Office of Inspector General
Audit Report
SUPERFUND
Superfund Interagency Agreements
Report No. 2001-P-00011
June 22, 2001

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Inspector General Divisions
Northern Division:
Robert Bronstrup
Leah Nikaidoh
Mike Davis
Tim Roach
Ann Weiland
Central Division:
Randy Holthaus
Angela Bennett
Dan Howard
Regions Covered:
Regions 2, 5, 6, and 7
Program Offices Involved:
Office of Solid Waste and Emergency
Response
Office of Administration and Resources
Management

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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
OFFICE OF THE INSPECTOR GENERAL
NORTHERN DIVISION
77 WEST JACKSON BOULEVARD
CHICAGO, IL 60604-3590
June 22, 2001
MEMORANDUM
SUBJECT: Report No. 2001-P-00011
Superfund Interagency Agreements Audit

5321
X ^
a
FROM: Leah L. Nikaidoh /s/
Audit Manager
Northern Audit Division
TO:	Michael Shapiro
Acting Assistant Administrator
Office of Solid Waste and Emergency Response (OSWER)
David O'Connor
Acting Assistant Administrator
Office of Administration and Resources Management (OARM)
David Ullrich
Acting Regional Administrator
Region 5
Attached is our report entitled Superfund Interagency Agreements. We discussed our
findings with your staff and issued a draft report. We summarized your comments in the final
report and included your complete responses in Appendices 1, 2, and 3.
We appreciate the cooperation of your staff and the assistance provided throughout the
audit. The staff exhibited a genuine interest in working with us to improve Superfund interagency
agreements and helped add value to this audit. The proactive participation and cooperation of
officials in OSWER, OARM, and Regions 2, 5, 6 and 7 throughout the audit greatly helped us in
completing this national review timely.
ACTION REQUIRED
In accordance with EPA Order 2750, you, as the action official, are required to provide
this office a written response to the audit report within 90 days of the final audit report date. For
corrective actions planned but not completed by the response date, reference to specific milestone
dates will assist in deciding whether to close this report. Region 5, in its response, provided

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corrective actions and milestone dates. Therefore, no further response is required for Region 5.
Region 5 should track any actions planned, but not yet completed, in its management tracking
system.
This audit report contains findings that the Office of Inspector General (OIG) has
identified and corrective actions OIG recommends. This audit report represents the opinion of
OIG, and the findings in this audit report do not necessarily represent the final EPA position.
Final determinations on matters in this audit report will be made by EPA managers in accordance
with established EPA audit resolution procedures.
We have no objection to the release of this report to the public. If you have any questions,
please contact me at (513) 487-2365, or Mike Davis at (513) 487-2363. Please refer to the
report number 2001 -P-00011.
Attachment
2

