U.S. ENVIRONMENTAL PROTECTION AGENCY
OFFICE OF INSPECTOR GENERAL
Semiannual Report to Congress
April 1, 2011-September 30, 2011
EPA-350-R-11-036
November 2011
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Index of Reporting Requirements
Inspector General Act of 1978, as amended
Requirement Subject
Section 4(a)(2) Review of legislation and regulations
Section 5(a)(1) Significant problems, abuses, and deficiencies
Section 5(a)(2) Significant recommendations for corrective action
Section 5(a)(3) Reports with corrective action not completed
Section 5(a)(3) Peer reviews conducted
Section 5(a)(4) Matters referred to prosecutive authorities
Section 5(a)(5) Information or assistance refused
Section 5(a)(6) List of reports issued
Section 5(a)(7) Summaries of significant reports
Section 5(a)(8) Audit, inspection, and evaluation reports—questioned costs
Section 5(a)(9) Audit, inspection, and evaluation reports—funds to be put to better use
Section 5(a)(10) Prior audit, inspection, and evaluation reports unresolved
Section 5(a)(11) Significant revised management decisions
Section 5(a)(12) Significant management decisions with which OIG disagreed
Pages
36-37
4-36
4-32
64
37-38
11-12, 33-36,44-45
None
46-53
4-32
40-42, 45-53
40-42, 45-53
41-42, 54-63
None
None
Abbreviations
ADH
BEI
CAFO
CFR
CSB
DCAA
DPL
EPA
FY
IDEQ
OARM
OGD
OIG
OMB
Arkansas Department of Health
Bennett Environmental, Inc.
Concentrated Animal Feeding Operation
Code of Federal Regulations
U.S. Chemical Safety and Hazard Investigation Board
Defense Contract Audit Agency
Department of Public Lands (Commonwealth of the Northern Mariana Islands)
U.S. Environmental Protection Agency
Fiscal year
Idaho Department of Environmental Quality
Office of Administration and Resources Management
Office of Grants and Debarment
Office of Inspector General
Office of Management and Budget
Cover photos:
An assortment of images related to work done by the EPA Office of Inspector General
during the semiannual reporting period. Clockwise, from top left: the Deepwater
Horizon platform fire (EPA photo); a farmer spraying pesticides (National Institute of
Environmental Health Sciences photo); an image of the earth (National Aeronautics
and Space Administration digital image); pipes for a Recovery Act clean water project
(EPA OIG photo); and oil collected in bags for landfill disposal (EPA photo).
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/oi
Printed on 100% recycled paper (minimum 50% postconsumer)
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Semiannual Report to Congress
April 1, 2011—September 30, 2011
Message to Congress
Arthur A. Elkins, Jr.
During this semiannual period, I completed my first full year as the
Inspector General of the United States Environmental Protection
Agency (EPA). This Semiannual Report to Congress contains the
results of our work for the reporting period April 1, 2011, through
September 30, 2011. While we conducted work in numerous areas,
several themes were prominent. In addition to our mandatory work,
we performed multiple reviews related to issues of concern to policy
makers and the American people: climate change, the ongoing
cleanup of the Gulf Coast oil spill, the spending of stimulus funds,
and homeland security.
I am pleased to announce that as part of our planning efforts, we
have developed the framework for a new strategic plan for the
Office of Inspector General. The framework includes a new vision
and mission, as well as new values, goals, and objectives, which we
will use to guide our organization as we strive to perform at the
highest level possible.
In September 2011, we reported on our review of EPA's process leading to its greenhouse gases
endangerment finding. We determined that EPA met statutory requirements for rulemaking.
However, whether EPA's review of its technical support document met requirements for peer
review depends on whether the technical support document is considered a highly influential
scientific assessment; we believe it is, but the Agency disagreed. In another review, we found that
EPA has plans to reduce its own greenhouse gas emissions as required by Executive Order 13514,
but funding for some of the projects in the plan has not been authorized or appropriated by
Congress, which may adversely impact the Agency's ability to meet its goals.
We conducted four separate reviews of EPA's cleanup efforts related to the April 2010
BP Deepwater Horizon offshore drilling unit explosion and oil spill in the Gulf of Mexico. EPA
helped shape the federal government's requirements for BP's waste management activities, but
EPA did not have adequate waste management guidance for a spill of this magnitude in place at
the time. EPA had limited cash on hand to fund its response work and, despite receiving a cash
advance of $32 million from the Coast Guard, EPA incurred an Anti-Deficiency Act violation.
EPA also temporarily charged non-oil-spill funds such as Superfund, and reprogrammed funds to
its response work, but this resulted in a purpose violation because the Superfund cannot be used
for oil spill response. We concluded that EPA needs a new approach to enable it to fund
emergency responses to oil spills. Our work also indicated that EPA would have had better
efficacy data on dispersants available if it had updated the National Contingency Plan to include a
more reliable testing procedure.
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Semiannual Report to Congress April 1, 2011—September 30, 2011
We conducted various reviews and investigations regarding EPA's disbursement of funds
received from the American Recovery and Reinvestment Act of 2009 (Recovery Act). We found
that EPA's oversight process for Clean Water State Revolving Fund projects cannot ensure that
states are complying with Recovery Act requirements. In addition, EPA faced multiple
constraints that limited its ability to target funds to preserve and create jobs. Site visits at various
projects showed incorrect usage of work-hour data to calculate jobs created or retained, and
potential noncompliance with Buy American requirements. As a result of our investigative
efforts, one contractor settled a civil case involving violations of Buy American provisions and
another contractor pleaded guilty to submitting false contractor bonds.
Regarding homeland security, we found that EPA needs a better national system to track
emergency response equipment. Further, EPA has not addressed open recommendations
regarding cyber security, and needs classification guides for national security information.
In other reviews, we identified $6.6 million of potentially unneeded funds that could be
deobligated for three operator certification expense reimbursement grants; found that EPA was
not recovering all reasonable motor vehicle and engine compliance program costs; and found
that EPA has not collected comprehensive workload data or conducted workload analyses across
EPA in approximately 20 years.
Our investigation activities resulted in the conviction of four individuals in connection with a bid
rigging case in New Jersey; convictions of two state employees in a case involving travel fraud in
Arkansas; and the conviction of two individuals in Idaho for defrauding the state by using EPA
funds in an illegal scheme to install diesel emission reduction equipment on school buses.
The EPA Inspector General also serves as the Inspector General for the United States Chemical
Safety and Hazard Investigation Board. During the semiannual reporting period we issued two
management challenges to the Board that highlighted the need for the Board to clarify its
statutory mandate and promulgate a chemical incident reporting regulation.
Finally, I want to express my appreciation to the Agency and Congress for their support of the
work of the Office of Inspector General. We have made great progress and I look forward to
fulfilling the new Office of Inspector General vision of being the best in public service and
oversight for a better environment tomorrow.
Arthur A. Elkins, Jr.
Inspector General
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Semiannual Report to Congress April 1, 2011—September 30, 2011
Table of Contents
About EPA and Its Office of Inspector General 1
U.S. Environmental Protection Agency 1
EPA Office of Inspector General 1
OIG Initiates Update of Its Strategic Plan for FYs 2012-2016 1
Key Topics 4
Climate Change 4
Gulf Coast Oil Spill 6
Recovery Act 10
Homeland Security 16
Other Significant OIG Activity 19
Human Health and the Environment 19
Agency Business Practices and Accountability 25
Investigations 33
Other Activities 36
U.S. Chemical Safety and Hazard Investigation Board 38
Statistical Data 40
Profile of Activities and Results 40
Audit, Inspection, and Evaluation Report Resolution 41
Hotline Activity 43
Summary of Investigative Results 44
Scoreboard of Results 45
Appendices 46
Appendix 1—Reports Issued 46
Appendix 2—Reports Issued Without Management Decisions 54
Appendix 3—Reports With Corrective Action Not Completed 64
Appendix 4—OIG Mailing Addresses and Telephone Numbers 65
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Semiannual Report to Congress
April 1, 2011—September 30, 2011
About EPA and Its
Office of Inspector General
U.S. Environmental Protection Agency
The mission of the U.S. Environmental Protection Agency (EPA) is to protect human
health and the environment. As America's steward for the environment since 1970, EPA
has endeavored to ensure that the public has air that is safe to breathe, water that is clean
and safe to drink, food that is free from dangerous pesticide residues, and communities
that are protected from toxic chemicals. EPA had budget authority of $8.682 billion in
fiscal year (FY) 2011, and has requested $8.973 billion for FY 2012.
EPA Office of Inspector General
The Office of Inspector General (OIG) is an independent office of EPA that detects and
prevents fraud, waste, and abuse to help the Agency protect human health and the
environment more efficiently and cost effectively. Although we are part of EPA,
Congress provides us with a budget line item separate from the Agency's to ensure our
independence. The EPA OIG was created and is governed by the Inspector General Act
of 1978, as amended (P.L. 95-452). OIG staff are physically located at headquarters in
Washington, DC; at regional headquarters offices for all 10 EPA regions; and at other
EPA locations including Research Triangle Park, North Carolina, and Cincinnati, Ohio.
The OIG requested $60,766,000 for FY 2012, which is $4,760,000 more than the
President's Budget request for the OIG of $56,006,000. The additional resources in
FY 2012 are needed to strengthen our ability to investigate cyber attacks and develop and
deploy a prevention and mitigation strategy. The EPA Inspector General also serves as
the Inspector General for the U.S. Chemical Safety and Hazard Investigation Board
(CSB).
OIG Initiates Update of Its Strategic Plan for FYs 2012-2016
As part of a new vision and revitalization for the EPA OIG, Inspector General Arthur A.
Elkins, Jr., has kicked off a stakeholder-driven process for updating the OIG's Strategic
Plan for FYs 2012-2016. The approach for developing the new OIG Strategic Plan was
to blend consideration of EPA's mission and new strategic goals with (a) the OIG's
unique duties, role, authorities, and responsibilities as defined by the Inspector General
Act; and (b) the specific management values and vision of Mr. Elkins for inspiring the
greatest level of OIG success in performing its mission.
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Semiannual Report to Congress April 1, 2011—September 30, 2011
We initiated the process by soliciting input from the OIG's stakeholders and the entire
OIG staff to help define success both internally and externally. By performing a SWOT
(Strength, Weaknesses, Opportunities, and Threats) assessment and outreach to EPA
leadership, congressional committees, state associations, the U.S. Government
Accountability Office, and the Office of Management and Budget (OMB), we received
over 3,000 comments that helped OIG leadership build the plan's framework. After
preparing the first draft, we further refined and validated the framework by conducting
town hall meetings with our staff and seeking comments from EPA leadership. The next
step in completing the plan will be to again use the composite stakeholder input, along
with OIG leadership priorities, to develop the specific strategies and actions to implement
the plan's goals and objectives. When completed, this plan will be a living document that
will provide a unified direction with clear expectations.
The OIG's new vision, mission, value, goals, and objectives are as follows:
Vision
Be the best in public service and oversight for a better environment tomorrow.
Mission
Promote economy, efficiency, effectiveness, and prevent and detect fraud, waste,
and abuse through independent oversight of the programs and operations of the
EPA and CSB.
EPA OIG Values
• Customer Service: Everyone deserves to be treated with fairness, respect, and
dignity.
• Integrity: Our people and products are trustworthy.
• Accountability: We are individually and collectively responsible for all we do.
Goals
1. Contribute to improved human health, safety, and environment.
2. Contribute to improved EPA and CSB business practices and accountability.
3. Be responsible stewards of taxpayer dollars.
4. Be the best in government service.
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Semiannual Report to Congress April 1, 2011—September 30, 2011
Objectives
For Goal 1:
• Influence programmatic and systemic changes and actions that contribute to
improved human health, safety and environmental quality.
• Add to and apply knowledge that contributes to reducing or eliminating
environmental and infrastructure security risks and challenges.
• Make recommendations to improve EPA and CSB programs.
For Goal 2:
• Influence actions that improve operational efficiency and accountability
and achieve monetary savings.
• Improve operational integrity and reduce risk of loss by detecting and
preventing fraud, waste, abuse, or breach of security.
• Identify best practices, risks, weaknesses, and monetary benefits to make
recommendations for operational improvements.
For Goal 3:
• Promote and maintain an accountable, results-oriented culture.
• Ensure our products and services are timely, responsive, relevant and
provide value to our customers and stakeholders.
• Align and apply our resources to maximize return on investment.
• Ensure our processes and actions are cost effective and transparent.
For Goal 4:
• Maintain the highest ethical standards.
• Promote and maintain a diverse workforce that is valued, appreciated,
and respected.
• Enhance constructive relationships and foster collaborative solutions.
• Provide leadership, training, and technology to develop an innovative and
accomplished workforce.
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Semiannual Report to Congress
April 1, 2011—September 30, 2011
Key Topics
Climate Change
Since the enactment of the Global Change Research Act of 1990, EPA's research on climate change has
been part of a national and international effort. EPA is 1 of 13 federal agencies involved with the
U.S. Global Change Research Program. Greenhouse gases, which are gases that trap heat within the
atmosphere, were the focus of two reviews conducted during our semiannual reporting period.
Issues Noted Regarding Greenhouse Gases Endangerment Process
EPA met statutory requirements for rulemaking and generally followed
requirements and guidance for ensuring the quality of the supporting technical
information for its greenhouse gases endangerment findings. Whether EPA's
review of its technical support document met OMB requirements for peer review
depends on whether the technical support document is considered a highly
influential scientific assessment. In our opinion it is a highly influential
assessment, but the Agency disagreed.
On December 15, 2009, EPA published its Endangerment and Cause or Contribute
Findings for Greenhouse Gases Under Section 202(a) of the Clean Air Act. As the
primary scientific basis for EPA's findings, the Agency relied upon assessments
conducted by other organizations. EPA summarized the results of
these and other scientific assessments in a technical support
document. As a result of a congressional request, we reviewed
EPA's process for ensuring the quality of the technical
information supporting the endangerment findings.
An image of the earth. (Digital image
from National Aeronautics and Space
Administration)
In our opinion, the technical support document is a highly
influential scientific assessment because EPA weighed the
strength of the available science by its choices of information,
data, studies, and conclusions included in and excluded from the
document. As such, it required a more rigorous EPA peer review
than what occurred. EPA officials told us they did not consider
the technical support document a highly influential scientific
assessment. EPA noted that the document consisted only of
science that was previously peer reviewed, and that these reviews
were deemed adequate under the Agency's policy. EPA had the technical support
document reviewed by a panel of 12 federal climate change scientists. This review did
not meet all OMB requirements for peer review of a highly influential scientific
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Semiannual Report to Congress
April 1, 2011—September 30, 2011
A geothermal plant, part of
a greenhouse gas reduction
project. (U.S. Department of
Energy photo)
assessment primarily because the review results and EPA's response were not publicly
reported, and because 1 of the 12 reviewers was an EPA employee.
EPA's findings relied heavily on the results of scientific assessments and studies conducted
by other organizations. EPA's guidance for assessing other organizations' data does not
include procedures for, or a requirement to document, how EPA assessed the quality of
externally generated information prior to its dissemination. EPA provided statements in its
final findings notice that generally addressed the Agency's assessment factors for
evaluating scientific and technical information, and explained its rationale for accepting
other organizations' data. However, no supporting documentation was available to show
what analyses the Agency conducted prior to disseminating the information.
Our evaluation examined the data quality procedures EPA used in developing the
endangerment finding. We did not assess whether the scientific information and data
supported the endangerment findings.
We recommended that EPA (1) revise its Peer Review Handbook to accurately reflect
OMB requirements for peer review of highly influential scientific assessments, (2) instruct
program offices to state in proposed and final rules whether the action is supported by
influential scientific information or a highly influential scientific assessment, and (3) revise
its assessment factors guidance to establish minimum review and documentation
requirements for assessing and accepting data from other organizations. EPA stated that its
response to the final report will address our recommendations.
(Report No. ll-P-0702, Procedural Review of EPA 's Greenhouse Gases Endangerment
Finding Data Quality Processes, September 27, 2011)
EPA on Track to Meet Agency Greenhouse Gas Emissions Reduction
Requirements
EPA has completed its plan to reduce its own greenhouse gas
emissions as required by Executive Order 13514, but projected
reductions are contingent on the full funding and implementation of
the plan's energy efficiency projects.
On October 5, 2009, President Obama signed Executive Order 13514 to
establish an integrated strategy toward sustainability in the federal
government. The executive order introduced new greenhouse gas emissions
management requirements and required federal agencies to measure, report,
and reduce their greenhouse gas emissions.
EPA established a 25 percent greenhouse gas emission reduction target by
FY 2020. To reach this target, the Agency's primary strategy is to reduce its
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Semiannual Report to Congress
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facility energy intensity by 3 percent annually. EPA's Strategic Sustainability Performance
Plan outlines specific projects that the Agency will undertake to reduce emissions, but
funding for some of the projects has not been authorized or appropriated. Delays or deficits
in funding may adversely impact the Agency's ability to meet reduction goals.
We recommended that EPA's annual update of its Strategic Sustainability Performance
Plan report describe changes to greenhouse gas emission reductions and/or reduction
goals based on actual funding and status of projects, and adjust the overall reduction goal
as needed. The Agency concurred with the findings and recommendation.
(Report No. ll-P-0209, EPA 's Plan to Reduce Agency Greenhouse Gas Emissions Is on
Track to Meet Executive Order 13514 Requirements, April 12, 2011)
Gulf Coast Oil Spill
The Deepwater Horizon platform fire.
(EPA photo)
On April 20, 2010, the BP Deepwater Horizon mobile offshore drilling unit exploded in the Gulf of
Mexico, resulting in a severe fire. Two days later, the unit sank and began releasing several thousand
barrels of crude oil per day into the Gulf, primarily impacting the
coasts of Louisiana, Mississippi, and Alabama. The Secretary of
the U.S. Department of Homeland Security classified this oil
discharge as a "Spill of National Significance," meaning that the
spill was so complex it required extraordinary coordination of
federal, state, local, and responsible party resources to contain
and clean up the discharge. It was the first spill to receive such a
designation. The U.S. Coast Guard led the federal environmental
response actions, and EPA was one of the federal agencies
heavily involved in the cleanup. In this semiannual reporting
period, the EPA OIG issued four reports related to EPA's
involvement in the Gulf Coast oil spill; one of those reports also
addressed issues related to the Enbridge oil spill in Michigan. In addition, the OIG Office of
Investigations has provided criminal investigators to assist the U.S. Department of Justice with
investigations.
EPA Evaluating Its Oil Spill Response Communications
EPA shared the results of all data it collected at the BP and Enbridge oil spills
with state and local decisionmakers and impacted communities. EPA is
completing lessons-learned exercises to evaluate the effectiveness of its
responses to both oil spill incidents.
The purpose of this review was to determine what actions EPA took to communicate oil
spill risk to communities affected by the BP oil spill, as well as the July 26, 2010, Enbridge
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Semiannual Report to Congress April 1, 2011—September 30, 2011
oil spill that occurred in Michigan, which released an estimated 819,000 gallons of oil that
flowed into the Kalamazoo River.
EPA shared information in a number of ways. EPA developed Quality Assurance
Sampling Plans to collect data on the chemical contamination in air, water, and
sediments. EPA communicated data results and interpretations to the general public via
press conferences, fact sheets, community meetings, and the Internet and social
networking media. EPA's communications, which included details on voluntary
evacuations and drinking water advisories, assisted states and other federal agencies in
understanding the immediate and long-term impacts of the contamination. Further, EPA
issued a request for proposals for grants totaling up to $300,000 to further communication
efforts in the environmental-justice-designated communities impacted by the BP oil spill.
EPA's ongoing lessons-learned activities, which address the effectiveness of EPA's
communication strategy and activities, will allow the Agency to identify areas of success,
as well as areas that could be improved upon in responding to future emergency
situations. We made no recommendations.
(Report No. ll-P-0273, EPA Actively Evaluating Effectiveness ofltsBPandEnbridge
Oil Spill Response Communications, June 23, 2011)
EPA Should Improve Funding Practices for Oil Spill Responses
EPA should better track and recover its oil spill response costs and develop a
new approach to funding emergency oil spill response efforts.
The Coast Guard, as lead agency for the Gulf Coast oil spill response, authorized EPA to
monitor and respond to potential public health and environmental concerns. To do so,
EPA collected and managed environmental data, oversaw waste management activities,
and provided technical assistance. As of December 31, 2010, the Coast Guard had
authorized EPA to spend approximately
EPA's reimbursable oil spill response costs
as of March 3 2011 $61.9 million on response work. EPA bills its
costs and receives reimbursement from the Coast
Region 4 $11,398,046
Region 6 26,833,769
HQ Emergency Operations Center 7,995,927
Total $46,227,742
Guard.
EPA needs controls to ensure that its response
Source: OIG analysis of EPA data (data do not activity documents are consistent and provide a
include EPA's indirect costs). clear audit trail. Further, EPA needs controls in its
billing review to ensure that cost documentation
packages are clear and complete. EPA also needs to reach agreement with the Coast Guard
regarding the sharing of contractor-designated confidential business information; this
impasse has affected reimbursement of EPA's response costs. Until this matter is resolved,
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Semiannual Report to Congress
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reimbursement of EPA's response costs may be further delayed or denied, and may result
in an Anti-Deficiency Act violation as well as Prompt Payment rule penalties.
EPA also needs a new approach to better enable it to fund future emergency responses to
oil spills. Reimbursement from the Coast Guard was not immediate and EPA did not
have enough of its own resources to cover its increasing response activities. In an attempt
to prevent a funding shortfall, EPA issued guidance that allowed for temporary charging
to non-oil-spill appropriations and for the reprogramming of funds. EPA also sought and
received a cash advance for $32 million from the Coast Guard. Because EPA did not
have timely access to sufficient funds, it incurred an Anti-Deficiency Act violation in
November 2010. While EPA's actions ultimately provided it with access to funds, EPA
needs a new approach to better enable it to fund emergency responses to oil spills.
We recommended that EPA implement controls to ensure that documentation supports
authorized response activities and that response bills and supporting cost documentation
packages are clear and complete. We also recommended that EPA reach an agreement
with the Coast Guard on sharing confidential-designated business information; this
impasse has affected reimbursement of EPA's response costs. EPA should also seek new
or additional emergency response funding authority for oil spills. During the course of
this review, EPA took action to seek this authority. EPA agreed with most of our
recommendations.
(Report No. ll-P-0527, EPA 's Gulf Coast Oil Spill Response Shows Need for Improved
Documentation and Funding Practices, August 25, 2011)
Use of Dispersants Shows Need to Update National Contingency Plan
EPA may have had better efficacy data on dispersants during the Gulf Coast oil
spill if it had updated the National Contingency Plan to include a more reliable
testing procedure.
An overhead view of the Deepwater Horizon
oil spill. (U.S. Coast Guard photo)
The National Contingency Plan establishes national
response capability and coordination for oil spills. The
plan's Product Schedule lists spill-mitigating chemicals
that responders can use in carrying out the plan, including
dispersants that emulsify, disperse, or solubilize oil into
the water column. We received two hotline complaints
regarding the use of Corexit, a dispersant, during the Gulf
Coast oil spill response.
