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'V PROt^ office of inspector general
Catalyst for Improving the Environment
Audit Report
Idaho Superfund Credit Claim
Under EPA Support Agency
Cooperative Agreement No. V990431-01
Report No. 2004-4-00016
June 2, 2004
This audit report contains findings that describe problems the Office of Inspector General (OIG) has
identified and corrective actions the OIG recommends. The report represents the opinion of the OIG,
and findings contained in this report do not necessarily represent the final EPA position. Final
determinations on matters in this report will be made by EPA managers in accordance with
established audit resolution procedures.

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Report Contributors:
Keith Rei chard
Richard Valliere
Jan Lister
Abbreviations
Agreement	Support Agency Cooperative Agreement No. V990431-01
CFR	Code of Federal Regulations
EPA	Environmental Protection Agency
OIG	Office of Inspector General
OMB	Office of Management and Budget
State	State of Idaho

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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON, D.C. 20460
OFFICE OF
INSPECTOR GENERAL
June 2, 2004
MEMORANDUM
SUBJECT: Report No. 2004-4-00016
Idaho Superfund Credit Claim Under EPA Support Agency
Cooperative Agreement No. V990431-01
/ s/ "THuAaet /f.
FROM: Michael A. Rickey
Director, Assistance Agreement Audits
TO:	John Iani
Regional Administrator
As requested, we have examined the outlays reported by the State of Idaho under its support
agency cooperative agreement No. V990431-01 with the Environmental Protection Agency
(EPA). The cooperative agreement was authorized under section 104 of the Comprehensive
Environmental Response, Compensation and Liability Act (Superfund). This cooperative
agreement provided the administrative mechanism for recognizing the State's contribution to
cost sharing requirements for the Federally funded remedial actions at the Bunker Hill Superfund
site. The outlays reported represented the State's cost sharing contribution at the Bunker Hill
Superfund site for the period April 24, 1995, through April 30, 2000.
We have questioned $649,362 of unallowable reported outlays. The questioned outlays consist
of: (1) unallowable costs incurred before the award of the cooperative agreement;
(2) unsupported payroll costs; (3) unallowable pre-remedial action costs; and (4) duplicate costs.
This audit report contains findings that describe problems the Office of Inspector General (OIG)
has identified and corrective actions the OIG recommends. The report represents the opinion of
the OIG, and findings contained in this report do not necessarily represent the final EPA position.
The OIG has no objection to the release of this report to any member of the public upon request.
On March 26, 2004, we issued a draft report to the State for comment, and on May 6, 2004,
comments were provided. The State did not agree with the report findings.
Action Required
In accordance with EPA Manual 2750, the action official is required to provide this office with a
proposed management decision specifying the Agency's position on all findings and

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recommendations in this report. The draft management decision is due within 120 days of the
date of this transmittal memorandum.
If you have questions concerning this report, please contact Keith Reichard, Assignment
Manager, at (312) 886-3045.
Attachment

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Table of C
Independent Auditor's Report		1
Background 		3
Results of Audit 		5
Recommendations		9
Schedules
Schedule of Pre-Support Agency Cooperative Agreement Costs
Elizabeth Park (Project Number SVELIZ01)		11
Schedule of Pre-Support Agency Cooperative Agreement Costs
Nine Mile Creek (Project Number SV19ML01)		13
Schedule of Pre-Remedial Action Costs
Canyon Creek (Project Number SV2CNY08)		15
Appendices
A Scope and Methodology		17
B State's Response 		19
C Distribution 		21
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Independent Auditor's Report
We have examined the total outlay reported by the State of Idaho (State) under the
Environmental Protection Agency (EPA) support agency cooperative agreement (agreement), as
shown below:

Financial Status Report






Cumulative



Cooperative
Date
Period
Total Outlays
Federal
State

Agreement No.
Submitted
Ending
Reported
Share
Share

V990431-01
3/5/03
4/30/00
$7,936,605
$0
$7,936,605

The State certified that the outlays reported on the Financial Status Report, Standard Form 269A,
were correct and for the purposes set forth in the agreement. The preparation and certification of
the claim is the responsibility of the State. Our responsibility is to express an opinion on the
reported outlays based on our examination.
Our examination was conducted in accordance with the Government Auditing Standards issued
by the Comptroller General of the United States, and the attestation standards established by the
American Institute of Certified Public Accountants. We examined, on a test basis, evidence
supporting the reported outlays, and performed such other procedures as we considered necessary
in the circumstances (see Appendix A for details). We believe that our examination provides a
reasonable basis for our opinion.
We limited our review to the State's outlays reported on the Financial Status Report dated
March 5, 2003. The outlays reported represents the State's 5-year credit claim as required by the
agreement. We did not examine the total cost of remedial actions from which the State derived
its 10-percent share.
We have questioned $649,362 of unallowable reported outlays. The questioned outlays consist
of: (1) unallowable costs incurred before the award of the cooperative agreement; (2)
unsupported payroll costs; (3) unallowable pre-remedial action costs; and (4) duplicate costs.
In our opinion, because of the effects of the matters discussed in the preceding paragraph, the
outlays reported on the Financial Status Report do not present fairly, in all material respects, the
allowable outlays incurred in accordance with the criteria set forth in the agreement. As a result,
we have questioned $649,362 of the $7,936,605 in outlays reported (see Results of Audit
section).
"KeitA IReicduvid
Keith Rei chard
Assignment Manager
Field Work End: March 18, 2004
1

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2

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Background
EPA awarded the support agency cooperative agreement to the State on May 3, 1995. The
following table provides some basic information about the authorized project period and the
funds awarded under the agreement covered by this audit.
Cooperative
Agreement No.
Total
Costs
State
Share
Project
Period
V990431-01
$115,000,000
$11,500,000
04/24/1995-04/30/2000
The agreement was authorized under section 104 of the Comprehensive Environmental
Response, Compensation and Liability Act (Superfund). This agreement provides the
administrative mechanism for recognizing the State's contribution to cost sharing requirements
for Federally funded remedial actions at the Bunker Hill Superfund site. The cost of remedial
action is anticipated to be $115,000,000, of which the State's share is 10 percent. Beginning
5 years from the date of the cooperative agreement, and each year thereafter, the State was
required to submit documentation of its accumulated expenditures/credits/services to EPA for
evaluation. The purpose of this reporting was to ensure the State is accumulating sufficient
expenditures/credits/services to achieve its cost share.
To assist the reader in obtaining an understanding of the report, key terms are defined below:
Reported Outlays:	Program expenses or disbursements claimed by the State
on the Financial Status Report (Standard Form 269A).
Questioned Outlays:	Outlays that are: (1) contrary to a provision of a law,
regulation, agreement, or other documents governing the
expenditure of funds; (2) not supported by adequate
documentation; or (3) not approved by a responsible agency
official.
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4

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Results of Audit
We have questioned unallowable outlays of $649,362 detailed as follows:
Organization*
Reported
Outlays
Questioned
Outlays
Note
Silver Valley Natural Resources Trust
$6,356,811
$596,005
1
Bureau of Disaster Services
$852,473
$0

Division of Environmental Quality
$513,763
$53,357
2
Panhandle Health District
$213,558
$0

Totals
$7,936,605
$649,362

* For reporting purposes, these four State organizations will be jointly referred to
as the State.
Note 1: We have questioned unallowable outlays of $596,005. The questioned outlays consist
of: (1) unallowable costs incurred before the award of the cooperative agreement;
(2) unsupported payroll costs; (3) unallowable pre-remedial action costs; and
(4) duplicate costs. The questioned costs are detailed as follows:
Description
Questioned
Outlays
Note
Unallowable pre-award costs
$366,649
a
Unsupported payroll costs
$116,490
b
Unallowable pre-remedial action costs
$29,933
c
Duplicate costs
$82,933
d
Totals
$596,005