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Table of Contents
Abbreviations 	iii
Introduction	1
Purpose	1
Background	1
Summary of Results	2
Agency Comments and OIG Evaluation	3
Scope and Methodology 	3
Findings and Recommendations	4
1: Regions Could Improve the Process for Reviewing
Qualifications of Servicing Agencies and Their Contractors 	4
2: IAG Terms and Conditions Generally Defined the
Responsibilities of EPA and its Servicing Agencies	11
3: EPA Generally Monitored IAGs
in a Consistent and Effective Manner 	13
4: The 1991 OSWER Directive
Was Inconsistently Implemented	15
5: Memorandums of Understanding
with Federal Agencies Need Improvement 	17
Exhibits
A: Environmental Accomplishments 	19
B: IAG Cost Summary 	22
C: Details on Scope and Methodology 	23
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Appendices
1: OSWER Response to Draft 	25
2: OARM Response to Draft	27
3: Region 5 Response to Draft	29
4: Report Distribution 	31
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Abbreviations
EPA
Environmental Protection Agency
IAG
Interagency Agreements
Manual
Project Officer Manual
MOU
Memorandum of Understanding
OARM
Office for Administration and Resources Management
OIG
Office of Inspector General
OSWER
Office of Solid Waste and Emergency Response
RMD
Resource Management Directives
USACE
U.S. Army Corps of Engineers
in
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Introduction
Purpose
The Superfund program had almost $3.5 billion in active or recently
completed Interagency Agreements (IAGs) obligated as of
September 2000 for removal and remedial activities. Our overall
audit objective was to determine whether the U.S. Environmental
Protection Agency (EPA) had effective controls in place to ensure
its Superfund IAGs achieve expected environmental results in a
timely, cost-effective, and efficient manner. The three specific sub-
objectives designed to answer the overall objective were:
Does EPA (a) determine qualifications of servicing agencies and
contractors, and (b) ensure the IAG terms and conditions define
the responsibilities of EPA and its servicing agencies?
 Does EPA monitor IAGs in a consistent and effective manner?
Is the 1991 Office of Solid Waste and Emergency Response
(OSWER) Directive regarding assignment of remedial actions
between EPA contracts and the U.S. Army Corps of Engineers
(USACE) practical for planning Superfund remedial activities?
Background
Congress established the Superfund program by passing the
Comprehensive Environmental Response, Compensation, and
Liability Act in 1980 to locate, investigate, and clean up the worst
uncontrolled or abandoned hazardous waste sites nationwide. To
clean up these sites EPA uses a variety of extramural instruments
(such as contracts, assistance agreements, and IAGs) to perform
specific Superfund remedial and removal activities. An IAG is a
written agreement between Federal agencies in which one agency
needing supplies or services obtains them from another Federal
agency (the servicing agency) on a reimbursable basis. EPA may
also sign Memorandums of Understanding (MOUs) with servicing
agencies to formally specify responsibilities, as well as establish the
policies and set the framework for the funded IAGs.
EPA has two offices that are responsible for administering
Superfund IAGs: (1) OSWER, and (2) the Office for
Administration and Resources Management (OARM). The
OSWER is responsible for overall management of the Superfund
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program at EPA. Within each Region, Project Officers and
Remedial Program Managers monitor specific Superfund IAGs to
ensure goods and services paid for by EPA are received. The
OARM is responsible for issuing IAG policy and guidance.
EPA has issued two Resource Management Directives (RMDs) that
pertain to EPA's Superfund IAGs. RMD 2550C addresses the
policies and procedures that govern the relationship between EPA
and its servicing agencies under an IAG. RMD 2550D contains
specific information on the use of IAGs in the Superfund program,
and provides requirements relating to cost documentation, project
specific conditions, and billing conditions.
Summary of Results
EPA generally had effective controls in place to ensure its
Superfund IAGs achieve expected environmental results in a timely,
cost-effective, and efficient manner. The terms and conditions in
the individual IAGs defined the roles and responsibilities of EPA
and its servicing agencies, and most Regions reviewed and
monitored IAGs in a consistent and effective manner. However,
there are areas in which EPA could make enhancements to the IAG
process to ensure it receives the products and services paid for.
Specifically:
Regions did not consistently determine the qualifications of
servicing agencies and their contractors.
Region 5 did not include in its IAGs all required terms and
conditions, and did not monitor IAGs on a consistent basis.
The 1991 OSWER Directive was out of date and inconsistently
used by Regions to assign Superfund work between EPA
contractors and IAGs with the US ACE.
Additionally, we noted that three MOUs between EPA and other
agencies excluded important terms and conditions needed for
safeguarding the Superfund Trust Fund.
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OSWER, OARM, and Region 5 all generally concurred with our
findings and recommendations, and their planned corrective actions
were responsive to our recommendations. Both OSWER and
OARM expressed concern that discussing servicing agency and
contractor qualifications could lead to a potential de facto
debarment of contractors. We conducted an exit conference on
June 20, 2001 to discuss concerns with the draft report. As a
result, we revised our findings and recommendations in this final
report to mitigate the concern of a potential de facto debarment.
We reviewed a total of 18 active or recently completed IAGs from
Regions 2, 5, 6, and 7 to accomplish our objectives. Exhibit A lists
environmental accomplishments related to these IAGs; exhibit B
provides a cost summary for each IAG; and, exhibit C provides
additional details on our audit scope and methodology.
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Rnding^mtn*ecomme^
Finding 1: Regions Could Improve the Process for Reviewing
Qualifications of Servicing Agencies and Their Contractors	
EPA Regions did not consistently determine and/or document the
qualifications of servicing agencies and their contractors in
accordance with EPA guidance. Also, the Regions did not check
on servicing agency/contractor performance in other Regions to
learn if they had incurred any problems. These conditions generally
occurred due to a lack of effective processes. Consequently, there
was an increased risk that a servicing agency and/or contractor with
known performance problems in one Region could be awarded
work in other Regions, which could result in EPA paying excessive
amounts and/or receiving inadequate service.
Guidance Emphasizes EPA guidance emphasizes the importance of determining servicing
Importance of	agency qualifications. The Project Officer Manual (Manual)
Qualifications	requires every Decision Memorandum to include an explanation as
