31-MAR-03
           DITS
               TOTAL ASSISTANCE AGREEMENT  REPORTS =  5
                                                                                                          0       0
    -3-00001  New York, State of                           09-OCT-02
    -3-00002  Magnolia Municipal  Water System              09-OCT-02
    -3-00003  Brigham and Women's Hospital, Inc.            10-OCT-02
    -3-00004  National Academy of Sciences                 10-OCT-02
    -3-00005  Magnolia, City of                           22-OCT-02
    -3-00006  California State University                  22-OCT-02
    -3-00007  Laguna, Pueblo of                           24-OCT-02
    -3-00008  Washoe Tribe of Nevada and California         24-OCT-02
    -3-00009  Washoe Tribe of Nevada and California         24-OCT-02
    -3-00010  Conrad, City of                             25-OCT-02
    -3-00011  Fort Worth, City of                         31-OCT-02
    -3-00012  Yankton Sioux Tribe                         31-OCT-02
    -3-00013  Fond du Lac Reservation                      Ol-NOV-02
    -3-00014  Southeastern States Air Resource Managers, In Ol-NOV-02
2003-3-00016  Southeastern States Air Resource Managers, In Ol-NOV-02
           c.  2001
2003-3-00017  Blackfeet Tribe of the Blackfeet Indian Reser 07-NOV-02
           vation
2003-3-00018  Greenville Rancheria                         08-NOV-02
2003-3-00019  Spokane Tribe                               08-NOV-02
2003-3-00020  Tyrone, Borough of                           12-NOV-02
2003-3-00021  The Academy of Natural Science               13-NOV-02
2003-3-00022  Eight Northern Indian Pueblos Council, Inc.  ( 15-NOV-02
           FY 2000)
2003-3-00023  Eight Norythern Indian Pueblos,  Inc.  (FY  2001 15-NOV-02
                                                                    PAGE 29 - OCTOBER 1, 2002 THROUGH MARCH 31, 2003

-------
Report Number
                                   Title
                                                           Final Report
                                                               Issued
                                                                     Ineligible
                                                                       Costs
                                                                                        Questioned  Costs
                                                                                                                        Recommended
                                                                                                                       Efficiencies
                               Unsupported
                                  Costs
Unreasonable  (Funds Be Put
   Costs	To  Better Use)
2003-3
2003-3
2003-3
2003-3
2003-3
2003-3
2003-3
2003-3
2003-3
2003-3
2003-3
2003-3
2003-3
2003-3
2003-3
2003-3
2003-3
2003-3
2003-3
2003-3
2003-3
2003-3
2003-3
2003-3
2003-3
2003-3
2003-3
2003-3
2003-3
2003-3
2003-3
2003-3
2003-3
2003-3
•00027  Shoshone  &  Arapahoe Tribes,  Wind River
      ation
-00028  Huntington  Beach
-00029  National  Institute For Environmental Re
-00030  3  Rivers  Wet  Weather,  Inc.
-00031  Southern  Appalachian Mountains Initiati
-00032  Pleasant  Point Passamaquoddy Tribe
-00033  Seneca  Nation of Indians
-00034  Alliance  for  Chesapeake Bay,  Inc.
-00035  Lake  Wallenpaupack Watershed District
-00036  San Luis  Valley Resource Conservation a
      elopment Area
-00037  Palau National Government,  Republic of
-00038  Palau National Government,  Republic of
-00039  Palau National Government,  Republic of
-00040  Salt  Lake County FY 2000
-00041  SALT  LAKE COUNTY FY 2001
-00042  Cocopah Indian Tribe FY 1999
-00043  Cocopah Indian Tribe FY 2000
-00044  Chickalon,  Native Village of
-00045  Palau National Government,  Republic of
-00046  Palau National Government,  Republic of
-00047  Stevens Village Council
-00048  Chickalon,  Native Village of
-00049  Alabama,  State of
-00050  America's Clean Water Foundation
-00051  Nortwood, City of
-00052  American  Council for an Energy-Efficien
      omy
-00053  Rock  river  Water Reclamation District
-00054  The Pacific American Foundation
-00055  The Pacific American Foundation
-00056  White Earth Reservation Tribal Council
-00057  Sherwood  Valley Band of Porno Indians
-00058  Sherwood  Valley Band of Porno Indians
-00059  Sac and Fox Nation of Oklahoma
-00060  Colorado, State of
-00061  Colorado, State of
-00062  Georgia,  State of
-00063  Valdese,  Town of
-00064  King  Cove,  City of,  Alaska
-00065  Blair County  Convention & Sports Facili
       hority
-00066  Fayal,  Town of
-00067  Round Valley  Indian Tribe of the Round
       Reservation
-00068  North Dakota  Rural Water Association
-00069  Alfred  University
-00070  Arkansas, University for Medical Scienc
-00071  Water Environment Research Foundation
-00072  Alabama Water Pollution Control Author!
-00073  Rhode Island  and Providence Plantations
       e  of
-00074  Nevada, State of
-00075  Washington, State of
-00076  Washington, State of
-00077  Ohio, State of
-00078  Montana,  State of
-00079  New Mexico  Finance Authority
-00080  Kentucky, Commonwealth of
-00081  North Carolina,  State of
-00082  Connecticut,  State of
-00083  Burns Paiute  Tribe
-00084  Kaiser  Foundation Health Plan, Inc
-00085  Lower Sioux Indian Community
-00086  National  Alliance for Hispanic Health
-00087  Fallon  Paiute-Shoshone Tribe
-00088  Wisconsin,  State of
-00089  Kansas, State of
-00090  Missouri, State of
-00091  Missouri, State of

