EPA-350-R-07-003
November 2007
OFFICE OF INSPECTOR GENERAL
Semiannual Report to Congress
April 1, 2007 - September 30, 2007
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EPA Inspector General
Vision
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) fully inform the
Administrator and the Congress about problems and deficiencies identified by the Office
of Inspector General relating to Agency programs and operations.
We are catalysts for improving the quality of the environment and Government through
problem prevention and identification, and cooperative solutions.
Mission
Add value by promoting economy, efficiency, and effectiveness within EPA and the
delivery of environmental programs. Inspire public confidence by preventing and
detecting fraud, waste, and abuse in Agency operations and protecting the integrity of
EPA programs.
To find out more about the U.S. Environmental Protection Agency
Office of Inspector General and its activities, visit our Website at:
http://www.epa.gov/oiq
Cover photos:
Clockwise, from top left: A caution sign at a Superfund site in Ringwood, New Jersey
(photo by EPA Office of Inspector General); Maryland farmland being encroached by
housing development (photo from U.S. Department of Agriculture); contaminated soil
in Panola County, Texas (photo from Texas Commission on Environmental Quality);
and air pollution generated at an industrial facility (photo from EPA).
Printed on 100% recycled paper (minimum 50% postconsumer)
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Message to Congress
During this semiannual period, we conducted many reviews focusing on how well the
U.S. Environmental Protection Agency (EPA) has been protecting the environment, in
addition to whether the Agency has been performing in an economical and efficient
manner. Nearly two-third of the reports we published during the period focused on
achieving environmental results. We also noted more than $18 million in potential
monetary benefits.
EPA and its Chesapeake Bay watershed partners will not meet 2010 goals for reducing
loadings from developed lands. In fact, new development is increasing loadings at rates
faster than restoration efforts can reduce them. The population in the watershed, which
currently exceeds 16 million, is projected to surpass 19 million before 2030. We issued a
report during this period that recommended that EPA take more of a leadership role in
reversing the trend of increasing loadings from developed and developing land, with
particular emphasis on new development and smart growth, and we are helping the
Agency find ways to do so.
We performed two separate reviews of the Ringwood Mines/Landfill Superfund site in
New Jersey, as requested by congressional representatives from that State. We found that
while EPA oversight met many requirements, EPA could have conducted a more
thorough investigation on the removal of paint sludge. We also looked at environmental
justice concerns at the site, because area residents said they were treated unfairly because
of their racial makeup and socioeconomic status. We did not find discriminatory actions
on the part of EPA, but we did find that problems with communications and relationships
impeded effective cooperation between EPA and residents.
We questioned millions of dollars in reported outlays due to unallowable outlays being
claimed, lack of support, and noncompliance with financial and program management
standards for grants awarded to the Environmental Careers Organization, Cheyenne River
Sioux Tribe, and Ozone Transport Commission. At the request of the EPA Office of
Water, we initiated numerous reviews of costs claimed under Special Appropriation Act
Project grants, and noted various instances of ineligible costs claimed. Also, we provided
a congressional requestor with various details on earmark grants awarded during a
15-month period.
EPA needs to better justify and support its decisions to enter into Superfund interagency
agreements with the U.S. Army Corps of Engineers. In Fiscal Years 2005-2006, EPA
made over $500 million in such payments to the Corps to perform Superfund cleanups,
but did not always adequately support its decisions to do so. EPA did not develop
independent cost estimates to ensure the interagency agreements awarded to the Corps
were based on sound financial decisions. Further, EPA's lack of oversight contributed to
the Corps accumulating $2.5 million in excess Management and Support fees from
Superfund.
Related to our review of a Hotline complaint, EPA has indicated it plans to connect
homes in a small rural Texas community to a water system, to provide residents with
clean, permanent drinking water. In the meantime, EPA has been providing bottled water
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to the community. Further, EPA said it will assess whether the site qualifies for cleanup
under EPA's Superfund program.
This semiannual report includes details on these and other issues, including investigations
that resulted in payments to the Federal Government and criminal, civil, or administrative
actions. We will continue to work with the Agency and Congress, serving as a catalyst
for improving the environment.
Bill A. Roderick
Acting Inspector General
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Table of Contents
OIG Management's Focus 1
Environmental Results and Financial Integrity Emphasized 1
Actions Being Taken as a Result of OIG Work 2
Congressional Requests Addressed 3
OIG Budget Outlook Improves 4
Significant OIG Activity 5
Air 5
Water 6
Land 10
Cross-Media 13
Grants 16
Contracts 21
Financial Management 23
Risk and Program Performance 24
Information Resources Management 25
Public Liaison 27
Investigations 30
Testimony 33
Chemical Safety and Hazard Investigation Board 34
Other Activities 36
Statistical Data 40
Profile of Activities and Results 40
Audit Report Resolution 41
Summary of Investigative Results 43
Scoreboard of Results 44
Appendices 45
1 - Reports Issued 45
2 - Reports Issued Without Management Decisions 49
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OIG Management's Focus
Environmental Results and Financial Integrity Emphasized
The EPA Office of Inspector General (OIG) continued to focus on examining how well
EPA has been performing in its efforts to improve human health and environmental
quality, as well as on detecting waste and potential financial savings.
For the semiannual reporting period just ended, 65 percent of the OIG reports published
(26 of 40) were program evaluations and performance audits that focused on how EPA
can better achieve environmental results. These reports involved such topics as:
• Reducing pollution in the Chesapeake Bay from developing lands.
• Ensuring safe drinking water for a community encountering contamination.
• Improving data on enforcement actions.
• Investigating problems at a Superfund site.
• Providing better policies for voluntary programs.
• Providing better oversight for water discharge permits with noncompliance issues.
• Better managing Superfund Alternative sites.
• Strengthening the ENERGY STAR program.
• Applying promising practices to tribal grant programs.
Program evaluations assess how well a program is working. Program evaluations are
performed at EPA OIG by a staff with diverse backgrounds - including accounting,
economics, environmental management, and various scientific fields - and they comply
with the rigorous generally accepted government auditing standards. Program
evaluations can assess: (1) strategic planning and process implementation, to determine
whether a program is designed and operating as intended; (2) the extent to which a
program is achieving its outcome objectives; (3) the extent to which the program
outcomes are affecting subsequent impacts; and (4) the benefits of program results
compared to the costs. The objective of OIG program evaluations is to examine root
causes, effects, and opportunities leading to conclusions and recommendations that
influence systemic changes and promote improved delivery of the Agency's mission.
Program evaluations are similar to program results audits and performance audits, and
based on the generally accepted government auditing standards these names can be
used interchangeably.
The remaining 35 percent of the reports that we published during the semiannual period
(14 of 40) focused on ways EPA can belter manage it resources, with particular focus on
ensuring that its grant and contracting funds are properly spent. In OIG reports published
during the semiannual period, we noted more than $ 18 million in questioned costs and
recommended efficiencies.
The OIG will continue to focus on reviewing both how well EPA is achieving
environmental results and spending money in a financially efficient manner. To that end,
the OIG has already begun to actively increase its staff in the areas of both performance
audit/program evaluation and financial auditing.
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Actions Being Taken as a Result of OIG Work
During this reporting period, EPA agreed to take various actions as a result of OIG work.
The following actions related to the OIG's two external goals.
To contribute to improved human health and environmental quality...
• EPA agreed to provide more leadership in reversing the trend in the Chesapeake
Bay watershed of new development causing pollution into the Bay to increase at
rates faster than restoration efforts are reducing them.
• EPA agreed to communicate better with residents near a New Jersey Superfund
site regarding its cleanup efforts.
• EPA agreed to track and report cleanup progress at Superfund Alternative sites.
• EPA has been providing bottled water to residents in a small Texas community
who have contaminated well water, and indicated it will connect impacted homes
to a water system.
To improve EPA's management, accountability, and program operations...
• EPA will attempt to resolve $6.0 million in costs claimed by the Environmental
Careers Organization that we questioned due to noncompliance with standards.
• EPA will resolve $3.1 million in outlays made by the Cheyenne River Sioux
Tribe questioned due to financial management problems.
• EPA can make timely and better use of $3.423 million in the special account for
the Thermo Chem Superfund site by transferring the funds to the Superfund trust
fund or by reclassifying funds in a special account to other priority response
activities because the funds are no longer needed at the site.
• EPA will resolve $2.7 million in outlays reported by the Ozone Transport
Commission; the recipient claimed unallowable outlays for contractual services,
indirect costs, and in-kind costs.
• EPA established a plan for the use of $2.5 million in excess Management and
Support fees paid to the U.S. Army Corps of Engineers under Superfund
interagency agreements.
• EPA saved nearly $2.0 million as the result of an OIG investigation of an EPA
grantee that improperly treated its Government agreements as fixed rate rather
than cost reimbursable.
• EPA will attempt to recover a total of about $850,000 from several cities based
on OIG reviews of costs claimed under Special Appropriation Act Project grants.
• EPA has proposed a reorganization of its Office of Policy, Economics, and
Innovation to provide for a more robust evaluation of EPA programs.
We provide details on these and other issues throughout this semiannual report.
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Congressional Requests Addressed
During the semiannual period, the OIG performed several audits and evaluations
specifically requested by Congress.
As part of a request from U.S. Senator Barbara A. Mikulski of Maryland on progress in
cleaning up the Chesapeake Bay watershed, we looked at the impact of urban land. EPA
and its Chesapeake Bay watershed partners will not meet 2010 load reduction goals for
developed lands. In fact, new development is increasing nutrient and sediment loads at
rates faster than restoration efforts are reducing them. EPA could show greater
leadership in helping communities reverse the trend of increasing loads from developed
lands by concentrating on lowering loads from new development. Further details are on
page 6. In a prior semiannual period, we issued reports related to agricultural and air
deposition issues in response to the request. Another review on wastewater treatment
facility pollution is in progress.
Members of Congress representing New Jersey raised concerns about the cleanup of the
Ringwood Mines/Landfill Superfund site in that State. We conducted two separate
reviews and found the following:
• While EPA's oversight of cleanup at Ringwood met many requirements, EPA
could have conducted a more thorough investigation. After EPA removed the
site from the Superfund National Priorities List in 1994, several more cleanup
actions occurred, and residents continued to discover paint sludge. This
prompted EPA to restore the site to the National Priorities List - a first in
Superfund's history. Paint sludge continued to be discovered because EPA did
not ensure that the initial site investigation conducted by the site operator, Ford
Motor Company, was comprehensive. Further details are on page 10.
• We did not find evidence to indicate that EPA's actions to investigate or
remediate environmental conditions at the Ringwood site were affected by the
area's racial, cultural, or socioeconomic status. However, problems with
communications and relationships impeded effective cooperation between EPA
and residents, thus impacting community perceptions. Further details are on
page 27.
U.S. Senator Tom Coburn of Oklahoma requested that we review congressional earmark
grants awarded by EPA to determine the number of earmarks awarded, costs associated
with managing such grants, and the impact earmarks had on advancing EPA's mission.
For the 15-month period ending March 31, 2006, EPA awarded 444 earmark grants,
totaling $454 million, and spent about $4.9 million to award and manage those grants.
Our review of 86 of those grants found that 82 were for projects aimed at contributing to
EPA's Strategic Plan mission and goals. Further details are on page 19.
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OIG Budget Outlook Improves
At the end of this semiannual reporting period, Congress had not yet passed an
appropriations act to fund the OIG for Fiscal Year 2008. Thus, the OIG is operating
under a continuing resolution. Should the continuing resolution provide funding
equivalent to the Fiscal Year 2007 level, this would translate to an annual amount of
$50.5 million for the OIG, allocated for the duration of the continuing resolution.
The Fiscal Year 2008 President's Budget contained a transfer of responsibility for
funding contract audit work currently performed by the Defense Contract Audit Agency
from the OIG to EPA's Office of Administration and Resources Management. The
contract audit support proposed for transfer consists of audits of EPA contracts and
contractors used in the award and management of EPA contracts. These audits are an
integral part of the management of the Agency's programs and resources. Thus, the
OIG's responsibility should be to oversee, rather than perform or contract for, these
contract audits, which are a program operating responsibility. Since Congress has not yet
passed a Fiscal Year 2008 funding bill for EPA, it remains unclear how this issue will be
resolved. The OIG currently is not funded to provide this support.
In another recent development with budget implications, the OIG won the right to
continue to perform the EPA financial statement audit after a competitive sourcing study.
Given this fact, as well as congressional direction provided thus far in the Fiscal Year
2008 budget process, the OIG is in the process of filling additional full-time equivalent
positions as quickly as possible. The additional personnel will enhance the OIG's
evaluation, audit (in areas other than the financial statement audit), and investigative
capabilities.
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Significant OIG Activity
Helping to make air safe and healthy to breathe.
Projected Pollutant Reductions Assessed for Enforcement Actions
and Settlements
The accuracy and reliability of EPA's projected reductions in air and water
pollution have depended on the specific programs in which the enforcement
actions took place.
More reliable data were available to project reductions from oil spill and power plant
cases than other Clean Water Act and Clean Air Act cases, respectively. Improved
internal control processes contributed to more accurate pollutant reduction estimates.
However, we noted some inconsistencies in calculating projected Clean Air Act emission
reductions, including the use of different methodologies for estimating post-compliance
emissions from power plant cases.
EPA's projections were heavily influenced
by a few large cases. Less than 1 percent of
the Clean Water Act cases accounted for
52 percent of the projected reductions from
concluded Clean Water Act enforcement
actions. In Fiscal Year 2004, two power
plant cases accounted for projection of over
600 million pounds in reductions, about
78 percent of the Clean Air Act total.
Facilities were on target to meet projected
reductions for the Clean Air Act cases
reviewed, but it will take years to complete
all corrective actions so we could not
determine whether total projected reductions
had been achieved. Clean Water Act cases
were also making progress toward meeting
projected reductions. We presented our results to EPA in a briefing and did not make any
recommendations. We conducted this review at the request of the Office of Management
and Budget.
(Report No. 2007-B-00002, Assessment of EPA 's Projected Pollutant Reductions
Resulting from Enforcement Actions and Settlements, July 24, 2007 - Report Cost:
$397,274)
Air pollution being generated (EPA photo).
For details on an additional air issue, please refer to page 17, "Ozone Transport
Commission Claimed Unallowable Outlays of $2.7 Million."
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Water
Ensuring that drinking water is safe and sources are protected.
Development Growth Outpacing Progress in Restoring
Chesapeake Bay
EPA and its Chesapeake Bay watershed partners will not meet the 2010 load
reduction goals for developed lands. In fact, new development is increasing nutrient
and sediment loads at rates faster than restoration efforts are reducing them.
In response to a request from U.S. Senator Barbara A.
Mikulski of Maryland to look into EPA efforts to clean up
the Bay, we looked at progress in reducing contributions
from developed and developing lands. Over 64,000 square
miles of land drain to the Chesapeake Bay. Population in
the watershed exceeds 16 million and is projected to
surpass 19 million before 2030.
Developed lands contribute less than one-third of the Bay
loads but would require about two-thirds of the overall
estimated restoration costs. Consequently, EPA and its Bay
partners focused on more cost-effective approaches, such as
upgrading wastewater facilities and implementing
agricultural best practices.
Maryland farmland being encroached by
housing development (photo from
U.S. Department of Agriculture).
Communities can cost effectively start to reverse the trend of increasing loads from
developed lands by concentrating their efforts on new development. If communities do
not do so, loads from developed lands
will continue to increase rather than
diminish. Restoration costs will
increase, the Bay will not be restored as
desired, and water quality degradation
and loss of aquatic life will continue.
We recommended that the EPA
Chesapeake Bay Program Office
prepare and implement a strategy that
demonstrates leadership to reverse the
trend of increasing nutrient and
sediment loads from developed and
developing lands. The office should
also work with Bay partners to set
realistic, community-level goals for
reducing loads from developed and
developing lands. EPA concurred with
our recommendations.
j Chesapeake Bay Watershed
Chesapeake Bay Watershed
(map from EPA Chesapeake Bay Program Office)
(Report No. 2007-P-00031, Development Growth Outpacing Progress in Watershed
Efforts to Restore the Chesapeake Bay, September 10, 2007 - Report Cost: $783,489)
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Federal Facilities in Chesapeake Bay Watershed Generally Comply
with Water Permits
EPA and the States are doing well managing how major Federal facilities comply
with their National Pollutant Discharge Elimination System (NPDES) permits.
One hundred Federal facilities discharge into the Chesapeake Bay or its tributaries. Nine
of those facilities operate under major NPDES permits.
In EPA's last reporting period (2004), major
Federal facilities in the Chesapeake Bay
watershed had a lower rate of significant
noncompliance than other Federal and non-
Federal major-permit facilities nationwide.
Only one of the nine Chesapeake Bay Federal
facilities, or 11 percent, was in significant
noncompliance. This compares to a national
rate of 22 percent for all NPDES-permitted
Federal facilities and 20 percent for non-
Federal facilities. Upgrades for the one
Chesapeake Bay Federal facility in significant
noncompliance - the Washington Aqueduct -
are expected to be completed in December
2009.
Naval Surface Warfare Center Indian Head is a
Federal facility in the Chesapeake Bay watershed
operating under a major NPDES permit (photo
from Naval Support Facility Indian Head Website).
We made no recommendations in this report. We conducted the review as a result of an
Office of Management and Budget request.
(Report No. 2007-P-00032, Federal Facilities in Chesapeake Bay Watershed Generally
Comply with Major Clean Water Act Permits, Septembers, 2007'- Report Cost:
$184,914)
Total Maximum Daily Load Program Needs to Improve to
Demonstrate Environmental Results
EPA does not have comprehensive information on how effective the Total
Maximum Daily Load (TMDL) program is nationwide. Thus, the Agency cannot
determine if TMDL implementation activities are occurring in a timely manner,
and the extent to which TMDLs are restoring impaired water.
TMDLs are designed to play a critical role in restoring impaired waters by calculating
pollutant loads consistent with water quality standards. A TMDL specifies the amount of
a pollutant that a waterbody may receive and still meet water quality standards.
EPA is responsible for working with States to develop TMDLs to address impaired
waters. EPA measures the pace at which TMDLs are developed and approved. For the
last 2 years, EPA and States have exceeded goals for these measures. However,
developing meaningful measures of the environmental results of water quality programs
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is challenging. EPA needs to provide more management direction to improve its ability
to assess how well this critical program is functioning.
The Agency generally concurred with five of the six draft report recommendations with
comment, and proposed an alternative recommendation for the sixth instance.
(Report No. 2007-P-00036, Total Maximum Daily Load Program Needs Better Data and
Measures to Demonstrate Environmental Results, September 19, 2007' - Report Cost:
$188,780)
Better Oversight Needed Over Permitted Facilities in Significant
Noncompliance
EPA did not provide effective enforcement oversight of major facilities with
NPDES water discharge permits in long-term significant noncompliance.
EPA has authorized 45 States to administer the NPDES program, including enforcing
discharge permits. EPA maintains responsibility for overseeing and ensuring that Clean
Water Act regulations are enforced.
While flexibility is required in a national program, EPA inconsistently applied guidance
defining timely formal actions. EPA guidance did not provide meaningful direction on
what constitutes "appropriate" actions. In 21 of 56 facilities the OIG reviewed, EPA and
States did not take suitable formal enforcement actions to address all instances of
significant noncompliance. At the remaining 35 facilities, none of the enforcement
actions we could assess were taken on a
timely basis. EPA and States also did
not maintain complete and accurate
records of compliance and enforcement
activities.
Timely actions could help minimize the
millions of pounds of excess pollutants
released by these facilities. We estimate
that up to 51 million pounds of excess
pollutant loads were discharged from
July 2002 through June 2005 by 44
facilities reviewed, representing loads
that could be minimized.
Sloss Industries wastewater treatment facility in Alabama
(photo from Black Warrior RIVERKEEPER Website).
We recommended that EPA clarify and implement guidance for enforcement at facilities
in significant noncompliance, and implement a quality assurance program. EPA disputed
many of our findings, and its planned actions generally do not address the intent of our
recommendations.
(Report No. 2007-P-00023, Better Enforcement Oversight Needed for Major Facilities
with Water Discharge Permits in Long-Term Significant Noncompliance, May 14, 2007 -
Report Cost: $932,305)
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EPA Can Improve Its Oversight of Audit Followup
EPA is generally taking actions on the nine water-related reports we reviewed,
but we noted some delays in implementation and the need for improved
oversight.
We undertook this review to determine the status of Agency corrective actions
responding to OIG report recommendations. We selected reports on water issues
pertaining to the Office of Water and Office of Enforcement and Compliance Assurance
and examined recommendations each was to implement. We looked at how complete
and up to date the information is in the Management Audit Tracking System for the nine
reports.