to why the servicing agency was selected. The Manual also states:
Although the relationship under an IAG is with another
Federal agency, inadequate performance should be
considered in deciding whether to undertake future
cooperative efforts with that agency. Project Officers
should also report poor performance (in writing) to the
Grants Management Office.
Servicing Agency
Qualifications
Not Consistently
Determined or
Documented
Regions 6 and 7 formally documented the selection of the servicing
agency in the Decision Memorandums, which explain why the
servicing agencies were selected. In contrast, Regions 2 and 5 had
no information in any of the 10 IAG Decision/Action
Memorandums that we reviewed (5 for each Region) that
documented the qualifications and reasons for selecting the
servicing agency. Specifically:
Although Region 2 officials conducted reviews, they did not
document the reasons for selection in individual IAG
Decision/Action Memoranda (based upon such factors as past
performance, technical ability, etc.), primarily because they had
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been using the same servicing agency for a number of years.
Based on a 1983 MOU between EPA and the US ACE, as well
as a 1991 OSWER Directive1, they considered that to be
sufficient basis for using USACE.
Region 5 project managers said they were unaware of the
requirement to include a justification for selecting a particular
servicing agency. Additionally, servicing agency qualifications
were not always determined.
Information Needs	EPA has no effective process to report and disseminate
to Be Shared	servicing agency performance information among Regions. Only
Among Regions	4 of the 18 project managers (Project Officers, Remedial Program
Managers, and on-scene coordinators) for our review indicated they
asked other Regions about qualifications of servicing agencies. The
four project managers, however, had no documentation of such
discussions in any of their respective IAG files. The absence of an
effective process to evaluate servicing agency qualifications beyond
regional boundaries could result in poor-performing servicing
agencies being awarded additional work in other Regions.
For example, we noted a specific instance in which a servicing
agency with a history of contract management and contractor
performance problems successfully marketed services that it was
not able to deliver. In an EPA Office of Inspector General (OIG)
audit report issued January 22, 1996,2 we reported contractor
management problems with the five IAGs that the Department of
Interior's Bureau of Reclamation - the servicing agency - had at
EPA Region 8's Summitville site. The OIG identified problems
with the Bureau's ability to ensure that the appropriate contracting
decisions were made to monitor and control costs. In our report,
we indicated that the Department of Interior-OIG had identified
$5.8 million in contractor overpayments, under a separate
Department of Interior-OIG audit. The EPA-OIG recommended
that EPA reevaluate the suitability of the Bureau to continue
managing Region 8 cleanup sites and any future EPA Superfund
cleanup activities. However, on September 23, 1996, eight months
11991 OSWER Directive encourages EPA to assign remedial activity over $15 million to USACE.
2EPA Report No. 6400019, "Region 8 Needed to Further Improve Interagency Agreement Oversight to
Ensure Efficient Summitville Superfund Site Cleanup." This audit report was the result of a March 1995
Congressional request, in which a Congressman expressed concerns with the Bureau's contractor and the Bureau's
oversight of the contractor at the Summitville site.
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after the EPA-OIG report was issued, Region 5 officials (without
knowledge of the EPA-OIG audit report) awarded an IAG to the
Bureau and the same contractor to perform removal activities at the
Benton Harbor site, where problems in monitoring and controlling
costs were also encountered.
The absence of EPA having a national process for reporting poor
performing servicing agencies may have contributed to the Benton
Harbor IAG exceeding its estimated cost and time for completion.
A better process may have resulted in the selection of another
contractor to perform the work at Benton Harbor. The Benton
Harbor IAG, which involved radiation cleanup, was expected to
cost $2.7 million and take 2 years to complete. This IAG had a
final cost of $7.08 million, and the cleanup is still not complete.
Region 5 let the period of performance for the IAG expire, and
plans to finish the site cleanup with an EPA contractor.
Two EPA Councils	EPA has two national councils in place that could be used to
Could be Used to Share share information on IAGs and servicing agencies between the
Information Nationally Regions:
	Superfund Senior Regional Management and Acquisition
Council: The mission of this council is to provide guidance and
direction to Superfund program managers implementing
recommended improvements in management processes that
promote consistent approaches to managing high quality
cleanup projects. One of the council's emphases is to serve as a
conduit for information transfer.
	Grants Customer Relations Council: The mission of this
council is to provide a forum for discussing matters relating to
the administrative management of assistance agreements. An
objective of the council is to continually improve the Agency's
assistance agreement processes and systems, emphasizing a
preventative approach.
Although the Superfund Senior Regional Management and
Acquisition Council concentrates on contracting issues facing
Superfund, and the Grants Customer Relations Council focuses on
assistance agreements, little time is devoted to IAG issues as part of
either workgroup. Since the Superfund program had almost $3.5
billion awarded in active IAGs as of September 2000, incorporating
IAGs and servicing agency qualifications as part of those two
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council's missions or another IAG focus group could better ensure
that qualification issues are timely and fully resolved.
EPA Participated	The Regions participated in the contractor selection process with
in Contractor	USACE, in accordance with RMD 2550D, which encourages
Qualifications	Remedial Program Manager participation. For example, Region 2
Process	established a Contract Advisory Panel for the purpose of discussing
and selecting contractors that would be working on Superfund
IAGs with USACE. The Contract Advisory Panel consisted of the
USACE Program Manager and the EPA Remedial Program
Manager. The Remedial Program Manager's participation in this
process is important to ensuring the IAG is successfully completed.
However, this process did not include obtaining easily accessible
contract performance data.
The Regions did not obtain contractor performance data, in part
because the Directive does not specify how, or to what extent, the
Remedial Program Manager should participate in the contractor
selection process. Additionally, the Directive does not identify
what sources are available to obtain contractor performance
information. There are two sources that Remedial Program