EPA and the manufacturer of Corexit had completed
required steps to include Corexit products on the National
Contingency Plan Product Schedule. However, EPA has
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Semiannual Report to Congress
April 1, 2011—September 30, 2011
not updated the National Contingency Plan since 1994 to include the most appropriate
efficacy testing protocol. EPA has considered changing efficacy testing procedures, but
had not finalized the rulemaking before the Gulf Coast oil spill. Responders could have
used other dispersants, but not within the applicable window of time designated by a joint
EPA-Coast Guard directive. EPA involved senior officials in the response because the
Agency was not prepared for the unprecedented volume and duration of dispersant use,
and because additional clarity on roles and responsibilities was needed. The involvement
of senior EPA officials created confusion as to who at EPA led response efforts for
dispersant use.
The OIG's Office of Counsel reviewed an allegation in the hotline complaint that EPA
was covering up the effects of the dispersant being used (Corexit) and alluded to the EPA
Administrator committing perjury. The Office of Counsel did not find evidence
supporting the perjury allegation.
We recommended that EPA establish policies to review and update contingency plans,
incorporating lessons learned during the Gulf Coast oil spill, and clarify roles and
responsibilities for spills of national significance. We also recommended that EPA revise
the National Contingency Plan to incorporate the most appropriate efficacy testing
protocol and capture dispersant information, and that EPA develop a research plan on
long-term health and environmental effects of dispersants. The Agency generally agreed
with our recommendations.
(Report No. ll-P-0534, Revisions Needed to National Contingency Plan Based on
Deepwater Horizon Oil Spill, August 25, 2011)
EPA Should Clarify and Strengthen Its Waste Management Oversight
Role for Oil Spills
Although increased federal oversight of BP's waste management activities
improved transparency and provided additional measures to protect the
environment and public health during the Gulf Coast oil spill response, EPA did
not nave adequate waste management guidance for a
spill of this magnitude and fell short of some of its
goals.
As a support agency to the Coast Guard, EPA's oversight of
the Gulf Coast oil spill waste management activities
provided assurance that oil-contaminated waste was
disposed of properly. EPA helped shape the federal
government's requirements for BP's waste management
activities and had a key role in reviewing and approving
BP's waste management plans. EPA also assessed landfills,
Oil collected in bags being put into containers
for landfill disposal. (EPA photo)
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independently sampled waste, and kept the public informed about its oversight activities
and results.
However, EPA did not have adequate waste management guidance in place for a spill of this
magnitude at the time of the spill. EPA fell short of its own goals for waste management
oversight and did not conduct oversight for all states and facilities that received waste from
this spill. In addition, EPA's lack of planning and transparency on its decision to manage the
oil spill waste in a manner different than provided by guidance resulted in staff confusion,
frustration, and inefficiency. Although we obtained no evidence that these limitations had
negative effects, some delays in the disposal of the waste did occur.
We recommended that EPA work with other federal partners to determine whether the
National Contingency Plan and National Response Framework for waste management
oversight and roles should be updated; complete waste management guidance in area
contingency plans; develop a model waste management plan; and, to the extent needed,
seek additional authorities to perform waste management oversight in offshore spills of
national significance. We also recommended that EPA update the 2002 guidance on the
oil and gas exploration and production waste exemption. EPA agreed with some of our
recommendations.
(Report No. ll-P-0706, EPA Should Clarify and Strengthen Its Waste Management
Oversight Role With Respect to Oil Spills of National Significance, September 26, 2011)
Recovery Act
The American Recovery and Reinvestment Act of 2009 (Recovery Act),
signed by President Obama on February 17, 2009, provides the EPA OIG
$20 million for oversight activities through September 30, 2012. The OIG is
conducting audits, evaluations, investigations, and other reviews to ensure
economy and efficiency, and to prevent and detect fraud, waste, and abuse in
EPA's disbursement of the $7.2 billion it received under the Recovery Act.
As of September 30, 2011, the OIG has expended $12.4 million in Recovery
Act funds. OIG assignments include reviews based on concerns raised by the
public; individuals may report any suspicion of fraud, waste, or abuse via the
OIG hotline at http ://www.epa. gov/oig/hotline .htm.
**
RECOVERY.GOV
On May 4, 2011, Inspector General Arthur A. Elkins, Jr., testified before the Committee on
Transportation and Infrastructure, U.S. House of Representatives, on OIG's Recovery Act activities.
"While EPA has successfully awarded and obligated its Recovery Act funds, OIG work has shown that
improvement is needed in monitoring and assessing projects to ensure they meet stated environmental
goals and are not subject to fraud, waste, and abuse." Mr. Elkins noted OIG briefings, outreach, and
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Semiannual Report to Congress April 1, 2011—September 30, 2011
training have produced tangible results. For example, a City of Sacramento engineer who attended an
OIG fraud training session contacted the OIG regarding a concern, and our subsequent investigation
resulted in a contractor pleading guilty to defrauding the city (see below). Mr. Elkins concluded his
statement by noting, "Given the number and scope of projects funded by the Recovery Act, effective
oversight will be a challenge for EPA and its state partners. The OIG will continue to monitor and assess
EPA's Recovery Act activities in these and other areas."
Details on OIG Recovery Act efforts during the semiannual reporting period ending September 30, 2011,
follow.
Recovery Act Contractor Pays $120,216 to Settle Civil Case
On May 9, 2011, without admitting liability, Hayward Baker, Inc., entered into a civil
settlement with the U.S. Attorney for the District of South Dakota to settle a civil case
involving violations of the Buy American provisions of the Recovery Act. Hayward
Baker paid $120,216 to settle allegations that it improperly billed EPA for steel pipe that
was manufactured in Taiwan and South Korea.
The Recovery Act requires fund recipients to use American-made construction materials,
including steel pipe. Hayward Baker received Recovery Act funds under a subcontract
involving the environmental cleanup of the Gilt Edge Mine, located near Lead, South
Dakota. The project required that American-made steel pipe be used, but Hayward Baker
used some steel pipe manufactured in Taiwan and South Korea.
Contractor Pleads Guilty to Defrauding City of Sacramento of
Recovery Act Funds
On September 20, 2011, Peter Scott, President of Advantage Demolition and
Engineering, Roseville, California, pleaded guilty to two counts of submitting false
contractor bonds related to a Recovery Act water meter retrofit project for the city of
Sacramento, California.
In 2009, Sacramento received a Recovery Act grant from EPA to retrofit water meters on
city homes. According to court documents, in August and September 2009, Scott,
through his company, bid on eight of the project's water meter retrofit phases, submitting
surety bonds totaling $5 million that were purportedly issued by a bonding company. The
bonds were counterfeit and contained discrepancies. According to the plea agreement,
Scott admitted that the bond company attorney who purportedly signed the bonds was not
a representative of the bonding company, but was in fact a fictional person.
Sacramento had awarded two of the contracts to Advantage Demolition and Engineering.
The first contract was for $1.2 million (Phase 4); the second was for $2.2 million
11
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Semiannual Report to Congress April 1, 2011—September 30, 2011
(Phase 10). Advantage began work on the project in November 2009. However, in early
January 2010, city inspectors noticed problems with Advantage's work. On January 7,
2010, the city determined that the surety bonds submitted with the company's bids were
fraudulent and issued a stop-work order for Phases 4 and 10.
This case is being conducted with the Federal Bureau of Investigation.
EPA Faced Multiple Constraints to Targeting Recovery Act Funds
Multiple constraints limited EPA's ability to target funds to preserve and create
jobs, as well as reach those most impacted by the recession.
Recovery Act funds were intended to create or save jobs, address environmental and
other challenges, and assist those most impacted by the recession. EPA specifically
sought to address location-specific, community-based public health and environmental
needs with its Recovery Act dollars.
After obligating over $7 billion in Recovery Act funds, EPA was unable to assess the
overall impact of those funds on economically disadvantaged communities or those most
impacted by the recession. While EPA was able to track financial expenditures, it could
not track the distribution of its Recovery Act funds to economically disadvantaged
communities. The absence of definitions, data, and measures hindered the effort.
Short timeframes and emphasis on shovel-ready projects hampered the targeting of
disadvantaged communities. Further, states made many of the funding decisions.
We recommended that EPA establish a clear and consistent regime that can address
socioeconomic factors. EPA agreed to take corrective actions.
(Report No. ll-R-0208, EPA Faced Multiple Constraints to Targeting Recovery Act
Funds, April 11, 2011)
EPA and States Should Improve Oversight of Recovery
Act Clean Water Projects
EPA's oversight process for Clean Water State Revolving Fund
projects funded by the Recovery Act cannot ensure that states
are complying with requirements, and state oversight does not
always ensure subrecipient compliance.
The Clean Water State Revolving Fund Program received $4 billion of
Recovery Act funding for states to finance high-priority infrastructure
Pipes for a Recovery Act clean projects needed to ensure clean water. EPA made Recovery Act grants
water project. (EPA OIG photo) tQ ^ and ^^ ^ tQ
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Semiannual Report to Congress
April 1, 2011—September 30, 2011
EPA oversight guidance to the states is not detailed enough to ensure compliance with
Recovery Act requirements, and state oversight of Clean Water State Revolving Fund
projects did not always ensure subrecipient compliance with the Recovery Act. Some
states were not conducting adequate oversight of the Act's Buy American requirements,
and the frequency of inspections varied among states. EPA believes that it lacks statutory
authority to place requirements on states and gives states flexibility. Further, EPA did not
conduct and document reviews of state programs in a timely manner or use the resulting
review reports to make national program decisions. If states do not conduct proper
oversight, projects are at increased risk of fraud, waste, and abuse, and are also at risk for
not complying with Recovery Act requirements or achieving the Recovery Act's
economic recovery goals.
We recommended that EPA implement a plan to supplement state inspections and require
states to use an updated checklist during inspections. We also recommended that EPA
update the checklists regions use for semiannual reviews of states, establish deadlines for
completing those reviews, and analyze reviews for nationwide trends. EPA did not agree
with all of our recommendations and provided alternative corrective actions for some.
(Report No. ll-R-0519, EPA and States Should Strengthen Oversight of Clean Water
State Revolving Fund Recovery Act Projects, August 24, 2011)
Site Visits of Recovery Act Projects Conducted With Varying Results
As part of OIG efforts to ensure that EPA is spending Recovery Act funds in
accordance with requirements, we completed eight site visits during the
semiannual reporting period. As part of our visits, we toured the projects,
interviewed relevant parties, and reviewed documentation related to Recovery
Act requirements. For four sites, we identified no issues that required corrective
action by EPA or the recipients, but we found issues at four other sites.
The town of Buckeye, Arizona, is constructing a 1.5-million-gallon-
per-day expansion of its wastewater treatment facility. The project is
funded by a $12,000,000 Clean Water State Revolving Fund loan that
includes $6,372,285 in Recovery Act funds. The town used incorrect
and/or incomplete work-hour data to calculate jobs created or retained
for quarterly reports covering the 6-month period ended June 30, 2010,
and did not submit the report for the quarter ended September 30, 2010.
EPA agreed with our recommendations for correcting the quarterly
reports. (Report No. ll-R-0222, American Recovery and Reinvestment
Act Site Visit of the Wastewater Treatment Facility Expansion, Town of
Buckeye, Arizona, May 9, 2011)
Water treatment facility expansion in
Buckeye, Arizona. (EPA OIG photo)
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Semiannual Report to Congress April 1, 2011—September 30, 2011
For a project in Aibonito, Puerto Rico, the Puerto Rico Aqueduct and Sewer Authority
received a $2,606,900 loan of Recovery Act funds. The project involved various
improvements at the La Plata Water Treatment Plant. We were unable to determine the
total hours worked for employees due to variances in labor hours reported. As a result, we
could not determine compliance with wage rate or reporting requirements under the
Recovery Act. EPA agreed to take appropriate corrective actions. (Report No. ll-R-0232,
American Recovery and Reinvestment Act Site Visit of the La Plata Water Treatment Plant
Phase II Project, Aibonito, Puerto Rico, May 23, 2011)
For a project for the Ingenio Community, Toa Baja, Puerto Rico, $12,705,360 of
Recovery Act funds under the Clean Water State Revolving Fund program were provided
to fund sanitary sewer system improvements in multiple locations. During our review, the
Puerto Rico Aqueduct and Sewer Authority informed us of a potential instance of
noncompliance with the Recovery Act's Buy American provisions and the actions being
taken to resolve the matter. As a result, we did not complete our planned work in this
area. Also, we identified two subcontract agreements that did not contain the Recovery
Act requirements. EPA agreed to take appropriate corrective actions. (Report No.
11 -R-0233, American Recovery and Reinvestment Act Site Visit of Sanitary Sewer
System Improvements, Ingenio Community, Toa Baja, Puerto Rico, May 24, 2011)
The city of Ottawa, Illinois, received a $7,720,293 loan from the State of Illinois under
the Water Pollution Control Loan Program. The loan included $3,860,147 in Recovery
Act funds. The city will use the funds to rehabilitate and improve the city's waste water
treatment plant. The city could not provide sufficient documentation to support that some
manufactured goods used on the project met the Buy American requirements. The
documentation did not demonstrate clearly that items were either manufactured or
substantially transformed in the United States. As a result, the state's use of over
$3.8 million of Recovery Act funds is prohibited, unless a regulatory option is exercised.
Both the city and Region 5 disagreed with our conclusions and recommendation.
(Report No. ll-R-0700, American Recovery and Reinvestment Act Site Visit of
Wastewater Treatment Plant—Phase II Improvements Project, City of Ottawa, Illinois,
September 23, 2011)
For the city of Perkins, Oklahoma, the Perkins Public Works Authority received a
$7,225,000 loan from the Oklahoma Water Resources Board through the state's Clean
Water State Revolving Fund Financing Program. The purpose of the loan was to improve
the wastewater treatment facility to meet permitted discharge requirements. We identified
no issues that required corrective action. (Report No. ll-R-0214, American Recovery and
Reinvestment Act Site Visit of the Wastewater Treatment Facility Improvements Project,
Perkins, Oklahoma, May 2, 2011)
The Las Marias Potable Water System Phase IIA project in Las Marias, Puerto Rico
received $5,574,410 in Recovery Act funds under the Drinking Water State Revolving
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Semiannual Report to Congress
April 1, 2011—September 30, 2011
Pipes at the Las Marias Potable Water
System Phase IIA construction site.
(Photo courtesy Constructora De
Aguada, Inc.)
Fund program, consisting of a $3,189,359 grant and a $2,385,051 loan.
We identified no issues that required corrective action. (Report No.
ll-R-0241, American Recovery and Reinvestment Act Site Visit of Las
Marias Potable Water System Phase IIA Project, Las Marias, Puerto
Rico, May 25, 2011)
The city of Portland, Maine, received Recovery Act funds of
$2,063,665 through the Clean Water State Revolving Fund Program and
the Portland Water District received $380,205 through the Drinking
Water State Revolving Fund Program for the Clifton Street Water Main
Replacement Project. We identified no issues that required corrective
action. (Report No. ll-R-0248, American Recovery and Reinvestment
Act Site Visit of the Clifton Street Sewer Separation and Water Main
Replacement Projects, Portland, Maine, June 7, 2011)
For a Superfund project in Clermont, Lake County, Florida, EPA awarded a fixed price
contract under the Recovery Act to Polu Kai Services, LLC, to clean up contaminated
soils at the Tower Chemical Superfund Site. This remedial action consisted of
excavating, transporting, and disposing of soils contaminated with pesticides and other
composites, and restoring the excavated areas. The value of the contract was $4,197,177.
We identified no issues that required corrective action. (Report No. ll-R-0431,
American Recovery and Reinvestment Act Site Visit of the Tower Chemical Superfund
Site, Clermont, Lake County, Florida, August 3, 2011)
Identification of Unallowable Costs Results in $1 Million in Recovery
Act Funds Being Made Available for Texas Projects
As a result of a joint effort by Region 6 and the OIG, the Texas Water
Development Board reduced Recovery Act grant award amounts for water
projects by $1,057,189, according to the memorandum a Region 6 official sent to
the OIG on April 19,2011.
Region 6 had conducted a site visit to the Texas Water Development Board, during which
the region identified costs related to bond counsel and financial advisory fees that it
considered ineligible. The board did not agree with the region's position. The OIG
subsequently informed Region 6 of a hotline complaint it received related to unallowable
bond counsel and financial advisory fees paid for by the Texas board using Recovery Act
funds. The OIG met with the board and reached agreement that $1,057,189 was not
allowable. This enabled the board to reprogram the funds for other state water projects.
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Semiannual Report to Congress April 1, 2011—September 30, 2011
Homeland Security
The OIG conducts various reviews to help EPA prevent and deal with terrorist attacks and other threats,
including threats to its information technology systems and resources.
Improved System Needed to Track Emergency Response Equipment
Because EPA has not fully implemented its emergency equipment tracking
module, EPA's ability to protect public health and the environment in the event of
a nationally significant incident may be impaired.
Since September 11, 2001, EPA's emergency response focus has expanded with its new
role in homeland security. In May 2002, EPA determined that it needed to create a
national equipment tracking system to be better prepared for terrorist acts and nationally
significant incidents.
Although EPA spent $2.8 million as of October 2010 to develop and implement an
emergency equipment tracking module, EPA has not fully implemented the module, and
the module suffers from operational issues. Further, the regions using the module
continue to maintain their own tracking systems, resulting in wasted resources. Our
review of allegations in a hotline complaint found that EPA does not fully use the
equipment tracking module because no EPA office with overall authority has mandated
its use, EPA has made no formal effort to assess functionality and cost effectiveness, and
the equipment module is cumbersome and slow. EPA plans to spend another $5.5 million
over the next 15 years to maintain the module.
We recommended that EPA ensure that only essential equipment tracking data are
required to be recorded and determine whether the equipment module is the most cost-
efficient alternative. We also recommended that EPA mandate that regions and
emergency response teams employ the national tracking system that EPA decides to use.
The Agency concurred with the recommendations.
(Report No. 11 -P-0616, EPA Has Not Fully Implemented a National Emergency
Response Equipment Tracking System, September 13, 2011)
Key Actions to Address Cyber Threats Remain Incomplete
EPA has not addressed open recommendations regarding cyber security,
potentially putting the availability and integrity of Agency data at risk.
An advanced persistent threat is a cyber crime designed to steal or modify information
without detection. In November 2009, EPA reported 14 compromised systems related to
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Semiannual Report to Congress April 1, 2011—September 30, 2011
OIG investigation of advanced persistent threats. By September 2010, the Agency
reported that over 7,800 of its systems had communicated with known hostile Internet
Protocol addresses and, thus, could have been compromised.
Some recommendations for strengthening cyber security practices made in previous OIG
reports remain unimplemented, and we continue to find and report on similar weaknesses
at other EPA locations. If EPA does not address open recommendations and improve
cyber security practices, its information security weaknesses could negatively affect the
availability and integrity of all Agency data.
We recommended that EPA stress the importance of and expectation for completing audit
recommendations by the agreed-upon milestone date, strengthen management control
processes, and update the Enterprise Transition Plan Information Management segment.
The Agency agreed with our recommendations.
(Report No. ll-P-0277, EPA Has Taken Steps to Address Cyber Threats but Key Actions
Remain Incomplete, June 23, 2011)
EPA Needs Classification Guides for National Security Information
EPA has not established any official national security information classification
guides, even though EPA Administrators have taken original classification
actions. Without the guides, EPA may not be uniformly and consistently
identifying and classifying information.
Some EPA staff members are cleared to access, use, and create classified national
security information in the performance of their assigned duties. EPA policy requires that
a classification guide shall be developed for each system, plan, program, or project in
which classified information is involved.
According to EPA, classification guides have not been prepared because EPA
Administrators have only classified a few documents. Without classification guides,
information that should be identified for safeguarding could be unintentionally released,
resulting in harm to national security. The lack of classification guides is a material
internal control weakness in EPA's classified national security information program.
We recommended that the Administrator ensure the preparation, review, approval, and
distribution of appropriate security classification guides that conform to federal and
Agency requirements. EPA did not agree with the report's conclusions, and the
recommendations are unresolved. This early warning report presented a significant
finding requiring immediate attention. We will issue a final report that will discuss other
results of our review of EPA's classified national security information infrastructure.
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Semiannual Report to Congress April 1, 2011—September 30, 2011
(Report No. ll-P-0722, EPA Should Prepare and Distribute Security Classification
Guides, September 29, 2011)
Technical Network Vulnerability Assessed at Various Locations
The OIG conducted testing at various locations to identify network vulnerabilities.
If not resolved, these vulnerabilities can expose EPA's assets to unauthorized
access and potentially harm the Agency's networks.
The testing disclosed several high-risk and medium-risk vulnerabilities, as discussed in
three separate reports:
• Results of Technical Network Vulnerability Assessment: EPA's National Health
& Environment Effect Research Laboratory, Western Ecology Division (Report
No. ll-P-0429, Augusts, 2011)
• Results of Technical Vulnerability Assessment: EPA's Directory Service System
Authentication and Authorization Servers (Report No. ll-P-0597,
September 9, 2011)
• Region 9 Technical and Computer Room Security Vulnerabilities Increase Risk
to EPA's Network (Report No. ll-P-0725, September 30, 2011)
The OIG met with EPA information security personnel responsible for the issues noted in
each report to discuss the findings. The OIG issued recommendations in each report. The
full reports were not made available to the public due to the sensitive nature of the
technical findings.
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Semiannual Report to Congress
April 1, 2011—September 30, 2011
Other Significant OIG Activity
Human Health and the Environment
EPA Not Meeting All Requirements of Methamphetamine Act
EPA has not been able to meet all of its requirements under the 2007
Methamphetamine Remediation Research Act (Meth Act) because EPA's
authorized Meth Act funding of $3.5 million was never appropriated.
Thousands of clandestine meth labs are discovered in the United States each year.
Chronic exposure to residual meth lab chemicals that are not properly cleaned up can
cause cancer; damage to the brain, liver, and kidneys; and reproductive problems. The
Meth Act requires EPA to develop cleanup guidelines for meth labs; develop a research
plan to identify chemicals of concern and possible exposure, and evaluate cleanup
techniques; perform a study of residual effects of meth lab chemicals; and convene a
technology transfer conference every 3 years.
2010 Meth lab incidents
Calendar Year 2010
Total: 10,247
Total of All Meth Clandestine Laboratory Incidents
Including Labs, Dumpsites, Cnem/Glass/Equipment
Source: El Paw Intelligence Center (EPIC)
National Seizure System (NSS)
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Semiannual Report to Congress
April 1, 2011—September 30, 2011
A farmer spraying pesticides.
