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American Recovery and
Reinvestment Act Site Visit of the
Elizabeth City Well Field
Expansion Project,
Elizabeth City, North Carolina
Report No. 12-R-0109
December 8, 2011
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Report Contributors:
Jean Bloom
Phil Cleveland
Patrick Mclntyre
Shannon Schofield
Abbreviations
CFR Code of Federal Regulations
DWSRF Drinking Water State Revolving Fund
EPA U.S. Environmental Protection Agency
NCDENR North Carolina Department of Environment and Natural Resources
Cover photo: Well head at the Elizabeth City Well Field Expansion Site, Elizabeth City,
North Carolina. (EPA OIG photo)
Hotline
To report fraud, waste, or abuse, contact us through one of the following methods:
e-mail: OIG Hotline@epa.gov. write: EPA Inspector General Hotline
phone: 1-888-546-8740 1200 Pennsylvania Avenue NW
fax: 202-566-2599 Mailcode 2431T
online:
http://www.epa.gov/oiq/hotline.htm.
Washington, DC 20460
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U.S. Environmental Protection Agency
Office of Inspector General
At a Glance
12-R-0109
December 8, 2011
Why We Did This Review
The U.S. Environmental
Protection Agency Office of
Inspector General conducts site
visits of American Recovery
and Reinvestment Act of 2009
(Recovery Act) clean water and
drinking water projects. The
purpose of the visits is to
confirm compliance with
selected Recovery Act
requirements. We selected the
Elizabeth City Well Field
Expansion Project in Elizabeth
City, North Carolina, for
review.
Background
The city received a $2,366,255
Recovery Act loan from the
North Carolina Department of
Environment and Natural
Resources (NCDENR) under
the Drinking Water State
Revolving Fund program. The
loan included $1,183,127 in
principal forgiveness. The city
will expand its well field with
four new wells to meet the
state's 12 hour/day maximum
pumping requirement.
American Recovery and Reinvestment Act Site Visit
of the Elizabeth City Well Field Expansion Project,
Elizabeth City, North Carolina
What We Found
We conducted an unannounced site visit of the Elizabeth City Well Field
Expansion Project in Elizabeth City, North Carolina, in July 2010. We toured the
project site; interviewed city, NCDENR, engineering firm, and prime contractor
and subcontractor personnel; and reviewed documentation related to Recovery
Act requirements.
In the draft report, we questioned whether three manufactured goods used on the
project met the Buy American requirements of Section 1605 of the Recovery Act,
and whether engineering costs claimed were allocable to the Recovery Act
project. In response to the draft report, the city provided additional information to
support Buy American compliance for one item. The city took corrective action
and added the two remaining items to the project's Buy American de minimis
waiver list. We reviewed the de minimis list and concurred with the action taken
by the city to include those items on the list. We analyzed additional engineering
support received from Region 4 and the city, and agree that the costs incurred
prior to the Recovery Act were needed to make the project shovel-ready and,
therefore, were allocable to the project.
No additional issues or concerns came to our attention that would require action
from the city, NCDENR, or the U.S. Environmental Protection Agency.
For further information, contact
our Office of Congressional and
Public Affairs at (202) 566-2391.
The full report is at:
www.epa.qov/oiq/reports/2012/
20111208-12-R-0109.pdf
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| \ UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
| J | WASHINGTON, D.C. 20460
THE INSPECTOR GENERAL
December 8, 2011
MEMORANDUM
SUBJECT: American Recovery and Reinvestment Act Site Visit of the
Elizabeth City Well Field Expansion Project,
Elizabeth City, North Carolina
Report No. 12-R-0109
FROM: Arthur A. Elkins, Jr /U/Qn u
Inspector General
TO: Gwendolyn Keyes Fleming
Regional Administrator, Region 4
This is our report on the subject site visit conducted by the Office of Inspector General of
the U.S. Environmental Protection Agency. The report summarizes the results of our site
visit of the Elizabeth City Well Field Expansion Project.