Managers could consider:
contractor performance results from other EPA Regions, and
contractor information used by the servicing agency as part of
its contract management function.
EPA project managers should obtain information on contractor
performance so they can: (1) ensure the contractor is capable of
performing specific tasks required in the IAGs, and (2) address and
resolve any identified performance issues prior to awarding IAGs.
Such information, which should be maintained either by EPA or its
servicing agency, would include:
audit reports of the contractor and/or servicing agency contract
officials,
contractor evaluations prepared by the servicing agency, and
performance problems that are formally reported to Regional
Grants Management Offices by EPA project managers.
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An additional source of information on prior contractor
performance is the National Institutes of Health Contractor
Performance System. This is a tool used by Federal agencies for
researching qualifications and performance history of contractors.
EPA Project Officers and Remedial Program Managers may detect
contractors with a prior history of performance problems if they
begin using this system.
Conclusion
There is an increased risk that EPA could award IAGs to servicing
agencies with a history of poor performance unless Regions begin
using more available research tools. As previously noted, Region 5
selected the Bureau of Reclamation and its contractor for work at
Benton Harbor without taking into account performance problems
experienced with that servicing agency and contractor by another
Region. The Benton Harbor IAG was expected to take 2 years and
cost $2.7 million to complete, but the IAG cost $7.08 million and
the project is still not completed. Although we did not determine
how much of the overrun was due to legitimate reasons versus poor
performance, some of the more than $4 million in additional costs
could have been put to better use if qualifications (of both the
servicing agency and contractor) were confirmed prior to awarding
the IAG.
Recommendations
We recommend that OARM and OSWER:
1-1 Establish processes to: (a) review servicing agency
qualifications, (b) discuss IAG issues and servicing agency's
ability to monitor and control contractor performance, and (c)
report poor performance to the appropriate authorities.
1-2 Direct Regions to follow guidance to document selection of
servicing agencies under their IAGs.
Actions Taken
by Region	As a result of our discussions, Region 2 agreed to document the
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justification for selecting a servicing agency in all future Superfund
IAGs. The Region 5 Section Chief for Remedial Response also
agreed that including such information was reasonable.
Further, Region 5 agreed to standardize their IAG format to include
documentation of the rationale used to select an IAG versus a
contract. Region 5 also agreed to document the requirement in an
internal control memo for distribution and use in training within the
Superfund Division. We believe these steps are positive, but
additional actions need to be taken to fully implement the
recommendations.
Agency Comments
and OIG Evaluation	Although OSWER asserted that project officers should closely
monitor work under IAGs, they disagreed with the recommendation
to discuss contractor performance among Regions because such
discussions could lead to a potential de facto debarment situation.
OSWER considered evaluating the performance of another Federal
agency's contracting operations and the performance of the other
agency's contractor to be beyond the scope and authority of project
officers. It is OSWER's contention that EPA was only responsible
for justifying the selection, not qualifications, of the servicing
agency in its decision memorandums.
OARM agreed with the underlying premises of the recommendation
that EPA needs to pay greater attention to contractor performance
on IAGs. However, OARM was also concerned that such a
process, if not properly structured, would result in a de facto
debarment of contractors outside of the government-wide
debarment and suspension system. OARM warned that de facto
debarment could result in contractors filing lawsuits against Agency
officials in their individual capacities alleging violations of due
process rights.
We modified the report and recommendations after considering the
comments from OARM and OSWER, and consultation with our
legal counsel. We recognize that: (1) IAGs are agreements EPA
directly into enters with another agency and not the other agency's
contractor, and (2) contractors are entitled to due process of their
rights. However, EPA is not prohibited from discussing a servicing
agency's ability to monitor and control contractor performance
among Regions. If such discussions identify poor performance, it
should be shared among the Regions and reported to the
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appropriate authorities for resolution without resulting in a de facto
debarment. Such discussions among the Regions are important
since EPA has the ultimate fiduciary responsibility to safeguard the
Superfund trust fund. In addition, there are tools (i.e., audit
reports, contractor evaluations prepared by servicing agencies,
performance problems reported to Regional Grants Management
Offices, etc.) that are available and could be furnished to project
officers in order to evaluate another Federal agency's contracting
operations and the performance of the other agency's contractor.
These evaluations do not exceed the scope and authority of project
officers. Also, the EPA's IAG Project Officer manual requires
decision memorandums to include an explanation of why the other
agency was selected, and we believe it is reasonable and prudent to
expect a servicing agency's qualifications to be part of such an
explanation.
Finding 2: IAG Terms and Conditions Generally Defined the
	Responsibilities of EPA and its Servicing Agencies
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IAG terms and conditions generally defined the responsibilities of
EPA and its servicing agencies for all 18 IAGs reviewed. Also, all
of the RMD 2550D-required reporting requirements were included
in the IAGs in Regions 2, 6, and 7. However, the Region 5 IAGs
did not consistently include the following reporting requirements:
Weekly status reports
Upcoming activities
Budgeting on task-by-task basis
 Key Problems
This resulted in Region 5 not receiving necessary information to
manage projects.
RMD 2550D requires that specific project reporting requirements
be included in each IAG, including: (1) holding weekly status
updates, and, (2) submitting monthly progress reports to EPA with
important information on work being accomplished under the IAG
(such as scheduled and completed work, cost, problems resolved,
key personnel changes, deliverables submitted, upcoming
events/activities, and budget data on a task-by-task basis). The
information required under RMD 2550D is needed for the Project
Officer and Remedial Program Manager to actively plan and
manage their projects.
Regions 2, 6, and 7 included the required terms and conditions in