          TOTAL SINGLE AUDIT REPORTS = 91
                                                     nd  Dev
21-JAN-03
21-JAN-03
21-JAN-03
22-JAN-03
22-JAN-03
22-JAN-03
22-JAN-03
28-JAN-03
04-FEB-03
04-FEB-03
05-FEB-03
ll-FEB-03
13-FEB-03
13-FEB-03
14-FEB-03
27-FEB-03

21-FEB-03
25-FEB-O
25-FEB-O
27-FEB-O
27-FEB-O
27-FEB-O
27-FEB-O
04-MAR-O
04-MAR-O
05-MAR-O
05-MAR-O
05-MAR-O
05-MAR-O
14-MAR-03
14-MAR-03
14-MAR-03
17-MAR-03
17-MAR-03
17-MAR-03
24-MAR-03
24-MAR-03
24-MAR-03
25-MAR-03
25-MAR-03
25-MAR-03
25-MAR-03
25-MAR-03
28-MAR-03
28-MAR-03
31-MAR-03
31-MAR-03
                                                                      $2,153,061
http://www.epa.gov/oig — PAGE 300

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                                                                                                                       Recommended
                                                                           	Questioned Costs	 Efficiencies
                                                          Final Report     Ineligible    Unsupported    Unreasonable (Funds Be Put
Report Number	Title	Issued	Costs	Costs	Costs	To Better Use)
                 TOTAL OIG ISSUED CONTRACT  REPORTS = 3                $162,807                0               0       $15,672