While EPA is generally undertaking actions on the reports we reviewed, several actions
were past agreed-to milestone dates. The Office of the Chief Financial Officer, in its
oversight role, can do more to monitor the audit followup process. That Office's annual
audit followup reporting to Congress did not present required information on specific
audit recommendations or reasons for delays in taking corrective actions. OIG also found
that the Management Audit Tracking System was incomplete and had mistakes.
We recommended that the Office of Water and Office of Enforcement and Compliance
Assurance periodically review audit management information for accuracy and
completeness. They should also follow the certification process for closing out reports,
and maintain a list of corrective actions taken. We made various recommendations to the
Office of the Chief Financial Officer for improving oversight. The Agency generally
agreed with our recommendations.
(Report No. 2007-P-00025, EPA Can Improve its Oversight of Audit Followup, May 24,
2007- Report Cost: $104,602)
For details on additional water issues, please refer to:
• Page 5, "Projected Pollutant Reductions Assessed for Enforcement Actions and
Settlements."
• Page 18, "Reviews of Special Appropriation Act Project Grants Note Ineligible Claims."
• Page 27, "Complete Assessment Needed to Ensure Safe Drinking Water for Rural
Texas Community."
• Page 28, "Decision Needed on Regulating Cooling Lagoons at North Anna Power Station.
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Land
Improving waste management cleanup - includes Superfund.
Limited Investigation at Ringwood Superfund Site Led to Missed
Contamination
EPA's oversight of cleanup at the Ringwood Mines/Landfill Superfund site in
New Jersey met many requirements, but EPA could have conducted a more
thorough investigation.
EPA placed the Ringwood site on the Superfund National Priorities List in 1983 and
removed the site from the list in 1994 after determining that the site was protective of
human health and the environment. After 1994, several more cleanup actions occurred at
the site, and residents continued to discover paint sludge,
prompting EPA for the first time in Superfund's history to
restore a site to the list. Members of Congress requested
us to look at several issues related to the site.
We found that based on limited initial investigation,
EPA Region 2 selected a remedy that addressed site
groundwater and surface water concerns. EPA ensured
implementation of the remedy and removal of identified
paint sludge. However, EPA did not comply with the
community notification requirements when conducting
5-year reviews.
A caution sign at the Ringwood site
(EPA OIG photo taken August 2006).
The initial site investigation was conducted by the plant
operator, the Ford Motor Company. Paint sludge
continued to be discovered because EPA did not ensure that Ford conducted a
comprehensive investigation. EPA could have ensured that Ford conducted a more
comprehensive survey of the 500-acre site and made better use of aerial photographs.
Also, EPA itself could have conducted a more thorough search for records involving
waste disposal activities at the site by better enforcing disclosure requirements on Ford.
Currently, under EPA orders, Ford is conducting an ongoing, comprehensive site
investigation. If done properly, this second investigation should address concerns about
the initial site investigation. We
recommended that EPA Region 2
provide the Ringwood community
with sufficient notification on
initiation and results of 5-year
reviews, and ensure that Ford
submits all relevant information. EPA agreed with those recommendations. EPA
Region 2 did not agree with another recommendation on providing staff with written
guidance on records management policies; Region 2 stated it has already complied with
pertinent EPA policies. The issue remains open and unresolved.
(Report No. 2007-P-00039, Limited Investigation Led to Missed Contamination at
Ringwood Superfund Site, September 25, 2007 - Report Cost: $544,626)
Results of a separate review at the Ringwood site,
on environmental justice and communication
concerns, are discussed on page 27.
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EPA Needs to Improve Controls for Superfund Alternative Sites
Approach
EPA will not be able to demonstrate outcomes and results of the Superfund
Alternative sites approach until it addresses management control limits and
makes controls more transparent.
The Superfund Alternative sites approach is an alternative to listing sites on the National
Priorities List. Since the 1980s, EPA has used variations of this approach to clean up
hazardous waste sites, but has been criticized for
its management and implementation of this
approach.
We found that EPA has not finalized the universe
of Superfund Alternative sites. Further, EPA does
not have controls over designating Superfund
Alternative sites in Superfund information systems
or documenting hazard assessments for the sites.
In addition, EPA only measures results at
Superfund Alternative sites for one of six
Superfund cleanup measures. Until EPA
addresses these limits in management controls and
makes these controls more transparent, it cannot
demonstrate outcomes and results of the
Superfund Alternative approach.
The Superfund Alternative site approach is being
used at the Tremont City Landfill near Springfield,
Ohio (EPA photo).
We recommended that EPA track and report cleanup progress at Superfund Alternative
sites, and improve its communications, information, and transparency about the approach.
EPA concurred with most of the recommendations.
(Report No. 2007-P-00026, EPA Needs to Take More Action in Implementing Alternative
Approaches to Superfund Cleanups, June 6, 2007' - Report Cost: $580,203)
EPA Could Better Use $3.324 Million from Special Account for
Thermo Chem Superfund Site
EPA Region 5 missed an opportunity in 2005 to make timely and better use
of $2.8 million in the special account for the Thermo Chem Superfund site.
Specifically, the Region could have funded other priority response activities by
reclassifying funds no longer needed at the Thermo Chem site. Region 5 can
also make use of an additional $524,000 of the remaining special account funds
that have no current planned use.
Superfund legislation authorizes EPA to retain and use funds received in settlements to
address Superfund response actions contemplated in settlement agreements. EPA retains
these funds in site-specific "special" accounts in EPA's Hazardous Substance Superfund
Trust Fund. Thermo Chem is a former waste solvent reprocessing and storage site near
Muskegon, Michigan.
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In 2004, Region 5 staff recommended the reclassification of approximately $2.8 million
from the Thermo Chem special account because these funds were not needed at the site.
However, these funds were not reclassified because the site managers were unaware that
action was needed or required.
We recommended that Region 5 reclassify approximately $2.8 million (plus additional
accrued costs) from the Thermo Chem special account to fund other priority response
activities. We also recommended that Region 5 reclassify, or transfer to the trust fund as
appropriate, approximately $524,000 of the Thermo Chem special account that has no
planned future use.
We noted our findings in an "Early Warning" report; our review of Thermo Chem is
continuing.
(Report No. 2007-S-00002, Making Better Use of Superfund Special Account Funds for
Thermo Chem, August 20, 2007)
Superfund's Board of Directors Needs to Complete
Recommendations from Its 120-Day Study
EPA to on the its 2004 on
the be
In April 2004, EPA completed a report, requested by then Acting Deputy Administrator
Stephen Johnson, entitled Superfund: Building on the Past, Looking to the Future, more
commonly known as The 120-Day Study. The report had 102 recommendations. In
response to the report, the EPA's Acting Deputy Administrator created a Superfund
Board of Directors to prepare, coordinate, and execute action plans to address the report's
recommendations. We followed up on three of the report's recommendations, involving:
• Analyzing Superfund sites to determine how many were Resource Conservation
and Recovery Act (RCRA) facilities and if they were a burden to the program,
• Determining whether RCRA-regulated facilities would continue to be in the
Superfund program, and
• Determining whether promulgating new regulations for non-RCRA-regulated
facilities would reduce the future needs of the Superfund program.
While EPA has completed its work on the first two recommendations, it has not yet done
so for the third. We recommended that the Board review a sample of the implemented
study recommendations to confirm that the actions taken were complete and responsive
to the original study recommendations.
(Report No. 2007-P-00029, Superfund's Board of Directors Needs to Evaluate Actions to
Improve the Superfund Program, August 1, 2007 - Report Cost: $246,015)
For details on an additional land issue, please refer to page 21, "EPA Can Improve Its
Management of Superfund Interagency Agreements with U.S. Army Corps of Engineers."
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Cross-Media
Issues involving overlapping areas - includes homeland security.
EPA Needs to Strengthen ENERGY STAR Program
The ENERGY STAR Program, which promotes energy-efficient products, needs
to be strengthened to be an innovative, effective, and efficient approach to
environmental protection.
In 2006, EPA reported that using ENERGY STAR products prevented estimated
greenhouse gas emissions equivalent to those from 23 million vehicles, saving Americans
an estimated $12 billion in their utility bills. However, the processes that EPA set in
place to ensure the integrity of the program (product specification setting and revision,
product self-certification, product verification testing, and label utilization monitoring)
could be improved. For example, the criteria for revising specifications were unclear.
Types of ENERGY STAR Products by Sales Since 1992
(courtesy EPA)
COMPUTERS
AND MONITORS
31%
OTHER 6%
LIGHTING
22%
OFFICE
EQUIPMENT
18%
CONSUMER
ELECTRONICS
23%
EPA does not have reasonable assurance that the product self-certification process is
effective. Product verification testing lacks clearly documented procedures. Also, there
is little oversight of the use of the ENERGY STAR label in retail stores, where
consumers are most likely to come into contact with the program. We recommended that
EPA strengthen management controls, clarify and document criteria, establish a quality
assurance program, and improve its oversight of the program. EPA disagreed with many
of our conclusions, saying that it had already implemented many of our
recommendations. We consider some issues unresolved.
(Report No. 2007-P-00028, ENERGY STAR Program Can Strengthen Controls
Protecting the Integrity of the Label, August I, 2007 - Report Cost: $338,079)
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Voluntary Programs Could Benefit from Agency-wide Policies
EPA has no Agency-wide policies that require voluntary programs to collect
comparable data or conduct regular program evaluations. Without a consistent
set of policies, EPA cannot determine the overall environmental impact of its
voluntary programs, nor whether voluntary programs are succeeding or failing.
The current voluntary program definitions are difficult for EPA program offices to apply,
because the scope of EPA's voluntary program definitions has changed drastically in the
last 4 years. The number of voluntary programs reported over the years has varied
between 54 and 133. However, EPA officials told us the actual number of programs has
not changed significantly; rather, changes to program definitions simply expanded the
scope of the populations.
EPA also does not have a system to develop, test, and market new programs. Thus, EPA
cannot ensure that programs have the necessary elements to demonstrate their impact, or
whether they are effective in achieving environmental results.
We recommended that the Deputy Administrator provide the Associate Administrator for
the Office of Policy, Economics, and Innovation with the authority to develop,
implement, and oversee mandatory Agency-wide management policies for voluntary
programs. These policies should implement a systematic management approach similar
to a research and development model, and develop specific definitions or criteria that
outline the general intent and function for the EPA voluntary programs currently
operating.
(Report No. 2007-P-00041, Voluntary Programs Could Benefit from Internal Policy
Controls and a Systematic Management Approach, September 25, 2007' - Report Cost:
$135,649)
Strategic Agricultural Initiative Needs Revisions to
Demonstrate Results
The Strategic Agricultural Initiative program has not demonstrated how it fulfills
its unique role of helping growers transition away from high-risk pesticides as
identified by the Food Quality Protection Act.
The program helps growers replace high-risk pesticides phased out or restricted because
of the Agency's pesticide ree valuations. Since 2001, the program has given out about
$4 million in grants.
The program does not have a strategic plan or similar documents that link project mission
and associated goals, logic model, performance measures, and data the program
collected. Headquarters and the regions have inconsistent priorities for implementing the
program. This lack of structure makes it difficult to measure and validate results. Also,
program databases, used to gather data on project performance, lack definitions and
structure and thus contain incomplete and extraneous information.
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We recommended that EPA develop a needs assessment for the Strategic Agricultural
Initiative program to demonstrate how it fulfills its role in meeting Food Quality
Protection Act requirements. If the need is demonstrated, EPA should create a strategic
plan that sets clear priorities for program direction. EPA agreed to reassess the need for
the program and develop a strategic plan if determined to be needed. These
recommendations should result in approximately $1.5 million in annual grant funds put to
better use because either the grants will no longer be needed or their effectiveness will be
enhanced.
(Report No. 2007-P-00040, Strategic Agricultural Initiative Needs Revisions to
Demonstrate Results, September 26, 2007 - Report Cost: $307,570)
EPA Could Apply Approaches Other Agencies Use to Better
Measure Compliance
We noted practical approaches that other Federal regulatory agencies use to
measure compliance that EPA can also use to generate better compliance
information.
EPA's Office of Enforcement and Compliance Assurance faces many obstacles in
measuring compliance, including limited knowledge of its universe, limited resources,
and difficulties in collecting data from States. Because other agencies face similar
obstacles, the practical approaches used by some to overcome these obstacles can also be
applied by EPA. These approaches include using statistical information to monitor
enforcement and compliance programs and demonstrate program results.
We recommended that EPA establish a plan of action, with milestones, to incorporate
using statistical methods to demonstrate the enforcement and compliance results. EPA
accepted our recommendations.
(Report No. 2007-P-00027, Overcoming Obstacles to Measuring Compliance: Practices
in Selected Federal Agencies, June 20, 2007 - Report Cost: $440,022)
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G T3 H IS Improving EPA's use of assistance agreements.
Environmental Careers Organization Costs of $6 Million Questioned
The Environmental Careers Organization, which received five grants from EPA to
provide internships to students in the environmental field, did not comply with
financial and program management standards.
We questioned $6,027,814 out of $18,797,104 in claimed costs because the
Environmental Careers Organization:
• Could not support the indirect general and administrative and "mission and
placement" outlays,
• Did not maintain support for distributing salaries and wages claimed as indirect
general and administration and "mission placement,"
• Could not support relocation outlays, and
• Drew EPA funds in excess of those needed to meet immediate needs.
We recommended that EPA (1) recover payments of $4,750,342 unless the recipient can
modify its accounting system; (2) recover payments of $1,277,472 incurred for ineligible
costs; (3) rescind the final indirect cost rate approved for the fiscal year ended
December 31, 2004; and (4) require the recipient to establish policies and procedures for
relocating interns that comply with Federal guidance. The recipient responded to our
draft report but did not provide additional information to change the findings and
recommendations.
(Report No. 2007-4-00065, The Environmental Careers Organization Reported Outlays
for Five EPA Cooperative Agreements, June 25, 2007 - Report Cost: $265,099)
Cheyenne River Sioux Tribe Outlays of $3.1 Million Questioned
We questioned $3,101,827 of $3,736,560 in EPA outlays reported by the
Cheyenne River Sioux Tribe under five grants because of financial management
problems.
EPA awarded five agreements to the Tribe to fund a variety of environmental activities.
The Tribe did not comply with financial and program management standards. The Tribe
did not:
• Follow labor cost documentation requirements for Federal grants;
• Compete contracts, justify sole-source procurements, or perform cost analyses;
• Demonstrate that fuel costs charged were equitably allocated;
• Properly account for vehicle leases;
• Comply with regulations and internal policy when purchasing equipment;
• Properly compute and claim indirect costs; and
• Maintain documentation for recipient share of costs reported.
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The Tribe also was not able to demonstrate that it completed all work under the
agreements.
We recommended that EPA Region 8's Regional Administrator disallow and recover the
Federal share of ineligible costs of $64,765. The Region should also require the Tribe to
provide sufficient documentation for the remaining $3,037,062 questioned, and disallow
and recover the Federal share of any outlays the Tribe cannot support. The Region
should confirm that all work under the agreement has been satisfactorily completed.
(Report No. 2007-4-00078, Cheyenne River Sioux Tribe Outlays Reported Under Five
EPA Assistance Grants - Report Cost: $241,026)
Ozone Transport Commission Claimed Unallowable Outlays of
$2.7 Million
We questioned $2,723,706 of $9,042,706 in reported outlays by the Ozone
Transport Commission because the recipient claimed unallowable outlays for
contractual services, indirect costs, and in-kind costs.
EPA awarded four assistance agreements to the Ozone Transport Commission to assess
and design strategies to reduce haze in the Northeastern United States and to fund the
Commission's ongoing operations. With the exception of the questioned costs, the outlays
presented fairly, in all material respects, the allowable outlays incurred in accordance with
the terms and conditions of the agreements and applicable laws and regulations.
For the amount questioned, the recipient:
• Did not compete contracts, justify sole-source procurements, or perform cost
analysis of contracts;
• Claimed indirect costs without approved indirect rates; and
• Did not maintain adequate documentation for in-kind costs used as recipient
match.
We recommended that EPA recover the questioned outlays of $2,723,706 unless the
recipient provides sufficient documentation to support the related claimed costs in
accordance with Federal regulations; and that EPA direct the recipient to implement
procedures to address issues relating to procuring contracts, calculating indirect cost
rates, and documenting in-kind costs.
(Report No. 2007-4-00068, Ozone Transport Commission Incurred Costs Under EPA
Assistance Agreements XA98379901, OT83098301, XA97318101, and OT83264901,
July 31, 2007-Report Cost: $200,644)
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Reviews of Special Appropriation Act Project Grants Note
Ineligible Claims
At the request of the EPA Office of Water, we initiated reviews of costs claimed
under Special Appropriation Act Project grants, and noted various instances of
ineligible costs claimed.
Since 1992, EPA has awarded 5,015 Special Appropriation Act Project grants, totaling
over $5 billion, based on congressional earmarks. EPA awards these grants to State and
local governments and quasi-governmental agencies (such as water improvement
districts) to assist in planning, designing, and constructing wastewater and drinking water
facilities.
We reviewed certain Special Appropriation Act Project grants awarded in Regions 2, 5,
8, and 9, and, to date, noted the following issues, which we addressed in quick reaction
reports.
• The City of Fallen, Nevada, did not meet the Federal grant requirements for
financial management systems. In particular, the City claimed pre-award costs in
excess of the eligible amounts, and did not support amounts for matching costs
claimed and funds drawn under EPA grants. As a result, we recommended that
EPA recover $350,916 in Federal funds. The City of Fallen also did not disclose
lobbying activity as required under Federal requirements. (Report No. 2007-2-
00040, Cost and Lobbying Disclosure Issues Under EPA Grant Numbers
X98981901 andXP97914901 Awarded to the City ofFallon, Nevada,
September 26, 2007)
• The City of Middletown, New York, did not incur preaward grant costs during
the period required. Therefore, costs of $853,002 claimed under the EPA grant
are ineligible for Federal reimbursement since those costs were incurred prior to
the fiscal year for which the funds were appropriated. We recommended that the
City of Middletown repay the $433,700 in Federal funds already drawn down.
(Report No. 2007-2-00039, Ineligible Federal Funds Drawn on EPA Grant No.
XP98284701 Awarded to the City of Middletown, New York, September 25,
2007)
• The City of Huron, South Dakota, did not reduce total grant costs by $947,586
for amounts received from local water agencies. This resulted in the City
drawing $68,203 in excess Federal funds. The City of Huron anticipates
receiving additional reimbursements upon completion of the project, which
should result in the repayment of additional Federal funds. (Report No. 2007-2-
00030, Excess Federal Funds Drawn on EPA Grant No. XP98838901 Awarded
to the City of Huron, South Dakota, August 1, 2007)
We plan to continue auditing Special Appropriation Act Project grants in Fiscal Year
2008.
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Number of EPA Earmark Grants and Impact Noted
Between January 1, 2005, and March 31, 2006, EPA awarded 444 earmark
grants totaling $454 million, accounting for about 13 percent of the grant dollars
EPA awarded. During this same time, EPA spent about $4.9 million to award
and manage the 444 earmark grants.
We looked into the number and impact of earmark grants in response to a congressional
request. We defined a congressional earmark as a numbered line item within a House
Conference Report specifying a dollar amount, recipient, and particular project. During
the review period, the cost to award and manage all EPA grants totaled $100.3 million,
while the cost to award and manage EPA's earmark grants totaled $4.9 million (see table).
EPA's Cost to Award and Manage Earmarks
Cost Category
Cost of salaries and overhead for project officers and grants
specialists to award and manage the 444 earmarks from
January 1, 2005, through March 31, 2006
Regional Offices of Congressional and Intergovernmental
Relations costs to track and assist with awarding earmark grants
Office of the Chief Financial Officer costs to track and assist with
awarding earmark grants
Headquarters Office of Congressional and Intergovernmental
Relations costs to track and assist with awarding earmark grants
Contractual costs for the Stakeholder Database
Dollar Amount
$4,342,331
Total EPA Cost to Award and Manage Earmarks
$4,911,646
Source: OIG calculations based on EPA workforce and budget models.
Our review of work plans for 86 of the 444 earmark grants found that 82 were for projects
aimed at contributing to EPA's Strategic Plan mission and goals. Grant work plans for the
other four grants did not demonstrate how the projects would promote EPA goals:
• A nonprofit organization used about half of its grant funds to purchase computers
for a high school and support student trips between the United States and the
U.S. Virgin Islands.
• A university studied noise levels from parked, idling trains.
• A local government did not identify how two grants were going to achieve the
objectives stated in the work plans or how the projects would impact the
environment.
We did not make any recommendations. In its response to our draft report, EPA said it
believed the grants for the nonprofit and the university contributed to EPA's mission; we
do not agree. For the two grants to the local government, EPA is working with the
recipient to revise the work plans.