(National Institute of Environmental
Health Sciences photo)
EPA has met some, but not all, of its requirements under the Meth Act. According to EPA
staff, EPA has not been able to fully implement the Meth Act requirements because EPA's
authorized Meth Act funding of $3.5 million was never appropriated. As a result, EPA's
work to meet the Meth Act's requirements has been funded by resources redirected from
other programs. In addition, EPA has no controls in place to track legislative requirements
Agency-wide. EPA relies on its program offices to do so, but these program offices also do
not have controls in place to track all legislative requirements.
We recommended that EPA determine its ability to implement the Meth Act requirements
and communicate its plan to Congress. We also recommended that EPA update several
areas of the voluntary guidelines and develop internal controls to ensure legislative
requirements are identified, tracked, and met. EPA agreed with these recommendations.
(Report No. ll-P-0708, EPA Progress on the 2007Methamphefamine Remediation
Research Act, September 27, 2011)
EPA's Endocrine Disrupter Screening Program Needs Improvement
EPA's Endocrine Disrupter Screening Program has not developed a
management plan laying out the program's goals and priorities, nor established
outcome performance measures to track program results.
In 1996, the Food Quality Protection Act gave EPA the authority to screen and test
substances that may have an effect in humans that is similar to that of a naturally
occurring estrogen, or such other endocrine effects as the EPA Administrator may
designate. In 1998, EPA established the Endocrine Disrupter
Screening Program, which uses a two-tiered screening and testing
approach to assess endocrine effects. The program was expanded to
include androgenic and thyroid effects. However, after more than
14 years, the program has not determined whether any chemical is a
potential endocrine disrupter.
While we acknowledged that the program encountered difficulties
and delays, its lack of progress is also due to the lack of management
controls over the program. The Endocrine Disrupter Screening
Program needs to develop and implement plans and performance
measures to establish management control and accountability. For
example, the program missed milestones for chemical selection by
about 4!/2 years and for assay validation by 6 years. Concerned about program progress,
in 2007, Congress instituted reporting requirements, and in 2009, specified deadlines for
certain Endocrine Disrupter Screening Program activities. As a result, EPA recently
published two Endocrine Disrupter Screening Program documents for public comment.
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Semiannual Report to Congress April 1, 2011—September 30, 2011
Nonetheless, the OIG remains concerned about the continuing program delays, and
recommended that the Agency develop a comprehensive management plan for the
Endocrine Disrupter Screening Program so that EPA's leadership, Congress, and the
public can assess whether the goals and key activities of the program are being achieved
within reasonable cost and schedule. We also recommended that EPA define and identify
the universe of chemicals, develop and publish a standardized methodology for
prioritizing the universe of chemicals for screening and testing, finalize criteria to
evaluate testing data, develop performance measures, and hold annual program reviews.
EPA agreed with two of our recommendations, and four remain unresolved.
(Report No. ll-P-0215, EPA 's Endocrine Disruptor Screening Program Should
Establish Management Controls to Ensure More Timely Results, May 3, 2011)
EPA's Voluntary Children's Chemical Evaluation Program Did Not
Achieve Goals
EPA has not demonstrated that it can achieve children's health goals with a
voluntary program, and the general public does not have access to a readily
understandable source of chemical exposure information to determine potential
risks to children.
Executive Order 13045 directed federal agencies to place a high priority on protecting
children from environmental and safety risks. The 1998 Chemical Right-to-Know
Initiative satisfied that order by directing EPA to test chemicals to which children are
disproportionately exposed. EPA accordingly established the Voluntary Children's
Chemical Evaluation Program pilot.
The Voluntary Children's Chemical Evaluation Program pilot did not achieve its goals to
design a process to assess and report on the safety of chemicals to children. The pilot had
a flawed chemical selection process and lacked an effective communication strategy.
Programmatic effectiveness was hampered by industry partners who chose not to
voluntarily collect and submit information, and EPA's decision not to exercise its
regulatory authorities under the Toxic Substances Control Act to compel data collection.
The Voluntary Children's Chemical Evaluation Program is no longer operational, and the
Agency has no plans to revive, replace, or terminate it. As a result, the Agency is not
meeting the intent of Executive Order 13045, the Chemical Right-to-Know Initiative, or
the Voluntary Children's Chemical Evaluation Program pilot.
We recommended that EPA design and implement a new process to assess the safety of
chemicals to children that (1) identifies the chemicals with highest potential risk to
children, (2) applies the Toxic Substances Control Act regulatory authorities as
appropriate for data collection, (3) interprets results and disseminates information to the
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Semiannual Report to Congress April 1, 2011—September 30, 2011
public, and (4) includes outcome measures that assure valid and timely results. EPA
agreed with most of our recommendations.
(Report No. ll-P-0379, EPA's Voluntary Chemical Evaluation Program Did Not Achieve
Children's Health Protection Goals, July 21, 2011)
EPA Needs Communication Strategy for Libby Superfund Site
Region 8 does not have an overall communication strategy to guide, coordinate,
and evaluate its communication efforts at the Libby Asbestos Superfund Site.
The Libby site includes portions of the towns of Libby and Troy, Montana. An inactive
vermiculite mine contaminated with naturally occurring asbestos is located 7 miles
outside of Libby. About 12,000 people live within a 10-mile radius of the town of Libby.
EPA has conducted cleanup activities at the Libby site since 2000.
Despite Region 8's extensive communication efforts that exceed
minimum Superfund requirements, residents have recurring
questions. Region 8 also has not fully satisfied community
concerns about health risk nor effectively communicated the
limitations of its risk assessment. An overall communication
strategy could help Region 8 assess the effectiveness of and
improve its communication activities.
Handouts at the EPA information We recommended that EPA Region 8 revise the Libby community
center in Libby. (EPA photo) engagement plan to serve as the overall communication strategy by
identifying key messages and including timelines, measures of
success, and mechanisms for identifying public concerns and obtaining public feedback.
Region 8 agreed to take sufficient corrective actions.
(Report No. ll-P-0430, An Overall Strategy Can Improve Communication Efforts at
Asbestos Superfund Site in Libby, Montana, August 3, 2011)
Potential Issues Noted at Two Deleted Superfund Sites
Hyperspectral imaging data, on-site testing, and/or soil samples revealed
contamination issues at the Middletown Road Dump site in Annapolis, Maryland,
and the Matthews Electroplating site in Roanoke County, Virginia.
The OIG entered into an interagency agreement with the U.S. Geological Survey to
develop and test hyperspectral remote sensing technologies for the detection of fugitive
and residual contamination at deleted Superfund waste sites. Subsequently, the U.S.
Geological Survey entered into an interagency agreement with the U.S. Air Force Civil
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Semiannual Report to Congress
April 1, 2011—September 30, 2011
Hog confinement. (EPA photo)
Air Patrol to use its remote sensing system to collect hyperspectral imagery at five
deleted former National Priorities List sites in Maryland and Virginia.
Conditions at two of the five deleted Superfund sites we visited in EPA Region 3 may
warrant additional attention from EPA. Hyperspectral imaging data identified an anomaly
at the Middletown Road Dump site that proved to be leachate coming from the landfill.
On-site testing also indicated hydrocarbons pooling in surface waters, and soil samples
collected contained amounts of arsenic, chromium, mercury, and antimony that exceeded
established levels. Soil samples taken at the Matthews Electroplating site contained
amounts of arsenic, nickel, and antimony that exceeded EPA's established levels.
We presented our results in an early warning report to Region 3, and the Agency agreed
with our recommendations to assess whether any additional action is warranted. OIG
work is ongoing to assess the usefulness of remote sensing technology as an OIG
oversight tool.
(Report No. ll-P-0433, Observed Conditions at Five Deleted Superfund Sites,
August 3, 2011)
EPA Should Strengthen Oversight of Georgia's Concentrated Animal
Feeding Operation Program
In response to a hotline complaint that EPA Region 4 was not adequately
overseeing Georgia's Concentrated Animal Feeding Operation (CAFO) Program,
we found significant deficiencies.
A CAFO is a facility where more than 1,000 animal units are confined and fed for a total
of 45 days or more in any 12-month period. The Clean Water Act prohibits the discharge
of pollutants from any point source, including CAFOs, to
navigable waters unless authorized by permit.
Region 4 gave Georgia's CAFO program a positive
assessment because the Georgia Environmental Protection
Division reported that all 48 of the CAFOs with liquid
manure waste systems were inspected in 2010. However, we
identified a number of deficiencies for 34 of those 48
CAFOs. CAFOs were operating without National Pollutant
Discharge Elimination System permits or Nutrient
Management Plans, inspection reports were missing required
components, and the Georgia Department of Agriculture was
not assessing compliance with permit conditions. Region 4 did not assure that these
components of Georgia's CAFO program met requirements. As a result, there was a
significant risk that Georgia's CAFO program was failing to protect water quality.
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Semiannual Report to Congress April 1, 2011—September 30, 2011
We recommended that Region 4 implement controls as established in a 2007
memorandum of agreement between EPA Region 4 and the Georgia Environmental
Protection Division to assure CAFO inspections are accurate and complete. The region
agreed with our recommendation.
(Report No. ll-P-0274, Region 4 Should Strengthen Oversight of Georgia's
Concentrated Animal Feeding Operation Program, June 23, 2011)
Region 4 Should Increase Oversight of North Carolina's Thermal
Variances Renewals
Because of North Carolina Division of Water Quality and EPA Region 4
procedural lapses in National Pollutant Discharge Elimination System permit
renewals, it cannot be determined whether waters are protected from harmful
environmental effects caused by thermal discharges. A hotline complaint alleged
that North Carolina's permits do not protect waters from thermal discharges.
Power and industrial facilities draw water from rivers and lakes to cool equipment, and
then discharge those cooling waters at a higher temperature back into those waterbodies.
Either a state or EPA may issue a variance under Clean Water Act Section 316(a) to
allow facilities to discharge cooling waters at an alternative thermal effluent limit that is
still protective of aquatic life.
Region 4 has not adequately implemented management controls, contained in its
memorandum of agreement with North Carolina, that would assure that National
Pollutant Discharge Elimination System permits comply with the Clean Water Act and
applicable federal regulations. The state and Region 4 will not make further
determinations on the thermal variances until these facilities request National Pollutant
Discharge Elimination System permit renewals. As a result, until 2015, these facilities
will continue discharging heated waters as allowed under their current permits and
thermal variances. We also found that the state limited the public's opportunity to review
information and comment on these variances by not following regulatory requirements
for developing complete permit fact sheets and public notices.
We recommended that EPA Region 4 enforce the management controls of the National
Pollutant Discharge Elimination System memorandum of agreement; verify that thermal
variances are protective of a balanced, indigenous population; and verify that permit fact
sheets and public notices comply with federal regulations. The region agreed with our
recommendations.
(Report No. ll-P-0221, Oversight of North Carolina's Renewals of Thermal Variances,
May 9, 2011)
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Semiannual Report to Congress
April 1, 2011—September 30, 2011
Agency Business Practices and Accountability
Unneeded Funds Totaling $6.6 Million Identified for Deobligation
We identified $6.6 million of potentially unneeded funds that could be deobligated
for three operator certification expense reimbursement grants awarded by EPA
Regions 4 and 5.
To comply with the provisions of the Safe Drinking Water Act, EPA awards expense
reimbursement grants to states to provide training and certification to water system
operators.
For Region 4, we noted $3.3 million for Georgia and $2.3 million for North Carolina that
could be deobligated and the funds used for other purposes. For Region 5, we noted
$1.0 million for Wisconsin that could be deobligated. States faced numerous
impediments in spending the funds, such as staff shortages, the global recession, hiring
freezes, higher-priority water projects, and contractors not completing as much work as
initially proposed.
As a result of our recommendations, Region 4 deobligated over $3.3 million in unneeded
funds from Georgia. For North Carolina, Region 4 extended the project period end date to
January 1, 2012, to allow the state to use its remaining $2.3 million. Region 5 determined
that it could deobligate the $1.0 million we noted, plus an additional $1.2 million from
the Wisconsin grant.
(Report No. ll-P-0228, EPA Should Reduce Unliquidated Obligations Under Expense
Reimbursement Grants, May 16, 2011)
EPA Not Recovering All Reasonable Motor Vehicle and Engine
Compliance Program Costs
By not recovering all reasonable costs of administering the Motor Vehicle and
Engine Compliance Program, the federal government did not collect funds that
otherwise could have been available to offset the federal budget deficit.
EPA's Motor Vehicle and Engine Compliance Program ensures that vehicles and engines
comply with emission standards. The Clean Air Act authorizes EPA to establish fees to
recover all reasonable costs associated with this program. EPA's final rule of May 2004
provides specific requirements for assessing and collecting the fees.
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Semiannual Report to Congress April 1, 2011—September 30, 2011
EPA was not recovering all reasonable costs of
administering the program. We found a $6.5 million
difference between estimated program costs of
$24.9 million and fee collections of $18.4 million, based
on the Agency's cost estimate for FY 2010. EPA's final
rule of May 2004 limits the annual fee increases to
inflation adjustments to EPA's labor costs. The rule does
not allow fee increases to cover EPA's increasing costs.
EPA has not conducted a formal cost study since 2004 to
A vehicle undergoing a dynamometer test to determine its actual program costs, and has not updated
measure vehicle emissions. (EPA photo) , .
the formula in the 2004 tees rule to recover more costs.
We recommended that EPA update the 2004 fees rule to increase the amount of program
costs it can recover, and conduct biennial reviews of the fee collections and the full cost
of operating the program. EPA agreed with our recommendations.
(Report No. ll-P-0701, EPA Should Update Its Fees Rule to Recover More Motor
Vehicle and Engine Compliance Program Costs, September 23, 2011)
Region 5 Should Bill Superfund Oversight Costs More Timely
Untimely billing of oversight costs resulted in delays in replenishing the
Superfund Trust Fund, and therefore limited EPA's ability to timely clean up other
priority sites.
Although potentially responsible parties pay for cleanup at "Enforcement-Lead"
Superfund sites, EPA incurs oversight costs for monitoring the cleanup work. EPA is
authorized to recover these costs from potentially responsible parties.
Based on our audit of oversight billings for nine sites in Regions 1,5, and 9, we found
that Region 5 did not timely bill or did not bill approximately $8.6 million in oversight
costs for two sites. The $8.6 million consists of $2.5 million for costs incurred and
$6.1 million that was not billed prior to our audit. The untimely billing occurred because
the accounting staff has difficulty in allocating costs at sites with multiple agreements
and operable units, and the case management team has difficulty coordinating review of
oversight costs. Further, EPA's policies do not require oversight bills to be issued within
a specific time frame. We did not identify problems with oversight cost billings in
Region 1 or 9.
We recommended that the Region 5 Regional Administrator develop a policy to require
that oversight billings be issued no less frequently than annually, and develop procedures
to help staff prepare oversight billings and resolve billing problems. We also
recommended that the region bill potentially responsible parties for oversight costs at the
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Semiannual Report to Congress April 1, 2011—September 30, 2011
two Superfund sites. The Agency partially agreed with our recommendations and billed
$4 million of the $6.1 million.
(Report No. ll-P-0697, EPA Should Bill Superfund Oversight Costs More Timely,
September 22, 2011)
EPA Needs Workload Data to Better Justify Workforce Levels,
Resource Needs
EPA does not require program offices to collect and maintain workload data, and
the programs do not have databases or cost accounting systems to collect data
on time spent on specific mission-related outputs. Such data are needed to better
justify resource needs.
During the 1980s, EPA conducted comprehensive workload analyses to determine
appropriate workforce levels. EPA has not collected comprehensive workload data or
conducted workload analysis in approximately 20 years.
Federal guidance and standards emphasize the importance of planning work to determine
staffing needs. Without sufficient workload data, program offices are limited in their
ability to justify resource needs and must base budget decisions primarily on subjective
justifications. Organizations of varying sizes and missions have used workload models
for years to justify resource needs. During our audit, we identified some basic concepts of
workload modeling from which EPA could benefit.
We recommended that the Chief Financial Officer conduct a pilot project requiring EPA
offices to collect and analyze workload data on key project activities. The Chief Financial
Officer should use information from the pilot project, along with data from an ongoing
contractor study, to issue guidance to EPA program offices on how to collect, analyze,
and use workload data. EPA partially concurred with our recommendations.
(Report No. ll-P-0630, EPA Needs Workload Data to Better Justify Future Workforce
Levels, September 14, 2011)
EPA Should Improve Personal Computer Contract Oversight
EPA may pay as much as $1.9 million through September 2012 for leased
computers with accessories and technical support that it did not order.
During FY 2009, EPA contracted its desktop computer services with the CTS service
contract. The Office of Environmental Information has primary oversight of the contract,
and the Office of Administration and Resources Management manages the Agency's
personal property.
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Semiannual Report to Congress
April 1, 2011—September 30, 2011
EPA paid the CTS contractor a total of $489,734 over an 11-month period for 3,343
seats—a standard seat includes a leased computer with accessories and technical
support—not ordered by the Agency during the period. EPA did not accept the
contractor's monthly asset management performance self-rating for over a year because
of its nonperformance in properly accounting for and tracking assets. Additionally,
because EPA did not safeguard and track personal computers in accordance with property
regulations, it cannot account for 638 personal computers valued at over $1 million.
Some of these computers may have been replaced under the CTS contract.
We recommended that EPA review and/or modify the CTS contract to adjust the
minimum standard seat requirement, update the property manual to require the separation
of duties in property staff positions, and develop and implement certain processes. EPA
agreed with most of our recommendations.
(Report No. ll-P-0705, EPA's Contract Oversight and Controls Over Personal
Computers Need Improvement, September 26, 2011)
EPA Should Increase Awareness of Scientific Integrity Policies
The EPA Office of Research and Development should improve how it evaluates
the effectiveness of its policies and procedures for scientific integrity and
research misconduct.
EPA Order 3120.5 implements the federal policy on research misconduct, and the Office
of Research and Development and others formulated the Principles of Scientific Integrity
and the associated e-training to further highlight professional ethics for EPA scientists.
Currently, the Office of Research and Development does not test its policies and
procedures because it asserts that few reported instances of
misconduct means that misconduct generally does not occur.
However, staff may lack awareness of key criteria and reporting
requirements necessary to identify and report misconduct. An OIG
survey found that 65 percent of the respondents were unaware of
EPA Order 3120.5, and 32 percent were unaware of EPA's
Principles of Scientific Integrity. We also found that e-training has
not been updated since June 2005 and is not mandatory for Office
of Research and Development staff. Without these additional
internal control efforts, the Office of Research and Development
risks having its science called into question, potentially lessening
the credibility of its work.
Analysis performed at the Cincinnati
Laboratory. (EPA photo)
We recommended that the Office of Research and Development periodically test the
effectiveness of controls to address scientific integrity and research misconduct. We also
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Semiannual Report to Congress April 1, 2011—September 30, 2011
recommended that the office raise awareness of roles, responsibilities, and reporting
steps. The office agreed with our recommendations and provided a corrective action plan.
(Report No. ll-P-0386, Office of Research and Development Should Increase Awareness
of Scientific Integrity Policies, July 22, 2011)
Office of Research and Development Needs to Better Measure
Administrative Savings
The Office of Research and Development's efforts to reduce administrative costs
are noteworthy, but the office needs to improve its measurement mechanism for
assessing the effectiveness of its initiatives to reduce administrative costs.
The goals of the Office of Research and Development's Administrative Efficiencies
Project and the Information Technology Improvement Project, which are two separate
initiatives, include reducing costs by improving efficiency and effectiveness.
The Office of Research and Development used a detailed methodology for the surveys it
conducted during 2005-2010. However, only two surveys have been completed in
5 years, and these surveys only obtained a management perspective on administrative
costs and did not obtain data directly from individual employees, including staff who
spent time on administrative activities. Also, the surveys only considered a select number
of staff, and one survey used more detailed definitions for administrative functions than
the other, which may have impacted the comparability of results.
We recommended that the Office of Research and Development establish a more timely
and accurate system to measure its effective use of resources and to allow the office to
better manage its initiatives to reduce administrative costs. The office generally agreed
with our recommendation.
(Report No. ll-P-0333, Office of Research and Development Needs to Improve Its
Methodof Measuring Administrative Savings, July 14, 2011)
Lessons Learned From Region 7 Effort Could Increase Agency
Efficiency
Using lessons learned from a Region 7 rapid process improvement event
involving the National Pollutant Discharge Elimination System program can
increase benefits achieved in future process improvement efforts.
In August 2008, EPA headquarters, Region 7, and Region 7 states conducted a rapid
process improvement event (also known as a "Kaizen" event) to improve the
effectiveness and efficiency of the National Pollutant Discharge Elimination System
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Semiannual Report to Congress April 1, 2011—September 30, 2011
program. The event identified three process improvements and one implementation
action that can potentially be implemented in other regions. Agency-wide permitting
process changes could result in better communication; time and cost savings; and
avoidance of duplicate inspections, reviews, and data reporting.
Although event participants continued to follow up on the commitments and action items
identified, no single authority was responsible for tracking the process improvement
outcomes. Further, EPA encountered barriers involving scope, performance measures,
implementation, and accountability when planning the event.
We recommended that EPA identify process improvements from the Region 7 Kaizen
event that can be applied elsewhere, and that EPA develop a national policy on how to
plan, design, and implement business process improvement events. The Agency agreed
with our recommendation to apply results more widely but did not fully respond to our
recommendations on developing national policy.
(Report No. ll-P-0315, Agency-Wide Application of Region 7 NPDES Program Process
Improvements Could Increase EPA Efficiency, July 6, 2011)
EPA Should Resolve Audit Appeals More Timely
Because audits under appeal are not being resolved timely, at least $17.3 million
is not available to the government that could potentially be used to protect public
health and the environment.
When a grantee disagrees with a Final Determination Letter issued by EPA sustaining
some or all of the questioned costs identified in an audit of a completed grant, the grantee
can appeal to the Regional Administrator or Assistant Administrator of the issuing EPA
office.
EPA's efforts to resolve over $55 million for audits under appeal in Regions 2 and 5 were
not efficient, effective, or timely. Inadequate communications between audit follow-up
coordinators and EPA personnel responsible for resolving audits under appeal resulted in
inaccurate information in EPA's Management Audit Tracking System. Further, policies
and procedures were not complete and relevant. Federal and EPA regulations require that
appeals be resolved in the earliest practicable timeframe, but as of September 2010, 17 of
30 audits under appeal had been in resolution for 10 to 21 years.
We recommended that EPA ensure that the in-process revisions to EPA Manual 2750
include a communication strategy to ensure that EPA records current data on audits under
appeal, establish a finite number of reconsideration requests, and provide for consistency
among policies for resolving audits under appeal. The Agency generally agreed with the
report's findings but proposed alternatives to the recommendations.
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Semiannual Report to Congress April 1, 2011—September 30, 2011
(Report No. ll-P-0687, EPA Should Improve Timeliness for Resolving Audits Under
Appeal, September 21, 2011)
EPA Should Strengthen Travel Authorization Process Controls
The Agency's lack of sufficient management controls to ensure that travel
documents are properly routed and authorized leaves its travel system
vulnerable to fraud, waste, and abuse.