We performed this site visit as part of our responsibility under the American Recovery and
Reinvestment Act of 2009 (Recovery Act). The purpose of our site visit was to determine the
city's compliance with selected requirements of the Recovery Act pertaining to the Drinking
Water State Revolving Fund program. The city received a $2,366,255 Recovery Act loan from
the North Carolina Department of Environment and Natural Resources with $1,183,127 of
principal forgiveness.
Action Required
Because this report contains no recommendations, you are not required to respond to this report.
The report will be made available at http://www.epa.gov/oig. If you or your staff have any
questions regarding this report, please contact Melissa Heist, Assistant Inspector General for
Audit, at (202) 566-0899 or heist.melissa@epa.gov; or Robert Adachi, Director of Forensic
Audits, at (415) 947-4537 or adachi.robert@epa.gov.
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American Recovery and Reinvestment Act 12-R-0109
Site Visit of the Elizabeth City Well Field
Expansion Project, Elizabeth City, North Carolina
Table of
Purpose 1
Background 1
Scope and Methodology 1
Results of Site Visit 2
Buy American Requirements 2
Wage Rate Requirements 2
Financial Management and Reporting 3
Contract Procurement 3
Recommendations 4
City and Region 4 Responses 4
Office of Inspector General Comment 5
Status of Recommendations and Potential Monetary Benefits 6
Appendices
A City of Elizabeth City Response to Draft Report 7
B EPA Region 4 Response to Draft Report 11
C Distribution 13
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Purpose
The purpose of our unannounced site visit was to determine the City of Elizabeth
City's compliance with selected requirements of the American Recovery and
Reinvestment Act of 2009 (Recovery Act), P.L. 111-5, pertaining to the Drinking
Water State Revolving Fund (DWSRF) program.
Background
On April 14, 2009, the U.S. Environmental Protection Agency (EPA) awarded a
grant for $65,625,000 to the North Carolina Department of Environment and
Natural Resources (NCDENR) under the Recovery Act to capitalize its revolving
loan fund for financing the construction of drinking water facilities, green
infrastructure, program administration, and drinking water related activities. In
addition to the regulatory requirements in Title 40 Code of Federal Regulations
(CFR) Chapter 1, Subchapter B, the assistance award was subject to 2 CFR Part
176, Award Terms For Assistance Agreements That Include Funds Under the
American Recovery and Reinvestment Act of2009, Public Law 111-5.
In June 2009, the city entered into a loan agreement with NCDENR under the
DWSRF program to expand its well field with four new wells to meet the state's
12 hour/day maximum pumping requirement. The city received a Recovery Act
loan totaling $2,366,255, which included $1,183,127 of principal forgiveness.
Scope and Methodology
Due to the time-critical nature of Recovery Act requirements, we did not perform
this assignment in accordance with generally accepted government auditing
standards. Specifically, we did not perform certain steps that would allow us to
obtain information to assess the city's internal controls and any previously
reported audit concerns. As a result, we do not express an opinion on the
adequacy of the city's internal controls or its compliance with all federal, state, or
local requirements.
We conducted an unannounced site visit during the week of July 19, 2010. On
March 23-24, 2011, we performed a follow-up visit to the engineering firm hired
by the city to obtain Buy American certification documents. During our visits we:
1. Toured the proj ect site
2. Interviewed employees and managers on site, as well as city, engineering,
NCDENR, and prime contractor personnel
3. Reviewed documentation provided by the city, its contracted engineering
firm, NCDENR, and prime and subcontractors on the following matters:
a. Buy American requirements under Section 1605 of the Recovery
Act
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b. Wage Rate requirements (Davis-Bacon Act) under Section 1606 of
the Recovery Act
c. Limits on funds and reporting requirements under Sections 1604
and 1512 of the Recovery Act
d. Contract procurement
Results of Site Visit
Based on our site visit, no issues or concerns came to our attention that would
require action from the city, NCDENR, or EPA. The results of our work are
summarized below.