(Report No. 2007-P-00024, Number of and Cost to Award and Manage EPA Earmark
Grants, and the Grants' Impact on the Agency's Mission, May 22, 2007 - Report Cost:
$283,509)
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Tribes Using Many Promising Practices to Improve Environment
Tribes have made progress in overcoming barriers to successfully managing
environmental programs. Some tribes use promising practices that can be used
by others.
There are more than 560 federally recognized tribes in the United States. EPA funds
tribal core environmental programs through grants from its General Assistance Program.
The 14 tribes we visited provided examples of innovative practices, including:
• Collaboration and Partnerships. Tribes work cooperatively with Federal
agencies, other tribes, State and local governments, educational institutions, and
the private sector.
• Education and Outreach. Tribes educate the community regarding
environmental programs, and also obtain community input.
• Expanding Resources. Tribes have processes for finding alternative sources of
revenue for environmental efforts.
To further help tribes build on successful practices, we recommended that EPA work
with tribes to promote collaboration and partnerships, identify education and outreach
materials, and identify funding alternatives. EPA concurred with the recommendations.
We based our findings and recommendations in this report on information obtained
during a joint audit conducted by the EPA and Department of the Interior OIGs. A
separate, joint report, Tribal Successes: Protecting the Environment and Natural
Resources, provides details on specific successful practices implemented by each of the
14 tribes visited. The joint report can be viewed at the following link:
http://www.doioig.gov/upload/2007-G-0020.pdf
(Report No. 2007-P-00022, Promoting Tribal Success in EPA Programs, May 3, 2007-
EPA OIG Report Cost: $473,283)
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Contracts
Improving EPA's use of contracts.
EPA Can Improve Its Management of Superfund
Interagency Agreements with U.S. Army Corps of Engineers
EPA needs to better justify and support its decisions to enter into Superfund
interagency agreements with the U.S. Army Corps of Engineers.
In Fiscal Years 2005-2006, EPA made over $500 million in Superfund interagency
agreement payments to the U.S. Army Corps of Engineers to perform cleanups.
Both the decision memoranda EPA used to justify use of the Corps and methods of
oversight for monitoring the Corps' work needed improving. The decision memoranda
did not contain comparisons of alternatives considered. Further, EPA did not develop
independent cost estimates. As a result, EPA had limited assurance that the interagency
agreements it awarded to the Corps were
based on sound financial decisions. EPA
also did not always receive quality and
timely progress reports from the Corps, or
understand the services for which the
Corps was billing and the Agency was
paying. EPA's lack of oversight also
contributed to the Corps accumulating
$2.5 million in excess Management and
Support fees from Superfund.
US Army Corps
of Engineers
FEDERAL CREOSOTE
SUPERFUND SITE REMEDIATION
LAGOON A, MAN VILLE.NJ
i.'i.-i/t,').1;.'; _____ '''i.'i/'/
Sign at the entrance to the Federal Creosote Superfund
Site in Manville, New Jersey, managed by the U.S. Army
Corps of Engineers under an EPA interagency agreement
(EPA OIG photo).
We recommended and EPA agreed to
revise its policy to ensure it implemented
procedures for holding regions
accountable to develop and document
their own independent cost estimates for
Corps in-house costs, and conduct cost
analysis of alternatives when determining
whether to use the Corps. EPA also
agreed to develop a plan for using feedback reports as an oversight tool to monitor and
improve the Corps' performance. The improved monitoring would eliminate
$2.5 million in excess and idle Management and Support fees that EPA paid the Corps.
In its report on EPA's Fiscal Year 2008 budget, the House Appropriations Committee
required EPA to report by December 31, 2007, on how it will monitor EPA regions'
compliance with the revised policy. The committee cited the OIG report as important
work regarding Superfund and agreed with the report's conclusions and
recommendations.
(Report No. 2007-P-00021, EPA Can Improve Its Managing of Superfund Inter agency
Agreements with U.S. Army Corps of Engineers, April 30, 2007 - Report Cost: $216,840)
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Progress Made in Improving Federal Supply Schedule Use,
but More Action Needed
This followup review found that EPA implemented all but one of the
recommendations in a 2003 OIG report on Federal Supply Schedule orders, but
more action is needed.
Ordering agencies, such as EPA, can issue orders directly to contractors that are on
Federal Supply Schedules approved by the General Services Administration.
Since our prior audit, EPA published needed guidance, provided training, and is
acquiring a new acquisition information system. Regarding the one recommendation not
implemented, EPA did not provide samples of sole source justifications to program
offices due to technology challenges, but its plans to post justifications on EPA's Intranet
should resolve this issue.
We noted other issues that require attention. By ensuring that adequate market research
is conducted, EPA can increase competition. Also, independent government cost
estimates need improvement to ensure EPA does not overpay for services and supplies.
EPA agreed to act on all our new recommendations.
(Report No. 2007-P-00037, Progress Made in Improving the Use of Federal Supply
Schedule Orders, but More Action Needed, September 20, 2007 - Report Cost: $181,758)
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Financial Management
Improving the Agency's financial management.
Pesticide Funds' 2006 Statements Earn Unqualified Opinions
We rendered unqualified opinions on the Fiscal Year 2006 financial statements
for two funds used for managing pesticide fees.
The Pesticides Reregistration and Expedited Processing Fund (known as the FIFRA fund)
is used to deposit fees collected to expedite pesticide reregistration. The Pesticide
Registration Fund (known as the PRIA fund) was created in March 2004 to expedite new
registrations for certain pesticides in exchange for registration fees.
In addition to providing a clean opinion for both funds, we did not identify any material
internal control weaknesses. However, we noted several reportable conditions. EPA
materially understated the FIFRA payroll unfunded leave accrual and related expenses
reported in the draft financial statements, due to transferring a significant number of
employees at year-end from FIFRA to Environmental Programs and Management. As a
result, FIFRA liabilities and related expenses were understated by $1,964,312. Also,
EPA's Washington Finance Center did not sufficiently support FIFRA adjusting entries
to the Integrated Financial Management System. For PRIA, EPA did not timely obligate
$100,000 for worker protection activities.
We also did not identify any noncompliances that would result in a material misstatement
to the audited financial statements. We did find that for PRIA, EPA did not record
$100,000 in obligations for services performed during Fiscal Year 2006 in violation of
Title 31, U.S. Code, Section 1501 (documentary evidence requirement for Government
obligations).
We recommended that EPA provide closer monitoring of unfunded FIFRA leave at year-
end and closer oversight of the preparation of the financial statements. We also
recommended that EPA take various actions to more promptly record PRIA obligations
in the Integrated Financial Management System. Officials agreed with our
recommendations and began corrective actions.
(Report No. 2007-1 -00070, Fiscal Year 2006 and 2005 Financial Statements for the
Pesticides Reregistration and Expedited Processing Fund, May 30, 2007 - Report Cost:
$274,000; and Report No. 2007-1-00071, Fiscal Year 2006 and 2005 Financial
Statements for the Pesticide Registration Fund, May 30, 2007 - Report Cost: $249,000)
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Risk and
Program Performance
Improving EPA internal control processes,
structure, and workforce/manpower.
Tools for Assessing EPA Programs Can Be Improved
The Program Assessment Rating Tool (PART) is a good diagnostic tool and
management control process to assess program performance and focus on
achieving results. However, as currently designed, programs can be rated
"adequate" even though they receive low scores in the Program Results/
Accountability section of the PART.
As currently designed, programs can be rated "adequate" with a PART score of just
50 percent. As a result, EPA programs with low scores in the Program Results/
Accountability section are receiving overall passing, or adequate, scores. This heightens
the risk that actual program results may not be achieved, and detracts from PART's
overall focus on program results. Further, as PART assessments demonstrated, EPA does
not have an organizational element with overall responsibility for program evaluations,
and has not allocated sufficient resources to conduct evaluations. With the difficulty
EPA faces in measuring results, coupled with the absence of regular program evaluations,
there is a heightened risk that programs may not be achieving their intended results.
We recommended that the Office of Management and Budget modify its criteria and
increase transparency of PART results scores. While the Office of Management and
Budget did not provide formal written comments, they met with us and provided their
insight to improve the PART process. We recommended that EPA increase the use of
program evaluation, designate a senior official to be responsible for evaluations, and
allocate sufficient evaluation resources. EPA agreed with the recommendations, and has
proposed a reorganization of its Office of Policy, Economics, and Innovation to provide
for a more robust evaluation of its programs.
(Report No. 2007-P-00033, Using the Program Assessment Rating Tool as a
Management Control Process, September 12, 2007'- Report Cost: $684,025)
Overall Average PART Scores by Category
Source: OIG analysis of EPA and Office of Management and Budget
data. Overall, the average "Program Results" score for all 51 EPA
programs assessed was about 38 percent.
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Information Resources
Management
Helping the Agency maintain its
systems and data.
Improvements Needed to Increase Exchange Network Use
EPA established a partnership with the National Environmental Information
Exchange Network's governance bodies to assist it in accomplishing Network
initiatives, but more improvements are needed to ensure that Network partners
fully utilize the Network.
The Exchange Network is EPA's approach (and expected preferred method) for the
exchange of environmental data among Network partners. As of January 2007, 48 States
and 2 tribes used the Network. EPA has invested more than $162 million in the Network.
Exchange Network Usage Data
15 The number of Exchange Network data flows EPA has available for
Network partner use; includes 7 regulatory data flows.
48 States The number of Exchange Network partners using the Network to share
2 Tribes environmental information with EPA and other Network partners.
37 States The number of States using the Network to share regulatory data
with EPA.
Source: OIG compilation and analysis of information from www.exchanqenetwork.net
EPA should improve its methods for selecting and prioritizing which data flows to
implement. EPA also needs to complete measurements of Network initiatives, improve
its practices to determine cost effectiveness, and strengthen its policies to identify when
the Network should be used.
We recommended that EPA execute the Exchange Network Marketing and
Communications plan, develop a new plan for measuring performance, develop policies
and procedures for determining cost benefits, and include the Exchange Network in the
Enterprise Architecture. EPA generally agreed with our recommendations.
(Report No. 2007-P-00030, Improved Management Practices Needed to Increase Use of
Exchange Network, August 20, 2007 - Report Cost: $665,051)
EPA Needs to Strengthen Privacy Program Controls
Although EPA has made progress toward establishing its Privacy Program, the
program needs more emphasis.
Congress passed the Privacy Act of 1974 to protect the privacy of individuals regarding
information collected and maintained by the Federal Government. The Office of
Management and Budget has interpreted that this includes protecting "Personally
Identifiable Information," which is any information about an individual maintained by an
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agency - including employment, medical, and financial information - that can be used to
trace an individual's identity. A major loss of privacy information could result in
substantial harm, embarrassment, and inconvenience to individuals, including identity
theft.
EPA needs a more comprehensive management control structure to govern and oversee
its Privacy Program. In particular, EPA needs to establish goals and activities to measure
progress. Further, EPA needs to update its Privacy Program policies, and set up
compliance and accountability processes to ensure adherence with key program tenets.
We recommended that EPA establish goals and activities for the Agency's Privacy
Program, establish and use performance measures, and update policies and procedures.
The Agency agreed with the report's findings and recommendations.
(Report No. 2007-P-00035, EPA Needs to Strengthen Its Privacy Program Management
Controls, September 17, 2007 - Report Cost: $135,942)
For details on an investigation related to information resources, please refer to page 30,
"Additional Guilty Pleas and Sentencings in Software Piracy Case"
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Public Liaison
Addressing specific concerns of the public.
Environmental Justice and Communication Concerns
Complicated Ringwood Cleanup
We did not find that EPA's actions to remediate environmental conditions at the
Ringwood Mines/Landfill Superfund site in New Jersey were discriminatory, but
we did note communication problems.
About 500 acres around the mines in Ringwood,
New Jersey, became a Superfund site in 1983
because of dumped hazardous paint sludge.
Paint sludge was removed several times and the
site was deleted from the Superfund list in 1994.
But after several more removal actions were
necessary, the Agency put the site back on the
Superfund list in 2006. Residents said they were
unfairly treated because of their racial makeup
and socioeconomic status. Several believed
their health was adversely affected by exposure
to site contamination. Three members of the
New Jersey congressional delegation requested
that we look into residents' concerns.
Removal activity at the Ringwood site during
August 2006 (EPA OIG photo).
We did not find evidence to indicate that EPA's actions to investigate or remediate
environmental conditions at the Ringwood site were affected by the area's racial, cultural,
or socioeconomic status. However, problems with communication and relationships
impeded effective cooperation between EPA and
residents. Thus, we recommended that EPA address
the Ringwood community's perceptions, prepare a
community involvement plan, and increase
communication. EPA concurred with our
recommendations.
Results of a separate review
the Ringwood site, on EPA
oversight of the cleanup, are
discussed on page 10.
(Report No. 2007-P-00016, EnvironmentalJustice Concerns and Communication
Problems Complicated Cleaning Up Ringwood Mines/Landfill Site, April 2, 2007 -
Report Cost: $254,713)
Complete Assessment Needed to Ensure Safe Drinking Water for
Rural Texas Community
EPA has indicated it plans to connect homes in a small rural Texas community to
a water system, to provide residents with clean, permanent drinking water, and
will assess whether the site qualifies for Superfund cleanup.
In 1996, residents in a small community in Panola County, Texas, adjacent to a saltwater
disposal operation, began complaining of drinking water discoloration, stained kitchen
and bath fixtures, and gastrointestinal problems after consuming water. Most needed to
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obtain bottled water or water from relatives. The situation was brought to our attention
via a Hotline complaint.
In 2003, Texas officials found contaminated
groundwater and advised residents not to use
the water for domestic purposes. We found
that EPA officials began addressing the
problem in 2003. In 2005, EPA began
providing, and continues to provide, bottled
water to affected residents. Also in 2005, the
State instructed the site operator to install
additional monitoring wells. In 2006, the
State indicated it would take enforcement
action against the operator, but we found no
evidence that it did.
Contaminated soil at the Panola site (photo taken
April 2004 by Texas Commission on Environmental
Quality).
Responding to a petition filed by Panola
County residents in November 2006, EPA is
conducting an assessment to determine if the
site qualifies for cleanup under EPA's
Superfund program. Further, in its June 2007 response to our draft report, EPA said that
it intends to use removal action funds to pay for constructing a water line that will
provide the residents with access to a drinking water system. Consequently, we did not
make recommendations as a result of our work.
(Report No. 2007-P-00034, Complete Assessment Needed to Ensure Rural Texas
Community Has Safe Drinking Water, September 11, 2007 - Report Cost: $375,251)
Decision Needed on Regulating Cooling Lagoons at North Anna
Power Station
EPA should review the permitting process for the North Anna Power Station in
Virginia.
The North Anna Power Station has a permit allowing it to
discharge water from cooling lagoons in the Lake Anna
reservoir. The lake has two parts: a 9,600 acre reservoir that
provides water for the power station to operate, and 3,400
acres of lagoons to cool the water from the station's
condensers before the water returns to the reservoir. Both
parts of the lake are used for recreation. In 2005, the Friends
of Lake Anna, a citizens group, alleged that the water
discharge permit for the station inappropriately allowed the
cooling lagoons to be designated a waste heat treatment
facility exempt from the Clean Water Act. The group
believes that the cooling lagoons are waters of the United
States that should be regulated under the Clean Water Act.
A satellite image of Lake Anna
(photo from MapQuest, Inc. Website).
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Virginia water quality standards for Class III waters, such as Lake Anna, indicate that the
maximum temperature cannot exceed 32° Celsius (about 90° Fahrenheit). The current
and prior water discharge permits, as well as the draft permit being processed by
Virginia, exempt the cooling lagoons from the standards because they are considered a
waste treatment facility.
EPA retains authority to review and object to certain permits. The North Anna Power
Station permit is the type that must be reviewed by EPA Region 3. We recommended
that the Region 3 Regional Administrator decide whether additional time should be
requested to review the proposed permit for the power station, and consider letting the
public know of this action.
(Report No. 2007-P-00038, Decision Needed on Regulating the Cooling Lagoons at the
North Anna Power Station, September 20, 2007 - Report Cost: $54,900)
Hotline Activity
The following table shows EPA OIG Hotline activity regarding complaints of fraud,
waste, and abuse in EPA programs and operations that occurred during the past
semiannual and annual periods.
Semiannual Period
(April 1,2007-
September 30, 2007)
Inquiries and Complaints Received During Period
Issues Handled by EPA OIG
Inquiries Addressed Without Opening a Complaint
Complaints Opened
Complaints Closed
Complaints Open - Beginning of Period
Complaints Open - End of Period
Issues Referred to Others
EPA Program Offices
EPA Criminal Investigation Division
Other Federal Agencies
State/Local Agencies
446
105
100
5
5
10
10
341
74
7
34
226
Annual Period
(October 1 , 2006 -
September 30, 2007
798
195
188
7
9
12
10
603
124
21
68
390
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Investigative Actions
Importer Sentenced for Defrauding Luxury Car Buyers
Regarding EPA Standards
On June 14, 2007, Ali Raza, also known as Hassan Ali Raza, was sentenced in U.S.
District Court for the Northern District of Georgia to 41 months imprisonment followed
by 3 years probation on conspiracy charges. In addition, Raza was ordered to perform
200 hours of community service and pay $3,185,244 in restitution and a $100 special
assessment.
The sentence stems from charges that Raza imported luxury vehicles into the United
States that did not meet the U.S. Department of Transportation or EPA vehicle standards
for sale and use on U.S. roads.
Starting in 2000, Raza placed sales advertisements for high-priced foreign vehicles in
magazines. He misled potential buyers by asserting that the imported vehicles would
meet Federal highway and environmental standards or that the vehicles would be exempt
from those standards. After purchasing the vehicles, the buyers discovered that the
vehicles did not meet Federal standards and they were required to spend considerable
amounts of money to have these vehicles modified to meet Federal standards. As part of
his sentence, Raza agreed to pay full restitution to all the victims.
This investigation was conducted jointly with the Department of Homeland Security
Immigration and Customs Enforcement and the U.S. Department of Transportation
Office of Inspector General, with assistance from the Department of Homeland Security's
Customs and Border Patrol, the U.S. Department of Transportation's National Highway
Traffic Safety Administration, and the EPA Office of Transportation and Air Quality.
(Case Cost: $282,780)
Additional Guilty Pleas and Sentencings in Software Piracy Case
During June and July 2007, three defendants pled guilty in U.S. District Court for the
District of Nevada to a charge of conspiracy to commit copyright infringement. The
defendants were members of a computer software piracy group known as the "Rogue
Warriorz," a secretive underground organization that illegally altered and distributed
copyrighted software, movies, and games over the Internet.
The three defendants were among 21 persons indicted in June 2002 as part of "Operation
Bandwidth," a 2-year, multi-agency undercover operation to identify and prosecute
entities and individuals involved with illegal access to computer systems and the piracy
of proprietary software utilizing storage sites on the Internet.
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At least 18 members of the group were hackers who had illegally accessed EPA computer
systems to further the reproduction and distribution scheme. The three defendants were
each sentenced to 36 months probation with credit for time served, and ordered to pay a
$100 special assessment and a fine of up to $2,000. In addition, the judge ordered that all
property previously seized be forfeited.
This investigation is being conducted jointly with the Federal Bureau of Investigation and
the Defense Criminal Investigative Service. (Case Cost: $571,310)
Contractor Settles Civil Action for $15,000 Regarding
False Claims Case
On April 12, 2007, LMI & Associates (LMI) and its owners, Larry and Laura McClure,
of DeSoto, Texas, entered into a settlement agreement with the U.S. Attorney's Office for
the Northern District of Texas in which they agreed to pay $15,000 to settle a civil false
claims case.
The Government contended that LMI and the McClures submitted a $6,200 invoice to
EPA for work that was not authorized by EPA nor performed by LMI. EPA subsequently
paid the invoice. Due to a pending bankruptcy petition by the McClures, the settlement
amount will be included in the bankruptcy. Prior to reaching this settlement, the
McClures and LMI were debarred from Government contracting for 3 years.
In addition to the civil settlement reached with the Federal Government, on June 26,
2007, both McClures were indicted by the State of Texas. For defrauding EPA of
$6,200, they were each charged with theft, a felony under Texas law.
(Case Cost: $16,008)
EPA Saves $2 Million as a Result of an Investigation
As a result of an OIG investigation involving an EPA grantee, the EPA Office of Grants
and Debarment estimates that EPA saved $1,962,925. Since 1989, EPA has awarded
more than $50 million in grants to the grantee. Under these grants, graduate and
undergraduate students performed research projects and received training in EPA offices
around the country.