their IAGs because they had processes in place to ensure that the
terms and conditions were included. For example, these Regions
used standard language that incorporated all of the RMD 2550D
requirements as an IAG attachment. Region 5, however, has no
process to ensure that all requirements are included in the IAG
prior to issuance. Region 5 Remedial Program Managers were
unaware of RMD 2550D and therefore did not include all of the
required terms and conditions in their IAGs. As a result, they do
not receive needed information for monitoring assigned projects.
Recommendation
2-1 We recommend that Region 5 implement a process to ensure
that all of its IAGs contain the RMD 2550D elements.
Actions Taken
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by OSWER	OSWER stated that it also intends to work with the Grants
Administration Division to improve IAG and MOU terms and
conditions to address performance and oversight issues. We
believe OSWER's actions will further strengthen EPA's
administration and oversight of IAGs.
Agency Comments
and OIG Evaluation	Region 5 concurred with our finding and recommendation. Region
5 plans to make Superfund IAG project officers and technical staff
aware of the requirements of RMD 2550D by including the
requirements in an internal control memo and training to be
developed by a workgroup. The workgroup will be established in
the third quarter of Fiscal Year 2001 and the internal control memo
and training will be completed by the end of the first quarter of
Fiscal Year 2002. We believe Region 5's comments and planned
corrective actions are responsive to our recommendation.
Therefore, no further response is required for Region 5.
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Finding 3: EPA Generally Monitored IAGs
in a Consistent and Effective Manner
The Regions monitored their IAGs in a consistent and effective
manner, with the exception of Region 5. Three of the five IAGs in
Region 5 were not monitored on a consistent basis, due to the lack
of a process to ensure that monthly progress reports are sent to the
Project Officer by the servicing agency. Without regular reviews,
Region 5 is less likely to identify questionable billings and resolve
other discrepancies in a timely manner.
RMD 2550C, requires that the servicing agency provide monthly
progress and cost reports to the Project Officer. The Project
Officer has the responsibility to use this data for monitoring,
reviewing cost information, and resolving discrepancies identified in
the reports.
For Region 5, Remedial Program Managers were directly receiving
monitoring reports instead of Project Officers in some instances,
and thus Project Officers could not perform the required reviews.
In other instances, neither the Project Officer nor Remedial
Program Manager received the required reports. Region 5 had not
clearly and formally established a process to ensure that the
required reports are sent to Project Officers by the servicing
agency.
In 1998 Region 5's Contracts and Assistance Agreement Section
recognized that there were problems with receiving monitoring
information from US ACE. The section chief worked with US ACE
to correct the problem. However, monitoring reports are still not
received on a timely and consistent basis by the Project Officer.
Other Regions have used the monitoring reports to resolve
discrepancies. For example, Region 2 identified costs that were
inappropriately billed and paid to a servicing agency. A subsequent
review determined that the incorrect billings occurred because of a
problem with the servicing agency's accounting system, and the
incorrect charges were resolved by crediting future billings.
Recommendation
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3-1 We recommend that Region 5 establish a process that ensures
monitoring reports are received and reviewed by both the
Project Officers and Remedial Program Managers.
Agency Comments
and OIG Evaluation	Region 5 concurred with our finding and recommendation.
Region 5 plans to establish a workgroup in the third quarter of
Fiscal Year 2001 that will review how to improve the monitoring
process of IAGs in a consistent and effective manner. The
workgroup will consider other Regional processes and implement
its new process by the end of the first quarter of Fiscal Year 2002.
We believe R5's comments and planned corrective actions are
responsive to our recommendations. Therefore, no further
response is required for Region 5.
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Finding 4: The 1991 OSWER Directive
Was Inconsistently Implemented
The 1991 OSWER Directive3, which provides policy on assigning
remedial work, was out of date and not consistently used by the
Regions. This 10-year-old policy was not consistently used due to
ambiguities and the implementation of new EPA Superfund
procurement strategies.
The purpose of the 1991 OSWER Directive was to provide a policy
for the Regions to use when assigning remedial work between
EPA's remedial contractors and US ACE through IAGs. The policy
states that: (1) remedial actions over $15 million should be assigned
to US ACE; and, (2) assignment of projects to the Alternative
Remedial Contracting Strategy or USACE should not be based
solely on remedial action value. Subsequently, OSWER and
OARM introduced a new Contracts 2000 strategy that outlined a
new menu approach that allowed Regions discretion when selecting
a procurement option.
Our review showed the four Regions did not consistently use the
Directive. For example:
Region 6 considered the Directive as a planning option.
Nonetheless, they submitted waivers to OSWER that justified
why they did not use USACE for projects over $15 million.
Region 7 used the Directive as a planning tool, but did not use
it as the sole basis for awarding IAGs to USACE.
Region 2 believed the Contracts 2000 Strategy superseded the
Directive's dollar thresholds.
Region 5 did not find the Directive relevant to its current work,
since it did not have active IAGs exceeding the $15 million
threshold.
OSWER officials stated the Contracts 2000 Strategy did not
supersede its 1991 Directive. They said the 1991 Directive was
intended to provide flexibility in how Superfund remedial work was
3The OSWER Directive is entitled, "Revisions of Policy Regarding Superfund Project Assignment
between Alternative Remedial Contracting Strategy Contractors and the U.S. Army Corps of Engineers."
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assigned. OSWER explained that its Directive listed factors (such
as dollar value) that needed to be considered when assigning
Superfund work. However, it did not require work to be assigned
to US ACE based solely on dollar thresholds.
The ambiguity of the Directive, in conjunction with the new
procurement strategies in the Contracts 2000 Strategy, resulted in
Regions inconsistently implementing the Directive. It is a good
business practice to periodically review issued policies to ensure
that such policies will meet the goals and strategies of its
organization.
Recommendation
4-1 We recommend that OSWER review and update its 1991
OSWER Directive to ensure its goals and strategies are met.
Action Taken