GovTrip is the EPA travel management system that provides travelers with automated
travel planning and reimbursement capabilities. The General Services Administration
authorized the use of GovTrip. EPA's Office of the Chief Financial Officer manages
GovTrip for the Agency.
The EPA travel program lacks sufficient management controls to ensure that travel
documents are properly routed and authorized. The system allows unauthorized personnel
to self-approve travel, and does not ensure that GovTrip routing lists are controlled to
ensure an independent review of travel. We did not identify any instances of fraud during
our review.
We recommended changes to prevent the self-authorization of travel at any level within
the Agency, and to prevent personnel from being on routing lists that give them the
authority to self-authorize travel. We also recommended that computer programs be run
monthly to determine whether travelers are in compliance with policy. The Agency's
response included an attachment that addressed each of our recommendations, along with
proposed corrective actions and completion milestones.
(Report No. ll-P-0223, EPA Needs to Strengthen Management Controls Over Its Travel
Authorization Process, May 10, 2011)
EPA Taking Steps to Recapture Improper Payments
Although EPA does not claim to have a formal payment recapture audit program,
many of its activities to recapture improper payments meet OMB's definition of a
payment recapture audit program.
Each year, the federal government loses billions of dollars on improper payments to
individuals, organizations, and contractors. In November 2010, OMB required all agencies
to submit a payment recapture audit plan describing current payment recapture efforts.
In its January 2011 submission to OMB, EPA stated that it did not have a formal payment
recapture audit program. However, based on the OMB guidance issued in April 2011 and
information EPA had previously submitted to OMB, many of the activities EPA already
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Semiannual Report to Congress April 1, 2011—September 30, 2011
conducts meet the definition of a payment recapture audit program. We reviewed EPA's
improper payments methodology and found three areas in which all improper payment
efforts were not quantified: contract cost issues identified by the Defense Contract Audit
Agency, costs questioned identified during Agency post-award grant reviews, and costs
questioned in OIG and Single Audit reports.
We recommended that EPA report the results of all activities when reporting on its
payment recapture audit program in 2011, and the Agency agreed.
(Report No. ll-P-0362, EPA Needs to Reexamine How It Defines Its Payment Recapture
Audit Program, July 19, 2011)
Allegations Regarding Contract Termination Not Substantiated
In response to a hotline complaint, we found that allegations that EPA unfairly
terminated a contract with ASW Associates, Inc., and that EPA had replaced
Superfund appropriations with Recovery Act funds, were not substantiated.
EPA awarded ASW Associates, Inc., a Superfund contract for environmental remediation
services in September 2008. In January 2009, the U.S. Department of Energy suspended
ASW from contracting with government agencies for submitting invoices with false
certifications. EPA consequently awarded a second contract to a different contractor to
obtain the same services.
We found that the ASW contract was solely funded with Superfund appropriations and
no Recovery Act appropriations were obligated. Secondly, the ASW contract was not
terminated for convenience as alleged; EPA elected not to exercise an option. Although
none of the complainant's allegations were substantiated, EPA could have awarded a less
risky contract type. EPA awarded a time and materials contract but could have awarded a
fixed-price contract. Also, EPA did not perform some required contract administration
functions, such as required annual invoice reviews and an interim contractor performance
evaluation.
We made recommendations to EPA to address the issues noted, and EPA agreed to take
the needed corrective actions.
(Report No. ll-P-0217, Hotline Allegations Unsubstantiated, but Region 7 Contract
Administration and Award Issues Identified, May 4, 2011)
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Semiannual Report to Congress April 1, 2011—September 30, 2011
Investigations
Criminal Charges Continue In Bid Rigging Case at New Jersey
Superfund Sites
Four men were sentenced in U.S. District Court for the District of New Jersey on
criminal charges related to a bid rigging case at several New Jersey Superfund sites.
Two of the four men received prison sentences.
• On September 12, 2011, Robert P. Griffiths, a former executive of Bennett
Environmental, Inc. (BEI), was sentenced to 50 months in prison. Griffiths was
sentenced for participating in money-laundering and fraud conspiracies in
connection with contracts at the Federal Creosote Superfund Site in Manville,
New Jersey, and for impeding a proceeding before the U.S. Securities and
Exchange Commission. Griffiths was also sentenced to pay a $15,000 fine and
$4,644,379 in restitution, jointly and severally with other co-conspirators.
Griffiths' sentencing follows his July 6, 2009, guilty plea to defrauding the EPA
with others by inflating the prices he charged to an EPA prime contractor and
providing kickbacks to employees of that prime contractor at the Federal
Creosote site. Griffiths and his co-conspirators were given the bid prices of BEFs
competitors, which allowed BEI to submit the highest possible bid prices and still
be awarded the subcontracts. Kickbacks were in the form of money, lavish
cruises, entertainment tickets, pharmaceuticals, and electronics. The
co-conspirators were able to allocate at least $43 million in fraudulently awarded
subcontracts to BEI for work at the Federal Creosote site. BEI is a Canada-based
company that treats and disposes of contaminated soil.
Griffiths and his co-conspirators also conspired to commit international money
laundering so that Griffiths could personally benefit from the fraud and kickback
scheme. In addition, Griffiths made false statements to the U.S. Securities and
Exchange Commission to deceive the Commission and conceal his conduct in the
fraudulent scheme.
• On May 23, 2011, Norman Stoerr, a former contracts administrator for Sevenson
Environmental Service, based in Niagara Falls, New York, was sentenced to
8 months of home detention and 60 months of probation. He was also ordered to
pay a $25,000 fine and $391,228 in restitution, jointly and severally with other
co-conspirators. Stoerr's sentencing follows his 2008 guilty plea to charges of
fraud, bid rigging, and tax crimes. Stoerr solicited and accepted thousands of
dollars in kickbacks in exchange for his help in getting companies lucrative
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Semiannual Report to Congress April 1, 2011—September 30, 2011
subcontract work at the Federal Creosote site and the Diamond Alkali Superfund
Site in Newark, New Jersey.
• On April 26, 2011, Victor Boski and his company, National Industrial Supply,
were sentenced to 36 months' probation. He was also ordered to pay a $25,000
fine and $50,000 in restitution, jointly and severally with other co-conspirators.
National Industrial Supply was ordered to serve 36 months probation and pay a
$32,000 fine and $50,000 in restitution, joint and severally with other
co-conspirators. In March 2009, Boski and National Industrial Supply, an
industrial pipes, valves, and fittings supply company located in Middlesex,
New Jersey, pleaded guilty to participating in a separate kickback and fraud
conspiracy at the Federal Creosote and Diamond Alkali Superfund sites.
• On April 6, 2011, John Drimak and his company, JMJ Environmental, Inc.,
a Laurel Springs, New Jersey, wastewater treatment supply company, were
sentenced to 18 months in prison to be followed by 36 months' probation. He
was also ordered to pay a $30,000 fine and $283,242 in restitution, jointly and
severally with other co-conspirators. JMJ Environmental was ordered to serve
12 months' probation and pay $283,242 in restitution, jointly and severally with
other co-conspirators. In July 2008, Drimak and JMJ Environmental pleaded
guilty to bid rigging, fraud, and tax charges in connection with paying kickbacks
for subcontracts for wastewater treatment supplies and services at the Federal
Creosote and Diamond Alkali Superfund sites.
To date, 10 individuals and 3 companies have been charged as part of this investigation.
More than $6 million in criminal fines and restitution have been imposed, and five
individuals have been sentenced to serve prison time.
This case is being conducted with the Internal Revenue Service Criminal Investigation
Division.
Two State Employees Sentenced for Travel Fraud
On August 8, 2011, former Arkansas Department of Health (ADH) employee Craig
Burger was sentenced in the Circuit Court of Pulaski County, Arkansas, to 8 years in
prison to be followed by 12 years of supervised probation. He was also ordered to pay
$45,306 in restitution to ADH for his role in falsely claiming hotel expenses for
approximately 5 years while being paid under an EPA Drinking Water State Revolving
Fund loan awarded to ADH.
On September 14, 2011, another former ADH employee, Mark Allen Mclntosh, was
sentenced to 60 months of probation and 50 hours of community service, and ordered to
pay a $2,500 fine and $275 in court costs, for his role in falsely claiming hotel expenses.
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Semiannual Report to Congress April 1, 2011—September 30, 2011
Under the State Revolving Fund loan, Burger and Mclntosh were paid to visit community
water systems to provide training and technical assistance to water operators. For a period
of 3 to 5 years, Burger and Mclntosh falsely claimed meals and hotel expenses by
submitting false hotel and per diem receipts to ADH for payment.
Two Sentenced for Defrauding Idaho Department of Environmental
Quality
Jorge Garcia and Karen Damberg Garcia, both of Boise, Idaho, were sentenced in U.S.
District Court for the District of Idaho for conspiring to defraud the Idaho Department of
Environmental Quality (IDEQ) of EPA grant funds that were to be used to install diesel
emission reduction equipment on school buses. Jorge Garcia was sentenced to 30 months
in prison to be followed by 3 years of supervised release. Karen Garcia was sentenced to
5 months of probation with 10 months of home detention, also to be followed by 3 years
of supervised release. The two were also ordered to pay $42,333 in restitution to IDEQ.
In 2008, Jorge Garcia was a project manager for IDEQ and was in charge of the school
bus diesel emission reduction project. He was to identify school districts eligible for the
project, identify vendors to provide the parts for the diesel retrofits, and determine how to
complete the installation of the reduction technology. Using the name Emission Control
Systems, the Garcias submitted a bid to IDEQ for the retrofit work. The bid was
submitted using only Karen Damberg's name and did not disclose Jorge Garcia's role in
the business. IDEQ awarded the contract to the firm, which was paid $332,320 under the
contract. The mechanic hired by Garcia to perform the work under the contract was not
experienced in the work he was asked to do, resulting in improper installation that
damaged school buses. IDEQ estimates that it will cost $208,000 to repair the buses and
$477,000 to properly install the diesel emission reduction devices.
Grantee Sentenced in Fraud Scheme
On May 24, 2011, Martin Cabrera, former Vice President, Saipan Pacific Environmental
Planning and Consulting, Saipan, was sentenced in the U.S. District Court for the District
of Oregon for one count of wire fraud. Cabrera was previously indicted in the Judicial
District of the Commonwealth of the Northern Mariana Islands, where the crime
occurred. Cabrera was ordered to serve 3 years of supervised probation, and to pay
$8,650 in restitution to EPA and $3,950 to the Commonwealth of the Northern Marianas
Islands' Department of Public Lands (DPL).
Cabrera was awarded a DPL contract funded by EPA in May 2007 for completion of
Phase I Environmental Site Assessments. Cabrera fraudulently used the identities and
work experience of others in the contract proposal he submitted to the DPL. Saipan
Pacific Environmental Planning and Consulting was awarded a DPL contract based on its
proposal, received a partial payment from DPL, and later produced no deliverables.
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Semiannual Report to Congress April 1, 2011—September 30, 2011
Cabrera repeatedly failed to meet with DPL to discuss his lack of performance and
ultimately fled Saipan and moved to Oregon.
Former Commonwealth Official Found Guilty
On September 23, 2011, Franz Reksid, former Special Assistant to the Secretary of DPL
in the Commonwealth of the Northern Mariana Islands, was found guilty of bribery in the
U.S. District Court for the Northern Mariana Islands.
From 2007 to 2009, Reksid was the special assistant to the DPL secretary, responsible for
managing DPL contracts with funding provided from EPA Brownfield grants. In
February 2009, Reksid recommended that a contract, previously awarded in 2007 to John
Scott, President, All Hazards Management Professionals, LLC, Yona, Guam, be amended
to include an additional $200,000 for the cleanup and disposal of unexploded ordnance
located at the Marpi Village Homestead Site. The original contract for $297,152 required
Scott to assess the Commonwealth of the Northern Mariana Islands government-owned
lands on Saipan for unexploded ordnance located on the Marpi site. While recommending
the above-mentioned contract amendment to the DPL secretary, Reksid sought and
received from Scott a $3,000 "loan."
The investigation determined that Reksid only sought approval from the DPL secretary
and other DPL officials to amend the contract to extend the amount of time but not for
the additional $200,000. Former DPL officials testified at Reksid's trial that he concealed
from them his intentions to add $200,000 to Scott's existing contract and never sought
their approval for such a change order. Reksid ultimately routed the amended version of
Scott's contract to the finance department using the signature page of the original 2007
contract in order to receive the additional funding made available by EPA to DPL.
Other Activities
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 are the audit, evaluation, investigation, and legislative experiences of the OIG,
as well as our participation on the Council of the Inspectors General on Integrity and
Efficiency. During the reporting period, we reviewed 103 proposed changes to
legislation, regulations, policy, and procedures that could affect EPA and/or the Inspector
General, and provided comments on 10. We also reviewed drafts of OMB circulars,
memoranda, executive orders, program operations manual, directives, and
reorganizations. Details on two items follow.
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Semiannual Report to Congress April 1, 2011—September 30, 2011
Proposed Revisions to EPA Order 1400.1 A3, Preventing Violence in The Workplace.
EPA's Office of Human Resources proposed revisions to EPA Order 1400.1 A3. The
revised Order affirms EPA's commitment to protect EPA and non-EPA employees while
in EPA-controlled space or wherever official duties are performed. The Order also
provides a collaborative mechanism intended to prevent violence in the workplace
through an Agency-wide strategy for education, intervention, and incident response and
reporting. We identified apparent inconsistencies with the stated purpose of the
document. We also provided a number of comments to help strengthen and clarify the
policy, including that the OIG has primary investigative jurisdiction on behalf of EPA
and will lead investigations into workplace violence.
National Security Staffs Proposed Executive Order, Structural Reforms to Improve
the Security of Classified Networks and the Responsible Sharing and Safeguarding of
Classified Information. The National Security Staffs proposed Executive Order would
direct certain structural reforms to ensure responsible sharing and safeguarding of
classified information on computer networks. We identified a number of areas where we
believe the department's or agency's inspector general could provide the needed oversight,
expertise and assistance. We also commented that the inspector general of a federal
department or agency that operates or accesses classified computer networks shall:
(a) Designate cleared personnel to provide oversight and investigations of agency
or department programs.
(b) Perform and/or coordinate insider threat investigations with the Federal Bureau
of Investigation or other law enforcement entities.
(c) Report on independent assessment and findings to the respective taskforce,
committee, and executive agent.
(d) Assign representation to the Insider Threat Task Force.
Peer Reviews Conducted
The most recent external peer review of the EPA OIG was conducted by the U.S.
Department of Homeland Security OIG in accordance with Government Auditing
Standards and guidelines established by the Council of the Inspectors General on Integrity
and Efficiency. The Homeland Security OIG reviewed our system of quality controls for
the period October 1, 2005, through September 30, 2008. The report, issued July 10, 2009,
contained no recommendations, and the EPA OIG received a rating of pass.
The EPA OIG conducted an external peer review of the system of quality control for the
audit organization of the Treasury Inspector General for Tax Administration. Our review
of that organization covered the period April 1, 2006, through March 31, 2009, and was
also completed in accordance with Government Auditing Standards and guidelines
established by the Council of the Inspectors General on Integrity and Efficiency. Our
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April 1, 2011—September 30, 2011
report, issued February 3, 2010, contained no recommendations and provided the
Treasury Inspector General for Tax Administration a rating of pass.
U.S. Chemical Safety and Hazard Investigation Board
The U.S. Chemical Safety and Hazard Investigation Board (CSB) was
created by the Clean Air Act Amendments of 1990. CSB's mission is
to investigate accidental chemical releases at facilities, report to the
public on the root causes, and recommend measures to prevent future
occurrences.
In FY 2004, Congress designated the EPA Inspector General to serve as the Inspector General for CSB.
As a result, 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. Details on our work involving CSB are at
http://www.csb.gov/service.default.aspx.
EPA OIG Proposes Management Challenges for CSB
On August 3, 2011, the EPA OIG provided to CSB two management challenges. Details
on the challenges follow.
• Clarifying CSB's Statutory Mandate. OMB Circular A-123 instructs agencies
to design a management structure that helps ensure accountability for results as
they develop and execute strategies for implementing agency programs and
operations. CSB stated that it needed to seek additional guidance from OMB and
Congress before it commits to a long-term plan of action, and agreed to work
with Congress to clarify its statutory mandate. CSB requested clarification from
Congress in November 2009, but as of August 2011, CSB had not received a
response. After Congress clarifies CSB's statutory mandate, CSB's greatest
challenge as it develops outcome-oriented performance goals and measures will
be getting data to measure results.
• Promulgating a Chemical Incident Reporting Regulation. CSB has not
published a chemical incident reporting regulation as envisioned in the Clean Air
Act Amendments. In 2008, the U.S. Government Accountability Office
recommended that CSB publish a regulation requiring facilities to report all
chemical accidents. In 2009, CSB notified the public of a proposed reporting
regulation. CSB had not published the regulation as of August 2011. As CSB
continues its efforts to implement a chemical incident reporting regulation, it
should consider how the regulation would coordinate with other chemical
incident reporting requirements, the impact such a requirement will have on its
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Semiannual Report to Congress April 1, 2011—September 30, 2011
resources, and the cost effectiveness associated with using an existing chemical
incident reporting system.
In response, CSB indicated that its strategic plan is under major redevelopment, with
emphasis on outcome-related goals and objectives for measuring the CSB's effectiveness.
CSB also indicated that it would publish a regulation in 2011, but was largely doing so to
comply with the statutory requirement. CSB did not believe the regulation would result in
significantly more timely or accurate notification of incidents.
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Semiannual Report to Congress
April 1, 2011—September 30, 2011
Statistical Data
Profile of Activities and Results
Audit and evaluation operations
Office of Inspector General reviews
April 1,2011-
September 30, 201 1 FY
($ in millions) 2011
Questioned costs * $3.8 $6.7
Recommended efficiencies * $58.0 $65.5
Costs disallowed to be recovered $0 $0.06
Costs disallowed as cost efficiency $54.6 $62.1
Reports issued by DIG 46 85
Reports resolved 514 721
(Agreement by Agency officials
to take satisfactory corrective
actions) **
Audit and evaluation operations
Reviews performed by Single Audit Act auditors
April 1,2011-
SeptemberSO, 2011 FY
($ in millions) 201 1
Questioned costs * $1 .5 $4.0
Recommended efficiencies * $0 $0
Costs disallowed to be recovered $0.4 $0.6
Costs disallowed as cost efficiency $0 $0
Single Audit Act reviews 468 636
Agency recoveries $2.7 $7.0
Recoveries from audit and
evaluation resolutions of current
and prior periods (cash collections
or offsets to future payments) ***
Investigative operations
April 1,2011-
SeptemberSO, 2011
($ in millions)
Total fines and recoveries **** $3.2
Cost savings $0.028
Cost avoidances $0.820
Cases open during period 77
Cases closed during period 45
Indictments/informations of persons 8
or firms
Convictions of persons or firms 14
Civil judgments/settlements/filings 1
FY
2011
$3.9
$0.028
$2.2
131
84
17
15
1
Questioned costs and recommended efficiencies are
subject to change pending further review in the audit
resolution process.
Reports resolved are subject to change pending
further review.
Information on recoveries from audit resolutions is
provided by EPA's Office of Financial Management
and is unaudited.
Fines and recoveries resulting from joint
investigations.
40
-------
Semiannual Report to Congress
April 1, 2011—September 30, 2011
Audit, Inspection, and Evaluation Report Resolution
Status report on perpetual inventory of reports in resolution process
for semiannual period ending September 30, 2011
Report category
A. For which no management
decision was made by
April 1,2011*
B. Which were issued during the
reporting period
C. Which were issued during the
reporting period that required
no resolution
Subtotals (A + B - C)
D. For which a management
decision was made during the
reporting period
E. For which no management
decision was made by
September 30, 2011
F. For which no management
decision was made within
6 months of issuance
No. of
reports
60
507
412
155
457
110
26
Report issuance
($ in thousands)
Questioned
costs
$14,083
5,390
0
19,473
5,358
14,115
1,159
Recommended
efficiencies
$0
54,647
0
54,647
54,647
0
0
Report resolution costs
sustained
($ in thousands)
To be
recovered
$528
134
0
662
662
0
0
As
efficiencies
$0
54,647
0
54,647
54,647
0
0
Any difference in number of reports and amounts of questioned costs or recommended efficiencies between this
report and our previous semiannual report results from corrections made to data in our audit tracking system.
Status of management decisions on OIG reports
This section presents additional statistical information that is required by the Inspector General Act of
1978, as amended, on the status of EPA management decisions on reports issued by the OIG involving
monetary recommendations. Tables 1 and 2 cannot be used to assess results of reviews performed or
controlled by the OIG. Many of the reports were prepared by other federal auditors or independent public
accountants. EPA OIG staff do not manage or control such assignments. Auditees frequently provide
additional documentation to support the allowability of such costs subsequent to report issuance.
41
-------
Semiannual Report to Congress
April 1, 2011—September 30, 2011
Table 1: Inspector General-issued reports with questioned costs for semiannual period ending
September 30, 2011 ($ in thousands)
Report category
A. For which no management decision was made by
April 1,2011 **
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, 2011
Reports for which no management decision was made
within 6 months of issuance
No. of
reports
24
13
37
9
9
-
23
10
Questioned
costs *
$14,083
5,390
19,473
5,358
662
4,696
14,115
1,159
Unsupported
costs
$10,004
4,332
14,336
2,002
583
1,419
12,334
1,159
Questioned costs include unsupported costs.
Any difference in number of reports and amounts of questioned costs between this report and our previous
semiannual report results from corrections made to data in our audit, inspection, and evaluation tracking system.
Table 2: Inspector General-issued reports with recommendations that funds be put to better use
for semiannual period ending September 30, 2011 ($ in thousands)
Report category
A.
B.
For which no management decision was made by April 1 , 201 1 *
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
(iii) Dollar value of non-awards or unsuccessful bidders
D.
For which no management decision was made by September 30, 201 1
For which no management decision was made within 6 months of issuance
No. of
reports
0
5
5
5
5
0
0
0
0
Dollar
value
$0
54,647
54,647
54,647
54,647
0
0
0
0
Any difference in number of reports and amounts of funds put to better use between this report and our previous
semiannual report results from corrections made to data in our audit, inspection, and evaluation tracking system.
Audits, inspections, and evaluations with no final action as of September 30, 2011, over 365 days past
the date of the accepted management decision (including audits, inspections, and evaluations in appeal)
Audits, inspections, and evaluations
Program
Assistance agreements
Contract audits
Single audits
Financial statement audits
Total
Total
36
10
0
17
1
64
Percentage
56
16
0
27
1
100
42
-------
Semiannual Report to Congress
April 1, 2011—September 30, 2011
Hotline Activity
The following table shows EPA OIG hotline activity regarding complaints of fraud, waste, and abuse in
EPA programs and operations during the past semiannual reporting period and for the annual period
ending September 30, 2011.