An investigation was opened to address allegations that the grantee submitted false and/or
fraudulent claims to the Government. The investigation determined that, since at least
1997, the grantee improperly treated its Government agreements as fixed rate rather than
cost reimbursable. This resulted in "surplus" funds that the grantee failed to return to the
Government. The investigation further determined that the grantee did not track all of its
costs as required by Office of Management and Budget circulars and the Code of Federal
Regulations.
As a result of the investigation, EPA terminated the program, and notified the grantee that
it would not receive any additional EPA grant funds after May 11, 2007. This prevented
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the future outlay of approximately $2 million dollars to the grantee, who could not
properly account for money.
This investigation is being conducted jointly with the Offices of Inspector General of the
General Services Administration, U.S. Department of Agriculture, and U.S. Department
of Commerce. (Case Cost: $127,028)
Audit Report
EPA Needs to Respond More Timely to Employee Misconduct
While EPA generally took disciplinary action when deemed appropriate on employee
misconduct identified by the OIG in Reports of Investigation, Agency actions were not
timely. We also found six instances in which EPA's actions did not appear to meet the
minimum guidelines in EPA Order 3120.1, Conduct and Discipline Manual.
EPA policies require the Agency to initiate disciplinary actions within 30 days from the
date the OIG's Office of Investigations issues a Report of Investigation. However, EPA
took an average of almost 200 days to do so. According to several EPA action officials,
the reason EPA may not initiate disciplinary action within 30 days is because the Agency
cannot complete the process recommended in the EPA Disciplinary Process Handbook
within that timeframe.
We found six cases in which the Agency did not take disciplinary actions that were
severe enough, considering the nature of the misconduct. For example:
• EPA only gave an oral admonishment to an employee who was absent without
authorization for over 400 hours.
• Another employee, who had pled guilty in court to using a credit card stolen from
another Federal agency for personal purchases, received only a letter of
reprimand.
• A third employee, who had pled guilty to bank fraud and was sentenced to a day
in jail and 5 years probation, had a 45-day suspension recommended by the
employee's supervisor reduced by the action official to 14 days.
We recommended that EPA re-evaluate the 30-day reporting requirement to consider a
timeframe more in line with the time needed to accomplish EPA's disciplinary process.
We also recommended that EPA provide the OIG with an action plan when established
timeframes cannot be met and ensure that disciplinary actions taken are sufficient and
appropriate. The Agency generally agreed with our recommendations.
(Report No. 2007-M-00003, EPA Needs to Respond More Timely to Reports of
Investigation, May 7, 2007 - Report Cost: $35,537)
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Testimony
Providing testimony before congressional committees.
Assistant Inspector General Testifies on EPA's Implementation of
Environmental Justice
On July 25, 2007, Wade Najjum, Assistant Inspector General for Program Evaluation,
testified before the Senate Environment and Public Works Subcommittee on Superfund
and Environmental Health during a hearing on EPA's environmental justice programs.
Based on what the OIG found in two prior reports, Mr. Najjum testified on how EPA has
incorporated environmental justice within its programs and activities.
A 2004 report found that EPA had not identified minority and low-income communities,
or defined the term "disproportionately impacted." In the absence of environmental
justice definitions, criteria, or standards from EPA, regional and program offices
individually took steps to implement environmental justice policies.
"The result was inconsistency in determining environmental justice communities across
EPA regions and programs," said Mr. Najjum. "We concluded that EPA had not fully
implemented the Order and was not consistently integrating environmental justice into its
day-to-day operations at that time." The OIG made 12 recommendations; EPA disagreed
with 11 of them.
A 2006 report found that EPA program and regional offices have not routinely performed
environmental justice reviews, and that these offices lacked clear guidance to follow
when conducting such reviews. "We concluded that EPA cannot determine whether its
programs have a disproportionately high and adverse human health or environmental
effect on minority and low-income populations without performing these types of
reviews," Mr. Najjum said. The OIG made recommendations to address these issues.
EPA agreed with all the recommendations.
Mr. Najjum noted in his testimony that EPA made some progress in addressing
environmental justice issues since the issuance of the OIG's reports. He noted that EPA
had moved from almost total disagreement with the OIG's recommendations in 2004 to
agreeing with all recommendations in 2006.
"These are all positive steps, but EPA recognizes that more work needs to be done,
particularly in its efforts to making environmental justice part of its mission by
integrating environmental justice into its decision making, planning, and budgeting
processes," said Mr. Najjum. "EPA needs to be able to determine if their programs,
policies, and actions have a disproportionate health or environmental impact on minority
or low-income populations."
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Chemical Safety and Hazard Investigation Board
The Clean Air Act Amendments created the U.S. Chemical Safety and Hazard
Investigation Board (CSB). CSB 's mission is to investigate accidental chemical releases
at facilities, to report to the public on the root causes, and to recommend measures to
prevent future occurrences.
In Fiscal Year 2004, Congress designated the EPA OIG to serve as the Inspector General
for the CSB. The EPA OIG has the responsibility to audit, evaluate, inspect, and
investigate CSB's programs, and to review proposed laws and regulations to determine
their potential impact on CSB's programs and operations.
CSB Improved Security of Information System Resources
In Fiscal Year 2006, CSB made significant changes that enhanced the security of
information system resources, according to a review conducted by a contracted
consulting firm. CSB reorganized staff, consolidated functions, and took steps to correct
all the security weakness identified during Fiscal Year 2005. However, the review found
that the General Support System adopted did not address many Federal requirements.
Further, CSB had not tested the General Support System's contingency plan during Fiscal
Year 2006 and the content of the plan needs improvement. CSB also had not identified
or implemented policies and procedures that address the protection of sensitive
personally identifiable information.
(Report No. 2007-P-00019, Evaluation of U.S. Chemical Safety and Hazard Investigation
Board's Compliance with the Federal Information Security Management Act and Efforts
to Protect Sensitive Agency Information (Fiscal Year 2006), April 23, 2007)
CSB Did Not Adhere to Merit Promotion Plan
We conducted this review in response to an anonymous Hotline allegation of unfair
hiring practices at CSB. CSB reassigned three investigators to supervisory positions with
promotion potential to the GS-15 level. Two other CSB employees had applied for the
positions but were not selected.
In our view, CSB used an overly subjective and inconsistent approach that did not adhere
to its Merit Promotion Plan. CSB's selection process did not emphasize experience as a
factor, as required, even though CSB officials said they announced the supervisory
positions in-house because successful candidates needed knowledge of CSB. Not
adhering to the Merit Promotion Plan suggested favoritism.
O OO
We recommended that for future promotions, CSB should evaluate candidates and
manage the selection process in accordance with CSB policy. We also recommended that
CSB update the Merit Promotion Plan. CSB generally concurred with our
recommendations, but objected to the implication that it did not manage the selection
process in accordance with CSB policy or basic principles of fairness. CSB has indicated
34
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it conducted benchmarking of its Merit Promotion Plan against those in five other Federal
agencies.
(Report No. 2007-S-00001, U.S. Chemical Safety and Hazard Investigation Board
Did Not Adhere to Its Merit Promotion Plan, June 4, 2007 - Report Cost: $147,907)
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Other Activities
OIG Works with Agency to Strengthen Followup Process
As part of a joint effort with the Agency to strengthen the audit followup process, the
OIG began implementing a new OIG followup policy for independent verification of
Agency followup actions in response to OIG recommendations. The combined efforts
address the need to coordinate, verify, track, and report on the status of Agency actions
taken on OIG recommendations.
According to the Institute of Internal Auditors, followup is a process by which "internal
auditors determine the adequacy, effectiveness and timeliness of actions taken by
management on all reported audit findings." Office of Management and Budget Circular
A-50 notes that audit followup is a "shared responsibility" between the audited and
auditor entities.
Both the OIG and EPA's Office of the Chief Financial Officer, which is the Agency
organization responsible for followup, have recognized that this complex process is not
consistently understood or implemented. Further, they agreed that the Agency Audit
Management Tracking System does not have complete records from which the status of
actions can be determined, and there is no independent oversight to verify whether
agreed-to actions are being completed.
The Office of the Chief Financial Officer and the OIG initiated separate and joint actions
to improve Agency attention to its process and accountability for completing agreed-to
actions on OIG recommendations. The Chief Financial Officer, with input from the OIG,
issued executive directions to EPA leadership on their responsibility for audit
management, including instructions for recording the status of actions with explanations
in the Agency Audit Management Tracking System, and requirements for management
certification that agreed-to actions have been completed. Also, the Office of the Chief
Financial Officer and the OIG conducted Agency-wide training on followup.
During this semiannual period, the OIG began conducting independent reviews on the
status of Agency actions taken on selected nonfmancial OIG recommendations
summarized in the Inspector General's Semiannual Reports to Congress for the preceding
4-year period. These reviews will be ongoing, to provide updated inventory reports to the
Deputy Administrator and Assistant Administrators on the status of Agency action on
OIG recommendations. They will classify the status of recommendations as:
(1) implemented, (2) unimplemented for management attention, and (3) in progress.
Additionally, the OIG will use this review process to help improve the quality of OIG
recommendations.
EPA OIG Staff Help Lead Government-wide Training Program of
New Auditors
EPA OIG staff played an important role in developing key training courses for
Government auditors through the President's Council on Integrity and Efficiency. With
36
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the dissolution of the Inspector General Audit Training Institute, a collaborative effort
among the Inspector General audit community occurred to provide introductory auditor
training for Fiscal Year 2007. The Introductory Training Task Force filled a critical gap
for the audit community to provide basic training in professional competencies for entry
level personnel.
This collaborative effort brought together resources and instructors for five 2-week
sessions of intensive introductory classes. The task force members used volunteered
resources to design the curriculum, arrange facilities, obtain and update course materials,
schedule students and instructors, and deliver training. Between April 1 and
September 28, 2007, the task force trained nearly 200 entry-level personnel from
22 Federal Inspector General and Department of Defense audit organizations.
Several members of the EPA OIG were key task force organizers; developers of the
curriculum, instructional, and presentation materials; and actual instructors. Deborah
Heckman taught a half-day session, "Overview of the Government Auditing Standards."
Jerri Dorsey and Chris Dunlap taught a 1-day class, "Evidence, Documentation, and
Determining Significance of Results and Sufficiency of Evidence." Michael Binder, who
served as one of the organizers, taught nearly 4 days of classes on the Inspector General
Act, Audit Planning, Fraud Detection, Followup, Audit Communications, Reporting, and
Behavioral Aspects of Auditing.
OIG Staff Speak at National Conferences
Members of the EPA OIG have been nationally recognized and sought as guest speakers
at association and industry training conferences for their knowledge and leadership in
developing and implementing innovative approaches in planning, performance
measurement, quality assurance, and internal control assessment.
In April 2007, Michael Binder gave a presentation at the EPA National Budget
Conference on linking performance, planning, and accountability for return on
investment through the application of logic models, a hierarchy of measures, and activity-
based cost accounting. In May 2007, Mr. Binder gave a presentation at the Performance
Institute National Conference on Auditing for Results on the use of logic models and
Strengths, Weaknesses, Opportunities, and Threats (SWOT) analysis to plan, measure,
and report results.
Deborah Heckman gave a presentation in May 2007 at a National Association of
Inspectors General conference on implementing a meaningful audit quality assurance
process. At the same conference, Mr. Binder participated in a presentation on OIG
strategic planning and performance measurement for results from concept to action. This
conference was attended by several hundred participants representing State and local
offices of inspector general from across the country. The invitation to speak was issued
because the Association selected the EPA OIG Strategic Plan and Performance Measures
as an industry best practice.
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Legislation and Regulations Reviewed
Section 4(a) of the Inspector General Act requires the Inspector General to review
existing and proposed legislation and regulations relating to the program and operation of
EPA and to make recommendations concerning their impact. The primary basis for our
comments is the OIG's audit, evaluation, investigation, and legislative experiences, as
well as our participation on the President's Council on Integrity and Efficiency. During
the reporting period, we reviewed 24 proposed changes to legislation, regulations, policy,
and procedures that could affect EPA. We provided comments on 14 of those proposed
changes. We also reviewed drafts of Office of Management and Budget circulars, a
program operations manual, directives, and reorganizations. Details on several items
follow.
Proposed Revisions to Government Auditing Standards for Quality Control and
Assurance and Peer Review. The EPA OIG provided several comments and
suggestions on the proposed revisions to the quality control and assurance section of the
Government Auditing Standards, including:
• External Peer Review Frequency - Sarbanes-Oxley requires inspections
annually or every 3 years depending on the volume of work of the public audit
organization. The requirement for organizations that comply with the
Government Auditing Standards is less stringent. The rules should be at least as
rigorous as Sarbanes-Oxley.
• Paragraph 3.53 f. - This paragraph does not prescribe or recommend the
frequency of monitoring compliance with quality control.
• Paragraph 3.53 f.(6) - This paragraph requires a "determination of corrective
actions necessary." However, a requirement to follow up (track) the corrective
actions to determine whether the problems have been corrected should also be
included.
Personal Identity Verification and Smart Card Policy for Assistance Recipients.
EPA's Office of Grants and Debarment proposed to update the Assistance Administration
Manual by adding a section outlining EPA policy regarding grantee security requirements
under Homeland Security Presidential Directive - 12. The purpose of this revision was to
strengthen the management of common identification standards for individuals working
under EPA assistance agreements. We commented that the Agency already had existing
guidance in this area that should be referenced in the Office of Grants and Debarment's
guidance. Also, we noted that the Agency's existing guidance included a two-part test
that must be met before someone is to be granted a Personal Identity Verification badge,
and commented that the Office of Grants and Debarment's guidance did not include this
two-part test. The Office of Grants and Debarment agreed with our comments.
Proposed Revision to Resources Management Directive System 2520,
Administrative Control of Appropriated Funds, Exposure Draft 3.1. We noted that
some of our previously submitted comments on exposure draft 3.0 were not incorporated
into exposure draft 3.1. We asked that the Office of the Chief Financial Officer consider
incorporating our previous comments into the final draft prior to submitting the document
to the Office of Management and Budget for approval. We believe the Office of the
Chief Financial Officer missed an opportunity to make a linkage between Funds Control,
the Federal Managers' Financial Integrity Act, and Office of Management and Budget
38
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Circular A-123 beyond merely acknowledging these requirements. Administrative
Control of Appropriated Funds should be more explicit about the requirements of the
Federal Managers' Financial Integrity Act and Office of Management and Budget
Circular A-123. The responsibility for the administrative control of funds starts with
each EPA manager in carrying out basic supervisory and controllership functions. It is
not confined to the budget and financial management staff. Resources Management
Directive System 2520 needs to have a linkage to management responsibility for creating
a strong control environment, and the executing and testing controls, as is required by the
Federal Managers' Financial Integrity Act and Office of Management and Budget
Circular A-123.
39
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Statistical Data
Profile of Activities and Results
Audit Operations
Office of Inspector General Reviews
April 1 , 2007 to
September 30, 2007 Fiscal
($ in millions) 2007
Questioned Costs *
• Total $14.3 $41.1
• Federal $11.5 $38.2
Recommended Efficiencies *
• Federal $7.3 $16.6
Costs Disallowed to be Recovered
• Federal $26.4 $29.5
Costs Disallowed as Cost Efficiency
• Federal $5.8 $15.1
Reports Issued - Office of
Inspector General Reviews 40 71
Reports Resolved
(Agreement by Agency officials
to take satisfactory corrective
actions)** 132 236
Audit Operations
Other Reviews
(Reviews Performed by Another Federal Agency
or Single Audit Act Auditors)
April 1 , 2007 to
September 30, 2007 Fiscal
($ in millions) 2007
Questioned Costs *
• Total $77.6 $267.2
• Federal $7.3 $17.9
Recommended Efficiencies *
• Federal $0.0 $13.0
Costs Disallowed to be Recovered
• Federal $5.2 $6.7
Costs Disallowed as Cost Efficiency
• Federal $0.0 $0.0
Reports Issued - Other Reviews
• EPA Reviews Performed by
Another Federal Agency 82 198
• Single Audit Act Reviews 77 152
Total 159 350
Agency Recoveries
Recoveries from Audit Resolutions
of Current and Prior Periods
(cash collections or offsets to
future payments) *** $0.6 $1 .6
Investigative Operations
April 1 , 2007 to
September 30, 2007
($ in millions)
Fines and Recoveries $4.291
(including civil) ****
Cost Savings ***** $1 .963
Cases Open During Period 27
Cases Closed During Period ****** 34
Indictments/Informations of Persons 1 9
or Firms
Convictions of Persons or Firms 2
Civil Judgments/Settlements/Filings 3
Fiscal
2007
$5.003
$1.963
44
99
21
10
4
Questioned Costs and Recommended Efficiencies
are subject to change pending further review in the
audit resolution process. Total Questioned Costs
include contracts of other Federal agencies.
Reports Resolved are subject to change pending
further review.
Information on Recoveries from Audit Resolutions
is provided by EPA's Office of Financial
Management and is unaudited.
Total includes actions resulting from joint
investigations.
Total Fiscal Year 2007 Federal (EPA) cost
efficiencies, including those from investigative
operations and unrecognized amounts from the
prior semiannual period, equal $33.9 million.
Includes three cases closed in prior period.
40
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Audit Report Resolution
Status Report on Perpetual Inventory of Reports in Resolution Process
for Semiannual Period Ending September 30, 2007
Report Category
A. For which no management
decision was made by
April 1 , 2007 *
B. Which were issued during the
reporting period
C. Which were issued during the
reporting period that required
no resolution
Subtotals (A + B - C)
D. For which a management
decision was made during the
reporting period
E. For which no management
decision was made by
September 30, 2007
F. Reports for which no
management decision was
made within 6 months of
issuance
No. of
Reports
146
199
81
264
132
132
59
Report Issuance
($ in thousands)
Questioned
Costs
$77,520
$18,819
$0
$96,339
$42,327
$54,012
$36,980
Recommended
Efficiencies
$13,068
$7,324
$0
$20,392
$5,879
$14,513
$13,013
Report Resolution Costs
Sustained
($ in thousands)
To Be
Recovered
$31,473
$137
$0
$31,610
$31,610
$0
$0
As
Efficiencies
$0
$5,824
$0
$5,824
$5,824
$0
$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.
Status of Management Decisions on Inspector General Reports
This section presents statistical information as required by the Inspector General Act of 1978, as
amended, on the status of EPA management decisions on reports issued by the OIG involving monetary
recommendations. As presented, information 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.
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Table 1 - Inspector General-Issued Reports with Questioned Costs for Semiannual Period Ending
September 30, 2007 (dollars in thousands)
Report Category
A. For which no management decision was made by
April 1 , 2007 **
B. New reports issued during period
Subtotals (A + B)
C. 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. For which no management decision was made by
September 30, 2007
Reports for which no management decision was made
within 6 months of issuance
No. of
Reports
67
45
112
52
33
19
60
25
Questioned
Costs *
$77,520
$18,819
$96,339
$42,327
$31,610
$10,717
$54,012
$36,980
Unsupported
Costs
$28,256
$12,535
$40,791
$4,833
$203
$4,630
$35,958
$25,049
Questioned costs include the unsupported costs.
Any difference in number of reports and amounts of questioned costs between this report and our previous
semiannual report results from corrections made to data in our audit tracking system.
Table 2 - Inspector General-Issued Reports with Recommendations that Funds Be Put to Better Use
for Semiannual Period Ending September 30, 2007 (dollars in thousands)
Report Category
A. For which no management decision was made by April 1 , 2007 *
B. Which were issued during the reporting period
Subtotals (A + B)
C. 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
(ii) Dollar value of non-awards or unsuccessful bidders
D. For which no management decision was made by September 30, 2007
Reports for which no management decision was made within 6 months
of issuance
No. of
Reports
3
3
6
4
2
1
1
1
1
Dollar
Value
$13,068
$7,324
$20,392
$5,879
$5,824
$50
$5
$14,513
$13,013
Any difference in number of reports and amounts of funds put to better use between this report and
previous semiannual report results from corrections made to data in our audit tracking system.
our
Audits with No Final Action as of September 30, 2007, Which Are Over 365 Days Past the Date of the
Accepted Management Decision (including Audits in Appeal)
Audits
Program
Assistance Agreements
Contract Audits
Single Audits
Financial Statement Audits
Total
Total
31
0
0
13
1
45
Percentage
69%
0%
0%
29%
2%
100%
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Summary of Investigative Results
Summary of Investigative Activity during Period
Cases open as of April 1, 2007
Cases opened during period
Cases closed during period
Cases pending as of September 30, 2007
118
27
34
111
Investigations Pending by Type as of September 30, 2007
Contract
Assistance Agreement
Employee Integrity
Program Integrity
Computer Crime
Laboratory Fraud
Other
Total
Superfund
5
0
0
2
1
6
3
17
Management
11
28
19
6
3
24
2
93
Split Funded
0
1
0
0
0
0
0
1
Total
16
29
19
8
4
30
5
111
Results of Prosecutive Actions
Criminal Indictments / Informations / Complaints
Convictions
Civil Judgments / Settlements / Filings
Fines and Recoveries (including Civil)
Prison Time
Prison Time Suspended
Probation
Community Service
EPA OIG Only
5
0
3
$15,423
0 months
0 months
60 months
0 hours
Joint*
14
2
0
$4,275,182
140 months
0 months
252 months
400 hours
Total
19
2
3
$4,290,605
140 months
0 months
312 months
400 hours
Administrative Actions
Suspensions
Debarments
Voluntary Exclusions
Other Administrative Actions
Total
Cost Savings
EPA OIG Only
7
1
1
15
24
$0
Joint*
0
4
1
4
9
$1,962,925
Total
7
5
2
19
33
$1,962,925
* With another Federal agency.