2003-1-00001 CH2M Hill Inc.-FY2002  IT General  Controls  Sys  04-OCT-02
             tern
2003-1-00002 GET Environmental Services Inc.-FY2000 Incurr  04-OCT-02
             ed Cost
2003-1-00003 Parallax, Inc.-FY1999  Incurred  Cost            04-OCT-02
2003-1-00004 Parallax, Inc.-FY2000  Incurred  Cost            04-OCT-02
2003-1-00005 McWane & Company-FY99  Incurred  Cost            04-OCT-02
2003-1-00006 CH2M Hill Inc.-FY 2000  Floorcheck             04-OCT-02
2003-1-00007 OAO Corporatlon-FY2000  Incurred Cost          08-OCT-02
2003-1-00008 URS Corporatlon-FYl999  Incurred Cost          08-OCT-02
2003-1-00009 DCT,  Inc.-FY2000 Incurred Cost                 08-OCT-02
2003-1-00010 Eastern Research 6roup-FY2000  Incurred Cost    08-OCT-02
2003-1-00011 Louis Berger & Associates, Inc.-FY97 Incurred  08-OCT-02
              Cost
2003-1-00012 Great Lakes  Envlronmental-FY2001  Incurred  Cos  08-OCT-02
             t
2003-1-00013 Parsons Engineering  Sclence-FY99  Incurred  Cos  08-OCT-02
             t
2003-1-00014 CH2M Hill Inc.-FY2000  Incurred  Cost
2003-1-00015 IT Group-FY2002  Billing System
2003-1-00016 ROY F. WESTON INC.-FY  1995 ARCS 68-W9-0057
2003-1-00017 PRC/Tetra Tech EMI-FY2000 Incurred Cost
2003-1-00018 Alternative  Energy Department,  Inc.-FY95-98
2003-1-00019 Alternative  Energy Development, Inc.-FY 1999
             Incurred Cost
2003-1-00021 Henderson Assoclates-FY96 Incurred Cost
2003-1-00022 Henderson Assoclates-FY97 Incurred Cost
2003-1-00023 Henderson Assoclates-FY98 Incurred Cost
2003-1-00024 Henderson Assoclates-FY1999 Incurred Cost
2003-1-00025 Gannett Fleming  Environmental  Englneers-FY200  18-OCT-02
             0 Incurred Cost
2003-1-00026 Gannett Fleming  Environmental  Engineers,  Inc.  18-OCT-02
             -FY2001 I/C
2003-1-00027 Shaw Envlronmentalslnfra(IT Group)-FY2002  Dal  23-OCT-02
             ly Equip. Rates
2003-1-00028 DynCorp,Inc.-FY2000  Incurred Cost             24-OCT-02
2003-1-00029 ManTech Environmental  Technology-Final Audit   12-NOV-02
2003-1-00030 Roy F. Weston-FY2000 Incurred Cost            12-NOV-02
2003-1-00031 FEV of America-FY2001  Incurred  Cost            13-NOV-02
2003-1-00036 URS Greiner  Woodward-Clyde Federal-FY1999  Inc  19-NOV-02
             urred Cost
2003-1-00037 Systems Research s Applications-FY99 Incurred  19-NOV-02
              Cost
2003-1-00038 Transcontinental Enterprises,  Inc.-FY1999  Inc  19-NOV-02
             urred Cost
2003-1-00039 CH2M Hill Companies-Home Office Allocation FY  19-NOV-02
             E 12/31/00
2003-1-00040 CH2M Hill ISE Business  Groups-Intermediate Al  19-NOV-02
             location FYE 00
2003-1-00042 SoBran Inc.-FY2001 Incurred Cost               22-NOV-02
2003-1-00043 Environmental Chemical  Corporation-FY1998  Inc  25-NOV-02
             urred Cost
2003-1-00044 Tetra Tech EM Inc.-FY94-98 CACS 68-W5-0055
2003-1-00046 Gruzen Samton-FY99 Incurred Cost
2003-1-00047 ESE (Harding ESE)-FY2000 Incurred Cost
2003-1-00049 ESE (Harding ESE)-FY1999 Incurred Cost
2003-1-00050 Computer Based Systems-FY2000  Incurred Cost
2003-1-00051 Tetra Tech NUS,  Inc.-FY2000 Incurred Cost
2003-1-00052 URS Greiner  Woodward-Clyde-FY99 Incurred Cost  22-JAN-03
              Supplemental
2003-1-00053 Techlaw Inc.-FY2000  Incurred Cost             29-JAN-03
2003-1-00054 TechLaw Inc.-FY2001  Incurred Cost             29-JAN-03
2003-1-00056 Environmental Chemical  Corporation-FY1999  Inc  21-FEB-03
             urred Cost
2003-1-00057 Black S Veatch Holding  CO.-FY2000 I/C of Corp  31-JAN-03
                                                                       PAGE XX - OCTOBER  1,2002  THROUGH MARCH 31,2003