Buy American Requirements
In the draft report, we questioned whether three manufactured goods used on the
project met the Buy American requirements of Section 1605 of the Recovery Act.
We changed our position after analyzing additional information provided by the
city in response to the draft report. The information provided demonstrated that
one item met the requirements for substantial transformation. The city also
submitted a revised de minimis list, which included two items originally
questioned for not meeting Buy American requirements. We reviewed the Buy
American de minimis waiver list and concurred with the action taken by the city
to include those items on the list.
We did not identify any issues or concerns regarding Buy American requirements.
Based on our interviews and work performed, the city, its contracted engineer,
and contractor are fully aware of the Buy American requirements under Section
1605 of the Recovery Act. The Buy American requirements were included in
contract documents. The city relied on its contracted engineer to review Buy
American certifications. The engineer stayed up to date with Buy American
guidance by visiting the NCDENR website and attending training. The engineer
and prime contractor rejected and substituted some of the manufacturers based
upon Buy American guidance. Based on our physical observations of materials on
site, our review of Buy American supporting documentation, and Internet research
performed on the manufacturers, materials used for the project comply with Buy
American requirements.
Wage Rate Requirements
We did not identify any issues or concerns regarding the city's compliance with
wage rate requirements. Section 1606 of the Recovery Act requires all mechanics
and laborers employed on projects funded directly by—or assisted in whole or in
part with—Recovery Act funds to be paid wages at rates no less than the locally
prevailing rate, as determined by the U.S. Department of Labor. These wages are
commonly known as Davis-Bacon Act wages and generally include a requirement
that employers submit certified payroll reports to the U.S. Department of Labor.
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The contractor submitted signed certified payrolls to certify compliance with wage
rate requirements. We selected two pay periods for review and testing—the pay
periods beginning May 3, 2010, and July 19, 2010. We reviewed certified payrolls
and verified that the contractor and subcontractors were paying their employees at
least the minimum required prevailing wage rates.
Financial Management and Reporting
We did not identify any issues or concerns with the city's ability to meet the
reporting requirements under Section 1512 of the Recovery Act. We reviewed
documents that showed the reimbursement process for the city. The city submits
its reimbursement request to the NCDENR's Division of Water Quality,
Construction Grants and Loans Section. Based on our review of these documents,
no issues or concerns came to our attention.
We obtained copies of the Recovery Act jobs created/retained reports submitted
to the NCDENR. These reports are used in preparing the report required under
Section 1512 (c) of the Recovery Act. Based upon the information provided,
nothing came to our attention that caused us to take exception with the
subrecipient's compliance with Section 1512 (c).
We did not identify any issues or concerns with the city's compliance with
Section 1604, which states that Recovery Act funds cannot be used for any casino
or other gambling establishment, aquarium, zoo, golf course, or swimming pool.
Based upon our review of the loan document and contract project specifications,
and observations at the site, the funds were not being used for any prohibited
items identified in the Recovery Act.
Contract Procurement
We reviewed the city's procurement of its contractor. We did not identify any
issues or areas of concern with contract procurement. The city solicited bids twice
for the project and received one bid each time. A notice of award was signed by
the city in 2007. An EPA Region 4 employee initially communicated to
NCDENR that the project should be re-bid based on the age of the bid and the
possibility of reducing the project's price. The city provided legal documents
from its attorney that indicated the city could potentially lose a lawsuit because
the city had signed a notice of award with the contractor. NCDENR managers
requested specific statutory citations and language from EPA that would support
their decision to have the city re-bid the project. EPA headquarters determined
that as long as the contractor is willing to incorporate all necessary Recovery Act
provisions and requirements in the contract, and comply with the provisions, the
project can move forward without being re-bid. Change order 1 incorporated the
Recovery Act requirements into the contract.
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Recommendations
We have no recommendations.