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Scoreboard of Results
Scoreboard of OIG Fiscal Year 2007 Performance Results
Compared to Fiscal Year 2007 Annual Performance Goal Targets
All results reported in Fiscal Year 2007, from current and prior years' work, are as reported in OIG
Performance Measurement and Results System and the Inspector General Operations Reporting system.
OIG Fiscal Year 2007 Government Performance
and Results Act Annual Performance Targets
Compared to Fiscal Year 2007 Results Reported
Supporting Measures
Goal: Contribute to Human Health and Environmental Quality Through Improved Business Practices,
Accountability, and Integrity of Program Operations
Environmental Improvements/Actions/Changes
Improvements in Business/Systems/Efficiency
Risks Reduced or Eliminated
Target: 318; Reported: 464 (146%)
7 Legislative/regulatory changes/decisions
7 Examples of environmental improvement
5 Environmental best practices implemented
19 Management best practices implemented
27 Environmental policy, process, practice, control
changes
115 Management policy, process, practice, control
changes
268 Certifications/validations/verifications/corrections
16 Environmental/mgt. risks reduced/eliminated
Environmental and Business Recommendations,
Challenges, Best Practices, and Risks Identified
Target: 925; Reported: 949 (103%)
26 Environmental Recommendations
(for Agency/stakeholder action)
784 Management Recommendations
(for Agency/stakeholder action)
28 Critical congressional or public management
concerns addressed
12 Best environmental practices identified
59 Best management practices identified
19 Referrals for Agency action
13 New FMFIA/A-123/mgt. challenges/risks identified
8 Environmental risks identified
Return on Investment: Potential dollar return
as percentage of OIG budget $50.4 million
Target: $75.6 M; Reported: $95.2 M (EPA) (126%)
(Dollars in Millions)
$ 56.3 Questioned costs (net EPA)
$ 29.7 Recommended efficiencies, costs saved (EPA)
$ 5.0 Fines, recoveries, settlements
$ 4.2 Additional efficiencies not in resolution process v
Criminal, Civil, and Administrative Actions
Reducing Risk of Loss/Operational Integrity
Target: 80; Reported: 103 (129%)
10 Criminal convictions
21 Indictments/informations/complaints
4 Civil judgments/settlements/filings
68 Administrative actions
Sustained Monetary Recommendations and Savings
Achieved from Current and Prior Periods: $ 53.4 M
Sustained Environmental and Management
Recommendations Sustained for Resolution:
354
(no goals established)
(Dollars in Millions)
$ 36.3 Questioned costs sustained
$17.1 Cost efficiencies sustained or realized *
15 Environmental recommendations sustained
339 Management recommendations sustained
* $2 million in efficiencies from investigative operations was sustained but not submitted through Agency resolution process.
44
-------
Appendices
Appendix 1 - Reports Issued
The Inspector General Act requires a listing, subdivided according to subject matter, of each report issued
by the OIG during the reporting period. For each report, where applicable, the Inspector General Act also
requires a listing of the dollar value of questioned costs and the dollar value of recommendations that
funds be put to better use.
Questioned Costs
Report No.
Title
Final
Report
Issued
Ineligible
Costs
Unsupported Unreasonable
Costs Costs
Federal
Recommended
Efficiencies
PERFORMANCE REPORTS
2007-P-00016
2007-P-00019
2007-P-00020
2007-P-00021
2007-P-00022
2007-P-00023
2007-P-00024
2007-P-00025
2007-P-00026
2007-P-00027
2007-P-00028
2007-P-00029
2007-P-00030
2007-P-00031
2007-P-00032
2007-P-00034
2007-P-00035
2007-P-00036
2007-P-00037
2007-P-00038
2007-P-00039
2007-P-00040
2007-P-00041
Ringwood Mines/Landfill Superfund Site
Chemical Safety Board - FISMA & Pll Report for FY 2006
FY 2006 Peer Review of Commerce
EPA Contracting Through the Corps of Engineers
Assistance Agreements - Tribal Program Implementation Issues
Clean Water Compliance and Enforcement
Assistance Agreements - Impact of Earmarks
Followup on Actions in Response to OIG Water Reports
Status of Superfund Alternative Sites with No Signed Agreement
Benchmarking Other Organizations' Statistically Valid Compliance
Effectiveness of ENERGY STAR
Superfund Board of Directors
EPA's Implementation of Electronic Data Collection
Chesapeake Bay Land Use
Chesapeake Bay Federal Facilities Compliance with the CWA
Groundwater Contamination Panola County TX
EPA's Protection of Pll & Privacy Program
Planning for Future TMDL Reviews
Progress in Use of FSS Orders, But More Action Needed
Lake Anna Permit
OIG Congressional Request - Ringwood Mines/Landfill Superfund
Strategic Agricultural Initiative (SAI)
Voluntary Programs Could Benefits from Internal Policy Controls
TOTAL PERFORMANCE REPORTS = 23
2-Apr-07
23-Apr-07
24-Apr-07
30-Apr-07
3-May-07
9-May-07
10-May-07
24-May-07
6-Jun-07
20-Jun-07
1-Aug-07
1-Aug-07
20-Aug-07
10-Sep-07
6-Sep-07
11-Sep-07
17-Sep-07
18-Sep-07
20-Sep-07
20-Sep-07
25-Sep-07
25-Sep-07
25-Sep-07
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
$0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
$0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
$0
0
0
0
$2,500,000
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
$1,500,000
0
$4,000,000
ASSISTANCE AGREEMENT REPORTS
2007-2-00030
2007-2-00039
2007-2-00040
2007-4-00065
2007-4-00068
2007-4-00078
City of Huron, South Dakota
City of Middletown, New York
City of Fallon, Nevada
Environmental Careers Organization
Ozone Transport Commission
Cheyenne River Sioux Tribe
TOTAL ASSISTANCE AGREEMENT REPORTS = 6
30-Jul-07
25-Sep-07
26-Sep-07
25-Jun-07
31-Jul-07
24-Sep-07
$109,453
$433,700
$311,607
$1,277,472
0
$64,765
$2,196,997
0
0
$39,309
$4,750,342
$1,519,361
$3,037,062
$9,346,074
0
0
0
0
0
0
$0
0
0
0
0
0
0
$0
SINGLE AUDIT REPORTS
2007-3-00077
2007-3-00078
2007-3-00079
2007-3-00080
2007-3-00081
2007-3-00082
2007-3-00083
2007-3-00084
2007-3-00085
2007-3-00086
2007-3-00087
2007-3-00088
2007-3-00089
2007-3-00090
2007-3-00091
2007-3-00092
2007-3-00093
2007-3-00094
2007-3-00095
2007-3-00096
2007-3-00097
Lake Superior State University - FY 2005
Vermont, State of - FY 2004
Western Michigan University- FY 2006
Duke University - FY 2005
Michigan State University - FY 2005
Texas, State of - FY 2005
Wayne State University - FY 2005
Michigan Department of Agriculture - FY 2004
Wyoming, University of - FY 2005
Hawaii Department of Health - FY 2005
Hobart, City of- FY 2005
Wyandotte, City of - FY 2005
Rockford, City of- FY 2005
Sparta, City of- FY 2005
Guam, Government of - FY 2004
Guam, Government of - FY 2005
Commonwealth of the Northern Mariana Islands - FY 2003
Commonwealth of the Northern Mariana Islands - FY 2004
Commonwealth of the Northern Mariana Islands - FY 2005
Fort Independence Indian Community of Paiute Indians - FY 2005
Los Angeles, Department of Water and Power - FY 2005
3-Apr-07
3-Apr-07
5-Apr-07
5-Apr-07
5-Apr-07
12-Apr-07
12-Apr-07
12-Apr-07
12-Apr-07
23-Apr-07
23-Apr-07
23-Apr-07
24-Apr-07
24-Apr-07
24-Apr-07
24-Apr-07
1-May-07
1-May-07
1-May-07
14-May-07
14-May-07
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
$12,808
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
$21,107
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
45
-------
Questioned Costs
Report No.
2007-3-00098
2007-3-00099
2007-3-00100
2007-3-00101
2007-3-00102
2007-3-00103
2007-3-00104
2007-3-00105
2007-3-00106
2007-3-00107
2007-3-00108
2007-3-00109
2007-3-00110
2007-3-00111
2007-3-00112
2007-3-00113
2007-3-00114
2007-3-00115
2007-3-00116
2007-3-00117
2007-3-00118
2007-3-00119
2007-3-00120
2007-3-00121
2007-3-00122
2007-3-00123
2007-3-00124
2007-3-00125
2007-3-00126
2007-3-00127
2007-3-00128
2007-3-00129
2007-3-00130
2007-3-00131
2007-3-00132
2007-3-00133
2007-3-00134
2007-3-00135
2007-3-00136
2007-3-00137
2007-3-00138
2007-3-00139
2007-3-00140
2007-3-00141
2007-3-00142
2007-3-00143
2007-3-00144
2007-3-00145
2007-3-00146
2007-3-00147
2007-3-00148
2007-3-00149
2007-3-00150
2007-3-00151
2007-3-00152
2007-3-00153
Title
Cortina Indian Rancheria - FY 2005
Athabascan Tribal Governments - FY 2005
Georgia, State of- FY 2005
Burlington, City of- FY 2005
Sumner, City of- FY 2005
American Society of Civil Engineers and Affiliates - FY 2005
Alliance for the Chesapeake Bay, Inc. - FY 2005
Nondalton Tribal Council - FY 2003
Nondalton Tribal Council - FY2004
Washington, State of - FY 2005
Northern Marianas College - FY 2005
Native Village of Kotzebue - FY 2005
University of Southern California - FY 2005
Center for Watershed Protection, Inc. - FY2005
American Cities Foundation - FY 2005
Clarksburg, City of- FY 2005
Red Cliff Band of Lake Superior Chippewas - FY 2005
Children's National Medical Center and Subsidiaries - FY 2005
Wayne, Charter County of - FY 2004
Harvard University - FY 2005
Harvard University - FY 2006
Lake Michigan Air Directors Consortium - FY 2005
Vermont, State of - FY 2006
Guam Waterworks Authority - FY 2005
Wayne, Charter County of - FY 2005
Green Bay Metropolitan Sewerage District - FY2005
Oregon, State of - FY 2006
Kingbrook Rural Water System, Inc. - FY 2005
Native Village of Goodnews Bay - FY 2005
Minnesota Public Facilities Authority - FY 2005
Hoopa Valley Tribe -FY 2005
Rosebud Sioux Tribe, SD - FY 2005
Picayune Rancheria of the Chukchansi Indian Tribe - CA 2005
Sac & Fox Nation of Missouri - FY 2005
Pyramid Lake Paiute Tribe - FY 2002
National Caucus and Center on Black Aged, Inc. - FY 2005
Harbor Branch Oceanographic Institution, Inc. - FY 2005
Tennessee, State of - FY 2006
Natl Assoc. of Develop Organizations Rsch Found - FY 2005
Delaware, State of - FY 2006
Puget Sound Clean Air Agency - FY 2005
New York, State of - FY 2006
North Carolina, State of - FY 6/30/06
South Dakota Association of Conservation Districts, Inc.
Tesuque, Pueblo of, NM - FY 2005
Pit River Tribe -FY 2005
San Juan Pueblo, NM - FY 2005
Southeastern States Air Resources Managers, Inc. - FY 2005
Missouri, State of- FY 2006
West Virginia, State of - FY 2006
Soboba Band of Luiseno Indians - FY 2005
Florida, State of- FY 2006
Seminole Nation of Oklahoma - FY 2005
Havasupai Tribe - FY 2005
New Mexico Environment Department - FY 2005
Wayne County Water and Sewer Authority - FY 2005
TOTAL SINGLE AUDIT REPORTS = 77
Final
Report
Issued
14-May-07
15-May-07
18-May-07
18-May-07
18-May-07
18-May-07
18-May-07
21-May-07
21-May-07
21-May-07
21-May-07
21-May-07
24-May-07
29-May-07
29-May-07
29-May-07
29-May-07
11-Jun-07
12-Jun-07
20-Jun-07
22-Jun-07
22-Jun-07
29-Jun-07
9-Jul-07
10-Jul-07
10-Jul-07
12-Jul-07
16-Jul-07
16-Jul-07
16-Jul-07
23-Jul-07
23-Jul-07
23-Jul-07
24-Jul-07
24-Jul-07
24-Jul-07
25-Jul-07
25-Jul-07
26-Jul-07
26-Jul-07
26-Jul-07
26-Jul-07
27-Jul-07
2-Aug-07
2-Aug-07
6-Aug-07
7-Aug-07
16-Aug-07
16-Aug-07
16-Aug-07
23-Aug-07
27-Aug-07
28-Aug-07
6-Sep-07
6-Sep-07
20-Sep-07
Ineligible
Costs
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
$3,426
0
0
0
0
0
$17,978
0
$54,284
0
0
0
$593,390
0
0
0
0
$681,886
Federal
Unsupported Unreasonable Recommended
Costs Costs Efficiencies
$345,788
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
$1,102,607
0
0
0
0
0
0
0
0
0
0
0
0
0
$178,348
0
0
0
0
0
0
$1,506,919
0
0
0
0
0
0
0
0
0
0
0
0
$33,963
0
0
0
$3,188,732
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
$0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
$0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
$0
OIG-ISSUED CONTRACT REPORTS
2007-4-00053
2007-4-00056
2007-4-00062
2007-4-00063
2007-4-00064
2007-4-00069
Mixed Funding Claim No. 2 - Bofors-Nobel
York Oil CERCLA Response Claim Nos. 3 and 4
Application Controls Over E&E's Time & Expense System
E&EFY 2005 Adequacy Review
Mixed Funding Claim No. 2 - Armour Road
York Oil Mixed Funding Claim No. 5
TOTAL OIG-ISSUED CONTRACT REPORTS = 6
4-Apr-07
26-Apr-07
14-May-07
23-May-07
4-Jun-07
31-Jul-07
0
0
0
0
0
0
$0
0
0
0
0
0
0
$0
0
0
0
0
0
0
$0
0
0
0
0
0
0
$0
DEFENSE CONTRACT AUDIT AGENCY (DCM) CONTRACT REPORTS
2007-1-00057
2007-1-00058
2007-1-00059
2007-1-00060
2007-1-00061
2007-1-00062
2007-1-00063
2007-1-00064
Tetra Tech NUS, Inc. - FY 9/30/2004 Incurred Cost
Environomics - FYE 12/31/2005 Incurred Cost
National Academy of Sciences - FY 12/31/2004 Incurred Cost
Zedek Corporation - FYE 10/31/2003 Incurred Cost
Lockheed Martin Services Group - FY 12/31/2004 I/C
Earth Tech Remediation Services - FY2003 Incurred Cost
Kemron Environmental Services FYE 5/31/2004 Incurred Cost
URS Operating Services Inc.-FY 1997 Incurred Cost
2-Apr-07
2-Apr-07
5-Apr-07
6-Apr-07
10-Apr-07
10-Apr-07
19-Apr-07
23-Apr-07
0
0
$70,900
$2,727
$694,178
$29,227
0
$569,748
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
46
-------
Questioned Costs
Report No.
2007-1-00065
2007-1-00066
2007-1-00067
2007-1-00068
2007-1-00069
2007-1-00072
2007-1-00073
2007-1-00074
2007-1-00075
2007-1-00076
2007-1-00077
2007-1-00078
2007-1-00079
2007-1-00080
2007-1-00081
2007-1-00082
2007-1-00083
2007-1-00084
2007-1-00085
2007-1-00086
2007-1-00087
2007-1-00088
2007-1-00089
2007-1-00090
2007-1-00091
2007-1-00092
2007-1-00093
2007-1-00094
2007-1-00095
2007-1-00096
2007-1-00097
2007-1-00098
2007-1-00099
2007-1-00100
2007-1-00101
2007-1-00102
2007-1-00103
2007-1-00104
2007-2-00025
2007-2-00026
2007-2-00027
2007-2-00028
2007-2-00029
2007-2-00031
2007-2-00032
2007-2-00033
2007-2-00034
2007-2-00035
2007-2-00036
2007-2-00037
2007-2-00038
2007-2-00041
2007-2-00042
2007-2-00043
2007-2-00044
2007-4-00054
2007-4-00055
2007-4-00057
2007-4-00058
2007-4-00059
2007-4-00060
2007-4-00061
2007-4-00066
2007-4-00067
2007-4-00070
2007-4-00071
2007-4-00072
2007-4-00073
2007-4-00074
2007-4-00075
2007-4-00076
2007-4-00077
2007-4-00079
2007-4-00080
Title
EC/R Incorporated - FY 12/31/2004 Incurred Cost
Systems Research & Applications - FY 2005 Incurred Cost
Bionetics Corp - FY 2004 Incurred Cost
Business Technologies & Solutions, Inc.