by OSWER
During our monthly meetings with the OSWER and the Regions,

OSWER agreed that the Directive should be reviewed and updated.
Agency Comments
and OIG Evaluation
OSWER concurred with our finding and recommendation. OSWER
established a subgroup under the Design/Construction Phase II
workgroup to revise the 1991 OSWER directive entitled "Revisions
of Policy Regarding Superfund Project Assignment between
Alternative Remedial Contracting Strategy Contractors and U.S.
Army Corps of Engineers." We believe OSWER's comments and
planned corrective actions are responsive to our recommendations.
However, we believe a date for when such action will be completed
is needed to ensure its successful implementation.
Finding 5: Memorandums of Understanding
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with Federal Agencies Need Improvement
The Memorandums of Understanding (MOUs) that EPA entered
into with three servicing agencies to establish terms and conditions
for the management of Superfund IAGs did not include some terms
and conditions that would be useful for safeguarding the Superfund
Trust Fund. This condition occurred because EPA has no
applicable guidance governing MOUs for Superfund IAGs. As a
result of these omissions, the EPA Superfund Trust Fund is at risk
of not being reimbursed when a servicing agency or contractor
performs poorly.
For example, there were no terms and conditions that required:
Audits of the servicing agency's contractor upon completion of
the Superfund IAG.
Regular meetings between EPA and the servicing agency on a
national level to discuss IAG performance issues.
The servicing agency to identify recent reviews and audits of its
contracting practices, and a contractor performance system
used to evaluate contractors.
Since the ultimate fiduciary responsibility of safeguarding the
Superfund Trust Fund remains with EPA, a condition of recourse
for poor performance should be included in all MOUs entered with
servicing agencies performing under a Superfund IAG.
Currently, the MOU with the U.S. Coast Guard is the only MOU
that included a condition for recourse when a servicing agency
poorly performed its duties. For example, the MOU with the U.S.
Coast Guard stated that:
If based on an audit by the Department of Transportation
Inspector General, the U.S. Coast Guard determines that
any direct or indirect costs charged to Superfund are
unallowable, the U.S. Coast Guard will immediately notify
the EPA and promptly reimburse Superfund.
During our review, we also noted that the Assistant Administrator
for OSWER signed MOUs with the USACE in 1983, the Bureau of
Reclamation in 1987, and the U.S. Coast Guard in 1994. Since the
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Assistant Administrator for OARM issues IAG policy, we believe
the MOU process could be strengthened by also having that
Assistant Administrator review and approve the MOUs.
Recommendations
We recommend that OARM and OSWER:
5-1 Update all MOUs for Superfund IAGs to ensure that the
language is consistent.
5-2 Require the signature of both the OSWER and OARM
Assistant Administrators on all MOUs.
5-3 Develop terms and conditions to be included in all MOUs that
ensure: (a) final contractor audits will be performed of all
individual IAGs, and unallowable costs are reimbursed to
EPA; (b) periodic meetings are held by national servicing
agency officials to address any IAG performance issues; and,
(c) servicing agencies will provide audit and other pertinent
contract information to EPA, upon request, including
contractor information from its contractor performance
system.
Agency Comments
and OIG Evaluation	OSWER concurred with our finding and recommendations.
OSWER initiated a plan to revise the MOUs between EPA and
other Federal Agencies. OARM, however, did not respond to the
finding and recommendations. We believe OSWER's comments
and planned corrective actions meet the intent of our
recommendations. However, OSWER should establish milestones
that designate when the corrective action will be completed. In
addition, these corrective actions should be coordinated as a joint
effort between OSWER and OARM to ensure the revised MOUs
incorporate critical elements of both Superfund cleanup activities
and prudent IAG management practices.
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Exhibit A:
Environmental Accomplishments
Part of our activity during this audit focused on identifying the environmental benefits that
occurred with each IAG. We defined "environmental accomplishments" as the specific activities
that were included as part of each site's remedial action, as defined under the Record of Decision.
Generally, these were output events. If possible, we included expected environmental outcomes
as part of site remediation. All 18 IAGs accomplished improvements to the environment
according to EPA records. Below, in matrix form, is a summary of accomplishments that were
recorded in each Region:
Region 2
IAG Name
U.S. Radium
 34,000 cubic yards of radium contaminated material was removed.
Lipari Landfill
	Extracted and treated approximately 100 million gallons of on-site landfill leachate.
	Treated approximately 105 million gallons of off-site ground water.
	Excavated 128,000 tons of contaminated soils for the Chestnut Branch Marsh and
backfilled the excavated area with clean fill.
	Dredged and removed more than 85,000 tons of sediments from Alcyon Lake.
	Reduced the landfill leachate migration to off-site areas by 95%.
GCL Tire & Treat
	Excavated and treated over 82,000 cubic yards of contaminated soil and debris.
	Decontaminated and disposed of two 30,000 gallon steel treatment tanks.
	Decontaminated and disposed of 5,800 gallons of free product.
	Decontaminated and disposed of asbestos containing material.
	Decontaminated and disposed of 1,900 tons of creosote treated wood chips.
	Decontaminated and disposed of recycled 85 used tires.
Grand Street
 Relocation of all residents
Latex Industries
	Recycled or treated over 130,000 gallons of contaminated liquids (including flammable
organic liquids and PCB liquid wastes).
	Removed over 1,200 drums and 22 underground tanks.
	Destroyed 1,525 shock-sensitive materials.
	Removed 37 truckloads of non-hazardous combustible trash.
	Incinerated 12,048 gallons of flammable PCB solids.
	Sent 113,050 gallons of non-flammable PCB solids to an off-site landfill.
	Demolished 2 contaminated buildings (39,400 square feet) and disposed of the debris
off-site.
	Removed and disposed of 30 processing vats.
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Exhibit A
Page 2 of 3
Region 5
I AG Name
Ott Story/Cordova
 1,397,220 pounds of contaminants removed from 1,524,240,000 gallons treated.
Arcanum Iron &
Metal
	30,000 tons of battery casings removed from the site.
	Lead levels at the start of project were 20,000 ppb - 72,000 ppb and now are under 400
ppb (which is the maximum level for residential use).
	Farmers grow soybeans on the backfilled soil.
Benton Harbor
	200 5-gal containers of laquer and other organics removed.
	56 drums of radium-painted gauges removed.
	82 roll-offs of shredded material below 5 picoCuries/gm for radium shipped for disposal.
	24 roll-offs of shredded debris exceeding 5 picoCuries/gram (Ra-226) that were
hazardous waste (cadmium) shipped for disposal.
Allied Paper
	150,000 cubic yards of PCB-contaminated residual pulp waste, soil and sediment was
removed from the 22 acre site.
	Approximately 8 million gallons of contaminated water were treated and discharged.
	271,000 tons of clean backfill material were imported and placed within the excavation
limits.
Rapid Response
	44,836 tons of contaminated soil and sediment were excavated from Pettibone Creek,
plus 38,094 tons of contaminated soil were stabilized.
	A water pipeline to a nearby community was completed.
	1,200 cubic yards of soil were excavated and sent to a landfill. Pollutant levels in water
samples were lowered, which resulted in not needing municipal water hookups at well
water homes.
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Exhibit A
Page 3 of 3
Region 6
I AG Name
Environmental Accomplishments
Ouachita-Nevada
Wood Treaters
	Contaminated soils were excavated, removed, and disposed of properly.
	Contents of drum waste were mixed with the excavated site soils and disposed of
properly.
	Ground storage tanks were also emptied, decontaminated, and scrapped.
Bayou Bonfouca
	Excavation and onsite incineration of creosote waste piles and heavily contaminated
bayou sediment.
	A Resource Conservation and Recovery Act cap was placed over residues from the
incinerator and residual surface soils.
	Pump/ treatment/re-injection of contaminated groundwater.
Agriculture Street
Landfill
 The latest Pollution Report prepared by the On-Scene Coordinator, for the week of
September 18, 2000, noted that Operable Units 1 and 3 were completed in Phase I.
Operable Unit 2, residential area, had 42 homes remaining for cleanup. Of the 42
homes, 27 had been given recent access for cleanup. Construction/cleanup of these 27
homes was expected to take 14 weeks. The latest USACE Project Report, dated
December 2000, noted that 3 laccess agreements had been secured, with 25 homes
completed by Christmas.
Southern
Shipbuilding
 The incineration for Southern Shipbuilding was completed and all equipment associated
with the remedial action was demobilized in December 1996.
American Creosote
Works
	56,544 tons of PCB and creosote-contaminated soil incinerated.
	In-situ biological treatment of contaminated soil, and 26.7 million gallons of
contaminated groundwater.
	Remedy will reduce groundwater contamination to an acceptable level.
Region 7
I AG Name
Oronogo-
Duenweg
 1,998 properties have been excavated for lead-contaminated soil.
Cherokee
County
 A total of 602 residential homes had been remediated, thereby reducing public exposure to
soils with elevated lead and cadmium concentrations, thus reducing public exposure to
soils
with elevated lead and cadmium concentrations.
Omaha Lead
	135 properties have been excavated and backfilled, and have been planted with sod.
	Lead impacted soils have been removed from thirty properties.
	Preliminary screening by EPA indicated that some 211 properties out of the 348 tested had
elevated lead concentrations.
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Exhibit A
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Exhibit B:
IAG Cost Summary
Region	l.\(> Niimc	Project Number
Region 2