a. The State claimed $366,649 incurred after the Bunker Hill Superfund site was
listed on the National Priority List, but before the State's cooperative agreement
was awarded on May 3, 1995. The provisions of Title 40, Code of Federal
Regulations (CFR) 35.6285(c)(2)(E)(ii) provides that expenditures incurred after a
site is listed on the National Priority List are unallowable if the costs are incurred
prior to the award of a cooperative agreement. Accordingly, we have questioned
$186,990 for Elizabeth Park and $179,659 for Nine Mile Creek; schedules on the
questioned costs are on pages 11 and 13, respectively.
State's Comments:
The State believes the costs associated with Elizabeth Park and Nine Mile Creek
should be counted as match costs. The State entered into a State Superfund
Contract and signed the support agency cooperative agreement that specifically
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listed the Elizabeth Park and Nine Mile Creek projects as match eligible. The
Nine Mile Creek project was approved by an Action Memo, signed by EPA and
others, dated July 13, 1994, well ahead of the April 1995 support agency
cooperative agreement.
Auditor's Response:
The questioned costs were incurred after the Bunker Hill Superfund site was listed
on the National Priority List, and prior to the award of the support agency
cooperative agreement, and thus are unallowable in accordance with 40 CFR
35.6285(c)(2)(E)(ii).
b. The State was unable to provide source documentation to support payroll costs
claimed as required by Office of Management and Budget (OMB) Circular A-87,
Attachment B, Section 11(h), and 40 CFR 31.21(b)(6). We were provided with a
summary of the employees' labor costs. However, the State was unable to
provide supporting documentation such as: (1) bi-weekly time sheets, and
(2) salary or labor rates paid. Also, the State could not support the fringe benefit
costs claimed. In the absence of supporting documentation, we have questioned
the total amount claimed of $116,490.
State's Comments:
The State agrees that when the documentation was requested it was unavailable;
however, the State maintains that the required documentation did exist, and
through an unfortunate misunderstanding, most of the documentation was
destroyed. The State was able to provide source documentation for approximately
10 percent of the period reviewed. In addition the State provided electronic
copies of actual payroll "runs" as well as microfiche copies of the payments. The
State requirements for documenting costs were present during the period reviewed
and those policies still exit.
Auditor's Response:
The State did not furnish us with sufficient documentation either during our field
work or in response to the draft report to support the claimed payroll costs.
Accordingly, the costs remain questioned.
c. According to the State, it inadvertently claimed unallowable pre-remedial action
costs of $29,933. These costs were incurred after the award of the cooperative
agreement on May 3, 1995, and before the award of the Canyon Creek
construction contract. The cooperative agreement provided that only remedial
action costs could be used as a credit for the State's cost share requirement. EPA
has defined remedial action to include the actual construction or implementation
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phase of a Superfund site cleanup following remedial design. The State
considered all costs incurred before the construction contract award date to be
pre-remedial action costs and not allowable as a State credit. The questioned
costs are shown in the schedule on pages 15 and 16.
State's Comments:
The State acknowledges that some of the $82,933 (see schedule on pages 15 and
16) identified for the Canyon Creek project were pre-remedial costs. However,
the State believes that the costs of $53,000 for the power pole removal should be
counted as match costs.
Auditor's Response:
We concur that the costs to remove the power pole are allowable remedial action
costs, and have reinstated the $53,000 amount. However, $29,933
($82,933 - $53,000) in pre-remedial costs remain questioned.
d. The State inadvertently claimed pre-remedial costs of $82,933 for the Canyon
Creek project twice. The questioned costs are shown in the schedule on pages 15
and 16.
State's Comments:
The State did not comment.
Note 2: We have questioned $53,357 in excess costs reported for the institutional controls
program. Institutional controls were remedial actions at sites to minimize the
potential for human exposure to contamination and/or protect the integrity of a
remedy by limiting land or resource use. In this case, the institution controls
consisted of installing top soil in residential and nonresidential sites. In reviewing
the State's supporting documentation, we found that the State's calculations
contained mathematical errors, and some of the measurements were based on
estimated quantities rather than actual quantities. Accordingly, the State
re-measured the sites, and recalculated the costs for the institutional controls.
Based on re-measuring the sites, the State determined that the reported costs were
overstated by $53,357.
State's Comments:
The State did not comment.
7