City and Region 4 Responses
The Office of Inspector General received comments to the draft report and
supplemental information from the city and Region 4. NCDENR did not provide
written comments to our draft report.
The city disagreed with the following findings in the site visit report:
1. The city did not provide sufficient documentation to assure compliance
with the Buy American requirements.
2. The city claimed reimbursement for engineering costs outside of the scope
of the Recovery Act project.
The city provided supplemental documentation for the electrical switchgear and
included the site lights and poles on their project de minimis list. The city
disagreed that the non-Recovery Act-funded equipment was subject to Buy
American provisions because it was supplied and owned by the city's electric
distribution utility and not the water and sewer utility, which are two separate
enterprise accounts. The city disagreed with the engineering costs finding because
the purpose of the project was to increase the safe yield of the city's well field,
and these were necessary preliminary assessment costs needed for the project to
accomplish that goal. The full text of the city's comments and the Office of
Inspector General detailed responses are included in appendix A.
Region 4 agreed with the Buy American issues identified in the report for the
electrical switchgear, and the site lights and poles. The region disagreed that the
non-Recovery Act-funded transformer was subject to the Buy American
provisions because it was not included in the engineering plans and specifications
for the project, nor was it procured or installed by the project contractor and/or
subcontractors. The region disagreed with the recommendation to recover the
engineering costs associated with the planning phase of the project because the
state reviewed the costs and determined that they were eligible expenses per state
procurement laws and regulations. The full text of Region 4's comments is
included in appendix B.
On October 18, 2011, we held an exit conference with representatives from EPA
Region 4, NCDENR, and the city. We were informed that Region 4 worked
collaboratively with NCDENR on the Region 4 response. Region 4, NCDENR,
and the city disagreed with the Office of Inspector General's determination that
non-Recovery Act-funded equipment was subject to Buy American requirements.
However, the city reluctantly agreed to include the non-Recovery Act-funded
equipment on the de minimis list, to avoid a finding. Region 4, NCDENR, and the
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city disagreed that the engineering costs for well rehabilitation and well number
12 were outside the scope of the project. Region 4 and the city subsequently
provided additional supporting documentation to substantiate their position.
Office of Inspector General Comment
We modified our report based upon the additional Buy American documentation
received from the city. We evaluated the additional documentation provided to
justify substantial transformation for the electrical switchgear and determined that
it was sufficient to meet the guidelines for substantial transformation. We
reviewed and concurred with the action taken by the city to include the costs for
site lights and poles and non-Recovery Act-funded equipment on the de minimis
list.
Based upon our exit conference and review of the supplemental documentation
provided, we agree that the engineering costs incurred for rehabilitating existing
wells and exploring well number 12's viability were necessary to make the
Recovery Act-funded well field project shovel-ready. We adjusted the report
accordingly.
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Status of Recommendations and
Potential Monetary Benefits
RECOMMENDATIONS
POTENTIAL MONETARY
BENEFITS (In $000s)
Rec.
No.
Page
No.
Subject
Status1
Action Official
Planned
Completion
Date
No recommendations
Claimed
Amount
Agreed To
Amount
1 0 = recommendation is open with agreed-to corrective actions pending
C = recommendation is closed with all agreed-to actions completed
U = recommendation is unresolved with resolution efforts in progress
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Appendix A
City of Elizabeth City Response to Draft Report
DIANNE PIERCE-TAMPLEN. MMC
ROGER McLEAN
MAYOR PRO TEM
ANITA HUMMER
CITY MANAGER
RICHARD C. OLSON
CITY CLERK
MAYOR
CITY COUNCIL MEMBERS
LENA HILL-LAWRENCE
JEAN M. BAKER
MICHAEL E. BROOKS
RICKEY E. KING
JOHNNIE B. WALTON
BETTY S. MEGGS
JOSEPH A. STIMATZ
CITY OF ELIZABETH CITY
September 7, 2011
Robert Adachi
Director of Forensic Audits
75 Hawthorne Street
San Francisco, CA 94105
RE: Site Visit Report - Elizabeth City Well Field Expansion Project
EPA Project No. OA-FY10-A-0203
Mr. Adachi,
The City has reviewed the Report of the Office of Inspector General USEPA Recovery and
Reinvestment Act site visit of the Elizabeth Citv Well Field Expansion Prolect. Elizabeth Citv
North Carolina. The City does not agree with either of the significant findings of the site visit
report, which are as follows:
1. The City did not provide sufficient documentation to assure compliance with the Buy
American requirements of the section 1605 of the Recovery Act.