U.S. Radium
DW 96941732-01
$ 85.12

Lipari Landfill
DW 96941594-01
40.94

GCL Tire & Treat
DW 96941783-01
17.00

Grand Street
DW 96941785-01
12.48
Region 5
Latex Industries
DW 96941781-01
27.00

Ott Story/Cordova
DW 96947932-01
6.00

Arcanum Iron & Metal
DW 96947813-01
.08

Benton Harbor
DW 96947782-01
7.08

Allied Paper
DW 96947885-01
9.50
Region (>
Rapid Response
DW 96947840-01
6.05

Ouachita-Nevada
Wood Treaters
DW 14950232-01
2.20

Bayou Bonfouca
DW 96934070-01
133.00

Agriculture Street Landfill
DW 96950261-01
23.00

Southern Shipbuilding
DW 96950210-01
22.67

American Creosote Works
DW 96950151-01
19.10
27.31
Region 7
Oronogo-Duenweg
DW 96952114-01

Cherokee County
DW 96952111-01
12.48

Omaha Lead
DW 96952155-01
3.59
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Exhibit C:
Details on Scope and Methodology
Fieldwork was conducted by EPA-OIG's Central and Northern Divisions in Regions 2, 5, 6, and 7
from October 2000 to February 2001, and consisted of the following:
Documentation review and analysis
	EPA Resource Management Directive 2550C
	EPA Resource Management Directive 2550D
EPA Interagency Agreement Policy and Procedures Compendium
Agency Government Performance and Results Act Goals 5 and 10
Regions 2 and 5 Federal Managers' Financial Integrity Act Reports for 1998 and 1999
	Region 6 Fiscal Year 2000 Mid-Year Report, and Region 7 Fiscal Year 2000 Report
IAG file documentation: Records of Decision, progress reports, Action Memoranda, and
correspondence
Regional Superfund Division organization charts
Personnel Interviewed
	EPA personnel: On-Scene Coordinators, Remedial Program Managers, Project Officers, and
supervisors located in the Regions and at Headquarters.
	Other personnel: Servicing agency personnel.
Sample Selection
We reviewed a total of 18 active or recently completed IAGs as part of this audit. The IAGs in
each Region were selected based upon the following criteria:
1.	High dollar value of the IAGs
2.	Variety of servicing agencies
We initially selected 20 IAGs from EPA's Grants Information Control System data base, which
listed a total of 915 IAGs with a combined value of about $3.5 billion. We discussed our sample
selection with each Region's management, and adjusted our sample to ensure the IAGs we
selected met our criteria and provided results that would answer our objectives. To help us
address our objectives, we reviewed three MOUs, between EPA and the USACE, Bureau of
Reclamation, and U.S. Coast Guard, as they pertained to IAGs.
We conducted our audit work at OSWER and OARM, and at Regions 2, 5, 6, and 7. We also
made a site visit to the Benton Harbor Superfund site in Michigan.
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Exhibit C
Page 2 of 2
The audit was performed in accordance with the Government Auditing Standards issued by the
Comptroller General of the United States as they relate to economy and efficiency and program
results audits. We reviewed internal controls as required by the Government Auditing Standards.
Prior Audit Coverage
EPA OIG Report No. 6400019, "Region 8 Needed to Further Improve Interagency Agreement
Oversight to Ensure Efficient Summitville Superfund Site Cleanup," was the result of a March
1995 Congressional request, in which a Colorado Congressman expressed concerns with the
Bureau's contractor and the Bureau's oversight of the contractor at the Summitville site. While
Region 8 had reduced the hazardous waste risks to the environment and the public, EPA did not
adequately oversee and monitor its servicing agency (the Bureau) to control costs and ensure
efficient cleanup. The report recommendations included that EPA evaluate the suitability of the
Bureau's Upper Colorado Regional Office to manage the Summitville site and any other future
EPA Superfund cleanup activities.
EPA OIG Report No. 2000-P-000004, entitled "Timely Deobligation of Interagency Agreement
Funds," reviewed the Agency's ability to timely deobligate unliquidated IAG balances for
reprogramming for use by other EPA programs. While EPA had policies and procedures in place
to timely deobligate funds, the program offices and the cognizant grant offices did not consistently
follow the procedures. This resulted in IAG funds remaining obligated to projects that were
either completed or cancelled.
EPA OIG Report No. 2000-P-000029, entitled "Follow-Up on Headquarters Interagency
Agreements," reported that project officers were adequately monitoring work under their IAGs.
However, the Project Officers needed to: (1) ensure they adequately documented goods and
services received, and (2) obtain more detailed payment information under disbursement IAGs.
Also, OIG observed that the Agency's directives needed to be updated and/or consolidated, and
that training related to managing IAGs needed to be expanded to adequately cover the material in
IAG-related directives.
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Appendix 1:
OSWER Response to Draft
Page 1 of 2
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON, DC 20460
MAY 31 2001
OFFICE OF
SOLID WASTE AND EMERGENCY
RESPONSE
MEMORANDUM
SUBJECT: Response to OIG Draft Audit Report
"Superfund Interagency Agreements Audit'
FROM:
Michael H. Shapiro
Acting Assistant Administrator
TO:
Leah L. Nikaidoh, Audit Manager
Northern Audit Division
The Office of Solid Waste and Emergency Response appreciates the opportunity to
comment on the subject draft report. The monthly conference calls were very helpful in keeping
us informed of the status of the audit, and we appreciated seeing an advanced copy of the draft
report for review and comment. The Grants Administration Division, Office of Administration
and Resources Management, will be forwarding their comments separately.
We are pleased that your summary of audit findings state that we have effective controls
in place to ensure that Superfund Interagency Agreements (IAGs) achieve expected
environmental results in a timely, cost-effective, and efficient manner. We do, however,
continue to have concerns about your suggested enhancements to our IAG process, specifically
the recommendation to determine the qualifications of servicing agencies and their contractors
and to discuss IAG issues and servicing agency/contractor performance information among
regions. While monitoring the performance of work performed is crucial to good project
management, barring contractors from work based on informal discussions could lead a project
officer into a defacto debarment situation. In addition, the report is asking IAG project officers
to exceed the scope of their authority in both evaluating the performance of another federal
agency's contracting operations and the performance of the other agency's contractors.
EPA uses other agencies to perform work because of their expertise and the cost savings
of using their established infrastructure. We expect that the other agency is capable of
performing the work. We only justify our selection, not the qualifications, of the other agency in
our decision memorandum. This is in line with EPA guidance. Every Federal Agency has
responsibilities delegated to them under Law and Executive Order 12580. EPA cannot mandate
how another agency performs its work, including how it awards and manages contracts. Even
though we cannot tell another agency how to do its work, there is no doubt that our project
Internet Address (URL)  http://www.epa.gov
Recycled/Recyclable  Printed with Vegetable Oil Based Inks on Recycled Paper (Minimum 30% Postconsumer)
Note: The original was signed by Stephen D. Luftig for Michael H. Shapiro.
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Appendix 1
Page 2 of 2
officers should be monitoring the performance of the work under their IAGs closely and
reporting any issues and concerns to their IAG specialist and the Federal agency involved. What
we can, and will do, is ensure that at our meetings with other Federal agencies, including the
U.S. Corps of Engineers, we will review the performance of ongoing work and raise any
performance issues to the other Federal Agency's management. Also, we intend to work with the
Grants Administration Division to improve IAG and memorandums of understanding (MOU)
terms and conditions to address performance and oversight issues.