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Other Matter
The State and a potentially responsible party entered into an agreement where the potentially
responsible party would pay 14.8 percent of all costs incurred in accomplishing the restoration of
the natural resources in certain portions of the South Fork of the Coeur d'Alene River. The
State included in the reported outlays costs of $44,080 incurred by this potentially responsible
party. EPA's Region 10 originally determined these costs to be ineligible. However, Region 10
informed us that the initial determination of ineligibility will be overturned and these costs will
be deemed allowable. Accordingly, Region 10 officials requested that we examine these costs to
determining whether the costs were adequately supported. The $44,080 reported on the March 5,
2003, financial status report plus an additional $12,695 was supported with appropriate
documentation. The additional $12,695 was included in earlier financial status reports; however,
the State inadvertently omitted these costs in preparing the financial status report submitted on
March 5, 2003. The State informed us that it will seek credit for these costs.
State's Comments:
The State intends to amend its claim and seek credit for the additional $12,695.
Auditor's Response:
See recommendation number 3.
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Recommendations
We recommend that EPA Region 10:
1.	Disallow the questioned costs of $649,362.
2.	Advise the State to maintain original source documentation to support future credit
claims.
Should EPA overturn its original decision and allow the $44,080 amount discussed in the "Other
Matter" section of this report, we recommend that EPA Region 10:
3.	Consider the additional incurred costs of $12,695 as match eligible costs.
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10

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Schedules
Schedule of Pre-Support Cooperative Agreement Costs
Elizabeth Park (Project Number SVELIZ01)




MFG
08/08/1994
063094
$43
MFG
08/31/1994
073194
$134
MFG
08/31/1994
83194
$174
MFG
08/31/1994
83194
$3,850
Pintlar
09/08/1994
1117
$138
Pintlar
10/03/1994
1126
$3,819
Proqressive Printinq
10/04/1994
10635
$162
Marsh Irwin
10/31/1994
102094
$870
Osburn Druq
10/31/1994
77856
$16
Osburn Druq
10/31/1994
77110
$45
Osburn Druq
10/31/1994
77110
$26
Zanetti Brothers
11/16/1994
12348
$32,828
Buildinq Maintenance
12/12/1994
2066831
$139
Ed Pommereninq
12/12/1994
9994
$2,463
MFG
12/12/1994
093094
$5,443
MFG
12/12/1994
103194
$8,139
Osburn Druq
12/12/1994
73105
$29
Swanson Distributinq
12/12/1994
352688
$125
MFG
12/23/1994
113094
$3,573
Zanetti Brothers
12/23/1994
12355
$103,649
G.T. Hall (trees)
01/13/1995
102494
$2,583
Jack Matranqa
02/02/1995
3
$1,313
MFG
02/02/1995
123194
$3,362
Jack Matranqa
03/03/1995
4
$240
Zanetti Brothers
03/29/1995
12356
$13,045
MFG
04/03/1995
022895
$782
Total


$186,990
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12

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Schedule of Pre-Support Cooperative Agreement Costs
Nine Mile Creek (Project Number SV19ML01)




Jack Matranqa
10/31/1994
1
$6,084
Osburn Druq
10/31/1994
78260
$45
Osburn Druq
10/31/1994
75031
$12
Panhandle Health
10/31/1994
svta-iul
$112
Panhandle Health
10/31/1994
5160
$130
Panhandle Health
10/31/1994
101294
$500
Pintlar
10/31/1994
1134
$110
Proqressive Printinq
10/31/1994
10893
$48
RDS
10/31/1994
1
$10,481
Swanson
10/31/1994
351919
$877
ERI
12/12/1994
1-24
$6,211
ERI
12/12/1994
2-24
$19,691
Jack Matranqa
12/12/1994
2
$13,220
MFG
12/12/1994
093094
$360
MFG
12/12/1994
093094
$6,816
MFG
12/12/1994
103194
$3,010
MFG
12/12/1994
103194
$732
MFG
12/23/1994
113094
$436
MFG
12/23/1994
113094
$6,412
Panhandle Health
12/23/1994
120794
$2,132
RDS
12/23/1994
81
$14,299
Aerial Mappinq
01/11/1995
2734
$4,975
Buildinq
02/2/1995
2070851
$14
ERI
02/2/1995
3-24
$18,049
Jack Matranqa
02/2/1995
3
$3,556
Kinkos
02/2/1995
0470050
$508
MFG
02/2/1995
123194
$123
MFG
02/2/1995
123194
$81
MFG
02/2/1995
123194
$9,227
Panhandle Health
02/2/1995
1194
$5,338
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Schedule of Pre-Support Cooperative Agreement Costs
Nine Mile Creek (Project Number SV19ML01)
(Continued)
Vendor
Invoice
Date
Invoice
Amount
Pintlar
02/2/1995
1151
$250
MFG
03/2/1995
013195
$210
MFG
03/2/1995
013195
$22,979
Jack Matranqa
03/3/1995
4
$867
Panhandle Health
03/3/1995
1294
$2,196
ERI
04/03/1995
4-24
$12,497
Jack Matranqa
04/03/1995
5
$140
Jack Matranqa
04/03/1995
5
$424
MFG
04/03/1995
022895
$6,456
Osburn Druq
04/03/1995
65335
$13
Osburn Druq
04/03/1995
10045
$30
Osburn Druq
04/03/1995
65335
$8
Total