2. The City claimed costs for engineering services outside of the scope of the Recovery Act
Elizabeth City offers the following additional information to be considered by the EPA Office of
Inspector General before the Site Visit Report is published as a Final Report for General
Circulation and before the Region 4 Regional Administrator must determine or negotiate
appropriate remedial action.
1. The Citv did not provide sufficient documentation to assure compliance with the Buy
American requirements under section 1605 of the Recovery Act. There were three
findings regarding the Buy American requirements of the Act:
Project.
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A. The Siemens Manufacturer of the electric switch gear provided a substantial
transformation checklist, for which EPA requested additional information. In part,
Elizabeth City rejected submittal 6 and 6a requiring additional information of the
'Substantial Transformation Documentation.' Attached are copies of the final
documentation Submittal 6b and, as requested by EPA, and a memorandum from
Siemens Industry, Inc. providing the additional documentation regarding compliance
with the Buy American provisions of the Act. Based on the attached Siemens
information and the City's April 14th response to EPA's communications, the City
believes that we provided full documentation and that the Siemens Electric Switch
Gear equipment is compliant with the Buy American provisions.
OIG Response: The city provided additional information from Siemens regarding the
manufacturing process followed for its electric panels. This includes fabricating raw
materials (sheet metal, copper, and aluminum/copper or aluminum) into a specific
shape/form (panel board enclosure/interior conductors), combining and assembling
together with other assemblies (circuit breakers) and raw materials (screws, wiring) to
produce an electrical panel board for a specific order/application. Based on our
analysis of this information, we have determined that sufficient documentation has
been provided to support substantial transformation. As a result, we adjusted the
report accordingly.
B. The Second finding regarding the Buy American provisions of the Act was in
reference to the Acuity Brands lighting for site lights and poles. The City agreed that
the Buy American documentation was not sufficient to comply with the Act.
However, on July l9th we asked the contractor, AG Schultz, to include the light poles
on the 'De-Minimums' list of materials and supplies. Attached is Schulte's letter to us
including Ttem H. - KAD light poles and fixtures.' To date, the 'De-Minimums' items
for the project total $8,894.41, or less than 2.2% of the materials, which is well
within the 5% De-Minimums allowed by the Act.
OIG Response: We reviewed the revised de minimis list and agree with the action
taken. We adjusted the report accordingly.
C. The third and final finding regarding the Buy American provisions of the Act included
a transformer labeled "Made in Mexico" valued at $3,641.00. The finding of the site
visit report was that the Buy American provisions of the Act precluded the intentional
splitting of ARRA projects into separate and smaller contracts to avoid Buy American
coverage.
The City strongly objects to the consideration that actions were taken to "split the
purchase" to avoid compliance. The transformer is supplied and owned by the City's
Electric Distribution Utility and not the Water and Sewer Utility. The transformer in
question was supplied by the Electric Distribution Utility to deliver the proper current
at the proper voltage for the well pumps.
The City does acknowledge that both the Electric Distribution Utility and the Water
and Sewer Utility are Enterprise Funds of the City, managed by the City. The two
funds are established under North Carolina Law, specifically NCGS §159-26, as
separate financial entities. I have enclosed the pertinent pages of the City of
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Elizabeth City 'Comprehensive Annual Financial Report', which reflect that they are
separate, stand alone funds. To infer that the City's Water and Sewer Utility had
control over equipment purchased by the City's Electric Distribution Utility would
mean that every power supply company that services an ARRA funded project would
be subject to the Buy American Provisions of the Act.