Issues open at the beginning of the period
Inquiries received during the period
Inquiries closed during the period
Inquiries pending at the end of the period
Issues referred to others
OIG offices
EPA program offices
Other federal agencies
State/local agencies
Semiannual period
(April 1,201 1-
SeptemberSO, 2011)
133
104
119
118
61
39
1
3
Annual period
(October 1,201 0-
SeptemberSO, 2011)
16
252
150
118
124
112
5
11
43
-------
Semiannual Report to Congress
April 1, 2011—September 30, 2011
Summary of Investigative Results
Summary of investigative activity during reporting period
Cases open as of April 1, 2011
Cases opened during period
Cases closed during period
Cases pending as of September 30, 201 1
178
77
45
210
Investigations pending by type as of September 30, 2011
Contract fraud
Assistance
agreement fraud
Employee integrity
Program integrity
Computer crimes
Other
Total
Superfund
8
2
3
1
0
1
15
Management
10
28
34
18
6
9
105
Split
funded
5
9
11
9
8
3
45
Recovery
Act
16
20
0
1
0
6
43
Chemical
Safety Board
0
0
1
1
0
0
2
Total
39
59
49
30
14
19
210
Results of prosecutive actions
Criminal indictments/informations/complaints
Convictions
Civil judgments/settlements/filings
Fines and recoveries (including civil)
Prison time
Home detention
Probation
Community service
EPA OIG only
1
4
1
$180,592
42 months
10 months
144 months
0 hours
Joint*
7
10
0
$2,902,693
188 months
8 months
456 months
50 hours
Total
8
14
1
$3,083,285
230 months
18 months
600 months
50 hours
'' With another federal agency.
Administrative actions
Suspensions
Debarments
Other administrative actions
Total
Administrative recoveries
Cost avoidance
EPA OIG only
32
7
3
42
$76,153
$471,117
Joint*
15
0
0
15
$0
$348,833
Total
47
7
3
57
$76,153
$819,950
* With another federal agency.
44
-------
Semiannual Report to Congress
April 1, 2011—September 30, 2011
Scoreboard of Results
Scoreboard of OIG FY 2011 performance results compared to
annual performance goal targets
All results reported in FY 2011, from current and prior years' work, are as reported in OIG Performance Measurement
and Results System, Inspector General Operations Reporting System, and Inspector General Enterprise
Management System. These results are unaudited.
OIG FY 2011 Government Performance and
Results Act annual performance targets
compared to FY 2011 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: 334
Reported: 272 (81%)
1 Legislative/regulatory changes/decisions
72 Environmental or management policy, process,
practice, control change actions taken
13 Best practices implemented
2 Environmental/health improvements
5 Environmental/business risks/challenges eliminated
94 Certifications/validations/verifications/corrections
9 Actions taken or resolved prior to report issuance
(not otherwise reported)
76 Recommendations reported as implemented
previously identified unimplemented by OIG follow-up*
Environmental and business
recommendations, challenges, best practices,
risks identified, Recovery Act technical
briefings
Target: 903
Reported: 1,943 (215%)
495 Recommendations (for Agency/stakeholder action)
22 Critical congressional or public management concerns
addressed
5 Best practices identified
31 Referrals for Agency action
8 New environmental or management operational risks
or challenges identified
61 Unimplemented recommendations identified
1,225 Findings without controlled recommendations
96 Awareness briefings/outreach sessions
Return on investment: Potential dollar return as
percentage (120%) of OIG budget $54.7 million
Target: $65.6 million
Reported: $82.4 million (151%)
($ in millions)
$10.8 Questioned costs (net EPA)
$67.7 Recommended efficiencies, costs saved (EPA)*
$3.91 Fines, recoveries, settlements
Criminal, civil, and administrative actions
reducing risk of loss/operational integrity
Target: 80
Reported: 160 (200%)
15 Criminal convictions
17 Indictments/informations/complaints
1 Administrative actions
104 Civil actions
24 Allegations disproved
Other (no targets established)
Sustained monetary recommendations and
savings achieved from current and prior
periods: $55.5 million
Sustained environmental and management
recommendations for resolution action
Recovery Act activity results (cumulative)
Total reports issued: 721
($ in millions)
$0.78 Questioned costs sustained
$54.7 Cost efficiencies sustained or realized
258 Sustained recommendations
163 Recovery Act awareness briefings/outreach sessions
(also counted above)
71 Recovery Act complaints received
85 OIG-produced reports
636 Reports by other audit entities with OIG oversight
Includes $2.16 million in savings from investigations.
45
-------
Semiannual Report to Congress
April 1, 2011—September 30, 2011
Appendices
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. This listing includes a section for
reports involving the American Recovery and Reinvestment Act of 2009.
Questioned Costs
Report no.
Report title
Date
Ineligible
costs
Unsupported
costs
Unreasonable
costs
Federal
recommended
efficiencies
PERFORMANCE REPORTS
11-P-0209 EPA's Plan to Reduce Agency Greenhouse Gas Emissions is on Track Apr. 12, 2011
11-P-0215 EPA's Endocrine Disruptor Screening Program Should Establish Controls May 3, 2011
11-P-0217 Hotline Allegations Unsubstantiated, But Region 7 Contract Issues Identified May 4, 2011
11-P-0221 Oversight of North Carolina's Renewal of Thermal Variances May 09, 2011
11-P-0223 Review of Travel Controls May 10,2011
11-P-0228 EPA Should Reduce Expense Reimbursement Grant Unliquidated Obligations May 16, 2011
11-P-0273 EPA BP and Enbridge Oil Spill Response Communication Jun. 23, 2011
11-P-0274 Region 4 Oversight of Georgia's Concentrated Animal Feeding Operations Jun. 23, 2011
11-P-0277 EPA Has Taken Steps to Address Cyber Threats but Key Actions Incomplete Jun. 23, 2011
11-P-0315 Agency-Wide Application of Region 7 NPDES Program Process Improvements Jul. 06, 2011
11-P-0333 ORD Needs to Improve Its Method of Measuring Administrative Savings Jul. 14, 2011
11-P-0362 EPA Needs to Reexamine Payment Recapture Audit Program Jul. 19, 2011
11-P-0379 EPA's Voluntary Chemical Evaluation Program Did Not Achieve Children Goals Jul. 21, 2011
11-P-0386 ORD Should Increase Awareness of Scientific Integrity Policies Jul. 22, 2011
11-P-0429 Technical Network Vulnerability Assessment: NHEERL Aug. 03,2011
11-P-0430 Communication Efforts as Asbestos Superfund Site in Libby Montana Aug. 03, 2011
11-P-0433 Observed Conditions at Five Deleted Superfund Sites Aug. 03, 2011
11-P-0527 EPA's Gulf Coast Oil Spill Response Shows Documentation, Funding Practices Aug. 25, 2011
11-P-0534 Revisions to National Contingency Plan Based on Deepwater Horizon Oil Spill Aug. 25, 2011
11-P-0597 Technical Vulnerability Assessment: EPA's Directory Service System Sep. 09, 2011
11-P-0616 National Emergency Response Equipment Tracking System Sep. 13,2011
11-P-0630 EPA Needs Workload Data to Better Justify Future Workforce Levels Sep. 14, 2011
11-P-0687 EPA Should Improve Timeliness for Resolving Audits Under Appeal Sep. 21, 2011
11-P-0697 Unbilled Oversight Costs Sep. 22,2011
11-P-0701 Fees Rule to Recover Motor Vehicle and Engine Compliance Program Costs Sep. 23, 2011
11-P-0702 EPA's Greenhouse Gases Endangerment Finding Data Quality Processes Sep. 26, 2011
11-P-0705 EPA's Contract Oversight and Controls Over Personal Computers Sep. 26, 2011
11-P-0706 Waste Management Role With Respect to Oil Spills of National Significance Sep. 26, 2011
11-P-0708 EPA Progress on the 2007 Methamphetamine Remediation Research Act Sep. 26, 2011
11-P-0722 EPA Should Prepare and Distribute Security Classification Guides Sep. 29, 2011
11-P-0725 Technical Vulnerability Assessment: Region 9 Sep. 30,2011
TOTAL PERFORMANCE REPORTS = 31
$0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
$0
$0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
$0
$0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
$0
0
0
0
0
5,500,000
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
$0
32,000,000
0
0
0
0
0
6,100,000
13,000,000
0
1,400,000
0
0
0
0
$58,000,000
SINGLE AUDIT REPORTS
11-3-0210 Seely Lake.Missoula County Water District FY 2009
11-3-0211 Sioux Falls South Dakota FY 2009
11 -3-0216 Beaver City, Utah FY 2010
11-3-0218 Columbus, Town of, Montana FY 2010
11-3-0219 Billings, City of FY 2010
11-3-0220 Hanson Rural Water System Inc. FY2010
11-3-0224 Lewis and Clark PSD 161 FY2010
11-3-0225 Menno School District No. 33-2, South Dakota FY 2010
11-3-0226 Missoula, Cityof, Montana FY2010
11-3-0227 Pablo Lake County Water and Sewer District Montana FY 2010
11-3-0229 Greybull, Town of, Wyoming FY2010
11-3-0230 Star Valley Ranch, Town of, Wyoming FY2010
11-3-0231 Superior, Town of, Montana FY 2010
11 -3-0234 Clear Lake, City of FY 2009
11-3-0235 Potlatch, City of FY 2009
11-3-0236 Wisconsin,State of FY 2010
11-3-0237 Connecticut.State of FY 2010
11-3-0238 New Hampshire.State of FY 2010
11-3-0239 Alamo Sewer and Water General Improvement District FY 2010
11-3-0240 Carson City, City of, Nevada FY 2010
11 -3-0242 North Dakota, State of
Apr. 26,
Apr. 29,
May 03,
May 05,
May 06,
May 06,
May 10,
May 10,
May 12,
May 12,
May 20,
May 20,
May 20,
May 24,
May 24,
May 24,
May 24,
May 24,
May 24,
May 24,
May 26,
2011
2011
2011
2011
2011
2011
2011
2011
2011
2011
2011
2011
2011
2011
2011
2011
2011
2011
2011
2011
2011
$0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
38,780
0
0
0
$0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
300,281
0
0
0
0
$0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
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
-------
Semiannual Report to Congress
April 1, 2011—September 30, 2011
Questioned Costs
Report no.
11-3-0243
11-3-0244
11-3-0245
11-3-0246
11-3-0247
11-3-0249
11-3-0250
11-3-0251
11-3-0252
11-3-0253
11-3-0254
11-3-0255
11-3-0256
11-3-0257
11-3-0258
11-3-0259
11-3-0260
11-3-0261
11-3-0262
11-3-0263
11-3-0264
11-3-0265
11-3-0266
11-3-0267
11-3-0268
11-3-0269
11-3-0270
11-3-0271
11-3-0272
11-3-0275
11-3-0276
11-3-0278
11-3-0279
11-3-0280
11-3-0281
11-3-0282
11-3-0283
11-3-0284
11-3-0285
11-3-0286
11-3-0287
11-3-0288
11-3-0289
11-3-0290
11-3-0291
11-3-0292
11-3-0293
11-3-0294
11-3-0295
11-3-0296
11-3-0297
11-3-0298
11-3-0299
11-3-0301
11-3-0302
11-3-0303
11-3-0304
11-3-0305
11-3-0306
11-3-0307
11-3-0308
11-3-0309
11-3-0310
11-3-0311
11-3-0312
11-3-0313
11-3-0314
11-3-0316
11-3-0317
11-3-0318
11-3-0319
Report title
Cave Creek, Town of, Arizona FY 2010
Eloy, City of, Arizona FY 2010
Flagstaff, City of, Arizona FY 2010
Boyce, Town of, Louisiana FY 2010
Alexandria, City of, Louisiana FY2010
Texas, State of FY 2010
California, State of FY 2010
Johnston, Town of, Rhode Island FY2010
Spencer, Town of, Massachusetts FY 2010
Delcambre, Town of FY 2010
Louisiana, State of FY 2010
Vermont, State of FY 2010
Florida, State of FY 2010
Fresno Metropolitan Flood Control District FY2010
Georgia, State of FY 2010
North Carolina, State of FY 2010
Mississippi, State of FY 2010
Mesa, City of, Arizona FY 2010
Tennessee, State of FY 2010
Arenzville, Village of FY 2010
SaultSte. Marie, City of FY 2010
Mineral County School District, Nevada FY 2010
Maryville, City of FY 2010
Grand Ledge, City of FY 2010
Wheaton Sanitary District FY 2010
Arizona, State of FY 2010
Grass Valley, City of, California FY2010
Evanston, City of FY 2010
Pershing County School District FY 2010
Long Beach, City of, California FY 2009
WHY Domestic Water Improvement District, Arizona FY 2009
Alexandria, City of FY 2009
Elbow Lake, City of FY 2009
Astoria, City of, Oregon FY2010
Wyoming, State of FY 2010
Bend, City of, Oregon FY 2010
Paris, City of, Missouri FY 2010
Gateway Metropolitan District FY 2009
California, City of FY 2010
Elk City, City of FY 2010
Dearborn, City of FY 20 10
Shreveport, City of FY 2009
South Central Regional Water District FY 2009
Southeast Water Users FY 2009
Palmer, City of FY 2009
Lower Columbia River Estuary Partnership
Harry S. Truman Water Supply District #2
Westwood Community Services District FY 2010
Toledo, City of, Iowa FY 2010
West Bloomfield, Charter Township of FY 2009
St. Ignace, City of FY 2009
Menasha, Town of FY 2009
Van Buren, Township of FY 2009
Rock Valley, City of, Iowa FY 2010
Washington, State of FY 2010
Houston, City of, Missouri FY2009
Nebraska, State of FY 2010
Missouri, State of FY 2010
West Virginia, State of FY 2010
Lowell, Massachusetts, City of FY 2010
Sioux City, City of, Iowa FY2010
Wymore, City of, Nebraska FY2010
Carterville, City of, Missouri FY2010
Delaware, State of FY 2010
South Carolina State Ports Authority FY 2010
Cameron, City of, Missouri FY2010
Pittsfield.Massachusetts, City of FY 2010
Montgomery County Community College, Pennsylvania - FY 2010
Culpeper, Virginia, Town of FY 2010
Mountain Lake Park, Maryland, Town of FY 2010
Provincetown, Massachusetts, Town of FY 2010
Date
May 26, 2011
May 31, 2011
May 31, 2011
Jun.02, 2011
Jun. 02, 2011
Jun. 07, 2011
Jun. 07, 2011
Jun. 13, 2011
Jun. 13, 2011
Jun. 13, 2011
Jun. 13, 2011
Jun. 14, 2011
Jun. 14, 2011
Jun. 14, 2011
Jun. 14, 2011
Jun. 14, 2011
Jun. 14, 2011
Jun. 14, 2011
Jun. 14, 2011
Jun. 15, 2011
Jun. 15, 2011
Jun. 16, 2011
Jun. 16, 2011
Jun. 16, 2011
Jun. 16, 2011
Jun. 16, 2011
Jun. 16, 2011
Jun. 21, 2011
Jun. 22, 2011
Jun. 23, 2011
Jun. 23, 2011
Jun. 23, 2011
Jun. 23, 2011
Jun. 23, 2011
Jun. 24, 2011
Jun. 24, 2011
Jun. 24, 2011
Jun. 24, 2011
Jun. 24, 2011
Jun. 24, 2011
Jun. 24, 2011
Jun. 24, 2011
Jun. 27, 2011
Jun. 27, 2011
Jun. 28, 2011
Jun. 28, 2011
Jun. 28, 2011
Jun. 28, 2011
Jun. 28, 2011
Jun. 28, 2011
Jun. 29, 2011
Jun. 29, 2011
Jun. 29, 2011
Jun. 29, 2011
Jun. 29, 2011
Jun. 29, 2011
Jun. 29, 2011
Jun. 29, 2011
Jun. 30, 2011
Jun. 30, 2011
Jun. 30, 2011
Jun. 30, 2011
Jun. 30, 2011
Jun. 30, 2011
Jul.05, 2011
Jul.05, 2011
Jul.05, 2011
Jul. 11,2011
Jul. 11, 2011
Jul. 11, 2011
Jul. 11,2011
Federal
Ineligible Unsupported Unreasonable recommended
costs costs costs efficiencies
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
59,209
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
113,972
0
0
0
0
0
0
10,504
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
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
-------
Semiannual Report to Congress
April 1, 2011—September 30, 2011
Questioned Costs
Report no.
11-3-0320
11-3-0321
11-3-0322
11-3-0323
11-3-0324
11-3-0325
11-3-0326
11-3-0327
11-3-0328
11-3-0329
11-3-0330
11-3-0331
11-3-0332
11-3-0334
11-3-0335
11-3-0336
11-3-0337
11-3-0338
11-3-0339
11-3-0340
11-3-0341
11-3-0342
11-3-0343
11-3-0344
11-3-0345
11-3-0346
11-3-0347
11-3-0348
11-3-0349
11-3-0350
11-3-0351
11-3-0352
11-3-0353
11-3-0354
11-3-0355
11-3-0356
11-3-0357
11-3-0358
11-3-0359
11-3-0360
11-3-0361
11-3-0363
11-3-0364
11-3-0365
11-3-0366
11-3-0367
11-3-0368
11-3-0369
11-3-0370
11-3-0371
11-3-0372
11-3-0373
11-3-0374
11-3-0375
11-3-0376
11-3-0377
11-3-0378
11-3-0380
11-3-0381
11-3-0382
11-3-0383
11-3-0384
11-3-0385
11-3-0387
11-3-0388
11-3-0389
11-3-0390
11-3-0391
11-3-0392
11-3-0393
11-3-0394
Report title
Berlin, Maryland, Town of FY 2010
New Jersey, State of FY 2010
New Mexico Environment Department FY 2010
Alliance, City of, Nebraska FY2010
Dyersville, City of, Iowa 2010
Federalsburg, Maryland, Mayor and Council of FY 2010
Garrett, Maryland, County of FY 2010
Tekamah, City of, Nebraska FY2010
Pittsburg, City of, Kansas FY2010
Delmar, Maryland, Mayor and Commissioners of FY 2010
Jane Lew, West Virginia, Public Service District FY 2010
Elkins, West Virginia, City of FY 201 0
Macomb, City of, Illinois FY 2010
Kansas, State of FY 2010
Taunton, Massachusetts, City of FY 2009
North Dakota Public Financing Authority FY 2010
Allegan, Michigan, City of FY 2010
Allen Park, Michigan, City of FY2010
Ann Arbor.Michigan, City of FY 2010
Battle Creek, Michigan, City of FY 2010
Center Line, Michigan, City of FY 2010
Fraser, Michigan, , City of FY2010
Puerto Rico Water Pollution Control Revolving Fund FY 2010
Gering, City of, Nebraska FY 2010
Nebraska, University of FY 2010
Laurens, City of, Iowa FY 2010
Sac City, City of, Iowa FY 2010
Sidney, City of, Nebraska FY2010
Baxter, City of, Iowa FY 20 10
Schuyler, City of, Nebraska FY2010
Duquesne, City of, Missouri FY2010
Sutherland, Village of, Nebraska FY 2010
Garner, City of, Iowa FY 2010
Wyoming, City of, Iowa FY2010
Tipton, City of, Missouri FY2010
Merrimack, New Hampshire, Town of FY 2010
St. Albans, Vermont, City of FY 2010
Brewster, Massachusetts, Town of FY 2010
Pioneer Valley Planning Commission, Massachusetts FY 201 0
Whitehall, City of FY 2009
Cosmos, City of FY 2009
Afton, Town of FY 2010
Ava, City of FY 20 10
Dover, North Carolina, Town of FY 2010
Greenwood, South Carolina, Metropolitan District FY 2010
Tennille, Georgia, City of FY 2010
L'anse, Michigan, Village of FY 2010
Metropolitan Council of the Twin Cities Area, Minnesota
Old Straitsville Water Association Inc., Ohio FY 201 0
Fontana Walworth Water Pollution Control Commission FY 2009
Energy United Water Corporation
Graham, North Carolina, City of FY 2010
Burlington Municipal Waterworks, Iowa FY 2010
Greene, North Carolina, County of FY 2010
Fort Madison, City of, Iowa FY 2010
Helen, Georgia, City of FY 2010
Storey County School District FY 2010
Encampment, Town of, Wyoming FY 2010
Mobridge-Pollock School District 62-2, South Dakota FY 2010
Pine Bluffs, Town of, Wyoming FY 2010
Townsend, City of, Montana FY 2010
Urbana, City of, Iowa FY 2010
Winifred, Town of, Montana FY2010
Truckees Meadow Water Authority, Nevada FY2010
Bremerton, City of, Washington FY2009
Keokuk Municipal Waterworks, Iowa FY 2010
Yankton, City of, South Dakota FY 2010
Knoxville, City of, Iowa FY 2010
Livingston, City of, Montana FY 2010
Monroe County, Public Water Supply District No. 2, Missouri
Rock Falls, City of FY 2010
Date
Jul. 12,2011
Jul. 12,2011
Jul. 13,2011
Jul. 13,2011
Jul. 13,2011
Jul. 13,2011
Jul. 13,2011
Jul. 13,2011
Jul. 13,2011
Jul. 13,2011
Jul. 13,2011
Jul. 13,2011
Jul. 13,2011
Jul. 14,2011
Jul. 14,2011
Jul. 14,2011
Jul. 15,2011
Jul. 15,2011
Jul. 15, 2011
Jul. 15, 2011
Jul. 15,2011
Jul. 15,2011
Jul. 15,2011
Jul. 15, 2011
Jul. 15, 2011
Jul. 15,2011
Jul. 15,2011
Jul. 15,2011
Jul. 15, 2011
Jul. 15, 2011
Jul. 15,2011
Jul. 15,2011
Jul. 15,2011
Jul. 15, 2011
Jul. 15, 2011
Jul. 18,2011
Jul. 18,2011
Jul. 18,2011
Jul. 18,2011
Jul. 18,2011
Jul. 18,2011
Jul. 19,2011
Jul. 19,2011
Jul. 19, 2011
Jul. 19, 2011
Jul. 19,2011
Jul. 19,2011
Jul. 19,2011
Jul. 19,2011
Jul. 20,2011
Jul. 20, 2011
Jul. 20, 2011
Jul. 20, 2011
Jul. 20,2011
Jul. 20, 2011
Jul. 20, 2011
Jul. 20, 2011
Jul. 21, 2011
Jul. 21,2011
Jul. 21,2011
Jul. 21, 2011
Jul. 21, 2011
Jul. 21, 2011
Jul. 25,2011
Jul. 25,2011
Jul. 25, 2011
Jul. 25, 2011
Jul. 25, 2011
Jul. 25, 2011
Jul. 25, 2011
Jul. 25, 2011
Federal
Ineligible Unsupported Unreasonable recommended
costs costs costs efficiencies
0
0
110,829
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
48
-------
Semiannual Report to Congress
April 1, 2011—September 30, 2011
Questioned Costs
Report no.