$179,659
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Schedule of Pre-Remedial Action Costs
Canyon Creek (Project Number SV2CNY08)




All Star Safe & Lock
05/22/1997
051497
$30
Buildinq
06/23/1997
2139151
$138
Coeur D Alene
05/22/1997
291
$79
Eric Lassfolk
06/23/1997
061397
$35
GTE Northwest
02/04/1997
011397A
$79
GTE Northwest
02/04/1997
011397B
$15
GTE Northwest
03/04/1997
020197
$36
GTE Northwest
03/04/1997
020197
$5
GTE Northwest
03/14/1997
021397-
$79
GTE Northwest
03/31/1997
030197
$21
GTE Northwest
04/23/1997
040197
$27
GTE Northwest
06/11/1997
051397
$94
GTE Northwest
06/11/1997
051397
$15
Gascard Inc
05/08/1997
050197
$98
Gascard Inc
06/11/1997
060197
$23
Golder Associates
03/31/1997
0000011
$2,726
Golder Associates
06/11/1997
11445
$5,221
Golder Associates
06/11/1997
11563
$6,847
Golder Associates
06/28/1997
0000011
$5,857
Jack Matranqa
03/17/1997
29
$2,297
Jack Matranqa
05/08/1997
30
$3,398
Loren W Cook
02/04/1997
16286
$5
Martha Calabretta
12/19/1996
120496
$37
Minde L Beehner
04/23/1997
040197
$5
Netlink Inc
05/22/1997
016982
$114
Olsten Staffinq
03/04/1997
000102
$228
Olsten Staffinq
04/23/1997
0001223
$285
Olsten Staffinq
04/23/1997
0001223
$285
Olsten Staffinq
04/23/1997
0001140
$317
Olsten Staffinq
06/11/1997
1423
$107
Osburn Druq
12/19/1996
127969
$20
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Schedule of Pre-Remedial Action Costs
Canyon Creek (Project Number SV2CNY08)
(Continued)




Osburn Drug
04/23/1997
158799
$30
Osburn Drug
04/23/1997
131597
$120
Osburn Drug
04/23/1997
131718
$2
Osburn Drug
04/23/1997
129584
$435
Osburn Drug
05/22/1997
159394
$43
Osburn Drug
05/22/1997
159394
$18
Osburn Drug
05/22/1997
159395
$62
Osburn Drug
05/22/1997
163687
$20
Osburn Drug
06/11/1997
158893
$7
Osburn Drug
06/11/1997
161103
$28
Osburn Drug
06/28/1997
160831
$9
Panhandle Health
03/31/1997
030197
$11
Rick Smith
12/19/1996
8535
$30
Sherry Lynn Krulitz
06/23/1997
061397
$35
Shoshone County
12/19/1996
120496
$12
Shoshone County
05/22/1997
050597
$2
Shoshone County
05/22/1997
69798
$79
Shoshone County
05/22/1997
21624
$107
SVL Analytical Inc
12/6/1996
62814
$360
Subtotal