If EPA elects to determine that the Electric Distribution Utility is subject to the Buy
American Provisions of the Act, the City would request that the transformer cost be
added to the De-Minimums list.
OIG Response: While we understand that this transformer was purchased by the
City's Electric Distribution Utility, which has its own enterprise funds separate from
the Water and Sewer Utility, we disagree that the equipment should not comply with
Buy American provisions of the Recovery Act. An April 28, 2009, EPA guidance
document, American Recovery and Reinvestment Act of2009, which discusses
implementation of Buy American provisions of P L. 111-5, states in part that ". . . any
project that is funded in whole or in part with ARRA funds, must comply with the
Buy American provisions." The guidance document further defines a "project" as all
construction necessary to complete the building or work regardless of the number of
contracts or assistance agreements involved so long as all contracts and assistance
agreements awarded are closely related in purpose, time, and place. The transformer
was purchased by the city's Electrical Utility in May 2010 to deliver the proper
current and the proper voltage for the well pumps. This clearly demonstrates the
relationship in purpose (for the well pumps), time (during the construction of the
Recovery project), and place (for use at the well field). Further, the EPA guidance
document states that Buy American provisions will apply to prevent splitting projects
into separate and smaller contracts or assistance agreements, particularly where the
activities are integrally and proximately related to the whole. The transformers are
integrally related to the project because they supply the necessary voltage to the
pumps and are proximately related because they are located in three of four well head
electrical sheds at the project site. Given the close relationship in purpose, time, and
place, and the integral and proximate location of the transformer to the overall
project, we believe that the Buy American provisions apply. After the exit
conference, the city updated its de minimis list to include the transformers. We agree
with that action and adjusted the report accordingly.
2. The Citv claimed costs for engineering services outside of the scope of the Recovery Act
Project:
The purpose of the project was to increase the safe yield of the City's well field.
Projects of this magnitude require preliminary assessment of options to accomplish the
goal. Investigation of the existing well field and alternative well location is certainly
within the generally accepted standards of preliminary engineering for this work. The
City believes that all of the engineering costs submitted for ARRA reimbursement are a
legitimate project cost for well field expansion or to increase yields. Attached is a letter
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dated June 10, 2011 from the City to David Giachini of NC-DENR's Public Water Supply
Section explaining the engineering costs on this project, dating back 2006.
Contrary to the comments in the Site Visit Report, we are of the understanding that
NCDENR officials do agree that all engineering costs submitted for this project are
legitimate, reimbursable costs.
OIG Response: Based upon our exit conference and review of the supplemental
documentation provided, we agree that the engineering costs incurred for rehabilitating
existing wells and exploring well number 12's viability were necessary to make the
Recovery Act-funded well field project shovel-ready. We adjusted the report accordingly.
I trust that the information submitted in this letter will provide enough background so that the
final 'Site Visit Report' will not have any significant findings contrary to the fact that the
Elizabeth City Well Field Expansion Project was in full compliance with the requirements of the
Presidents 'Recovery and Reinvestment Act'.