11-3-0395
11-3-0396
11-3-0398
11-3-0399
11-3-0400
11-3-0401
11-3-0402
11-3-0403
11-3-0404
11-3-0405
11-3-0406
11-3-0407
11-3-0408
11-3-0409
11-3-0410
11-3-0411
11-3-0412
11-3-0413
11-3-0414
11-3-0415
11-3-0416
11-3-0417
11-3-0418
11-3-0419
11-3-0420
11-3-0421
11-3-0422
11-3-0423
11-3-0424
11-3-0425
11-3-0426
11-3-0427
11-3-0428
11-3-0432
11-3-0434
11-3-0435
11-3-0436
11-3-0437
11-3-0438
11-3-0439
11-3-0440
11-3-0441
11-3-0442
11-3-0443
11-3-0444
11-3-0445
11-3-0446
11-3-0447
11-3-0448
11-3-0449
11-3-0450
11-3-0451
11-3-0452
11-3-0454
11-3-0455
11-3-0456
11-3-0457
11-3-0458
11-3-0459
11-3-0460
11-3-0461
11-3-0462
11-3-0463
11-3-0464
11-3-0465
11-3-0466
11-3-0467
11-3-0468
11-3-0469
11-3-0470
11-3-0471
Report title
Rockford.City of, Illinois FY 2009
Saratoga.Town of Wyoming FY 2010
Onarga, Illinois, Village of FY 2010
Guam Waterworks Authority FY 2010
Peru, Illinois, City of FY 2010
Pound, Virginia, Town of FY 2010
Chelyan Public Service District, West Virginia FY 2010
Sun Valley Public Service District, West Virginia FY 2010
Marmet, West Virginia, Municipality of FY 2010
Winfield, West Virginia , Municipality of FY 2010
Clarksburg Sanitary Board West Virginia FY 201 0
Westminster, Maryland,- City of FY 2010
Hanover, New Hampshire, Town of FY 2010
Cavalier, City of, North Dakota FY 2010
Shaftsbury, Vermont, - Town of FY 2010
Gloucester, Massachusetts, CityofFY2010
Dracut, Massachusetts, Town of FY 2010
Suburban Lock Haven Water Authority Pennslyvania FY 201 0
Dalles, City of, Oregon FY 2010
Utah Rural Water Association FY2010
Virginia City, Town of, Montana FY 2010
Pine Haven.Town of, Wyoming FY 2010
East Helena.City of, Montana FY 2010
Lewistown.City of, Montana FY 2010
Butte Silver Bow, City and County of , Montana FY 2010
Enderlin, City of, North Dakota FY 2010
Miles City, City of .Montana FY2010
Missoula, County of, Montana FY 2010
Rockland, Massachusetts, Town of FY 2010
Brattleboro, Vermont, Town of FY 2010
Bristol, Rhode Island, Town of FY 2010
Bristol , Vermont, Town of FY 2010
Hartford, Vermont, Town of FY 2010
Canastota.Village of, New York FY 201 0
Cape Charles, Municipal Corporation of.Virginia FY2010
Rutland, Vermont, City of FY 201 0
Marlinton .West Virginia, Municipality of FY 2010
Hertford, North Carolina, Town of FY 2010
Lake Lure, North Carolina, Town of FY 2010
Louisburg, North Carolina, Town of FY 2010
Milledgevile, Georgia, City of FY 2010
Lula, Georgia, City of FY 2010
Montevallo, Alabama, City of FY 2010
Orangeburg, South Carolina, City of FY 2010
Coon's Run Public Service District West Virginia FY 2010
Dale, Borough of , Pennsylvania FY 2010
Pennsboro, West Virginia, City of FY 2010
Salem, West Virgiia, Municipality of FY 2010
Bath, West Virginia, Municipality of FY 2010
Oceana, West Virginia,- Town of FY 2010
Miami Dade Water & Sewer Dept, Florida FY 2010
Frederick, Maryland, County of FY 2010
Houston Authority of Harris County Texas, Port of FY 2009
Natchitoches, Louisiana, City of FY 2010
College Park, City of, Georgia FY 2010
Clinton School District Iowa FY 2010
Big Bear Lake, City of , California FY 201 0
Central Shoshone County Water District Idaho FY 2010
Clackamas County, Oregon FY2010
Emeryville, City of, California FY2010
Georgia Environmental Finance Authority 2010
Harrah, City of FY 2010
American Samoa, Territory of FY 2010
Fairview, City of, Oregon FY2010
Leon, City of FY 2010
Gold Ridge Resource Conservation District California FY2010
Kauai, County of, Dept of Water, Hawaii FY 2010
Lander County School District, Nevada FY 2010
Illinois, University of FY 2009
Colorado Water Resources and Power Development Authority FY 2010
Charles City, Iowa, City of FY 2010
Federal
Ineligible Unsupported Unreasonable recommended
Date costs costs costs efficiencies
Jul.25, 2011
Jul.25, 2011
Jul. 25,2011
Jul. 25,2011
Jul. 25,2011
Jul. 26, 2011
Jul. 26, 2011
Jul. 26,2011
Jul. 26,2011
Jul. 26,2011
Jul. 26, 2011
Jul. 26, 2011
Jul. 26,2011
Jul. 26,2011
Jul. 26,2011
Jul. 26, 2011
Jul. 26, 2011
Jul. 26,2011
Jul. 27,2011
Jul. 28,2011
Jul. 29, 2011
Jul. 29, 2011
Jul. 29, 2011
Jul. 29, 2011
Jul. 29, 2011
Jul. 29, 2011
Jul. 29, 2011
Jul. 29, 2011
Jul. 29, 2011
Jul. 29, 2011
Jul. 29, 2011
Jul. 29, 2011
Jul. 29, 2011
Aug. 03, 2011
Aug. 03, 2011
Aug. 08, 2011
Aug. 08, 2011
Aug. 08, 2011
Aug. 08, 2011
Aug. 08, 2011
Aug. 08, 2011
Aug. 08, 2011
Aug. 08, 2011
Aug. 08, 2011
Aug. 09, 2011
Aug. 09, 2011
Aug. 09, 2011
Aug. 09, 2011
Aug. 09, 2011
Aug. 10, 2011
Aug. 10, 2011
Aug. 10, 2011
Aug. 11, 2011
Aug. 11, 2011
Aug. 11, 2011
Aug. 11, 2011
Aug. 12, 2011
Aug. 15, 2011
Aug. 15, 2011
Aug. 15, 2011
Aug. 16, 2011
Aug. 16, 2011
Aug. 16, 2011
Aug. 16, 2011
Aug. 16, 2011
Aug. 16, 2011
Aug. 16, 2011
Aug. 16, 2011
Aug. 17, 2011
Aug. 17, 2011
Aug. 17, 2011
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
49
-------
Semiannual Report to Congress
April 1, 2011—September 30, 2011
Questioned Costs
Report no.
11-3-0472
11-3-0473
11-3-0474
11-3-0475
11-3-0476
11-3-0477
11-3-0478
11-3-0479
11-3-0480
11-3-0481
11-3-0482
11-3-0483
11-3-0484
11-3-0485
11-3-0486
11-3-0487
11-3-0488
11-3-0489
11-3-0490
11-3-0491
11-3-0492
11-3-0493
11-3-0494
11-3-0495
11-3-0496
11-3-0497
11-3-0498
11-3-0499
11-3-0500
11-3-0501
11-3-0502
11-3-0503
11-3-0504
11-3-0505
11-3-0506
11-3-0507
11-3-0508
11-3-0509
11-3-0510
11-3-0511
11-3-0512
11-3-0513
11-3-0514
11-3-0515
11-3-0516
11-3-0517
11-3-0518
11-3-0520
11-3-0521
11-3-0522
11-3-0523
11-3-0524
11-3-0525
11-3-0526
11-3-0528
11-3-0529
11-3-0530
11-3-0531
11-3-0532
11-3-0533
11-3-0535
11-3-0536
11-3-0537
11-3-0539
11-3-0540
11-3-0541
11-3-0542
11-3-0543
11-3-0544
11-3-0546
11-3-0547
Report title
Dubuque, Iowa, City of FY 2010
Los Penasquitos Lagoon Foundation, California FY2010
Pittsfield, Illinois, City of FY 2010
Westmont, Illinois, Village of FY 2010
Aiken, County of, South Carolina FY 2010
Pontiac, Michigan, City of FY 2010
Westland, Michigan, City of FY 2010
Columbia, City of, South Carolina FY2010
Houston, Texas, City of FY 2010
Jeanerette, Louisiana, City of FY 2010
Oklahoma, Oklahoma, City of FY 2010
San Juan, New Mexico, County of FY 20 10
Lemoore, California, City of FY 2010
Louisa, Kentucky, City of FY 2010
LaBarge, Wyoming Town of FY 2010
Dona Ana Mutual Water Consumers Association, New Mexico FY 2010
Dover, City of, New Hampshire FY2010
Highlands, Town of, North Carolina FY 2010
Machias, Town of, Maine FY 2010
Johnson.Village of, Vermont FY 2009
Northside Industrial Development Company, Pennsylvania
Volant, Borough of, Pennsylvania FY2010
Pittsfield Charter, Township of, Michigan FY 2010
Keokuk, Iowa, City of FY 2010
Hartley, Iowa, City of FY 2010
Linn Creek, Missouri, City of FY 2010
Williamstown, Kentucky, City of FY 2010
Pendleton, South Carolina, Town of FY 2010
Franklin, Tennesee, City of FY 2010
Carroll County, Ohio FY 2009
Redwood Falls, Minnesota, City of FY 2009
Grand Chute-Menasha West Sewerage Commission Wisconsin FY 2010
Lansing, Michigan, City of FY 2010
Crossville, Tennesee, City of FY2010
Paulding , Georgia, County of FY 2010
Richmond Water Gas & Sewerage Works, Kentucky FY 2010
Ronda, North Carolina, Town of
Youngsville, North Carolina, Town of FY 2010
Murphy, North Carolina, Town of FY 2010
Pioneer Rural Water District of Oconee and Anderson Counties, SC FY 2010
Carroll County Water Authority, Georgia FY2010
Princeton Water and Wastewater, Kentucky FY 2010
Rawlins, City of, Wyoming FY 2010
Cresson , Borough of, Municipal Authority, Pennsylvania FY 2010
Calvert City, Kentucky, City of FY 2010
Caswell Beach, North Carolina, Town of FY 2010
Paintsville, Kentucky, City of FY 2010
Bloomingdale Utility District of Sullivan County, Tennessee FY2010
Monteagle, Tennessee, Town of FY 2010
Russellville, Kentucky, City of FY 2010
Southport, North Carolina, City of FY 2010
Desoto County, Mississippi, Regional Utility Authority of FY 2010
NewYork, NewYork, City of FY 2010
Cold Springs Rancheria of Mono Indians FY 2009
Puerto Rico-Commonwealth of Environmental Quality Board FY 2009
Greenport, NewYork, Incorporated Village of FY 2010
Richfield Springs, New York, Village of FY 201 0
Amsterdam, New York, City of FY 2010
Ventura, California, County of FY 2010
St Helens, City of, Oregon FY 2010
Anaconda Deer Lodge, County of, Montana FY 201 0
Valdosta, Georgia, City of FY2010
Franklin, City of , Louisiana FY2010
Taos, New Mexico, Town of FY 2010
Volunteers of America of North Louisiana FY 201 0
West Monroe, Louisiana, City of FY 2010
Harris County Municipal Utility District No. 148, Texas FY2010
Morro Bay, Bay Foundation of, California FY 2010
Winnfield, Louisiana, City of FY 2010
Ten Sleep, Wyoming, Town of FY 2010
Hagerstown, Maryland, City of FY 2010
Federal
Ineligible Unsupported Unreasonable recommended
Date costs costs costs efficiencies
Aug. 17, 2011
Aug. 17, 2011
Aug. 17, 2011
Aug. 17, 2011
Aug. 17, 2011
Aug. 17, 2011
Aug. 17, 2011
Aug. 17, 2011
Aug. 17, 2011
Aug. 17, 2011
Aug. 17, 2011
Aug. 17, 2011
Aug. 17, 2011
Aug. 17, 2011
Aug. 17, 2011
Aug. 17, 2011
Aug. 18, 2011
Aug. 18, 2011
Aug. 18, 2011
Aug. 18, 2011
Aug. 18, 2011
Aug. 18, 2011
Aug. 18, 2011
Aug. 22, 2011
Aug. 22, 2011
Aug. 22, 2011
Aug. 22, 2011
Aug. 22, 2011
Aug. 22, 2011
Aug. 22, 2011
Aug. 22, 2011
Aug. 22, 2011
Aug. 22, 2011
Aug. 22, 2011
Aug. 22, 2011
Aug. 22, 2011
Aug. 22, 2011
Aug. 22, 2011
Aug. 23, 2011
Aug. 23, 2011
Aug. 23, 2011
Aug. 23, 2011
Aug. 23, 2011
Aug. 24, 2011
Aug. 24, 2011
Aug. 24, 2011
Aug. 24, 2011
Aug. 24, 2011
Aug. 24, 2011
Aug. 24, 2011
Aug. 24, 2011
Aug. 24, 2011
Aug. 24, 2011
Aug. 24, 2011
Aug. 25, 2011
Aug. 25, 2011
Aug. 25, 2011
Aug. 25, 2011
Aug. 25, 2011
Aug. 25, 2011
Aug. 25, 2011
Aug. 25, 2011
Aug. 25, 2011
Aug. 25, 2011
Aug. 25, 2011
Aug. 25, 2011
Aug. 25, 2011
Aug. 25, 2011
Aug. 25, 2011
Aug. 25, 2011
Aug. 26, 2011
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
79,826
0
0
0
0
56,853
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
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0
0
0
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0
0
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0
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0
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0
0
0
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0
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0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
50
-------
Semiannual Report to Congress
April 1, 2011—September 30, 2011
Questioned Costs
Report no.
11-3-0548
11-3-0549
11-3-0550
11-3-0551
11-3-0552
11-3-0553
11-3-0554
11-3-0555
11-3-0556
11-3-0557
11-3-0558
11-3-0559
11-3-0560
11-3-0561
11-3-0562
11-3-0563
11-3-0564
11-3-0565
11-3-0566
11-3-0567
11-3-0568
11-3-0569
11-3-0570
11-3-0571
11-3-0572
11-3-0573
11-3-0574
11-3-0575
11-3-0576
11-3-0577
11-3-0578
11-3-0579
11-3-0580
11-3-0581
11-3-0582
11-3-0583
11-3-0584
11-3-0585
11-3-0586
11-3-0587
11-3-0588
11-3-0589
11-3-0590
11-3-0591
11-3-0592
11-3-0593
11-3-0594
11-3-0595
11-3-0596
11-3-0598
11-3-0599
11-3-0600
11-3-0601
11-3-0602
11-3-0603
11-3-0604
11-3-0605
11-3-0606
11-3-0607
11-3-0608
11-3-0609
11-3-0610
11-3-0611
11-3-0612
11-3-0613
11-3-0614
11-3-0615
11-3-0617
11-3-0618
11-3-0619
11-3-0620
Report title
San Francisco, California, City and County of FY 2010
Watford City ,City of, North Dakota FY 2009
Columbia, North Carolina, Town of FY 2010
California, University of FY 2010
Colfax, California, City of FY 2010
Pima, Arizona, County of FY 2010
South Tucson, Arizona, City of FY 2010
Brawley.Califomia, City of FY 2010
Delano, California, City of FY 2010
Los Angeles Department of Water and Power-Water System, FY 2010
Maui, Hawaii, County of FY 2010
Mendocino, California, County of FY2010
Adrian, Missouri.City of FY 2010
Deming, New Mexico, City of FY 2010
Rio Rancho, New Mexico, City of FY 2010
Ruidoso Downs, New Mexico, City of FY 2010
Del City, Oklahoma, City of FY 2010
Payson, Arizona, Town of FY 2010
Northeast States for Coordinated Air Use Management Inc (MA) FY 2010
Alachua, City of, Florida FY 2010
Amarillo, City of, Texas FY 2010
Ascension Consolidated Utilities District No 1, Louisiana FY 2010
Picuris Pueblo, New Mexico FY2008
Hawaii, County of, Hawaii FY 2010
Bennettsville, South Carolina, City of FY 2010
Atoka, Tennesee, Town of FY 2010
Wilmar Union School District, California FY 2010
Randolph, Massachusetts.Town of FY 2010
Bushnell, City of, Florida FY 2010
Central Oklahoma Master Conservancy District , Oklahoma FY 2010
Cullen, Town of, Louisiana FY 2010
Arlington School District, Vermont FY 2010
North Richland Hills, Texas, City of FY 2010
Wilmington, Delaware, City of FY 2010
St. Augustine Beach, Florida, City of FY 2010
Tohopekaliga Water Authority, Florida FY 2010
Natchez Water Works, Mississippi FY2010
Bird Island, Minnesota.City of FY 2010
Honolulu, City and County of, Hawaii FY 2010
Fort Worth, Texas, City of FY 2010
Ardmore, Oklahoma, City of FY 2010
Maricopa Domestic Water Improvement District, Arizona FY 2010
Crowley, Lousiana.Cityof FY2010
Labelle, Florida, City of FY 2010
North Miami Beach, Florida, City of FY 2010
White Lake, Michigan, Charter Township of FY 2010
Mercedes, Texas.City of FY 2010
Opelousas, Louisiana, City of FY 2010
Clewiston, Florida, City of FY 2010
Elko Band Council, NevadaFY2010
Peoria, City of, Illinois FY 2010
Fortville.Town of, Indiana FY2009
Alda, Nebraska, Village of FY 2010
Bennet, Nebraska, Village of FY 20 1 0
Malcolm, Nebraska, Village of FY 2010
Atlanta, Missouri, City of FY 2010
R & T Water Supply Association, North Dakota FY 2009
Edgewater, Florida, City of FY 2010
Ohio County Regional Wastewater District Inc., Kentucky FY 2009
Wanaque Valley Regional Sewerage Authority, New Jersey FY 2010
Casselberry, Florida, City of FY 2010
Cocoa, Florida, City of FY 2010
Grand Ridge, Florida, Town of FY 2010
North Salem, New York.Town of FY 2010
Amherst, New York, Town of FY 2010
Center for Creative Land Recycling, California FY 2009
Lancaster,-City of, Pennsylvania FY 2010
Cabazon Band of Mission Indians, California FY2010
Battelle Memorial Institute, Ohio FY 2010
Carrabelle, Florida, City of FY 2010
Alexandria, Minnesota, City of FY 2010
Date
Aug. 26, 2011
Aug. 25, 2011
Aug. 26, 2011
Aug. 26, 2011
Aug. 26, 2011
Aug. 26, 2011
Aug. 26, 2011
Aug. 26, 2011
Aug. 26, 2011
Aug. 26, 2011
Aug. 26, 2011
Aug. 26, 2011
Aug. 26, 2011
Aug. 29, 2011
Aug. 29, 2011
Aug. 29, 2011
Aug. 29, 2011
Aug. 29, 2011
Sep. 01, 2011
Sep. 02, 2011
Sep. 02, 2011
Sep. 02, 2011
Sep. 02, 2011
Sep. 07, 2011
Sep. 07, 2011
Sep. 07, 2011
Sep. 07, 2011
Sep. 07, 2011
Sep. 07, 2011
Sep. 07, 2011
Sep. 07, 2011
Sep. 07, 2011
Sep. 07, 2011
Sep. 07, 2011
Sep. 08, 2011
Sep. 08, 2011
Sep. 08, 2011
Sep. 08, 2011
Sep. 08, 2011
Sep. 08, 2011
Sep. 08, 2011
Sep. 08, 2011
Sep. 08, 2011
Sep. 08, 2011
Sep. 08, 2011
Sep. 08, 2011
Sep. 08, 2011
Sep. 08, 2011
Sep. 08, 2011
Sep. 09, 2011
Sep. 12, 2011
Sep. 12, 2011
Sep. 12, 2011
Sep. 12, 2011
Sep. 12, 2011
Sep. 12, 2011
Sep. 12,2011
Sep. 12,2011
Sep. 12,2011
Sep. 12,2011
Sep. 12, 2011
Sep. 12,2011
Sep. 12,2011
Sep. 12,2011
Sep. 12,2011
Sep. 12,2011
Sep. 12,2011
Sep. 13,2011
Sep. 14, 2011
Sep. 14, 2011
Sep. 14, 2011
Federal
Ineligible Unsupported Unreasonable recommended
costs costs costs efficiencies
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
12,564
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
13,696
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
51
-------
Semiannual Report to Congress
April 1, 2011—September 30, 2011
Questioned Costs
Report no.
