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• U.S. Environmental Protection Agency	n-p-0697

|	\ Office of Inspector General	September 22,2011
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At a Glance
Why We Did This Review
The purpose of this audit was to
determine whether the U.S.
Environmental Protection
Agency's (EPA's) Superfund
oversight bills reflect the correct
nature and dollar amount, and
whether EPA timely bills and
collects Superfund oversight
expenditures.
Background
Although potentially responsible
parties (PRPs) pay for cleanup at
Enforcement Lead Superfund
sites, EPA incurs oversight costs
from monitoring the PRPs"
cleanup work. The
Comprehensive Environmental
Response, Compensation, and
Liability Act authorizes EPA to
recover from PRPs Superfund
cleanup costs that are not
inconsistent with the National
Contingency Plan.
For further information,
contact our Office of
Congressional, Public Affairs and
Management at (202) 566-2391.
The full report is at:
www.epa.aov/oia/reports/2011/
20110922-11 -P-0697.pdf
Catalyst for Improving the Environment
EPA Should Bill Superfund Oversight Costs
More Timely
What We Found
Based on our audit of oversight billings for nine sites in Regions 1,5, and 9,
we found that Region 5 did not timely bill or did not bill approximately
$8.6 million in oversight costs for two sites. The $8.6 million consists of $2.5
million for costs incurred between 2000 and 2008 that were not timely billed,
and $6.1 million that was not billed prior to the start of our audit. During our
audit, Region 5 billed about $1 million of the $6.1 million. We did not
identify problems with oversight cost billings in Regions 1 or 9.
Region 5 did not timely bill oversight costs and has not billed certain costs
because the accounting staff has difficulty in allocating costs at sites with
multiple agreements and operable units, and the case management team has
difficulty coordinating review of oversight costs. Further, EPA's policies do
not require oversight bills to be issued within a specific timeframe. Untimely
billing of oversight costs results in delays in replenishing the Superfund Trust
Fund, and limits EPA's ability to timely clean up other priority sites to
further protect human health and the environment.
What We Recommend
We recommend that the Region 5 Regional Administrator direct the
Superfund Division Director to develop a policy to require that oversight
billings be issued no less than annually, and procedures to help staff prepare
oversight billings and resolve billing problems. We also recommend that the
Region 5 Regional Administrator direct the Superfund Division Director to
bill PRPs up to $4,319,545 incurred for the Allied Paper site and
approximately $783,845 for the Sauget site.
While Region 5 did not agree with the recommendation to issue a policy
requiring annual billings, Region 5 stated that it plans to bill any future
oversight costs on an annual basis. If the Agency bills annually as indicated,
that would address the intent of our recommendation. Region 5 agreed that
additional protocols are needed to ensure that management is made aware of
any projected delay in oversight billing and will develop standard operating
procedures. Region 5 partially satisfied our last recommendation by billing
$2,389,367 and $757,312 in costs for the Allied and Sauget sites,
respectively, through August 2,2011. Because of the timing of the billings,
we were unable to verify how much remains to be billed.

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