U.S. Environmental Protection Agency	2007-P-00021
Office of Inspector General	April 30 2007

At a Glance
Catalyst for Improving the Environment
Why We Did This Review
In Fiscal Year 2006, the U.S.
Environmental Protection
Agency (EPA) made about
$255 million in Superfund
Interagency Agreement (IAG)
payments to the U.S. Army
Corps of Engineers (the
Corps). We sought to
determine the effectiveness of
EPA's selection of the Corps
to perform cleanup, as well as
EPA's effectiveness in
monitoring Corps-conducted
cleanups.
Background
The goal of the Superfund
program is to clean up
hazardous waste sites that
pose risks to human health and
the environment. EPA
accomplishes Superfund goals
through a variety of
mechanisms, including IAGs.
An IAG is a written agreement
in which one Federal agency
(such as EPA) obtains supplies
and services from another
agency (such as the Corps) on
a reimbursable basis.
For further information,
contact our Office of
Congressional and Public
Liaison at (202) 566-2391.
To view the full report,
click on the following link:
www.epa.aov/oia/reports/2007/
20070430-2007-P-00021 .pdf
EPA Can Improve Its Managing of Superfund Interagency
Agreements with U.S. Army Corps of Engineers
What We Found
EPA needs to better justify and support its decisions to enter into Superfund IAGs
with the Corps. Decision memorandums used to justify awarding Superfund IAGs
to the Corps did not contain comparisons of alternatives considered. Further, EPA
did not develop independent cost estimates. This occurred because EPA generally
believes the Corps has more construction and contracting expertise to manage
Superfund projects than its own personnel. As a result, EPA has limited assurance
that the Superfund IAGs it awards to the Corps are based on sound decisions.
EPA regions have initiated some corrective actions, but further steps are needed.
EPA also needs to improve its monitoring of IAGs with the Corps to better
manage cost, timeliness, and quality. Specifically, the Agency needs to:
Ensure the Corps improves the quality and timeliness of monthly invoices
and progress reports it submits to EPA.
•	Ensure it knows what services the Corps is being paid for and that the
amount billed is based on clear supporting documentation.
•	Include terms and conditions in IAGs that establish criteria against which
the Corps" performance will be evaluated.
EPA regions indicated they were generally very satisfied with the majority of the
work performed by the Corps. Nonetheless, EPA needs to better monitor the more
than $250 million it pays to the Corps each fiscal year to clean up Superfund sites.
Improved monitoring would also eliminate $2.5 million in excess and idle
Management and Support fees that EPA paid the Corps that could be put to better
use in the Superfund program.
What We Recommend
EPA needs to develop its own independent cost estimates for Corps in-house costs,
conduct cost analysis of alternatives when determining whether to use the Corps,
and document actions taken. EPA also needs to require the Corps to improve the
format of its monthly reports, use the Intra-governmental Payment and Collection
System to reimburse the Corps for its in-house costs, address the $2.5 million in
Management and Support fees being held by the Corps, include terms in future
IAGs to allow better monitoring, and develop a plan on using feedback reports.
EPA agreed with all but one of our recommendations, and for this
recommendation it proposed an alternative action that meets the intent of our
recommendation.

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