We agree that the 1991 OSWER Directive entitled "Revisions of Policy Regarding
Superfund Project Assignment between Alternative Remedial Contracting Strategy Contractors
and the U.S. Army Corps of Engineers" needs to be revised, and we established a subgroup under
the Design/Construct Phase II workgroup to do so. We also agree that the memorandums of
understandings between EPA and other Federal Agencies should be revised, and we will begin
establishing a plan to revise them.
I am attaching the comments we submitted on the preliminary draft report for your
reference. The following two corrections should be made to the final report: 1) it should be
noted in the background section that the project officers and remedial program managers are
within the regions, not OSWER; and 2) the workgroups referenced in the first finding are not
workgroups, but councils. I am also attaching comments we received from the Bureau of
Reclamation.
If you have any questions concerning this response, please contact Barbara McDonough
of the Acquisition Resources Management Staff at 202-260-6674 or Johnsie Webster, OSWER
Audit Liaison, at 202-260-4475.
Attachments
cc:
David O'Connor
Barbara McDonough
Ken Skahn
John Riley
Rich Troast
Scott McMoran
David Ullrich
Joe Rauscher
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Appendix 2:
OARM Response to Draft
Page 1 of 2
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON, DC 20460
JUN 16 2001
OFFICE OF
ADMINISTRATION
AND RESOURCES
MANAGEMENT
MEMORANDUM
SUBJECT:
Comments on Draft Report-Superfund Interagency Agreements Audit
FROM:
David J. O'Connor
Acting Assistant Administrator
Office of Administration and Resources Management
TO:
Leah L. Nikaidoh
Audit Manager
Northern Audit Division
Thank you for the opportunity to comment on the Superfund Interagency Agreements
(IAGs) draft audit report issued on April 27, 2001. I understand that the Office of Solid and
Hazardous Waste has provided separate comments on the report.
I am very encouraged by the report's finding that the Agency is generally managing
Superfund IAGs in an effective manner. I have one comment on Recommendation 1-1, which
proposes, in part, that EPA establish a process to review Superfund contractors' performance and
qualifications and share the information among Regions.
I agree with the premise underlying Recommendation 1-1 that EPA needs to pay greater
attention to contractor performance to ensure that it receives the goods and services it orders
through IAGs. At the same time, I am concerned that the proposed process, if not properly
structured, would result in the "de facto" debarment of contractors outside of the government-
wide debarment and suspension system. This could prompt contractors to file lawsuits against
Agency officials in their individual capacities alleging violations of due process rights.
Under these circumstances, I believe that the process proposed under Recommendation
1-1 should be revised to address potential "de facto" debarment issues, including integrating the
process with EPA's debarment and suspension program. Staff from the Office of Grants and
Debarment are available to work with you to develop the necessary changes.
If you have any questions about these comments, please contact Howard Corcoran on
(202) 564-1903, Scott McMoran on (202) 564-5376, or Robert Meunier, EPA's Debarring and
Suspending Official, on (202) 564-5399.
Internet Address (URL)  http://www.epa.gov
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Note: The original was signed by David J. O 'Connor.
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Appendix 2
Page 2 of 2
cc: Jane Moore
Marty Monell
Sandy Womack-Butler
Paige Peck
Judy Davis
Barbara McDonough
Mike Shapiro
Mark Bialek
Howard Corcoran
Scott McMoran
Robert Meunier
John Showman
David Osterman
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Appendix 3:
Region 5 Response to Draft
Page 1 of 2
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGIONS
77 WEST JACKSON BOULEVARD
CHICAGO, IL 60604-3590
30 MAY 2001
REPLY TO THE ATTENTION OF
MEMORANDUM
SUBJECT: Response to Draft Audit Report on
Superfund Interagency Agreements
FROM: David A. Ullrich
Acting Regional Administrator
TO:	Leah L. Nikaidoh, Audit Manager
Northern Audit Division
Thank you for the opportunity to review and comment on the subject draft audit report. Our
response to the specific audit recommendations pertaining to Region 5 is attached. I would also
like to thank you for the opportunity for my staff to meet regularly with your audit team in person
or on conference calls as the audit progressed.
If you have any questions about this response, please contact Cindy Wakat at (312) 886-7338.
David A. Ullrich
Attachment
cc: Michael Shapiro, Acting Assistant Administrator (OSWER)
David O'Connor, Acting Assistant Administrator (OARM)
Recycled/Recyclable  Printed with Vegetable Oil Based Inks on Recycled Paper (Minimum 30% Postconsumer)
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Note: The original was signed by Norman Niedergang for David A. Ullrich.
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Appendix 3
Page 2 of 2
REGION 5 RESPONSE TO DRAFT AUDIT
REPORT ON SUPERFUND INTERAGENCY AGREEMENTS (IAGs)
Recommendation 1-2: Direct Regions to follow guidance to document selection of servicing
agencies under the IAGs.
Planned Corrective Actions:
We plan to standardize our format to include documentation of the rationale used to select an
I AG versus a contract. We will also document the requirement in an internal control memo for
distribution and use in training within the Superfund Division. We will establish a workgroup
during the third quarter of Fiscal Year (FY) 2001 that will include these tasks and complete the
revised format and internal control memo by the end of the first quarter of FY 2002.
Recommendation 2-1: We recommend that Region 5 implement a process to ensure that all of
its
IAGs contain the RMD 2550D elements.
Planned Corrective Actions:
Region 5 will make Superfund I AG project officers and technical staff aware of the requirements
of RMD 2550D by including the requirements in an internal control memo and training to be
developed by the workgroup referred to in our response to Recommendation 1-2. As stated
above, the workgroup will be established in the third quarter of FY 2001 and the internal control
memo and training will be completed by the end of the first quarter of FY 2002.
Recommendation 3-1: We recommend that Region 5 establish a process that ensures monitoring
reports are received and reviewed by both the project officers and remedial program managers.
Planned Corrective Actions:
The same workgroup referred to in the planned corrective actions above will also be directed to
review how to improve Region 5's monitoring of IAGs in a more consistent and effective
manner.
The workgroup will consider other regions' processes and develop a process that will work
within the structure and context of Region 5. The expected time frame for completion is the
same
as stated in our responses above.
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Appendix 4:
Report Distribution
Office of Inspector General
Inspector General
Headquarters Office
Assistant Administrator for Office of Solid Waste and Emergency Response (5101)
Assistant Administrator for Office of Administration and Resources
Management (3101)
Agency Followup Official (2710A)
Agency Audit Followup Coordinator (2724A)
Audit Followup Coordinator for Office of Solid Waste and Emergency Response (5103)
Audit Followup Coordinator for Office of Administration and Resources
Management (3102)
Associate Administrator for Congressional and Intergovernmental Relations (1301 A)
Director, Office of Regional Operations (1108A)
Associate Administrator for Communications, Education, and Media Relations (1101 A)
Director, Grants Administration Division (3903 A)
EPA Region 5
Director, Resources Management Division
Director, Superfund Division
Regional Offices
Regional Administrators
Regional Public Affairs Offices
Audit Followup Coordinator for Regions 2, 5, 6, and 7
Note: Report distribution was done electronically. Each action official was also provided with a
hard copy of this report. Additional hard copies are available, upon request.
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