-------
                                                           Final Report    Ineligible    Unsupported    Unreasonable  (Funds Be  Put
	Title	Issued	Costs	Costs	Costs	To Better  Use)
             orate Office
2003-1-00058 CH2M Hill Inc.-FY2002 Indirect Forward Pricin 31-JAN-03
             g Rates
2003-1-00059 Clean Air Vehicle Technology Center-FY2001 In 31-JAN-03
             curred Cost
2003-1-00062 TechLaw Inc.-FY98 Incurred Cost               13-FEB-03
2003-1-00063 TechLaw Inc-FY99 Incurred Cost                13-FEB-03
2003-1-00064 Roy F. Weston-FY97 ARCS Closeout 68-W8-0089   13-FEB-03
2003-1-00065 Bionetics Corporation-FY2001 Incurred Cost    13-FEB-03
2003-1-00066 Industrial Economics, Inc.-FY2000 Incurred Co 13-FEB-03
             st
2003-1-00069 ABT Associates Inc.-CACS 68-D2-0175           25-FEB-03
2003-1-00070 McWane & Company Inc.-FY2000 Incurred Cost    28-FEB-03
2003-1-00071 Toeroek Associates-FY1999 Incurred Cost       28-FEB-03
2003-1-00072 Sierra Research Inc.-FY2001 Incurred Cost     28-FEB-03
2003-1-00073 Parallax, Inc.-FY2001 Incurred Cost           28-FEB-03
2003-1-00075 Lee Wilson s Associates-FY2001 Incurred Cost  03-MAR-03
2003-1-00076 TN s Associates-FY2001 Incurred Cost          03-MAR-03
2003-1-00077 Toeroek Associates-FY2000 Incurred Cost       03-MAR-03
2003-1-00078 Armstrong Data Services-FY2000 Incurred Cost  05-MAR-03
2003-1-00079 Armstrong Data Services-FY98 Incurred Cost    05-MAR-03
2003-1-00080 Foster Wheeler Environmental Corp.-FY2000 RAC 06-MAR-03
              68-W9-8214
2003-1-00081 ABB Power Plant Laboratories-FY1987 thru 1994 10-MAR-03
              Incurred Cost
2003-1-00082 IT Group-QUATS Segment FY1999 Incurred Cost
2003-1-00084 Bechtel Group,
             ost
2003-1-00088 Integrated Laboratory Systems-FY2000 Incurred 28-MAR-03
              Cost
2003-1-00089 Griffin Services, Inc.-FY99 Incurred Cost     28-MAR-03
2003-1-00090 SCS Engineers-FY2001 Incurred Cost            28-MAR-03
2003-1-00091 Syracuse Research Corporation-FY2001 Incurred 31-MAR-03
              Cost
2003-2-00001 Asset Group Inc.-Preaward                     15-OCT-02

2003-2-00002 Dyncorp Systems s Solutions LLC-Preaward PR-C 26-NOV-02
             1-02-10152
2003-2-00004 IT Group-DACA45-98-D-0003 Delivery Order #16  22-JAN-03
2003-2-00006 Foster Wheeler Envtl. Corp.-Agreed Upon RFP F 13-FEB-03
             41624-02-R-8159
2003-4-00001 CH2M Hill Inc.-FY2002 Indirect/ODC System     09-OCT-02
2003-4-00002 Battelle Memorial Institute-IT Syst. Gen. Int 09-OCT-02
             ernal Control
2003-4-00003 CH2M Hill Companies, Ltd.-CAS 403             09-OCT-02
2003-4-00004 IT Group-FY2002 CAS 411 Material Acquisitions 09-OCT-02
2003-4-00005 IT Group-FY2002 CAS 408 Compensated Absences  09-OCT-02
2003-4-00006 IT Group-FY2002 CAS 404 Capitalization of Ass 09-OCT-02
             ets
2003-4-00007 IT Group-FY2002 Accounting System
2003-4-00008 Tetra Tech EMI-Budget System
2003-4-00009 CH2M Hill ISE-FY2002 CAS 403
2003-4-00010 Lockheed Martin Services Inc.-FY2002 CAS 414
2003-4-00011 Tetra Tech Inc.-FY2002 CAS 409
2003-4-00012 Tetra Tech Inc. - FY2002 CAS 404
2003-4-00013 Shaw Environmental
             tern s 1C
2003-4-00014 Shaw Environmental
             ct/Direct Cost
2003-4-00015 Tetra Tech NUS-FY2002 CAS 409                 30-OCT-02
2003-4-00016 Shaw Environmental s Infra.-FY2003 Daily Equi 06-NOV-02
             pment Rates
2003-4-00017 Shaw Environmental s Infra.-FY2002 Bidding/Bi 08-NOV-02
             lling Rates
2003-4-00018 Shaw EnviromentalSInfra.-FY2003 Estimated Dir 08-NOV-02
             ect Labor Rates
2003-4-00019 Tetra Tech NUS-FY2002 CAS 404                 08-NOV-02
2003-4-00020 Tetra Tech EMI-Internal Control               12-NOV-02
HTTP://WWW.EPA.GOV/OIGEARTH - PAGE 34