11-3-0621
11-3-0622
11-3-0623
11-3-0624
11-3-0625
11-3-0626
11-3-0627
11-3-0628
11-3-0629
11-3-0631
11-3-0632
11-3-0633
11-3-0634
11-3-0635
11-3-0636
11-3-0637
11-3-0638
11-3-0639
11-3-0640
11-3-0641
11-3-0642
11-3-0643
11-3-0644
11-3-0645
11-3-0646
11-3-0647
11-3-0648
11-3-0649
11-3-0650
11-3-0651
11-3-0652
11-3-0653
11-3-0654
11-3-0655
11-3-0656
11-3-0657
11-3-0658
11-3-0659
11-3-0660
11-3-0661
11-3-0662
11-3-0663
11-3-0664
11-3-0665
11-3-0666
11-3-0667
11-3-0668
11-3-0669
11-3-0670
11-3-0671
11-3-0672
11-3-0673
11-3-0674
11-3-0675
11-3-0676
11-3-0677
11-3-0678
11-3-0679
11-3-0680
11-3-0681
11-3-0682
11-3-0683
11-3-0684
11-3-0685
11-3-0686
11-3-0688
11-3-0689
11-3-0690
11-3-0691
11-3-0692
11-3-0693
Report title
Auburn Hills, Michiagan, City of FY 2010
Baudette, Minnesota, City of FY 2010
Big Lake , Minnesota, City of FY 2010
Brainerd, Minnesota, City of FY 2010
Fortville, Indiana, Town of FY 2010
Litchfield, Minnesota, City of FY 2010
Lynchburg, Ohio, Village of FY 2010
Gwinnett County Georgia FY 2010
Eatonton-Putnam Water and Sewer Authority, Georgia FY 2010
Churubusco, Indiana, Town of FY2010
Turtle Lake, Wisconsin, Village of FY2010
Liberty, Indiana, Town of FY 2010
Two Rivers, Wisconisn, City of FY 2010
Marinette, Wisconsin, City of FY 2010
Evansville.Wisconsin, City of FY 2010
Elephant Butte, City of, New Mexico FY2010
Colby, City of, Kansas FY 20 10
Bonifay, Florida, City of FY 2010
Hollywood, Florida, City of FY 2010
Apalachicola, Florida, City of FY 2010
Winona, Mississippi, City of FY 2010
BDW Water System Association, North Dakota FY 201 0
St. Ignace, Michigan, City of FY 2010
Grace, City of, Idaho FY 2010
Eunice, City of, LouisianaFY2010
Grand Isle, Town of, Louisiana FY2010
Illinois, State of FY 20 10
Del Norte, County of, California FY 2010
Port Authority of the City of Saint Paul, Minnesota FY 201 0
Stanley, Wisconsin, City of FY 2010
Van Buren, Michigan, Charter Township of FY 2010
Bucklin, Kansas, City of FY 2010
Public Water Supply District #8 of Clay County, Missouri FY 2010
Cole County Public Water Supply District No. 4, Missouri FY 2010
Sharpsville, Pennsylvania, Borough of FY 2010
Webster, South Dakota, City of FY 2010
Amherst, Wisconsin, Village of FY 2010
Woodland, City of, California FY 2010
Two Harbors, City of, Minnesota FY 2010
Monticello, Florida, City of FY 2010
Sebring, Florida, City of FY 2010
Tampa, Florida, City of FY 2010
Bayou Descannes Water System Inc., Louisiana FY 2010
Bogalusa, Louisiana, City of FY 2010
Caddo Parish Commission, Louisiana FY2010
Ipswich, South Dakota, City of FY 2010
Snyderville Basin Water Reclamation District, Utah FY 2010
Milbank, South Dakota, City of FY 2010
Lead, South Dakota, City of FY 2010
Minneapolis, Minnesota, City of FY 2010
West Bloomfield, Michigan, Charter Township of FY 2010
Whitewater, Wisconsin, City of FY 2010
Foley, Minnesota, City of FY 2010
Duluth, Minnesota, City of FY 2010
Hammond, City of, Louisiana FY2010
Ball, Louisiana, Town of FY 2010
Latino Community Development Agency, Oklahoma FY 2010
Anderson, Indiania, City of FY 2010
Lomira,Wisconsin,VillageofFY2010
Maquoketa, City of, Iowa FY2010
Stetsonville, Wisconsin, Village of FY 2010
Superior, Wisconsin, City of FY 2010
Whitestown, Indiana, Town of FY 2010
East Allen Parish Waterworks District, Louisiana FY 2010
Denton County Fresh Water Supply District No. 1-A , Texas FY 2010
Clay Rural Water System Inc., South Dakota FY 2010
Austin, Texas, City of FY 2010
Aberdeen, South Dakota, City of FY 2010
Northwood, North Dakota, City of FY 2010
Vanderbilt University, Tennesee FY 2010
Foster, Pennsylvania, Township FY 2009
Date
Sep. 14, 2011
Sep. 14, 2011
Sep. 14, 2011
Sep. 14, 2011
Sep. 14, 2011
Sep. 14, 2011
Sep. 14, 2011
Sep. 14, 2011
Sep. 14, 2011
Sep. 14, 2011
Sep. 14, 2011
Sep. 14, 2011
Sep. 14, 2011
Sep. 14, 2011
Sep. 14, 2011
Sep. 14, 2011
Sep. 14, 2011
Sep. 15,2011
Sep. 15,2011
Sep. 15,2011
Sep. 15,2011
Sep. 15,2011
Sep. 15,2011
Sep. 16,2011
Sep. 16,2011
Sep. 16,2011
Sep. 16,2011
Sep. 19,2011
Sep. 19,2011
Sep. 19,2011
Sep. 19,2011
Sep. 19,2011
Sep. 19,2011
Sep. 19,2011
Sep. 19,2011
Sep. 19,2011
Sep. 19,2011
Sep. 19,2011
Sep. 19,2011
Sep. 19,2011
Sep. 19, 2011
Sep. 19,2011
Sep. 19,2011
Sep. 19,2011
Sep. 19,2011
Sep. 19,2011
Sep. 19,2011
Sep. 20, 2011
Sep. 20, 2011
Sep. 20, 2011
Sep. 20, 2011
Sep. 20, 2011
Sep. 20, 2011
Sep. 20, 2011
Sep. 20, 2011
Sep. 20, 2011
Sep. 20, 2011
Sep. 20, 2011
Sep. 20, 2011
Sep. 20, 2011
Sep. 20, 2011
Sep. 20, 2011
Sep. 20, 2011
Sep. 20, 2011
Sep. 20, 2011
Sep. 21, 2011
Sep. 21, 2011
Sep. 21, 2011
Sep. 21, 2011
Sep. 21, 2011
Sep. 21, 2011
Federal
Ineligible Unsupported Unreasonable recommended
costs costs costs efficiencies
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
711,650
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
21,653
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
52
-------
Semiannual Report to Congress
April 1, 2011—September 30, 2011
Questioned Costs
Report no.
11-3-0694
11-3-0695
11-3-0696
11-3-0698
11-3-0703
11-3-0704
11-3-0707
11-3-0710
11-3-0711
11-3-0712
11-3-0713
11-3-0714
11-3-0715
11-3-0716
11-3-0717
11-3-0718
11-3-0719
11-3-0720
11-3-0721
11-3-0723
11-3-0724
Report title
Glen Falls, New York, City of FY 2010
Franklin, Pennsylvania, Town ship of FY 2009
Naples, Florida, City of FY 2010
Santa Cruz County, -Resource Conservation District of, California FY2010
San Andreas Sanitary District, California FY 2010
Crooked Creek Traditional Council, Alaska FY2008
Inkom, City of, Idaho FY 2010
Clean Fuels Ohio FY 2010
Eureka, County of, Nevada FY2010
Caneadea, Town of, New York FY 2010
Nicholson WaterS Sewer Association Inc., Mississippi FY2010
Red Lake Falls, Minnesota, City of FY 2010
Pear River County Utility Authority, Mississippi FY 2010
Sopchoppy, Florida, City of FY 2010
Tupelo, Mississippi, City of FY 2010
Weaver, Alabama, City of FY 2010
Philippi , West Virginia, City of FY 2010
Silver Creek, Missouri, Village of FY 2010
San Francisco Redevelopment Agency, California FY2010
Santee Sioux Nation, Nebraska FY2010
Canton, South Dakota, City of FY 2010
TOTAL SINGLE AUDIT REPORTS = 468
Date
Sep. 21, 2011
Sep. 21, 2011
Sep. 21,2011
Sep. 22, 2011
Sep. 26, 2011
Sep. 26, 2011
Sep. 26, 2011
Sep. 27, 2011
Sep. 27, 2011
Sep. 27, 2011
Sep. 27, 2011
Sep. 27, 2011
Sep. 29, 2011
Sep. 29, 2011
Sep. 29, 2011
Sep. 29, 2011
Sep. 29, 2011
Sep. 29, 2011
Sep. 29, 2011
Sep. 29, 2011
Sep. 29, 2011
Ineligible
costs
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
$1,057,508
Federal
Unsupported Unreasonable recommended
costs costs efficiencies
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
$472,309
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
$0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
$0
ATTESTATION REPORTS
11-4-0709
CERCLA Claim - Iron Horse Park Superfund Site
TOTAL ATTESTATION REPORTS = 1
Sep. 27, 2011
$0
$0
$0
$0
$0
$0
$0
$0
AMERICAN RECOVERY AND REINVESTMENT ACT OF 2009 REPORTS
11-R-0208
11-R-0214
11-R-0222
11-R-0232
11-R-0233
11-R-0241
11-R-0248
11-R-0431
11-R-0519
11-R-0700
OTHER REPORTS
11-N-0212
11-2-0213
11-2-0300
11-2-0699
EPA Faced Multiple Constraints to Targeting Recovery of Funds
Site Visit of Wastewater Treatment Facility Improvements, Perkins, Oklahoma
Site Visit of Wastewater Treatment Facility Expansion, Buckeye, Arizona
Site Visit of La Plata Water Treatment Plant Phase 1 1 , Aibonito, Puerto Rico
Site Visit of Sewer Improvements, Ingenio Community, Toa Baja, Puerto Rico
Site Visit of Las Marias Water System Phase IIA, Las Marias, Puerto Rico
Site Visit of Clifton Street Power/Water Main Projects, Portland, Maine
Site Visit of Tower Chemical Superfund Site, Clemont, Lake County, Florida
EPA and State Oversight of Clean Water State Revolving Fund Projects
Site Visit of Wastewater Treatment Plant-Phase II, Ottawa, Illinois
TOTAL AMERICAN RECOVERY AND REINVESTMENT ACT OF 2009
REPORTS = 10
Compendium of Unimplemented Recommendations - March 31, 2011
Agreed Upon Procedures EPA's First Quarter 201 1 Financial Statements
Agreed Upon Procedures EPA's Second Quarter 201 1 Financial Statements
Agreed Upon Procedures EPA's Third Quarter 201 1 Financial Statements
TOTAL OTHER REPORTS = 4
Apr. 11,2011
May 02, 2011
May 09, 2011
May 23, 2011
May 24, 2011
May 25, 2011
Jun. 07, 2011
Aug. 03, 2011
Aug. 24, 2011
Sep. 23, 2011
Apr. 29, 2011
May 02, 2011
Jun. 29, 2011
Sep. 23, 2011
$0
0
0
0
0
0
0
0
0
0
$0
$0
0
0
0
$0
$0
0
0
0
0
0
0
0
0
3,860,147
$3,860,147
$0
0
0
0
$0
$0
0
0
0
0
0
0
0
0
0
$0
$0
0
0
0
$0
$0
0
0
0
0
0
0
0
0
0
$0
$0
0
0
0
$0
TOTAL REPORTS ISSUED = 514
$1,057,508 $4,332,456
$0
$58,000,000
53
-------
Semiannual Report to Congress
April 1, 2011—September 30, 2011
Appendix 2—Reports Issued Without Management Decisions
For Reporting Period Ended September 30, 2011
The Inspector General Act requires a summary of each audit report issued before the commencement of the
reporting period for which no management decision had been made by the end of the reporting period, an
explanation of the reasons such management decision had not been made, and a statement concerning the desired
timetable for achieving a management decision on each such report. OMB Circular A-50 requires resolution within
6 months of a final report being issued. In this section, we report on audits with no management decision or resolution
within 6 months of final report issuance. In the summaries below, we note the Agency's explanation of the reasons a
management decision has not been made, the Agency's desired timetable for achieving a management decision, and
the OIG follow-up status as of September 30, 2011.
Report No. 10-P-0112, Results of Hotline Complaint Review of EPA Region 9 Hiring under the Federal Career
Intern Program, April 26, 2010
Summary: The hotline allegations against EPA Region 9 were unsubstantiated. We identified that the region
engaged in a prohibited personnel practice. Neither the Office of Personnel Management nor EPA prohibits the use
of a job fair and registration code as recruiting and hiring methods. However, Region 9 engaged in a prohibited
personnel practice by giving four Federal Career Intern Program job fair participants improper advantages not
provided to others attending the job fair.
Agency Explanation: Office of Human Resources has drafted a policy to establish an Agency-wide workforce program
that includes controls to ensure regular reviews of positions for efficiency, effectiveness, and mission
accomplishment. The policy must move through the Agency approval process. Senior management is considering
contractor support on this issue and a memorandum is forthcoming to the OIG to confirm that strategy. The projected
completion date is March 31, 2012.
OIG Follow-Up Status: Incomplete response.
Report No. 11-P-0136, EPA Needs Better Agency Wide Controls Over Staff Resources, February 22, 2011
Summary: This report evaluated the effectiveness of EPA's position management program. The OIG found that EPA
does not enforce a coherent program of position management to assure the efficient and effective use of its
workforce. While some organizational elements have independently established programs to control their resources,
there is no Agency-wide effort to ensure that personnel are put to the best use. As such, the OIG recommend that
OARM establish an Agency-wide workforce program that includes controls to ensure regular reviews of positions for
efficiency, effectiveness, and mission accomplishment.
Agency Explanation: Office of Human Resources has drafted a policy to establish an Agency-wide workforce program
that includes controls to ensure regular reviews of positions for efficiency, effectiveness, and mission
accomplishment. The policy must move through the Agency approval process. Senior management is considering
contractor support on this issue and a memorandum is forthcoming to the OIG to confirm that strategy. The projected
completion date is March 31, 2012.
OIG Follow-Up Status: Incomplete Response.
Report No. 10-P-0177, EPA's Revised Hiring Process Needs Additional Improvements, August 9, 2010
Summary: Our analysis of EPA's appointment process managed by the Office of Administration and Resources
Management (OARM) identified that EPA had not implemented critical technology upgrades or obtained other
resources necessary for the service center concept to succeed. EPA produced three reports, including its 2007
Business Case, which identified key factors for a successful transition to the service center concept. However, EPA
management implemented the transition without obtaining some of these key capabilities, including electronic
infrastructure.
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Agency Explanation: The OIG has accepted OARM's Corrective Action Plan with the exception of recommendations
2 and 3. OARM and OIG continue to disagree on these recommendations; therefore, this audit has not been closed.
OARM will continue to move forward on the remaining corrective actions.
OIG Follow-Up Status: No response.
Report No. 11-4-0113, Examination of Costs Claimed Under EPA Cooperative Agreement X83275501 Awarded
to the Montana Physical Sciences Foundation, November 8, 2010
Summary: This review examined EPA's assistance agreement to the Montana Physical Sciences Foundation. The
OIG found that the grantee did not meet Code of Federal Regulations (CFR) requirements for procurement. We noted
issues related to conflict of interest and sole source contract documentation. The OIG recommended that OARM
(1) disallow and recover $707,320 in costs claimed for the grantee's subcontract, (2) consider suspension and
debarment proceedings against the grantee and its subcontractor, (3) require the grantee to improve its procurement
process to ensure compliance with 40 CFR Part 30, and (4) establish special conditions for future EPA awards to the
grantee.
Agency Explanation: This audit is being handled by the Office of Grants and Debarment (OGD). OGD informed the
OIG on September 23, 2011, that it will provide its complete response to the OIG's determination by November 30,
2011.
OIG Follow-Up Status: Incomplete Response.
Office of Air and Radiation
Report No. 04-P-00033, Effectiveness of Strategies to Reduce Ozone Precursors, September 29, 2004
Summary: Our analysis of EPA emissions data for "serious," "severe," and "extreme" ozone nonattainment areas
indicated that some major metropolitan areas may not have achieved the required 3 percent annual emission
reductions in ozone precursor emissions. While EPA air trends reports have emphasized that ozone levels are
declining nationally and regionally, only 5 of 25 nonattainment areas designated serious to extreme had substantial
downward trends. EPA provided an action plan to the OIG that provided a partial list of actions planned, and we
closed 8 of the 25 recommendations. We believed that we may have been able to close six recommendations once
the final Milestone Compliance Demonstration rule was promulgated. However, in May 2006, EPA told us it had
decided not to issue the rule; it instead planned to issue guidance that EPA regions could share with states. We did
not agree that guidance is an acceptable alternative. As of September 12, 2008, the Agency had not agreed with the
other recommendations and had not submitted a complete response that addresses all the recommendations in the
report. We will continue to follow up on the Agency's actions.
Agency Explanation: EPA continues to disagree with the OIG recommendation to issue a Milestone Compliance
Demonstration Rule. EPA has agreed to reconsider the recommendation after reconsideration of the Ozone Standard
is completed. Resolution expected by December 2011.
OIG Follow-Up Status: Expect resolution by December 2011.
Report No. 08-P-0020, Maximum Achievable Control Technology Implementation Progress and Challenges,
October 31, 2007
Summary: EPA's National Emissions Inventory data indicate an overall decline in air toxic emissions concurrent with
implementation of the maximum achievable control technology standards. EPA plans to use National Emissions
Inventory data to assess the public health risk remaining from maximum achievable control technology sources of air
toxics emissions, but the reliability of data for site-specific emissions varies considerably. EPA has not established
objectives that define an acceptable level of quality for National Emissions Inventory data used in the residual risk
process. EPA guidance recommends that program offices develop data quality objectives for using data in such
decisionmaking processes. Given the uncertainties associated with National Emissions Inventory data, EPA could
over- or underestimate the public health risk from maximum achievable control technology sources of emissions.
Overstating risk could result in EPA placing regulations on industries that are not cost beneficial. Conversely,
understating risk could result in EPA not requiring regulations where needed to protect public health. The Agency has
agreed with the first recommendation in our audit report and provided acceptable milestones dates for its
implementation. The Agency has not agreed to establish the recommended state reporting requirements, and we
consider the issue unresolved.
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Agency Explanation: On February 14, 2011, the OIG requested clarification of the EPA's action plan timeline. EPA
sent a clarification letter to the OIG. On September 19, 2011, OIG stated that it is reviewing the letter.
OIG Follow-Up Status: Resolution under negotiation in headquarters.
Report No. 09-P-0151, EPA Does Not Provide Oversight of Radon Testing Accuracy and Reliability,
May 12, 2009
Summary: EPA does not perform oversight of radon testing device accuracy or reliability. The 1988 Indoor Radon
Abatement Act required that EPA establish proficiency programs for firms offering radon-related services, including
testing and mitigation. EPA established and operated proficiency programs until 1998, when it disinvested in these
programs. EPA asserts that it shares oversight responsibility with states and industry, including the two national
proficiency programs operating under private auspices. However, without oversight, EPA cannot assure that radon
testing devices provide accurate data on indoor radon risks or that radon testing laboratories accurately analyze and
report radon results. We recommended that EPA disclose that while radon testing is recommended, EPA cannot
provide assurance that commercially available radon testing devices or testing laboratories are accurate and reliable.
EPA generally agreed with this recommendation and stated that it will review and revise both its Web-based and
printed public materials, as appropriate. However, the Agency did not provide information on how it intends to
characterize the accuracy and reliability of radon testing in its public documents, and more information is needed.
Agency Explanation: EPA has completed its review of the data collected in studies to determine the accuracy and
reliability of radon testing devices. EPA is preparing a memo to the OIG laying out the results of that analysis. The
memo is expected to be signed by October 31, 2011.
OIG Follow-Up Status: Incomplete response.
Financial Analysis and Rate Negotiation Service Center
Report No. 06-4-00120, National Academy of Sciences—FY 2006 Info Tech System, July 20, 2006
Summary: The Defense Contract Audit Agency (DCAA) determined that the contractor's information technology
system general internal controls were inadequate in part.
Agency Explanation: Resolution on hold. Resolution of audit results is not EPA's responsibility, but the responsibility
of the Department of Defense. Therefore, an expected resolution date cannot be determined at this time.
OIG Follow-Up Status: Resolution pending receipt of additional information.
Report No. 06-4-00165, National Academy of Sciences—FY 2006 Indirect/Other Direct Costs System,
September 27, 2006
Summary: In DCAA's opinion, the contractor's service centers cost system and related internal control policies and
procedures were inadequate in part. DCAA's examination noted certain significant deficiencies in the design or
operation of the Indirect/Other Direct Costs system process.
Agency Explanation: Resolution on hold. Resolution of audit results is not EPA's responsibility, but the responsibility
of the Department of Defense. Therefore, an expected resolution date cannot be determined at this time.
OIG Follow-Up Status: Resolution pending receipt of additional information.
Report No. 06-4-00169, National Academy of Sciences—FY 2006 Labor System, September 29, 2006
Summary: In DCAA's opinion, the contractor's labor system and related internal control policies and procedures were
inadequate in part. DCAA's examination noted certain significant deficiencies in the design or operation of the internal
control structure.
Agency Explanation: Resolution on hold. Resolution of audit results is not EPA's responsibility, but the responsibility
of the Department of Defense. Therefore, an expected resolution date cannot be determined at this time.
OIG Follow-Up Status: Resolution pending receipt of additional information.
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Report No. 07-1-00016, URS Corporation (c/o URS Greiner, Inc.)—FY2001 Incurred Cost, November 13, 2006
Summary: 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 fringe, overhead, and general and administrative rates. Of the questioned indirect costs, EPA's share is
$401,412, for a total of $1,729,601 in questioned direct and indirect costs.
Agency Explanation: Resolution on hold. Resolution of audit results is not EPA's responsibility, but the responsibility
of the Department of Defense. Therefore, an expected resolution date cannot be determined at this time.
O/G Follow-Up Status: Resolution pending receipt of additional information.
Report No. 07-1-00061, Lockhead Martin Services Group—FY 12/31/2004 I/C, April 10, 2007
Summary: DCAA questioned $34,708,911 in claimed direct costs and proposed indirect costs. Further, DCAA did not
audit $338,864,655 in claimed direct and indirect costs for assist audits not yet received or for received assist audit
reports, the impact of which on the contractor's cost objectives has not yet been calculated. Additionally, DCAA
upwardly adjusted $48,224,805 in claimed base costs. EPA's share of the questioned costs totals $694,178. DCAA
did not provide any Cumulative Allowable Cost Work Sheet or Schedule of Allowable Costs by Cost Element by
Contract because the most current year with negotiated indirect rates is calendar year 1998. DCAA will issue a
supplemental audit report upon completion of its analysis of the assist audit results, and as the outstanding fiscal
years' indirect rates are negotiated, the requested Cumulative Allowable Cost Work Sheet and Schedule of Allowable
Costs by Cost Element by Contract will be provided.
Agency Explanation: Resolution on hold. Resolution of audit results is not EPA's responsibility, but the responsibility
of the Department of Defense. Therefore, an expected resolution date cannot be determined at this time.
O/G Follow-Up Status: Resolution pending receipt of additional information.
Report No. 07-4-00058, Science Applications Intl. Corporation—Companies 1, 6, and 9—FY 2006 Floorchecks,
April 30, 2007
Summary: On September 25, 2006, DCAA determined that the floorchecks disclosed no significant deficiencies in the
contractor's timekeeping or labor system in FY 2005. On February 27, 2007, DCAA determined that certain labor
practices require corrective actions to improve the reliability of the contractor's labor accounting system. DCAA did
not express an opinion on the adequacy of the contractor's labor accounting system taken as a whole.
Agency Explanation: Resolution on hold. Resolution of audit results is not EPA's responsibility, but the responsibility
of the Department of Defense. Therefore, an expected resolution date cannot be determined at this time.
O/G Follow-Up Status: Resolution pending receipt of additional information.
Report No. 07-1-00079, Science Applications Intl. Corporation—FYE 1/31/2005 I/C, July 18, 2007
Summary: DCAA submitted three audit reports under this assignment. DCAA accepted the claimed direct costs at
Companies 1 and 6 (there are no claimed direct costs at Company 9) and questioned proposed indirect costs and
rates at Companies 1, 6, and 9. DCAA questioned a total of $17,224,585 of Company 9's claimed indirect expenses
($9,938,874) and fringe benefit costs and rates ($7,285,711), of which $7,762,651 was allocated to other companies
that do not perform government work. Questioned indirect costs of $3,525,230 and $4,552,250 were allocated to and
questioned in the claimed general and administrative costs and rates of Companies 1 and 6, respectively. The
questioned fringe benefit rates in Company 9 resulted in questioned fringe benefit costs of $865,365 and $519,089
for Companies 1 and 6, respectively. DCAA questioned an additional $1,995,869 of Company 1 claimed indirect
expenses, and an additional $511,822 of Company 6 claimed indirect expenses. Total questioned costs in
Companies 1 and 6 are $11,969,625, of which $119,696 is applicable to EPA contracts.