Sincerely,
Richard C. Olson
City Manager
City of Elizabeth City
cc: Jessica G. Miles
Public Water Supply Section Chief
North Carolina Department of Environmental and Natural Resources
Email copy: John Trefry {trefry.john@epa.gov}
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Appendix B
EPA Region 4 Response to Draft Report
September 27, 2011
MEMORANDUM
SUBJECT: EPA Region 4 Response to Draft Audit Report:
American Recovery and Reinvestment Act Site Visit of the Elizabeth City Well
Field Expansion Project, Elizabeth City, North Carolina
Project No. OA-FY10-A-0203
FROM: Gwendolyn Keyes Fleming
Regional Administrator
TO: Shannon M. Schofield, CFE
Senior Auditor
EPA - Office of Inspector General
This is the response to the August 8, 2011, draft report issued by the Office of Inspector General
on the American Recovery and Reinvestment Act (ARRA) Site Visit of the Elizabeth City Well
Field Expansion Project Elizabeth City, North Carolina (the City). We reviewed the report issued
by your office and compared your findings to the information available in the project file
maintained by the State of North Carolina Drinking Water State Revolving Fund program and
supplemental information provided by the borrower. Based on this information, we offer the
following response to your draft findings:
1. Buy American Issues: The Environmental Protection Agency agrees that the information
included in the draft report on the City was accurate in accordance with the Buy
American provisions for two of the three items identified. Regarding the foreign made
switchgear manufactured by Siemens, two options for corrective action were given to the
City: replace the foreign made switchgear manufactured from Siemens using American
made parts; or, if replacement of this item is unattainable, include the components of the
switchgear in the de-minimis log for the project. With regard to the site lights and poles
manufactured by Acuity, the City will add the items to the de-minimis log for the project.
To date, the de-minimis items included in the log totaled $8,894.41, which is about 2.2
percent of the total material cost for this project. Therefore, the addition of these items
will not cause the City to exceed the five percent threshold established by the nationwide
waiver of the Buy American requirements of ARRA.
The EPA has determined that the transformer identified in the draft report is not subject
to the Buy American provisions. A review of the State's project files revealed that the
transformer is not part of the project, was not included in the engineering plans and
specifications and was not procured or installed by the contractor and/or subcontractors
for this project. The transformer is owned by the City's electric distribution utility and
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not the Water and Sewer Authority. The City provided documentation to support their
claim that these are separate financial entities established under North Carolina law,
NCGS 159-26. As such, we do not concur with the proposed recommendation to apply
the Buy American requirements of ARRA to the utility transformer, as the purchasing,
installation and operation of this piece of equipment resides within the City's electric
distribution utility.
2. Other matters, Engineering Costs: The EPA does not concur with the proposed
recommendation to recover the engineering costs associated with the planning phase of
the project. The invoices and costs associated with the project were reviewed by the State
and determined to be eligible expenses according to State procurement laws and
regulations. Also, attached is a memo dated June 10, 2011, from Elizabeth City's Public
Utilities Director to the State's project engineer which we believe sufficiently justifies the
specific engineering costs associated with this project. Further, the project summary
supports and justifies the costs associated with the tasks performed as part of the
preliminary engineering work as contained in the invoices that the City received for the
planning and design phase of the Well Expansion Project. EPA believes that this
information provides sufficient documentation regarding the questioned engineering costs
and proposes no further action.
If you or your staff has any further questions regarding this response, please contact James D.
Giattina, Water Protection Division Director, at (404) 562-9345.
Attachments (3)
1. Status of Region 4 Recommendations
2. June 10, 2011 Letter to David Giachini
3. Site Visit Report
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Appendix C
Distribution
Office of the Administrator
Regional Administrator, Region 4
Agency Follow-Up Official (the CFO)
Agency Follow-Up Coordinator
General Counsel
Assistant Administrator for Administration and Resources Management
Associate Administrator for Congressional and Intergovernmental Relations
Associate Administrator for External Affairs and Environmental Education
Director, Grants and Interagency Agreements Management Division
Audit Follow-Up Coordinator, Region 4
Public Affairs Officer, Region 4
Director, Water Protection Division, Region 4
Chief, Grants and SRF Management Section, Region 4
Section Chief, North Carolina Department of Environment and Natural Resources,
Public Water Supply Section
Team Leader, North Carolina Department of Environment and Natural Resources,
Public Water Supply Section, Loans and Grants Unit
City Manager, Elizabeth City, North Carolina
Public Utilities Director, Elizabeth City, North Carolina
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