-------
                                                                                                                       Recommended
                                                                                                                     Efficiencies
                                   Title
                                                          Final Report
                                                         	Issued
      -00021 Midwest Research  Institute-Material  Purchases
              Control Syst.
      -00022 Shaw Environmental  &  Inf ra-FY2003/2 004  Biddin
             g/Billing Rates
      -00023 Shaw Environmental  s  Inf ra . -FY2 003 Billing Sy
             stem & 1C
      -00024 Professional  s  Scientific Association-FY95 In
             curred Cost
      -00025 Battelle Memorial  Institute-Labor System  Inte
             rnal Controls
      -00026 Tetra Tech Inc.-FY2002  CAS  403
      -00027 Tetra Tech,  Inc . /BSV-FY19 98  I/C  Supplemental
             68-W7-3002
      -00028 Lockheed Martin  Services-Adequacy &  Complianc
             e of D/S
      -00030 Foster Wheeler  Environmental  Corp.-FY2003 CAS
      -00031 Bechtel  System &  Inf rast-Follow-up Compensati
             on System
      -00032 Bechtel  System s  Infrast-Info  Tech Sys  Gen  In
             ternal Control
      -00033 Shaw ESI-Financial  Condition
      -00034 Bechtel  Systems  s  Inf rast-Labor Accounting
      -00035 Roy F.  Weston,  Inc.-FY  1996 ARCS  68-W9-0046-C
             ancelled
      -00037 Industrial  Economics, Inc.-FY2003 Floorcheck
      -00038 Tetra Tech  EMI-Executive  Compensation
      -00039 CH2M Hill Inc.-FY2002 CAS 415
      -00040 CH2M Hill Inc.-FY2002 CAS 404
      -00041 Toeroek  Associates-FY2001 Accounting System R
             eview
      -00042 InfoPro  Inc.-FY98  Incurred Cost
      -00043 ASRC Aerospace Corporation-FY2000 Incurred  Co
             st
      -00044 CH2M Hill Inc.-FY2002 CAS 409
      -00045 Midwest  Research  Institute-CAS 408
      -00046 Lockheed Martin  Services-FY2003 Disclosure  St
             atement  Rev.  10
      -00047 EC6,Inc.-FY2000  Incurred  Cost
      -00048 Mega Tech,  Inc.-FY2000  Incurred Cost
      -00049 EC/R Inc.-FY2000  Incurred Cost
      -00050 EC/R Incorporated-FY99  Incurred Cost
13-FEB-03
13-FEB-03
19-FEB-03
19-FEB-03
05-MAR-03
                 TOTAL DCCA CONTRACT REPORTS  =126                       $4,417

2003-1-00045 2002  A6CY F/S  -  PREPARATION AND REPORTING -  FAD MASTER 29-JAN-03
                 TOTAL FINANCIAL STATEMENT REPORTS  =  1
                 TOTAL SPECIAL REVIEW REPORTS  =  2

                 TOTAL REPORTS ISSUED =   238
                                                                    $2,320,285
                                                                                      $1,644,618
                                                    0       0

                                                    0       $72,515,672
                                                                       PAGE XX - OCTOBER 1,2002 THROUGH MARCH 31,2003

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