Agency Explanation: Resolution on hold. Resolution of audit results is not EPA's responsibility, but the responsibility
of the Department of Defense. Therefore, an expected resolution date cannot be determined at this time.
O/G Follow-Up Status: Resolution pending receipt of additional information.
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Report No. 07-1-00080, Lockheed Martin Services, Inc.—FY 2005 Incurred Cost, August 6, 2007
Summary: DCAA questioned $595,792,539 in claimed direct costs and $10,982,460 in proposed indirect costs and
rates. None of the questioned direct costs are chargeable to any of the EPA contracts. A number of the EPA
contracts have indirect ceiling rates that are lower than the contractor's proposed indirect rates, and are not impacted
by the questioned indirect expenses and rates. However, there are EPA contract/subcontracts that do not have
indirect ceiling rates and are impacted by the questioned indirect rates. EPA's share of questioned indirect costs
totals $133,069.
Agency Explanation: Resolution on hold. Resolution of audit results is not EPA's responsibility, but the responsibility
of the Department of Defense. Therefore, an expected resolution date cannot be determined at this time.
O/G Follow-Up Status: Resolution pending receipt of additional information.
Report No. 07-4-00080, National Academy of Sciences—FY 2006 Budget System, September 26, 2007
Summary: In DCAA's opinion, the budget and planning system and related internal control policies and procedures
are inadequate in part.
Agency Explanation: Resolution on hold. Resolution of audit results is not EPA's responsibility, but the responsibility
of the Department of Defense. Therefore, an expected resolution date cannot be determined at this time.
O/G Follow-Up Status: Resolution pending receipt of additional information.
Report No. 08-4-0002, Science Applications Intl. Corp—Company 1 Compensation Follow-Up, October 2, 2007
Summary: In DCAA's opinion, the contractor's compensation 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 that could adversely affect the contractor's ability to record, process,
summarize, and report compensation in a manner that is consistent with applicable government contract laws
and regulations.
Agency Explanation: Resolution on hold. Resolution of audit results is not EPA's responsibility, but the responsibility
of the Department of Defense. Therefore, an expected resolution date cannot be determined at this time.
O/G Follow-Up Status: Resolution pending receipt of additional information.
Report No. 08-1-00114, Weston Solutions Inc.—FY 12/31/2004 Incurred Cost, March 24, 2008
Summary: DCAA determined that the contractor's claimed direct costs are acceptable; however, DCAA questioned
$2,082,837 in proposed indirect costs and rates. Further, DCAA applied penalties in accordance with Federal
Acquisition Regulation 42.709, and identified expressly unallowable costs subject to penalty that had been allocated
to various contracts specified in Federal Acquisition Regulation 42.709(b), including 11 EPA contracts. Of the
questioned costs, EPA's total share of questioned costs is $197,869, of which $164,163 is questioned overhead costs
and $33,706 is the questioned general and administrative costs.
Agency Explanation: Resolution on hold. Resolution of audit results is not EPA's responsibility, but the responsibility
of the Department of Defense. Therefore, an expected resolution date cannot be determined at this time.
O/G Follow-Up Status: Resolution pending receipt of additional information.
Report No. 08-1-00131, Washington Group International, Inc.—FY 2001 Incurred Costs, April 15, 2008
Summary: DCAA questioned $2,208,686 of claimed direct costs and $13,757,945 of proposed indirect costs and
rates, a total of $15,966,631. EPA's share of the questioned costs is $44,648.
Agency Explanation: Resolution on hold. Resolution of audit results is not EPA's responsibility, but the responsibility
of the Department of Defense. Therefore, an expected resolution date cannot be determined at this time.
O/G Follow-Up Status: Resolution pending receipt of additional information.
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Report No. 08-1-0130, Morrison Knudsen Corporation—FY 1999 Incurred Costs, April 15, 2008
Summary: DCAA questioned $3,705,233 in claimed direct costs and $3,472,023 in proposed indirect costs and rates,
a total of $7,177,256 in questioned costs. EPA's share of questioned costs is $57,369.
Agency Explanation: Resolution on hold. Resolution of audit results is not EPA's responsibility, but the responsibility
of the Department of Defense. Therefore, an expected resolution date cannot be determined at this time.
OIG Follow-Up Statistics: Resolution pending receipt of additional information.
Report No. 09-1-00034, Lockheed Martin Services Group—FY 2006 Incurred Cost, November 24, 2008
Summary: DCAA questioned $23,672,344 in claimed direct and proposed indirect costs and rates. Of this, $381,582
is claimed direct costs and $23,290,762 is proposed indirect costs and rates. DCAA also did not audit $159,778,286
in claimed subsidiary and subcontracts costs. EPA's share of the questioned costs is 3 percent, or $11,448 in claimed
direct costs and $698,722 in proposed indirect costs, a total of $710,170.
Agency Explanation: Resolution on hold. Resolution of audit results is not EPA's responsibility, but the responsibility
of the Department of Defense. Therefore, an expected resolution date cannot be determined at this time.
O/G Follow-Up Status: Resolution pending receipt of additional information.
Office of Enforcement and Compliance Assurance
Report No. 08-P-00278, Strategic Planning in Priority Enforcement Areas, September 25, 2008
Summary: The Office of Enforcement and Compliance Assurance has instituted a process for strategic planning in its
national enforcement priority areas. The FYs 2008-2010 strategic plans we reviewed—for air toxics, combined sewer
overflows, and mineral processing—contain an overall goal, a problem statement, and other key elements. However,
each of the plans is missing key elements to monitor progress and accomplishments and efficiently utilize Agency
resources. All three strategies lack a full range of measures to monitor progress and achievements. Two strategies
lack detailed exit plans. Additionally, the combined sewer overflow strategy does not address the states' key roles in
attaining the strategy's overall goal. The absence of these elements hinders Office of Enforcement and Compliance
Assurance from monitoring progress and achieving desired results in a timely and efficient manner.
Agency Explanation: The OIG issued a memorandum to the Office of Enforcement and Compliance Assurance on
January 20, 2010, that requested this office to change the designation of recommendation 2-2 in the Management
Audit Tracking System to "unresolved," and include it in the list of recommendations unresolved after a year. The OIG
indicated that it would pursue this matter through the formal EPA audit resolution process.
O/G Follow-Up Status: Referred to Audit Resolution Board.
Office of Environmental Information
Report No. 10-P-0177, EPA's Revised Hiring Process Needs Additional Improvements, August 9, 2010
Summary: This report reviewed EPA's appointment process managed by OARM to determine how the new process
for filling vacancies can be more efficient and effective. The OIG found that EPA had not implemented critical
technology upgrades or obtained other resources necessary for the service center concept to succeed. The OIG also
found that service centers did not consistently provide program managers with the best candidates, and data quality
and recruitment action processes need improvement. The OIG recommend that (1) EPA officials determine the scope
of services to be obtained from a line-of-business provider, select the provider, and develop and implement a plan to
migrate to the provider; and (2) the appropriate EPA official help program offices standardize position descriptions
and review EZ-Hire questions; increase subject matter expert involvement in evaluating applications; improve the
reorganization policy and procedures; obtain feedback on inquiries about personnel actions being processed; and
address various staffing, policy, and procedural issues.
Agency Explanation: This audit is assigned to three offices. OIG replied that the issues needing to be resolved are
with OARM; they will advise if OEI needs to adjust its Corrective Action Plan.
O/G Follow-up Status: No response
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April 1, 2011—September 30, 2011
Office of Grants and Debarment
Report No. 10-4-0067, Incurred Cost Audit of Three EPA Cooperative Agreements Awarded To National Tribal
Environmental Council, Inc., February 17, 2010
Summary: We questioned $2,802,222 of the $3,586,445 reported because the recipient claimed unsupported costs of
$2,768,490 and ineligible costs of $33,732 that did not comply with the financial and program management standards
of 40 CFR Subpart B, Part 30. While the recipient's work plans describe activities and planned deliverables, they do not
include a description of the recipient's goals or objectives for its participation in the Western Regional Air Partnership
and National Tribal Air Association. Without the goals and objectives, the annual reports could not include a
comparison of accomplishments with the objectives for the period, as required by 40 CFR Subpart B, Part 30.51. As a
result, EPA cannot determine whether the funds EPA provided the recipient achieved their intended purpose.
Agency Explanation: The OIG approved an extension for OGD's management decision to October 21, 2011.
OIG Follow-Up Status: No response.
Office of the Chief Financial Officer
Report No. 10-P-0177, EPA's Revised Hiring Process Needs Additional Improvements, August 9, 2010
Summary: Our analysis of EPA's appointment process managed by OARM identified that EPA had not implemented
critical technology upgrades or obtained other resources necessary for the service center concept to succeed. EPA
produced three reports, including its 2007 Business Case, which identified key factors for a successful transition to
the service center concept. However, EPA management implemented the transition without obtaining some of these
key capabilities, including electronic infrastructure.
Agency Explanation: This audit is assigned to three offices. OIG replied that the issues needing to be resolved are
with OARM; they will advise if the Office of the Chief Financial Officer needs to adjust its Corrective Action Plan.
OIG Follow-up Status: No response
Region 1—Regional Administrator
Report No. 10-3-0094, Indian Township Tribal Government—FY 2008, April 5, 2010
Summary: Our analysis identified significant variances between grant funds received from EPA and the funds expended
by the tribe. This difference created variances between funds left to draw and expend to financially close out the grants.
The total variance between funds left to draw and the funds left to expend was $14,668.
Agency Explanation: Region 1 has reviewed all grant agreements listed in the finding #2008-18. One grant
agreement has been left open with $11,821 left to draw down; all other grant agreements have been financially
closed. Region 1 spoke with the tribe on September 23, 2011, regarding the questioned costs. Region 1 is
coordinating with the recipient and program office to resolve $14,668 in questioned costs. The target date to resolve
questioned costs is October 30, 2011.
OIG Follow-Up Status: No response.
Region 4—Regional Administrator
Report No. 10-4-0001, Internal Control Weaknesses under EPA Grant Nos. I004802070 and BG96483308,
Awarded to the Eastern Band of Cherokee Indians, Cherokee, North Carolina, October 5, 2009
Summary: The OIG received a Hotline complaint regarding EPA assistance agreement nos. I004802070 and
BG96483308, awarded to the Eastern Band of Cherokee Indians, Cherokee, North Carolina. The grantee did not
have a conflict of interest, as alleged, and its Standard Form 272s were correct and prepared in compliance with
federal requirements, EPA policies, and grant terms and conditions. However, during the course of our examination,
we identified significant deficiencies in internal controls concerning equipment purchases and segregation of duties.
Some purchase authorizations were dated the same day equipment was delivered, three quotes were not always
obtained, and purchases were not always properly authorized. Also, one employee was authorized to write grant
proposals; solicit funding to carry out the program goals; prepare budgets; oversee the expenditure of funds; and
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purchase, maintain, repair, and inventory all equipment. We recommended that EPA require the grantee to comply
with its internal control policies and establish additional internal controls as needed.
Agency Explanation: Per the Grants Management Officer, the grantee's memorandum to the OIG will be revised to
address missing information as requested by the OIG. The projected completion date is December 30, 2011.
OIG Follow-Up Status: Resolution pending receipt of additional information.
Report No. 10-4-0003, Costs Claimed Under EPA Grant XP97424901 Awarded to West Rankin Utility
Authority, Flowood, Mississippi, October 13, 2009
Summary: The grantee did not meet the procurement and financial management requirements of Title 40 Code of
Federal Regulations Part 31. As a result, we questioned $1,745,457 in unsupported architectural and engineering
costs claimed. The grantee will need to repay $663,321 of grant funds. The grantee did not agree with those
questioned costs. Due to the noncompliances and internal control weaknesses noted, the grantee may not have the
capability to manage future grant awards.
Agency Explanation: As of September 21, 2011, the Grants Management Officer is in the process of drafting a memo
to EPA headquarters requesting a contracting deviation. The officer anticipates routing this memo to EPA
headquarters no later than December 30, 2011.
OIG Follow-Up Status: Incomplete response.
Report No.10-4-0013, Costs Claimed Under EPA Grant No. XP9468195 Awarded to the City of Flowood,
Mississippi, October 27, 2009
Summary: The grantee did not perform a cost analysis or negotiate a fair and reasonable profit as a separate element
of the contract price as required under Title 40 Code of Federal Regulations 31.36(f). As a result, we questioned
$1,755,157 in unsupported architectural and engineering costs claimed. The grantee will need to repay $896,224 of
grant funds. The grantee did not agree with those questioned costs.
Agency Explanation: As of September 21, 2011, the Grants Management Officer is in the process of drafting a memo
to EPA headquarters requesting a contracting deviation. The officer anticipates routing this memo to EPA
headquarters no later than December 30, 2011.
OIG Follow-Up Status: Incomplete response.
Report No. 11-3-0180, Cocoa-City of FY 2009, March 28, 2009
Summary: During the single audit, several adjustments were required to the Schedule of Expenditures of Federal
Awards initially provided by management. Adjustments were required to include amounts transferred to subrecipients,
to include additional expenditures resulting from closing journal entries made prior to the start of the audit and to
remove expenditures related to matching funds and amounts outside the period of availability.
Agency Explanation: The EPA letter to the recipient was mailed on September 29, 2011. EPA anticipates resolution
by October 30, 2011.
OIG Follow-Up Status: No response.
Region 7—Regional Administrator
Report No.11-3-0142, Grace Hill Settlement House FY 2009, March 4, 2011
Summary: The OIG questioned $456,940 as unsupported due to various internal control noncompliances, and lack of
support for contract procurements. We recommended that these funds be recovered unless adequate documentation
can be provided by the recipient. We also recommended that EPA impose special grant conditions, in accordance
with 40 CFR 30.21.
Agency Explanation: As of September 19, 2011, Region 7's final determination letter to submit to the OIG was still
being finalized by regional management. Final determination letter expected by October 31, 2011.
OIG Follow-Up Status: No response
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Region 8—Regional Administrator
Report No. 2007-4-00078, Cheyenne River Sioux Tribe, September 24, 2007
Summary: The tribe did not comply with the financial and program management standards under Title 40 Code of
Federal Regulations Parts 31 and 35, and OMB Circular A-87. We questioned $3,101,827 of the $3,736,560 outlays
reported. The tribe's internal controls were not sufficient to ensure that outlays reported complied with federal cost
principles, regulations, and grant conditions. In some instances, the tribe also was not able to demonstrate that it had
completed all work under the agreements and had achieved the intended results.
Agency Explanation: Region 8 is in the process of working with the tribe on writing policies and procedures that cover
tribal-wide financial and administrative management. The OIG has expressed to the region that it would not be
comfortable closing the audit until these procedures were in place. The region continues to conduct site visits and
regular meetings along with working with other federal agencies on solutions.
OIG Follow-Up Status: No response.
Report No. 08-3-0307, Oglala Sioux Tribe, FY 2004, September 30, 2008
Summary: The single auditor's findings indicate that the tribe may not be able to support the costs claimed under
EPA grants. As a result, we are questioning the costs claimed of $1,158,903.
Agency Explanation: Region 8 is conducting final follow up on issues identified in sampling and review. Final analysis
is expected to be completed by October 31, 2011. A conference call was held between Region 8 and the OIG office
in September to review status.
OIG Follow-Up Status: No response.
Report No. 09-3-0252, Oglala Sioux Tribe, FY 2005, September 29, 2009
Summary: The single auditor's findings indicate that the tribe may not be able to support the costs claimed under
EPA grants. As a result, we are questioning the costs claimed during 2005 of $307,323 as being unsupported.
Agency Explanation: Region 8 is conducting final follow up on issues identified in sampling and review. Final analysis
is expected to be completed by October 31, 2011. A conference call was held between Region 8 and the OIG office
in September to review status.
OIG Follow-Up Status: No response.
Report No. 09-3-0253, Oglala Sioux Tribe, FY 2006, September 30, 2009
Summary: The single auditor's findings indicate that the tribe may not be able to support the costs claimed under
EPA grants. As a result, we are questioning the costs claimed in 2006 of $530,042 as being unsupported.
Agency Explanation: Region 8 is conducting final follow up on issues identified in sampling and review. Final analysis
is expected to be completed by October 31, 2011. A conference call was held between Region 8 and the OIG office
in September to review status.
OIG Follow-Up Status: No response.
Region 9—Regional Administrator
Report No. 10-P-0112, Results of Hotline Complaint Review of EPA Region 9 Hiring under the Federal Career
Intern Program, April 26, 2010
Summary: The hotline allegations against EPA Region 9 were unsubstantiated. We identified that the region
engaged in a prohibited personnel practice. Neither the Office of Personnel Management nor EPA prohibits the use
of a job fair and registration code as recruiting and hiring methods. However, Region 9 engaged in a prohibited
personnel practice by giving four Federal Career Intern Program job fair participants improper advantages not
provided to others attending the job fair.
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Agency Explanation: OARM requested OIG to close recommendations 2 and 3 in May 2011. However, the OIG
stated that these recommendations will remain open but held in abeyance. No resolution can be reached until such
time that the Office of Personnel Management issues pertinent implementing regulations and, as a result, EPA can
develop implementing polices.
OIG Follow-Up Status: Incomplete response.
Report No. 11-3-0150, Summit Lake Paiute Tribe FY 2008, March 9, 2011
Summary: The OIG questioned as unsupported $291,097 in EPA expenditures. We found a lack of segregation of
duties over financial records, and interim financial status reports being filed late and not being reconciled to the
general ledger. Due to the severity of the findings and the going concern risk, we recommended that EPA consider
the recipient to be high-risk in accordance with 40 CFR 31.12, and place appropriate restrictions/grant conditions
upon the recipient. Also, we recommended that EPA input these findings into the Grantee Compliance Database and
consider this information as a part of future pre-award decisions.
Agency Explanation: A request to rescind the final determination letter was submitted to the OIG along with a request
for resolution hold pending outcome of an agreed-upon procedures review. The final report for the agreed-upon
procedures is expected to be released by the end of October.
OIG Follow-Up Status: Resolution pending receipt of additional information.
Report No. 11-3-0151, Summit Lake Paiute Tribe FY 2008, March 9, 2011
Summary: The OIG questioned as unsupported $301,113 in EPA expenditures. We found a lack of segregation of
duties over financial records, interim financial status reports being filed late and not being reconciled to the general
ledger, and the tribe drawing down grant funds to cover deficits in other funds. As a result, the single auditor
questioned $1,070,651 in deferred revenue balance in excess of cash on hand. Due to the severity of the findings
and the going concern risk, we recommended that EPA consider the recipient to be high-risk in accordance with 40
CFR 31.12, and place appropriate restrictions/grant conditions upon the recipient. Also, we recommended that EPA
input these findings into the Grantee Compliance Database and consider this information as a part of future pre-
award decisions.
Agency Explanation: A request to rescind the final determination letter was submitted to the OIG along with a request
for resolution hold pending outcome of an agreed-upon procedures review. The final report for the agreed-upon
procedures is expected to be released by the end of October.
OIG Follow-Up Status: Resolution pending receipt of additional information.
Region 10—Regional Administrator
Report No. 10-4-00241, Costs Claimed by the Alaska Native Tribal Health Consortium Under EPA Interagency
Agreement DW 75-95754001, September 30, 2010
Summary: The consortium did not meet financial management requirements specified by the Code of Federal
Regulations. EPA needs to recover $1,007,690 of $1,493,893 in costs questioned under the interagency agreement.
The questioned costs identified during the audit were primarily caused by a miscommunication between the
consortium and the U.S. Department of Health and Human Services on the application of approved indirect rates.
Agency Explanation: EPA staff met via teleconference with Indian Health Service and Alaska Native Tribal Health
Consortium staff to discuss possible approaches to resolving the OIG's findings and recommendations. The Indian
Health Service and Alaska Native Tribal Health Consortium will provide additional documentation to EPA by
November 1, 2011. After that, EPA will draft and submit another management decision and action plan to OIG.
Estimated date for resolution is December 31, 2011.
OIG Follow-Up Status: Incomplete response
Total reports issued before reporting period for which
no management decision had been made as of September 30, 2011 = 37
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Semiannual Report to Congress
April 1, 2011—September 30, 2011
Appendix 3—Reports With Corrective Action Not Completed
In compliance with reporting requirements in the Inspector General Act, Section 5(a)(3), "Identification of
Reports Containing Significant Recommendations Described in Previous Semiannual Reports on Which
Corrective Action Has Not Been Completed," and to help EPA managers gain greater awareness of
outstanding commitments for action, we developed a Compendium of Unimplemented
Recommendations. This separate document provides the information required in appendix 3 to this
Semiannual Report to Congress. This compendium (available upon request or at
http://www.epa.qov/oiq/reports/2012/20111031 -12-N-0034.pdf) is produced semiannually for Agency
leadership and Congress based on Agency reports on the status of action taken on OIG
recommendations and OIG selective verification of that reported status.
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Semiannual Report to Congress
April 1, 2011—September 30, 2011
Appendix 4—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
Atlanta
U.S. Environmental Protection Agency
Office of Inspector General
61 Forsyth Street, SW
Atlanta, GA 30303
Audit/Evaluation: (404) 562-9830
Investigations: (404) 562-9857
Boston
U.S. Environmental Protection Agency
Office of Inspector General
5 Post Office Square, Suite 100 (OIG15-1)
Boston, MA 02109-3912
Audit/Evaluation: (617) 918-1470
Investigations: (617) 918-1466
Chicago
U.S. Environmental Protection Agency
Office of Inspector General
77 West Jackson Boulevard
13th Floor (IA-13J)
Chicago, IL 60604
Audit/Evaluation: (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/Evaluation: (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/Evaluation: (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/Evaluation: (303) 312-6969
Investigations: (303) 312-6868
Kansas City
U.S. Environmental Protection Agency
Office of Inspector General
901 N. 5th Street
Kansas City, KS66101
Audit/Evaluation: (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/Evaluation: (212) 637-3049
Investigations: (212) 637-3041
Philadelphia
U.S. Environmental Protection Agency
Office of Inspector General
1650 Arch Street, 3rd Floor
Philadelphia, PA 19103-2029
Audit/Evaluation: (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/Evaluation: (919) 541-2204
Investigations: (919) 541-1027
San Francisco
U.S. Environmental Protection Agency
Office of Inspector General
75 Hawthorne Street (IGA-1)
7th Floor
San Francisco, CA 94105
Audit/Evaluation: (415) 947-4521
Investigations: (415) 947-4500
Seattle
U.S. Environmental Protection Agency
Office of Inspector General
12006th Avenue, 19th Floor
Suite 1920, M/SOIG-195
Seattle, WA 98101
Audit/Evaluation: (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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Report fraud, waste or abuse
e-mail: OIG_Hotline@epa.gov
write: EPA Inspector General Hotline
1200 Pennsylvania Avenue NW
Mailcode2431T
Washington DC 20460
fax: 202-566-2599 • phone: 1-888-546-8740
www.epa.gov/oig/hotline.htm
It's your money
It's your environment
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