Toeroek Associates Inc. - FY 12/31/2004 Incurred Cost
Metcalf & Eddy Inc. - FYE 9/30/2004 Incurred Cost
STG, Inc. - FYE 12/31/2002 Incurred Costs
Eastern Research Group, Inc. - FY 2005 Incurred Costs
Legin Group, Inc. - FY 12/31/2004 Incurred Cost
Tetra Tech EC, Inc. - FY 2005 Incurred Cost
CH2M Hill, Inc. -FY 2005 I/C
Syracuse Research Corporation - FY 2006 Incurred Cost
Science Applications Intl Corporation - FYE 1/31/2005 I/C
Lockheed Martin Services, Inc. - FY2005 Incurred Cost
Great Lakes Environmental Ctr - FY 12/31/2004 Incurred Cost
Aqua Terra Consultants - FY 06/26/2005 Incurred Cost
SecTek, Inc. - CFYE 9/30/2003 Incurred Cost
Northbridge Environmental - FY 2005 I/C
Transcontinental Enterprises, FYE 9/30/2003 Incurred Cost
Transcontinental Enterprises, Inc. - FY2004 Incurred Cost
Tetra Tech EC, Inc. - FY 10/1/2004 Incurred Cost
E. H. Pechan & Associates - FY 06/30/2001 Incurred Cost
STG, Incorporated - FYE 12/31/2003 Incurred Costs
ABT Associates Inc.- FY 2002 Incurred Cost
WRS Infrastructure & Environment, Inc. - FYE 12/31/2005 I/C
Zedek Corporation - FYE 10/31/2004 Incurred Cost
ICF Consulting Group, Inc. - FY 12/31/2004 Incurred Cost
COM Federal Programs Corp. - FY 12/31/2004 Incurred Cost
Gannett Fleming, Inc. - FY 2005 I/C
Vistronix, Inc. - FYE 12/31/2000 Incurred Cost
National Academy of Sciences FYE 12/31/2003 Incurred Cost
Shaw E&l QATS Segment - FY 2004 Incurred Cost Audit
Perrin Quarles Associates, Inc. - FY 2005 Incurred Cost
Environmental Restoration, LLC. - FY 2005 I/C
Logistics Manangement Instititue (LMI) - FY 9/30/2004 I/C
DynCorp, Inc. - FYE 12/31/2004 Incurred Cost
URS Operating Services lnc.-FY2001 Incurred Cost
Great Lakes Environmental Center - FY 2005 I/C
Enterprise Technology - FY 2005 I/C
PARS Environmental, LLC- Preaward PR-CI-07-10068
Matrix Environmental & Geotechnical Services - FY 2005 I/C
Tetra Tech NUS Inc. - FY 2004 RAG - 68-S6-3003
Tetra Tech/BVSPC Joint Ven-FY2001 RAG Closeout 68S73002
Project Resources, Inc. - FY 12/31/2004 Incurred Cost
Black & Veatch Special Proj. Corp.-FY2001 RAG 68-W-99-043
TN & Associates - FY 12/31/2004 Incurred Cost
CH2M Hill, Inc. - FY 2004 RAG - 68-W6-0025
CH2M Hill, Inc. - FY 2003 RAG - Contract S68-W9-8225
CH2M Hill, Inc. - FY 2004 RAG 68-W9-8225
COM Federal Program Corp - FY 2003 RAG - 68-W9-8210
CH2M Hill, Inc. - FY 2002 RAG 68-W9-8225
COM Federal Prog Corp-FY2003 RAG Ann'l Closeout 68-S7-3003
42'
URS Corporation-FY2000 RAG Closeout 68-W9-8228
COM Federal Prog Corp-FY2003 RAG Ann'l Closeout 68-W5-0022
Metcalf & Eddy, Inc. - FY 2007 Labor Floorcheck
Shaw Environmental & Infrastructure, Inc. - MAARS 6
Shaw Environmental & Infrastructure, Inc. - CAS 415
SAIC - Companies 1 , 6 & 9 - FY 2006 Floorchecks
SAIC - Company 6 - FY 2006 CAS 420
SAIC - Company 9 - FY 2006 Disclosure Statement
Shaw Environmental & Infrastructure, Inc. - Budget System
Metcalf & Eddy, Inc. - FY 2007 CAS 410
Battelle - ICAPS - FY 2006 Indirect & ODC System
Battelle - ICAPS - FY 2006 Billing System
Midwest Research Institute - FY 2005 Accounting System
CH2M Hill, Inc. (INC)- FY 2006 Estimating System
Tetra Tech EMI - CAS Revised Disclosure Statement FY2006
Tetra Tech EMI -CAS 418
CH2M Hill, Inc. (INC) - FY 2006 Indirect/ODC System
Tetra Tech EMI - CAS 420
Master Key Resources, LLC - Preaward Accounting Review
Weston Solutions, Inc. - FY 2006 Billing System
National Academy of Sciences - FY 2006 Budget System
TOTAL DCM CONTRACT REPORTS = 82
Final
Report
Issued
24-Apr-07
2-May-07
4-May-07
7-May-07
15-May-07
25-Jun-07
25-Jun-07
25-Jun-07
27-Jun-07
29-Jun-07
2-Jul-07
18-Jul-07
18-Jul-07
6-Aug-07
26-Jul-07
31-Jul-07
8-Aug-07
13-Aug-07
14-Aug-07
14-Aug-07
21-Aug-07
20-Aug-07
28-Aug-07
29-Aug-07
4-Sep-07
5-Sep-07
5-Sep-07
7-Sep-07
11-Sep-07
19-Sep-07
20-Sep-07
20-Sep-07
21-Sep-07
25-Sep-07
27-Sep-07
27-Sep-07
27-Sep-07
27-Sep-07
2-May-07
8-May-07
21-Jun-07
29-Jun-07
31-Jul-07
31-Jul-07
1-Aug-07
6-Aug-07
14-Aug-07
20-Aug-07
28-Aug-07
18-Sep-07
21-Sep-07
27-Sep-07
27-Sep-07
27-Sep-07
27-Sep-07
19-Apr-07
23-Apr-07
30-Apr-07
30-Apr-07
3-May-07
7-May-07
11-May-07
22-Jun-07
2-Jul-07
9-Aug-07
30-Aug-07
4-Sep-07
4-Sep-07
4-Sep-07
10-Sep-07
17-Sep-07
18-Sep-07
25-Sep-07
26-Sep-07
Federal
Ineligible Unsupported Unreasonable Recommended
Costs Costs Costs Efficiencies
0 0
$14,868 0
0 0
0 0
0 0
$10,782 0
0 0
$86,191 0
0 0
0 0
0 0
0 0
$119,696 0
$133,069 0
0 0
0 0
$61 0
$242,921 0
$35,067 0
$92,849 0
0 0
$3,662 0
$29,352 0
$123,686 0
0 0
$4,370 0
0 0
$18,494 0
0 0
0 0
$27,058 0
$51,615 0
$2,256 0
0 0
0 0
$11,230 0
$984,868 0
0 0
0 0
0 0
0 0
$5,132 0
0 0
0 0
0 0
0 0
0 0
0 0
0 0
$8,654 0
0 0
$3,305 0
0 0
$5,269 0
$24,522 0
0 0
0 0
0 0
0 0
0 0
0 0
0 0
0 0
0 0
0 0
0 0
0 0
0 0
0 0
0 0
0 0
0 0
0 0
0 0
$3,405,757 $0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
$0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
$0
47
-------
Questioned Costs
Report No.
Title
Final
Report Ineligible
Issued Costs
Federal
Unsupported Unreasonable Recommended
Costs Costs Efficiencies
FINANCIAL STATEMENT REPORTS
2007-1-00070 2006 FIFRA Financial Statement Audit (Master)
2007-1-00071 2006 PRIA Financial Statement Audit (Master)
TOTAL FINANCIAL STATEMENT REPORTS = 2
SPECIAL REVIEW REPORTS
2007-S-00001 CSB Personnel Activities - Hotline
2007-S-00002 Superfund Special Accounts - Thermo Chem
2007-S-00003 FY 2007 FISMA Evaluation
TOTAL SPECIAL REVIEW REPORTS = 3
30-May-07
30-May-07
31-May-07
20-Aug-07
25-Sep-07
0
0
$0
0
0
0
$0
0
0
$0
0
0
0
$0
$0
0
0
0
$0
0
0
$0
0
3,324,000
0
$3,324,000
TOTAL REPORTS ISSUED = 199
$6,284,640 $12,534,806
$0
$7,324,000
48
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Appendix 2 - Reports Issued Without Management Decisions
The Inspector General Act requires a summary of each audit report issued before the commencement of the
reporting period for which no management decision has been made by the end of the reporting period (including the
date and title of each such report), an explanation of the reasons such management decision has not been made,
and a statement concerning the desired timetable for achieving a management decision on each such report. (The
OIG provides the summary, the date and title of each such report. The Agency provides the explanation of the
reasons such management decision has not been made, and a statement concerning the desired timetable for
achieving a management decision on each such report.)
IG Followup Status Codes of Agency's Response at 09/30/2007:
[ ] No Response
0 Resolution Pending Receipt of Additional Information
1 Proposed Response Received Awaiting Final Determination
2 Incomplete Response Received
3 Proposed Response Received in Review Process
5 Report Reactivated/Awaiting Response
6 Resolution Under Negotiation in Headquarters
7 Referred to Audit Resolution Board
Office of Air and Radiation
Report No.: 2004-P-00033
Title: Effectiveness of Strategies to Reduce Ozone Precursors
Issued: 09/29/2004
Despite national and regional progress, some major metropolitan areas have not achieved the ozone precursor
emission reductions required by the 1990 Act. Our analysis of EPA emissions data for "serious," "severe," and
"extreme" ozone non-attainment areas indicates that some major metropolitan areas may not have achieved the
required 3-percent annual emission reductions in ozone precursor emissions. Since 1990, 23 of 28 emissions
reduction plans submitted by 10 of the serious to extreme non-attainment areas raised questions as to whether
required precursor emissions reductions were achieved by the dates specified in the Act. Further, precursor
emissions in some areas may actually have increased. While EPA air trends reports have emphasized that ozone
levels are declining nationally and regionally, only 5 of 25 non-attainment areas designated serious to extreme have
experienced substantial downward trends in ozone levels. For some areas, EPA data indicate emission controls for
the last 10 years have generally offset growth but have not significantly reduced ozone levels (emissions reductions
should be net of growth). Also, analyses by EPA and other researchers indicate that recent downward trends in
ozone may be more related to changes in weather patterns than emission reductions. Delays in reducing ozone
levels can have serious health implications for persons in non-attainment areas.
EPA provided an action plan to the OIG that provided a partial list of actions planned in response to our report and we
closed 8 of the 25 recommendations (Recs. 3-1, 3-4, 3-6, 6-2, 6-3, 8-1, 8-2, and 8-4). We sent a memo to EPA in
May 2005 explaining that, once the final Milestone Compliance Demonstration (MCD) rule is promulgated, we may
close out 6 additional recommendations (Recs. 2-2, 3-3, 5-1, 5-2, 5-3, and 5-5) if the MCD rule adequately addresses
these recommendations. Additionally, we explained that we may be able to close 5 other recommendations
(Recs. 2-1, 5-4, 6-1, 7-1, and 7-2) that the Agency was considering in concert with its efforts to address the
recommendations of the National Academy of Sciences/National Research Council's CAAAC Air Quality
Management work group. We also explained that we needed more specifics about the action(s) being taken or
planned to address other recommendations (Recs. 3-2, 3-5, 4-1, 4-2, 8-3, 8-5). Subsequently, in May 2006 we met
with management and staff of EPA's State and Local Programs Group/Air Quality Policy Division of the Office of Air
Quality Planning and Standards (OAQPS), and were told that the Agency had decided not to issue the MCD rule.
Instead, the Agency planned to issue guidance to EPA regions that they could share with their States. They
explained that such guidance would be faster than a regulatory approach and there were only a limited number of
areas at the time that fell into the serious, severe, or extreme non-attainment category under the new .08 ppm, 8-hour
ozone standard. Staff acknowledged that more areas may come under these categories in the future. We do not
agree that guidance is an acceptable alternative to following through on the Clean Air Act's mandate to promulgate
49
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rules requiring that States demonstrate progress in reducing precursor emissions, including a reliable method to
measure ozone precursor emission reduction efforts. Regarding the recommendations of the National Academy of
Sciences/National Research Council's CAAAC Air Quality Management work group, the Agency formed an ongoing
quality management task force. OAQPS officials said they would wait until the Agency task force report comes out
before they develop any other plan to address the OIG's open recommendations. We will continue to followup on the
Agency's actions regarding our Ozone Precursor Emissions report.
EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN MADE
As communicated to the OIG, OAQPS briefed and received AA guidance on the feasibility and effectiveness of an
MCD rule/guidance considering the recent Ozone Rule impact and Office of Management and Budget Good
Guidance requirements. We have prepared an alternative solution and requested to meet with the OIG on the issue
in October 2007.
DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION
Expect resolution by November 2007.
IG Followup Status as of: 09/30/2007 [ 2 ]
Report No.: 2005-P-00003
Title: Development of the Proposed MACT for Utility Units
Issued: 02/02/2005
Evidence indicated that EPA senior management instructed EPA staff to develop a Maximum Achievable Control
Technology (MACT) standard for mercury that would result in national emissions of 34 tons annually, instead of
basing the standard on an unbiased determination of what the top performing coal-fired units were achieving in
practice. The Clean Air Act requires that a MACT standard should, at a minimum, be based on the emissions levels
achieved by the top performing 12 percent of units, not a targeted national emissions result. The 34-tons-per-year
target was based on the amount of mercury reductions expected to be achieved from the co-benefit of implementing
nitrogen oxide and sulfur dioxide controls under a separately proposed, but related, air rule, known as the Clean Air
Interstate Rule. The 34-ton target was prescribed by EPA senior management, and prior estimates were lower.
Because the results of the MACT standard were prescribed and prior estimates were lower than what was proposed,
we believed it was likely that the standard understated the average amount of mercury emissions reductions
achieved by the top performing 12 percent of power units. We also reported that the Agency's cap-and-trade
proposal could be strengthened to better ensure that anticipated emission reductions would be achieved. On March
31, 2005, EPA issued the final Clean Air Mercury Rule (CAMR), which adopted a cap-and-trade approach to
controlling mercury emissions.
EPA submitted its response to our final report on May 4, 2005. Based on this response, we agreed to close out two
recommendations, hold three recommendations in abeyance pending the outcome of litigation, and hold four
recommendations open pending receipt of a corrective action plan for implementing those recommendations. After
EPA's initial response to our report, the Agency decided to open CAMR for reconsideration on October 28, 2005. On
January 25, 2006 the Agency requested an extension for completing its response to our report for all seven open
recommendations until the rule reconsideration process was completed. On February 2, 2006 we granted the
Agency's request for an extension. The reconsidered CAMR rule was issued May 31, 2006, essentially unchanged
from the earlier rule. On June 19, 2006, about 16 States filed lawsuits challenging EPA's reconsidered CAMR rule,
and on January 12, 2007, these and other suits were combined into one case which is pending before the U.S. Court
of Appeals - District of Columbia Circuit. Since our report raised questions about the data and process EPA used in
developing CAMR, we will hold the recommendations in abeyance until the Court's ruling, in which event they may be
applicable if the Agency conducts additional Mercury analyses. We will continue to monitor Agency actions
regarding the findings and recommendations in our February 2005 report.
EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN MADE
Resolution continues to be on Hold; Beyond Agency Control. This audit report partially overlaps the Mercury
Hotspots report 2006-P-00025, and we are waiting to see if an assessment of CAMR's impact is feasible using the
National Lake Fish Tissue Study as a baseline.
IG Followup Status as of: 09/30/2007 [ 0 ]
50
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Report No.: 2006-P-00017
Title: Emissions Factors Management, Use, and Benefits
Issued: 03/22/2006
Industry, EPA, State, local, and tribal agencies, environmental groups, and others use emissions factors to develop
the emissions data that underlie a host of important environmental decisions. These decisions include setting permit
limits for industrial facilities, developing control strategies, measuring environmental progress, assessing facility
compliance, and demonstrating results under the Government Performance and Results Act of 1993. About 80
percent of emissions determinations are the result of emissions factors. EPA has made progress in emissions factors
development since the OIG reviewed the program in 1996, but a large number of factors continue to be rated low.
The number of EPA-rated factors increased by nearly 94 percent, from 8,838 in 1996 to 17,110 in 2004. However,
the percentage of emissions factors rated below average or poor increased from 56 percent in 1996 to 62 percent in
2004. EPA faces significant challenges in improving emissions factors. We found (1) conflicting guidance on the
appropriate use of emissions factors, (2) a rating system which did not quantify the uncertainty associated with the
emission factor, (3) inadequate funding of the emissions factor program, and (4) lack of a comprehensive plan to
improve data collection and set emissions factor priorities. Without reliable emissions factors, users cannot be sure
that (1) air pollution control strategies target the right industries or products; (2) permitting programs establish
appropriate emission limits; or that (3) air programs are effective in reducing air pollution.
EPA generally agreed with our report and provided a corrective action plan to the OIG in August 2006 that enabled
the OIG to close 9 of 13 recommendations. We followed up with the Office of Air and Radiation in March 2007 and
confirmed that the Agency issued a Quality Management Plan in October 2006 calling for data used for the
development of emissions factors to meet data quality requirements; thus, we were able to close Rec. 3-2(e). We will
continue to monitor the Agency's actions regarding the findings and recommendations in our March 2006 Emissions
Factors report.
EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN MADE
The IG provided marked up Strategic Plan back to OAQPS. We are working final revisions based on their
recommendations. Expect resolution by November 2007. EPA continues to disagree with recommendation to commit
outyear funding to the emissions factors program, but will continue to appropriate balance resources and priorities in
the best interest of the EPA's mission.
DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION
Expect resolution by November 2007
IG Followup Status as of: 09/30/2007 [ 2 ]
Report No.: 2006-P-00025
Title: Mercury Hot Spots Analysis under CAMR
Issued: 05/11/2006
About 40 percent of U.S. man-made airborne mercury is emitted from coal-fired utilities. EPA adopted a nationwide
cap-and-trade program to reduce mercury emissions whereby utilities can buy and sell credits among one another in
a national emissions market. Utilities that cannot cost-effectively reduce emissions may buy allowances from units
that reduced emissions below established allowance limits. Several State agencies and environmental groups
objected to the cap-and-trade system. One concern was that a cap- and-trade program could result in localized areas
with unacceptably high levels of mercury, or "hotspots." Although the Agency concluded that the Clean Air Mercury
Rule (CAMR) will not result in "utility-attributable" hotspots, the OIG found in its evaluation that there were: gaps in
available data and science for mercury emissions estimates; limitations with the model used for predicting mercury
deposition; uncertainty over how mercury reacts in the atmosphere; and uncertainty over how mercury changes to a
more toxic form in waterbodies. Due to the uncertainties associated with the Agency's analysis of the potential for
mercury hotspots, the OIG recommended that the Acting Assistant Administrator for Air and Radiation work with the
Assistant Administrator for Research and Development to develop and implement a mercury monitoring plan,
including milestones and responsible program offices for implementing each component of the plan, to: (1) assess
the impact of CAMR, if adopted, on mercury deposition and fish tissue; and (2) evaluate and refine, as necessary,
mercury estimation tools and models.
EPA generally agreed with our report and provided a corrective action plan to the OIG in August 2006. After
assessing the Agency corrective action plan, the OIG kept the above recommendation open pending the receipt of
additional information from the Agency. The Agency responded to our request with additional information, but
indicated that it was unsure as to whether fish tissue sampling, specifically, would continue beyond 2008 due to
51
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budget limitations. Because data from fish tissue is necessary to monitor the impact of CAMR and the potential for
mercury hotspots, the OIG replied to the Agency in January 2007 that the recommendation would remain open. We
will review the final Agency budget to determine if a fish tissue sampling plan is a part of the EPA's activities for 2008.
Thus, a resolution to this recommendation is on hold while we await final Agency budget information.
EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN MADE
This report remains on hold by OIG due to issues beyond Agency control.
IG Followup Status as of: 09/30/2007 [ 0 ]
Office of Administration and Resources Management
Report No. :2007-P-00011
Title: Review of Interagency Contracts
Issued: 03/27/2007
The U.S. Government Accountability Office has designated management of interagency contracting a
govern me ntwide high-risk area since 2005. We sought to determine whether EPA effectively follows interagency
contracting requirements by ensuring products and services meet quality, cost, and timeliness requirements. We
also looked into whether opportunities exist to improve EPA's processes for managing interagency contracts.
We recommended that the Assistant Administrator for the Office of Administration and Resources Management:
(1) provide guidance to project officers for developing independent government cost estimates or other appropriate
cost information, as well as cost reasonableness assessments; (2) ensure that the Grants Administration Division
reviews cost reasonableness assessments prepared by program offices; (3) provide guidance to project officers for
identifying alternatives to the contracting vehicle selected; (4) strengthen the existing training to include how to
develop independent government cost estimates or other appropriate cost information, conducting cost
reasonableness assessments, and identifying alternatives; and (5) work with program officials to ensure that project
officer performance standards reflect their responsibilities for managing interagency contracts.
EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN MADE
Final corrective actions depend on the issuance of Office of Federal Procurement Policy guidance. While the
issuance of this guidance is beyond the Office of Grants and Debarment's (OGD's) control, we expect final action to
take place before July 2008.
IG Followup Status as of: 09/30/2007 [ 2 ]
Financial Analysis and Rate Negotiation Service Center
Report No.: 2004-1-00099
Title: Lockheed Martin Services Group - FYE 12/31/2002 Incurred Cost
Issued: 08/23/2004
The Defense Contract Audit Agency (DCAA) questioned indirect costs of $3,595,399 of which $2,128 is applicable to
EPA contracts. DCAA qualified the audit results pending receipt of assist audit reports. Audit on hold due to other
cognizant Federal Agency (DoD).
EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN MADE
Resolution on Hold
IG Followup Status as of: 09/30/2007 [ 0 ]
52
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Report No.: 2005-1-00171
Title: Advanced Technologies Systems, Inc. - FY 2003 Incurred Cost
Issued: 09/26/2005
DCAA questioned indirect costs for Fiscal Years 2001-2003.
• Applicable to Fiscal Year 2001: $13,904
• Applicable to Fiscal Year 2002: $6,891
• Applicable to Fiscal Year 2003: $13,928
Audit on hold due to other cognizant Federal Agency (DOE).
EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN MADE
Resolution on Hold
IG Followup Status as of: 09/30/2007 [ 0 ]
Report No.: 2006-4-00016
Title: Shaw Environmental & Infrastructure, Inc.-FY 2005 Billing Sys
Issued: 10/14/2005
The contractor's billing system and related internal control polices and procedures were considered inadequate in
part, resulting in a delay of the contract closeout process. Audit on hold due to other cognizant Federal Agency
(DoD).
EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN MADE
Resolution on Hold
IG Followup Status as of: 09/30/2007 [ 0 ]
Report No.: 2006-4-00046
Title: SAIC - FY 2004 Compensation System Review
Issued: 12/14/2005
In DCAA's opinion, the contractor's compensation system was inadequate. DCAA found deficiencies that may result
in unreasonable costs. Audit on hold due to other cognizant Federal Agency resolution (DoD).
EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN MADE
Resolution on Hold
IG Followup Status as of: 09/30/2007 [ 0 ]
Report No.: 2006-4-00094
Title: Computer Sciences Corporation - FY 2006 Floor Check
Issued: 04/18/2006
In DCAA's opinion, certain contractor labor practices require corrective action to improve the reliability of the
contractor's labor accounting system. Audit on hold due to other cognizant Federal Agency (DoD).
EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN MADE
Resolution on Hold
IG Followup Status as of: 09/30/2007 [ 0 ]
53
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Report No.: 2006-4-00100
Title: Black & Veatch SPC- FY 2005 MAAR 6 (Floor Check)
Issued: 05/08/2006
Based on DCAA's review, certain contractor labor practices require corrective action to improve the reliability of the
contractor's labor accounting system. DCAA also noted other matters involving the timekeeping system and related
internal controls which, although not considered to be significant deficiencies, are detailed in the report. Audit on hold
due to other cognizant Federal Agency (DoD).
EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN MADE
Resolution on Hold
IG Followup Status as of: 09/30/2007 [ 0 ]
Report No.: 2006-4-00120
Title: National Academy of Sciences - FY 2006 Info Tech System
Issued: 07/20/2006
DCAA determined that the contractor's Information Technology system general internal controls are inadequate in
part. Audit on hold due to other cognizant Federal Agency (ONR).
EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN MADE
Resolution on Hold
IG Followup Status as of: 09/30/2007 [ 0 ]
Report No.: 2006-4-00165
Title: National Academy of Sciences - FY 2006 Indirect/ODC System
Issued: 09/27/2006
In DCAA's opinion, the contractor service centers cost system and related internal control policies and procedures are
inadequate in part. DCAA's examination noted certain significant deficiencies in the design or operation of the
Indirect/Other Direct Costs system process. Audit on hold due to other cognizant Federal Agency.
EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN MADE
Resolution on Hold
IG Followup Status as of: 09/30/2007 [ 0 ]
Report No.: 2006-4-00169
Title: National Academy of Sciences - FY 2006 Labor System
Issued: 09/29/2006
In DCAA's opinion, the contractor's labor system and related internal control policies and procedures are inadequate
in part. DCAA's examination noted certain significant deficiencies in the design or operation of the internal control
structure. The assignment is on hold due to other cognizant Federal Agency.
EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN MADE
Resolution on Hold
IG Followup Status as of: 09/30/2007 [ 0 ]
54
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Report No.: 2007-4-00011
Title: National Academy of Sciences - FY 2006 Electronic Timekeeping System
Issued: 10/24/2006
DCAA determined that the contractor's Electronic Timekeeping System internal controls are inadequate in part. This
audit is on hold awaiting resolution by DoD, the cognizant agency.
EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN MADE
Resolution on Hold
IG Followup Status as of: 09/30/2007 [ 0 ]
Report No.: 2007-1-00016
Title: URS Corporation (c/o URS Greiner, Inc.) - FY 2001 Incurred Cost
Issued: 11/13/2006
DCAA questioned a total of $188,772,784 in direct and indirect costs. Of these, $5,585,929 are claimed direct costs,
of which $1,328,189 are from EPA Contract No. 68-W9-8225. The questioned indirect expenses, impacted all eight
fringe, overhead and G&A rates. Of the questioned indirect costs, EPA's share is $401,412, fora total of $1,729,601
in questioned direct and indirect costs. We note that the contractor did not agree with the questioned costs, so the
files provided by the contractor are not adjusted for the questioned costs. This audit is on hold awaiting resolution of
the questioned costs by DOD, the cognizant agency.
EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN MADE
Resolution on Hold
IG Followup Status as of: 09/30/2007 [ 0 ]
Report No.: 2007-4-00038
Title: Weston Solutions - FY 2006 Floor Checks
Issued: 01/08/2007
DCAA expressed no opinion on the adequacy of the contractor's labor accounting system taken as a whole, as it had
determined that certain labor practices required corrective action to improve the reliability of the labor accounting
system. The conditions are detailed in the "Statement of Conditions and Recommendations" section of the report.
This audit will be held open pending the results of the followup audit in 6 months.
EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN MADE
Resolution on Hold
IG Followup Status as of: 09/30/2007 [ 0 ]
Report No.: 2007-1-00036
Title: Parsons Infrastructure & Technology - FYE 12/31/2004 I/C
Issued: 01/25/2007
In DCAA's opinion, the direct costs for EPA contracts are acceptable, however, DCAA questioned the overhead and
G&A indirect rate. DCAA questioned direct costs but EPA contracts were not affected. Total questioned costs were
5,867,739, however EPA's portion is $9,975 or .17%. On hold pending resolution from DOD.
EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN MADE
Resolution on Hold
IG Followup Status as of: 09/30/2007 [ 0 ]
55
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Grants Administration Division (now Grants and Interagency Agreements Management Division)
Report No.: 2002-2-00008
Title: MBI International Assistance Agreement
Issued: 01/29/2002
MBI did not have adequate justification to support the award of sole source contracts. Also, MBI's procurement
practices did not meet Federal requirements. As a result, $1,301,365, consisting of $1,201,857 in contract costs and
$99,508 in consultant costs, is not eligible for Federal reimbursement. Further, there were apparent conflicts of
interest between MBI, its subsidiary (CRT), and companies created by CRT.
EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN MADE
OGD is developing an action plan to address complex issues for the recipient, and expects the Final Determination
Letter (FDL) in January 2008.
DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION
Expect resolution by January 2008
IG Followup Status as of: 09/30/2007 [ 5 ]
Report No.: 2003-S-00001
Title: Region 7 Grants Proactive
Issued: 05/29/2002
We questioned over $2 million because the Coordinating Committee on Automotive Repair (CCAR) did not account
for the funds in accordance with Federal rules, regulations, and terms of the agreement.
EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN MADE
OIG questioned all costs claimed ($2,026,837) on three projects between 1995-2001. CCAR has submitted the
required indirect cost rate information for the audit period and has provided documentation that its financial
management system and time distribution system meet the requirements of EPA's assistance regulations and Office
of Management and Budget Circular A-122. However, reconstructed accounting records CCAR submitted in
December 2005 for Fiscal Years 1996 and 1997 do not substantiate the costs they charged to the project. EPA
requested additional information to substantiate the costs, but CCAR has not responded. EPA will follow up with
CCAR and issue the final determination disallowing costs by November 2007.
DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION
Expect resolution by November 2007
IG Followup Status as of: 09/30/2007 [ 2 ]
Report No.: 2003-3-00113
Title: American Indian Science & Engineering Society 1999-2001
Issued: 04/23/2003
Costs were not approved or were not supported. Questioned costs totaled $104,760.
EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN MADE
There are three reports under review for the years 1999-2000. The report includes findings of inadequate internal
controls and questioned costs totaling $163,125. The report has been reviewed and the recipient's responses to the
findings are being reviewed. The response submitted indicates that procedures have been implemented and the
conditions no longer exist. However, GAD has received the audit report for audit period 2002. Although the report
does not question any costs, it indicates some of the pre-existing internal control issues still exist. GAD is working on
determining appropriate resolution and recommendations to resolve the findings. Final determination is expected
October 2007.
DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION
Expect resolution by October 2007
IG Followup Status as of: 09/30/2007 [ 5 ]
56
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Report No.: 2003-3-00114
Title: American Indian Science & Engineering Society 1999-2001
Issued: 04/23/2003
Cost were not approved and not properly supported. Questioned costs totaled $58,365.
EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN MADE
There are three reports under review for the years 1999-2000. The report includes findings of inadequate internal
controls and questioned costs totaling $163,125. The report has been reviewed and the recipient's responses to the
findings are being reviewed. The response submitted indicates that procedures have been implemented and the
conditions no longer exist. However, GAD has received the audit report for audit period 2002. Although the report
does not question any costs, it indicates some of the pre-existing internal control issues still exist. GAD is working on
determining appropriate resolution and recommendations to resolve the findings. Final determination is expected
October 2007.
DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION
Expect resolution by October 2007
IG Followup Status as of: 09/30/2007 [ 5 ]
Report No.: 2003-3-00121
Title: Assoc of State & Interstate Water Pol. Control Ags FY 2001
Issued: 05/07/2003
Grantee drew down $93,986 in excess of expenditures for three EPA programs.
EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN MADE
EPA is working on determining appropriate resolution and recommendations to resolve the findings. Final
determination is expected December 2007.
IG Followup Status as of: 09/30/2007 [ 5 ]
Report No.: 2003-4-00120
Title: Geothermal Heat Pump Consortium, Inc. - Costs Claimed
Issued: 09/30/2003
Questioned $1,153,472 due to material financial management deficiencies. The Consortium's financial management
system was inadequate in that the Consortium did not:(1) separately identify and accumulate costs for all direct
activities, such as membership support and lobbying; (2) account for program income generated by the activities
funded by the EPA agreements; (3) prepare or negotiate indirect cost rates; (4) prepare written procedures for
allocating costs to final cost objectives; (5) maintain an adequate labor distribution system; and (6) provide adequate
support for direct cost allocations. The Consortium also did not (1) competitively procure contractual services or
perform any of the required cost and price analyses; and (2) comply with all report requirements.
EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN MADE
OGD is reviewing the financial statements and the lobbying disclosure statements to identify allowable costs. The
Grants Specialist and new Branch Chief are working to resolve the issues of this audit.
DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION
Resolution is expected by January 2008
IG Followup Status as of: 09/30/2007 [ ]
Report No.: 2004-4-00014
Title: Consumer Federation of America Foundation -Costs Claimed
Issued: 03/01/2004
EPA awarded the cooperative agreements to the Consumer Federation of America Foundation based on applications
that showed labor and other operating costs. The Foundation did not have any employees, space, or overhead
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expenses. Instead, the Consumer Federation of America, an ineligible lobbying organization performed the work.
Also, the recipient did not manage the funds according to Federal regulations. As a result, we questioned over
$4 million.
EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN MADE
OGD has requested revised information from the recipient regarding some contracts. Waiting on the information and
OGD expects the FDL in November 2007.
DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION
Expect resolution by November 2007
IG Followup Status as of: 09/30/2007 [ 2 ]
Report No.: 2005-3-00036
Title: National Indian Health Board, FY 2002
Issued: 12/30/2004
The Board was allocating salary costs to grants based on pre-determined formulas. No support, in the form of time
sheets, was located for those allocations. Also, amounts charged to various grants were not always supported by
original documentation. Therefore, we questioned $31,960 as unsupported.
EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN MADE
Due to audit workload, audit resolution has been reassigned. GAD expects FDL December 2007.
DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION
Expect resolution by December 2007
IG Followup Status as of: 09/30/2007 [ ]
Report No.: 2005-3-00148
Title: American Registry of Pathology FY 2002
Issued: 04/06/2005
DCAA performed an incurred cost audit of the Research and Development Federal Cluster and questioned $356,574,
which it deemed to be unallowable, relating to direct and indirect costs. DCAA did not identify the amount applicable
to EPA funding. Recipient did not have specific controls in place to determine that vendors were not suspended or
debarred by the Federal Government.
EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN MADE
OGD has new management staff and a new specialist working on this audit. OGD expects resolution in January
2008.
DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION
Expect resolution by January 2008
IG Followup Status as of: 09/30/2007 [ ]
Report No.: 2005-3-00217
Title: American Indian Science and Engineering Society-FY 2002
Issued: 08/30/2005
The Society held $19,289 in deferred revenue for EPA grant, Surveys, Studies, Investigations, and Special Purpose.
EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN MADE
There are three reports under review for the years 1999-2000. The report includes findings of inadequate internal
controls and questioned costs totaling $163,125. The report has been reviewed and the recipient's responses to the
findings are being reviewed. Although the report does not question any costs, it indicates some of the pre-existing
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internal control issues still exist. GAD is working on determining appropriate resolution and recommendations to
resolve the findings. Final determination is expected December 2007.
DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION
Expect resolution by December 2007
IG Followup Status as of: 09/30/2007 [ ]
Report No.: 2005-3-00226
Title: Assoc State/Interstate Water Pollution Control Admin, FY 2002
Issued: 09/12/2005
Recording of grant expenditures was not done accurately or on a timely basis during the year. The recording of
fringe benefits related to direct grant salaries and wages and the recording of indirect costs associated with total
direct grant costs were not done monthly. In addition, direct salaries and wages were incorrectly recorded to the NPS
grant after the grant period expired. An adjustment was made to properly record these costs to the integrated grant.
Because the grants have expired, costs totaling $11,276 are being questioned due to over-requesting funds in excess
of supported costs.
EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN MADE
EPA is working on determining appropriate resolution and recommendations to resolve the findings. Final
determination is expected December 2007.
IG Followup Status as of: 09/30/2007 [ 5 ]
Report No.: 2006-3-00006
Title: Alfred University, FY 2004
Issued: 10/13/2005
The University's current accounting system provides certified payroll information on an individual grant basis.
However, the payroll distribution system does not provide a proportionate break down of each employee's total time
between each sponsored program he/she may be working on and other non-sponsored activities. The auditor
questioned costs of $649,506, but could not determine the direct impact upon EPA's program.
EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN MADE
OGD requested additional information from Alfred University. OGD is now working with University to obtain financial
paperwork on second audit (2007-3-00037) which contained the same findings as this audit. GAD expects FDL in
December 2007.
DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION
Expect resolution by December 2007.
IG Followup Status as of: 09/30/2007 [ ]
Report No.: 2006-3-00111
Title: National Tribal Environmental Council, Inc. FY 2003
Issued: 05/15/2006
The Council did not prepare or submit its Quarterly Financial Status Reports (FSR 269) to EPA.
EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN MADE
OGD has a new management staff. OGD expects FDL on October 31, 2007.
DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION
Expect resolution by October 2007
IG Followup Status as of: 09/30/2007 [ ]
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Report No.: 2006-4-00122
Title: AA - ASIWPCA
Issued: 07/31/2006
The Association did not comply with the financial and program management standards and the procurement
standards promulgated in Title 40 Code of Federal Regulations, Subchapter B, Part 30. The Association (1) could
not provide support for any of its general journal entries; (2) included duplicate recorded costs in its accounting
system; (3) could not always trace grant draws to the accounting records; (4) could not always support labor charged
to the EPA grants; (5) could not support the recorded indirect costs; (6) did not record all of its program income; (7)
did not have adequate written procedures for determining reasonable, allocable, and allowable costs; (8) drew EPA
grant funds in excess of the funds needed; and (9) did not complete the required single audits for fiscal years ended
June 30, 2004, and June 30, 2005. As a result, we questioned as unsupported a total of $1,883,590 in EPA grant
payments for seven grants.
EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN MADE
GAD is awaiting the finalization of the pre-award certification. At that time, GAD will develop a course of action to
universally resolve all of the audits for ASIWPCA. The final determination letter is expected before December 31,
2007.
DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION
Expect resolution by December 2007.
IG Followup Status as of: 09/30/2007 [ ]
Report No.: 2006-3-00199
Title: Howard University, FY 2005
Issued: 09/07/2006
The University had numerous program non-compliances related to timekeeping, funds matching, sub-recipient
monitoring, financial reporting and equipment disposal.
EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN MADE
Due to staff changes at Howard University, OGD is still waiting for the recipient to provide additional documentation.
OGD expects the FDL in December 2007.
DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION
Expect resolution by December 2007
IG Followup Status as of: 09/30/2007 [ ]
Report No.: 2006-3-00201
Title: American Water Works Association FY 2004
Issued: 09/13/2006
The Association did not comply with its existing procurement policies and procedures. There were two instances
where the Association could not produce adequate procurement records in accordance with Office of Management
and Budget Circular A-110.
EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN MADE
OGD is working with the recipient to resolve the procurement procedures. Resolution is expected in January 2008.
DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION
Expect resolution by January 2008
IG Followup Status as of: 09/30/2007 [ ]
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Report No.: 2007-4-00026
Title: AA - International City County Management Association
Issued: 11/28/2006
Questioned costs due to (a) lack of competition for contracts, (b) lack of oversight for sub-awards, (c) lack of
documentation on sub-grants, and (d) illegal indirect costs.
EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN MADE
OGD has prepared a draft FDL and is working with the OIG regarding the questioned cost. The final FDL is expected
in November 2007.
DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION
Expect Resolution by November 2007
IG Followup Status as of: 09/30/2007 [ ]
Report No.: 2007-4-00027
Title: AA - National Rural Water Association - Congressional
Issued: 11/30/2006
The Association's method of allocating indirect costs over total direct costs is contrary to the requirements of the
Office of Management and Budget Circular A-122. Currently, the Association does not exclude subcontracts or
subawards from its indirect cost allocation base. As a result, the EPA grants are bearing a disproportionate amount
of indirect costs. For the period from March 1, 1999, to February 29, 2004, EPA grants may have been over-
allocated by $2,021,821 in indirect costs. The exact amount of the indirect over-allocation will be determined during
negotiation of the indirect cost rate.
EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN MADE
OGD is working with the recipient to resolve the indirect cost issue and the recipient is preparing documentation to
support the sub-contract awards. OGD expects the FDL in December 2007.
DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION
Expect resolution by December 2007
IG Followup Status as of: 09/30/2007 [ ]
Report No.: 2007-3-00035
Title: National Environmental Health Association - FY 2004
Issued: 12/05/2006
The Association did not establish procedures to ensure that indirect costs were charged to grants in accordance with
the indirect cost plan and applicable regulations. Specifically, the Association accumulated "overhead costs" and
allocated these costs to the functions of the organizations including Federal grants, and also charged indirect costs to
grants based on the indirect cost rate. This could result in a duplication of overhead charges to certain programs. In
addition, the Association did not appear to follow a consistent methodology to allocate these costs. The Association
had several grant awards that did not coincide directly with the Association's fiscal year-end. Therefore, the grants
covered multiple fiscal years. The Association had not established procedures to ensure that grant accounting
provided information necessary to report results for the grant period, as well as the Association's fiscal year. In
addition, grant reports were not typically prepared from accounting records.
EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN MADE
OGD is working with the recipient to resolve the recipient to resolve the indirect cost issues. Expect the FDL in
January 2008.
DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION
Expect resolution by January 2008
IG Followup Status as of: 09/30/2007 [ ]
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Report No: 2007-3-00037
Title: Alfred University - FY 2005
Issued: 12/11/2006
The University's current system provided certified payroll information on an individual grant basis. However, the
payroll distribution system did not provide a proportionate breakdown of each employee's total time between each
sponsored program he or she may be working on and other non-sponsored activities. The auditor questioned costs
of $856,419, but could not determine the direct impact upon EPA's program.
EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN MADE
OGD combined two audits together to process FDL. OGD is now working with the University to obtain financial
paperwork on the current findings in both audits. GAD expects FDL in December 2007.
DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION
Expect resolution by December 2007
IG Followup Status as of: 09/30/2007 [ ]
Headquarters Procurement Operations Division
Report No.: 2007-2-00013
Title: IBM Business Consulting Services - Preaward - PR-HQ-05-1251
Issued: 12/21/2006
In DCAA's opinion, the cost or pricing data submitted by the offerer are inadequate in part. DCAA questioned
$13 million of the proposed direct labor, ODCs and subcontract costs.
EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN MADE
Resolution on hold. The contract was awarded in the first quarter of FY 2007 but EPA received a protest. The
Government Accountability Office will determine whether to sustain or deny the protest. Therefore, an expected
resolution date cannot be determined.
IG Followup Status as of: 09/30/2007 [ 0 ]
Office of Environmental Information
Report No.: 2006-P-00036
Title: Evaluation of Drinking Water Laboratory Procedures
Issued: 09/21/2006
Within the drinking water sample analysis process we identified hundreds of vulnerabilities that are not addressed by
EPA's process. These vulnerabilities can compromise the integrity of the analysis process and the quality of data
produced. Many of these vulnerabilities were identified by the OIG in 1999 and the Agency's own review in 2002,
with no action by the Agency. Moreover, States that have implemented new techniques to detect laboratory integrity
problems have found additional deficiencies, inappropriate procedures, and even cases of fraud. Their findings and
those of our own investigators show integrity can be, and has been, compromised. However, without any national
studies of water quality data that include examining the integrity of laboratories, the full extent of the problem remains
unassessed. Through our work with States, laboratory organizations, and other Federal agencies, we identified
promising techniques to help improve oversight and protect against inappropriate procedures and fraud in the
drinking water analysis process.
EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN MADE
OIG attended a meeting of the Quality and Information Council Steering Committee (QIC SC) on March 15, 2007.
The purpose was for OEI and the QIC SC to obtain a better understanding of the OIG's concerns and to inform the
OIG of the function and processes of the QIC SC in information policy development. At the conclusion of the
meeting, the QIC SC Chair suggested that the OIG attend future QIC SC meetings to provide ongoing dialogue
among the OIG, OEI, and other Agency offices via the QIC SC to resolve this issue. OEI is attempting to resolve this
issue by December 2007
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DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION
Expect resolution by December 2007
IG Followup Status as of: 09/30/2007 [ 1 ]
Office of Water
Report No.: 2007-P-00012
Title: AA-SRF Policy Review
Issued: 03/28/2007
EPA regulations and policies allowing States to use bonds repaid from State Revolving Fund (SRF) interest to meet
SRF match requirements are resulting in fewer dollars being available for water projects. Twenty States have used
the Clean Water SRF to repay bonds issued to meet the required fund match, and 16 of those States also did so for
the Drinking Water SRF. Current practices have resulted in an estimated $937 million less available for loans since
the inception of the SRF programs.
EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN MADE
Office of Water remains in disagreement with OIG's recommendation relating to the SRF State bond issue as of
August 18, 2007. Office of Water is awaiting OIG's final decision as to whether this matter will be referred to the Audit
Resolution Board for resolution.
DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION
Resolution cannot be determined at this time.
IG Followup Status as of: 09/30/2007 [ 6 ]
Region 1 - Regional Administrator
Report No.: 2007-1-00037
Title: SRF-New Hampshire 2005 Clean Water Audits
Issued: 02/05/2007
We issued an unqualified opinion on the financial statements but identified significant weaknesses in internal controls.
We qualified our opinion on compliance with applicable laws and regulations because the State did not comply with
the subrecipient monitoring requirements forfollowup on subrecipient Single Audits.
EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN MADE
Letter to Commissioner on June 6, 2007, 4 out of 5 issues acceptable responses from New Hampshire DES.
Subrecipient monitoring issue not resolved. Region 1 OEP forwarded HQ Office of Water subrecipient guidance
document dated August 13, 2007, to New Hampshire DES for review and action. Next step is for New Hampshire
DES to develop plan to comply with subrecipinet monitoring guidance. Closeout revised target February 2008.
DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION
Expected resolution by February 2008
IG Followup Status as of: 09/30/2007 [ 2 ]
Report No.: 2007-1-00044
Title: SRF-New Hampshire 2005 Drinking Water Audit
Issued: 02/26/2007
We rendered an unqualified opinion on the New Hampshire Drinking Water SRF Program financial statements for the
year ended June 30, 2005. We noted various reportable conditions that we considered material weaknesses in
internal controls. We qualified our opinion on compliance with applicable laws and regulations because the required
State match was underfunded by $228,436, set-aside costs were not separated and identifiable by the actual costs,
and the State did not follow up on subrecipient Single Audits.
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EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN MADE
Letter to Commissioner on June 6, 2007, 6 out of 7 issues acceptable responses from New Hampshire DES.
Subrecipient monitoring issue not resolved. Region 1 OEP forwarded HQ Office of Water subrecipient guidance
document dated August 13, 2007, to New Hampshire DES for review and action. Next step is for New Hampshire
DES) to develop plan to comply with subrecipient monitoring guidance. Closeout revised target February 2008.
DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION
Expected resolution by Februrary 2008
IG Followup Status as of: 09/30/2007 [ 2 ]
Region 2 - Office of Policy and Management
Report No.: 2005-3-00157
Title: Puerto Rico Environmental Quality Board (PREQB) - FY 2000
Issued: 05/05/2005
Due to the costs questioned in specific findings and lack of accounting records, we questioned all costs, totaling
$4,239,228. Region 2 has designated the grantee as "high risk" and implemented a corrective action plan to get the
grantee into compliance.
EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN MADE
PREQB is under a new workplan which has replaced the Corrective Action Plan. CPA review and certification of
costs from FY 1999-2001 is complete and grantee currently awaits CPA report. Completion of this audit resolution is
expected by December 31, 2007.
DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION
Expect resolution by December 2007
IG Follow-up Status as of: 09/30/2007 [ ]
Report No.: 2005-3-00158
Title: Puerto Rico Environmental Quality Board - FY 2001
Issued: 05/05/2005
Due to costs questioned in specific findings and lack of accounting records, we questioned all costs, totaling
$4,631,636. Region 2 has designated the grantee as "high risk" and implemented a corrective action plan to get the
grantee into compliance.
EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN MADE
PREQB is under a new workplan which has replaced the Corrective Action Plan. CPA review and certification of
costs from FY 1999-2001 is complete and grantee currently awaits CPA report. Completion of this audit resolution is
expected by December 31,2007.
DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION
Expected resolution by December 2007
IG Follow-up Status as of: 09/30/2007 [ ]
Report No.: 2005-3-00159
Title: Puerto Rico Environmental Quality Board - FY 2002
Issued: 05/05/2005
Due to costs questioned in specific findings and lack of accounting records, we questioned all costs, totaling
$2,987,768. Region 2 has designated the grantee as "high risk" and implemented a corrective action plan to get the
grantee into compliance.
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EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN MADE
PREQB is under a new workplan which has replaced the Corrective Action Plan. Among the items directly impacting
resolution of the audits are the indirect cost rates. PREQB has received final rates through FY 2005, and will use
those rates to request reimbursement of indirect costs for affected years, and prepare Financial Status Reports for
affected grants. There has been corrective action with many of the non-cost findings in these audits, and for those
costs from 2002 forward that have been CPA reviewed and certified, the disallowed costs are minimal. The overall
workplan, however, seems far from complete. We expect to possibly issue resolution letters on these audits by
3/31/08.
DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION
Expect resolution by March 2008
IG Follow-up Status as of: 09/30/2007 [ ]
Report No.: 2005-3-00156
Title: Puerto Rico Environmental Quality Board - FY 1999
Issued: 05/05/2005
Due to costs questioned in specific findings and lack of accounting records, we are questioned all costs, totaling
$5,503,986. Region 2 has designated the grantee as "high risk" and implemented a corrective action plan to get the
grantee into compliance.
EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN MADE
PREQB is under a new workplan which has replaced the Corrective Action Plan. CPA review and certification of
costs from FY 1999-2001 is complete and grantee currently awaits CPA report. Completion of this audit resolution is
expected by December 31, 2007.
DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION
Expect resolution by December 2007
IG Followup Status as of: 09/30/2007 [ ]
Report No.: 2005- 3 - 00168
Title: Puerto Rico Environmental Quality Board - FY 2003
Issued: 05/05/2005
Because Puerto Rico's accounting records were inadequate, we questioned all expenditures, totaling $3,313,010.
Region 2 has designated the grantee as "high risk" and implemented a corrective action plan to get the grantee into
compliance.
EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN MADE
PREQB is under a new workplan which has replaced the Corrective Action Plan. Among the items directly impacting
resolution of the audits are the indirect cost rates. PREQB has received final rates through FY05, and will use those
rates to request reimbursement of indirect costs for affected years, and prepare Financial Status Reports (for affected
grants. There has been corrective action with many of the non-cost findings in these audits, and for those costs from
2002 forward that have been CPA reviewed and certified, the disallowed costs are minimal. The overall workplan,
however, seems far from complete. We expect to possibly issue resolution letters on these audits by 3/31/08.
DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION
Expect resolution by March 2008
IG Followup Status as of: 09/30/2007 [ ]
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Report No.: 2005-3-00199
Title: Puerto Rico Water Pollution Control Revolving Fund
Issued: 06/27/2005
The Fund's administrative expenses of $184,646 were not reviewed and certified by an independent public
accounting firm recognized by EPA. Region 2 has implemented a corrective action plan to get the grantee into
compliance.
EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN MADE
CPA review of grantee costs has been completed and grantee is awaiting report. This audit is estimated to be
resolved by December 31, 2007.
DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION
Expect resolution by December 2007
IG Followup Status as of: 09/30/2007 [ ]
Report No.: 2006-3-00068
Title: Caribbean Environmental & Development Institute FY 1999
Issued: 02/22/2006
Accounting records did not comply with EPA regulations, property and equipment lists were not updated, financial
information did not agree with general ledgers, left-over cash from prior grants was used to fund current grants, and
monies received from EPA exceeded amount claimed as expenditures by $152,027.
EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN MADE
The CPA review of documentation is underway and is expected to be complete on or about 9/25/07. After receipt of
the CPA report, Region 2 will prepare audit resolutions, which are expected to be completed by 12/31/07.
DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION
Expect resolution by December 2007
IG Followup Status as of: 09/30/2007 [ ]
Report No.: 2006-3-00069
Title: Caribbean Environment & Development Institute FY 2000
Issued: 02/22/2006
Accounting records did not provide information in compliance with EPA regulations, property and equipment lists
were not updated, Financial Status Reports could not be reconciled to general ledgers, cash from expired grants was
used to pay current expenditures, and the Institute received $68,467 in monies from EPA in excess of their claimed
expenditures.
EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN MADE
The CPA review of documentation is underway and is expected to be complete on or about 9/25/07. After receipt of
the CPA report, Region 2 will prepare audit resolutions, which are expected to be completed by 12/31/07.
DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION
Expect resolution by December 2007
IG Followup Status as of: 09/30/2007 [ ]
Report No.: 2006-3-00164
Title: Puerto Rico, Commonwealth of, EQB - FY 2004
Issued: 07/20/2006
The grantee's fiscal control and accounting procedures were not adequate to provide the financial information
necessary for the efficient administration of the entity's operation. The grantee did not: (1) complete the physical
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inventory of the property and equipment; (2) maintain an adequate numerical sequence in the subsidiary of property
and equipment; and (3) include certain additions of property and equipment in the property and equipment listing
which were acquired with the Air Pollution Control program funds. The grantee did not submit numerous financial
and performance reports under various EPA grants in a timely manner. The auditors noted significant differences
between the amounts reported in the Schedule of Expenditures of Federal Awards, the grantee's internal accounting
records and the transactions recorded in the reports issued by the Puerto Rico Treasury Department.
EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN MADE
PREQB is under a new workplan which has replaced the Corrective Action Plan. Among the items directly impacting
resolution of the audits are the indirect cost rates. PREQB has received final rates through FY 2005, and will use
those rates to request reimbursement of indirect costs for affected years, and prepare Financial Status Reports for
affected grants. There has been corrective action with many of the non-cost findings in these audits, and for those
costs from 2002 forward that have been CPA reviewed and certified, the disallowed costs are minimal. The overall
workplan, however, seems far from complete. We expect to possibly issue resolution letters on these audits by
3/31/08.
DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION
Expect resolution by March 2008
IG Follow-up Status as of: 09/30/2007 [ ]
Region 4 - Office of Policy Management
Report No.: 2007-3-00016
Title: Roswell, City of FY 2004
Issued: 10/24/2006
The City drew EPA funds for reimbursement prior to actually paying for related grant expenses, in violation of Title 40
Code of Federal Regulations Part 31.
EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN MADE
Region 4 Action Official has prepared and submitted the Final Determination Letter to the OIG. Expect resolution
October 2007.
DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION
Expect resolution by October 2007
IG Followup Status as of: 09/30/2007 [ ]
Region 8 - Regional Administrator
Report No.: 2007-3-00003
Title: Blackfeet Tribe of the Blackfeet Indian Reservation, FY2004
Issued: 10/02/2006
The fixed asset records did not support the amounts reported on the financial statements. The auditor noted that
salary advances were increasing substantially each year, and the Tribe was not enforcing the policies and
procedures on the use of advances, repayments of advances and is not approving all advances before payment is
made. There was a severe deficiency noted during internal control testing. Time cards were being accepted without
employee signatures or the supervisor's signature for authorization of work done during the time period, W-4's were
missing, and current pay rates did not agree with the personnel file. A physical inventory of the Tribe's assets had not
been taken and reconciled with underlying property records and the general ledger. The Tribe did not have the
resources available to fund the deferred revenue amount reported on the statement of net assets. Six purchases did
not have supporting documentation. The total amount of transactions not in compliance was $6,596. The Tribe
loaned and expended a portion of the Tribal Worker's Compensation Program reserves.
EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN MADE
The Tribe responded in January 2007, with a response to one out of the seven findings for which we requested a
corrective action plan. We have requested a copy of the corrective action plan submitted to their cognizant agency
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(HHS). We have also requested a copy of the corrective action plan directly from HHS and expect to discuss with
them in October 2007. We expect resolution by November 2007.
DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION
Expect resolution by November 2007
IG Followup Status as of: 09/30/2007 [ ]
Region 8 - Office of Technical & Management Services
Report No.: 2007-3-00028
Title: Three Affiliated Tribes - FY 2004
Issued: 11/20/2006
Several general ledger accounts, including bank accounts, were not reconciled to the supporting documentation until
significantly after year-end. The Tribes did not have a system in place to identify those individuals whose personnel
costs were allocated to more than one award or cost activity and to ensure that the requirements were satisfied. The
Tribes did not update and submit revised financial reports to the awarding agencies. Significant variances were
noted between the submitted reports and the information per the Tribe's general ledger. Employees were using
General Services Administration vehicles and charged a flat mileage rate for reimbursement under its grants;
however, fuel purchases were already charged through various programs, resulting in duplicate charging of fuel
costs.
EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN MADE
Three letters have been sent to Tribes requesting written resolutions to audit findings. A verbal request has recently
been made with the Tribes to get a written resolution to audit findings. Expect resolution by June 30, 2008.
DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION
Expect resolution by June 2008
IG Followup Status as of: 09/30/2007 [ ]
Region 9 - Regional Administrator
Report No.: 2007-3-00072
Title: lone Band of Miwok Indians, FY 2003
Issued: 03/08/2007
The Band did not comply with the principles of fund accounting because a self-balancing set of accounts had not
been maintained for each of the Band's activities. Furthermore, the Band's general ledger was incomplete and only
included the cash disbursement transactions for the year. As a result, a general ledger and working trial balance had
to be constructed during the audit. Detailed records maintained for all capital assets were incomplete and did not
agree to the balances reported in the general ledger.
EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN MADE
The Region asked the tribe for additional documentation to verify eligible costs. The FDL is targeted for 10/30/07.
DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION
Expect resolution by October 2007
IG Followup Status as of: 09/30/2007 [ ]
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Region 9 - Policy & Management Division
Report No.: 2007-3-00008
Title: Havasupai Tribe - FY 2004
Issued: 10/10/2006
The Tribe did not procure goods and services for these grants in conformity with the requirements stated in the Office
of Management and Budget Common Rule, which requires that grantees follow their own procurement procedures if
they are consistent with Federal guidelines. Although the Tribe has procurement policies that are consistent with
Federal policies, they were not followed in procuring goods and services under the grant. Furthermore, there was no
evidence of the rational for the procurement method used, cost or price analysis, or basis for vendor selection.
EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN MADE
The recipient's response indicates completion of the corrective actions associated with the findings. The Region
requested verification so that an FDL can be written based on the tribe's responses. We are in the process of
verifying their successful completion. FDL is targeted no later than 10/30/07.
DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION
Expect resolution by October 2007
IG Followup Status as of: 09/30/2007 [ ]
Report No.: 2007-3-00007
Title: Havasupai Tribe - FY 2003
Issued: 10/10/2006
The Tribe did not maintain detailed property records for fixed assets purchased with Federal financial assistance.
Fixed assets were not inventoried on a biennial basis. The Tribe did not have current and complete policies and
procedures for accounting, procurement, personnel and programmatic compliance. The Tribe did not procure goods
and services for its EPA grant in conformity with the requirements stated in the Office of Management and Budget
Common rule, which requires that grantees follow their own procurement procedures if they are consistent with
Federal guidelines. Although the Tribe had procurement policies that are consistent with Federal policies, the Tribe
did not follow its policies when procuring goods and services under the grant. Furthermore, there was no evidence of
the rationale for the procurement method used, cost or price analysis, or basis for vendor selection. Financial status
reports were not filed, or were not timely filed for most of the Federal programs of the Tribe. During 2003, the
monitoring of the reporting for federal programs was improved; however, there were several reports that were not
filed as required.
EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN MADE
The recipient's response indicates completion of the corrective actions associated with the findings. The Region
requested verification so that an FDL can be written based on the tribes' responses. We are in the process of
verifying their successful completion. FDL is targeted no later than 10/30/07.
DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION
Expect resolution by October 2007
IG Followup Status as of: 09/30/2007 [ ]
Report No.: 2007-3-00047
Title: Cahto Tribe of the Laytonville Rancheria, FY 2004
Issued: 01/08/2007
The Tribe could not locate or obtain a copy of its quarterly performance and financial status reports, due to EPA, for
several quarters. Also, the Tribe was unable to complete and submit its annual Single audits in a timely manner.
During audit testing of general disbursements the auditor noted: (a) many supporting documents missing; (b)
documentation misfiled; (c) checks written for expenses that could not be supported by original vendor invoices; (d)
voucher covers not used to support approval of purchases; and (e) Federal procurement policies not followed. The
Tribe's property records were incomplete, and were not consistently updated when new assets were purchased,
causing the fixed assets to be materially misstated at December 31, 2004. Also, a complete inventory of property
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and equipment had not been completed and reconciled to the property records in the required 2-year period. The
Tribe submitted its FY 2003 Indirect Cost Proposal during the fourth quarter of 2004. Also, the Tribe did not submit a
proposal for FY 2004, instead requesting that the previously approved rate be carried forward until submissions could
be made.
EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN MADE
The recipient's response indicates completion of the corrective actions associated with the findings. The Region
requested verification so that an FDL can be written based on the tribes' responses. FDL is targeted no later than
10/30/07.
DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION
Expect resolution by October 2007
IG Followup Status as of: 09/30/2007 [ ]
Total reports issued for which no management decision has been made as of 9/30/2007: 59
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OIG Mailing Addresses and Telephone Numbers
Headquarters
U.S. Environmental Protection Agency
Office of Inspector General
1200 Pennsylvania Ave., NW (2410T)
Washington, DC 20460
(202) 566-0847
OIG Public Liaison Hotline
Address
U.S. Environmental Protection Agency
Office of Inspector General Hotline
1200 Pennsylvania Ave., NW (2491T)
Washington, DC 20460
Fax
202-566-2549
Email
OIG Hotlinefajepa.gov
Atlanta
U.S. Environmental Protection Agency
Office of Inspector General
61 Forsyth Street, SW
Atlanta, GA 30303
Audit: (404) 562-9830
Investigations: (404) 562-9857
Boston
U.S. Environmental Protection Agency
Office of Inspector General
One Congress Street, Suite 1100
Boston, MA 02114-2023
Audit: (617) 918-1470
Investigations: (617) 918-1468
Chicago
U.S. Environmental Protection Agency
Office of Inspector General
77 West Jackson Boulevard
13th Floor (IA-13 J)
Chicago, IL 60604
Audit: (312) 353-2486
Investigations: (312) 353-2507
Cincinnati
U.S. Environmental Protection Agency
Office of Inspector General
26 West Martin Luther King Drive
Cincinnati, OH 45268-7001
Audit: (513) 487-2360
Investigations: (513)487-2364
Dallas
U.S. Environmental Protection Agency
Office of Inspector General (6OIG)
1445 Ross Avenue, Suite 1200
Dallas, TX 75202-2733
Audit: (214) 665-6621
Investigations: (214)665-2790
Offices
Denver
U.S. Environmental Protection Agency
Office of Inspector General
1595 Wynkoop Street - 4th Floor
Denver, CO 80202
Audit: (303) 312-6872
Investigations: (303) 312-6868
Kansas City
U.S. Environmental Protection Agency
Office of Inspector General
901 N. 5th Street
Kansas City, KS 66101
Audit: (913) 551-7878
Investigations: (913) 551-7875
New York
U.S. Environmental Protection Agency
Office of Inspector General
290 Broadway, Room 1520
New York, NY 10007
Audit: (212) 637-3080
Investigations: (212)637-3041
Philadelphia
U.S. Environmental Protection Agency
Office of Inspector General
1650 Arch Street, 3rd Floor
Philadelphia, PA 19103-2029
Audit: (215) 814-5800
Investigations: (215) 814-5820
Research Triangle Park
U.S. Environmental Protection Agency
Office of Inspector General
Mail Drop N283-01
Research Triangle Park, NC 27711
Audit: (919) 541-2204
Investigations: (919) 541-1027
San Francisco
U.S. Environmental Protection Agency
Office of Inspector General
75 Hawthorne St. (IGA-1)
7th Floor
San Francisco, CA 94105
Audit: (415) 947-4521
Investigations: (415) 947-4500
Seattle
U.S. Environmental Protection Agency
Office of Inspector General
1200 6th Avenue, 19th Floor
Suite 1920, M/SOIG-195
Seattle, WA 98101
Audit: (206) 553-4033
Investigations: (206) 553-1273
Winchester
U.S. Environmental Protection Agency
Office of Inspector General
200 S. Jefferson Street, Room 314
P.O. Box 497
Winchester, TN 37398
Investigations: (423) 240-7735
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