$29,933
Washinaton Water
6/20/1997
BURKEP
$53,000*
Total


$82,933
These costs have been reinstated in note 1(c); however,
it remains as a duplicate costs claimed under note 1(d).
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Appendix A
Scope and Methodology
We performed our examination in accordance with the generally accepted government auditing
standards, and the attestation standards established for the United States by the American
Institute of Certified Public Accountants. We also followed the guidelines and procedures
established in the OIG Project Management Handbook dated November 5, 2002.
We conducted this examination to express an opinion on the reported outlays. To meet these
objectives, we asked the following questions:
1.	Is the State's financial management system adequate to account for grant funds in
accordance 40 CFR 31.20 and 40 CFRPart 35, Subpart O, paragraphs 35.6270
through 35.6290?
2.	Does the State maintain an adequate labor distribution system that conforms to
requirements of OMB Circular A-87?
3.	Does the State's procurement procedures for contractual services comply with
40 CFR 31.36 and 40 CFRPart 35, Subpart O, paragraphs 35.6550 through 35.6610?
4.	Is the State's reported cost share allowable under the agreement adequately supported
and allowable as a credit or match under the terms and conditions of the agreement,
OMB Circular A-87, and applicable regulations?
In conducting our examination, we reviewed the project files and obtained the necessary
cooperative agreement information for our examination. We interviewed EPA's Region 10
project staff to determine whether any concerns needed to be addressed during our examination.
We also interviewed State personnel to obtain an understanding of the accounting system and the
applicable internal controls as they relate to the reported costs. We obtained and reviewed the
single audit reports, General Accounting Office reports, and other EPA Inspector General reports
issued related to this assignment, to determine whether there were any reportable conditions and
recommendations addressed in those reports.
We reviewed management's internal controls and procedures specifically related to our
objectives. Our examination included reviewing the State's compliance with OMB Circular
A-87; 40 CFR Part 31, and Part 35, Subpart O; and the terms and conditions of the cooperative
agreement. We also examined the reported costs on a test basis to determine whether the costs
were adequately supported and eligible for reimbursement under the terms and conditions of the
cooperative agreement and Federal regulations. We conducted our field work from July 7, 2003,
to March 18, 2004.
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After gaining an understanding of the State's financial management system, we reconciled the
claimed costs to the State's accounting records. Based on our judgment we performed an
in-depth review of costs reported by the four State entities. We chose to perform a thorough
review of construction costs from all State projects, which represents approximately 80 percent
of the total costs. This specific cost element was chosen because of the risk associated with the
costs and the high dollar valve. For all other costs, we tested transactions on a judgmental basis
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Appendix B
State's Response
Richard Valliere
EPA-OIG
1 Congress Street
Boston, MA 02114-2023
RE: Idaho Superfund Credit Claim under EPA Support Agency cooperative
Agreement No. V990431-01
Dear Mr. Valliere:
Thank you for providing the March 26, 2004 draft audit report for the above referenced
cooperative agreement for our review. Our comments on the report are listed below
according to the annotation in your letter.
a.	The State of Idaho entered into a State Superfund Contract and signed a Support
Agency Cooperative Agreement (SACA) that specifically listed the Elizabeth Park and
Nine Mile Creek projects as being match eligible. In the third paragraph on page 4 of
the SACA it states that, "State expenditures which qualify as State credit include but are
not limited to those for response actions at Elizabeth Park and Nine Mile Creek,
including State expenditures for oversight of these actions." We believe the costs
associated with these projects ($186,900 for Elizabeth Park and $179,659 for Nine Mile
Creek) should be counted as match based on our agreement with Region 10 EPA.
Additionally, these projects meet the intent of Section II.B. of the SACA by improving
water quality in the South Fork of the Coeur d'Alene River. Furthermore, the Nine Mile
project was approved by an Action Memo, signed by EPA and others, dated July 13,
1994, well ahead of the April 1995 SACA.
b.	The Draft Audit Report has questioned payroll costs in the amount of $116,490
because the State could not provide documentation to support the costs. The State
agrees that when the documentation was requested, it was unavailable, however, the
State maintains that the required documentation did exist, and through an unfortunate
misunderstanding, most of the documents were destroyed. The State was able to
provide source documents for approximately 10% of the period be reviewed. In addition
the State provided electronic copies of actual payroll "runs" as well as microfiche copies
of the payments. All fringe benefits and actual costs were produced and made
available. The State's requirements for documenting costs were present during the
period reviewed and those policies still exist. Those requirements, as presented, fully
comply with OMB Circular A-87 requirements. Although the actual signed timesheets
could not be provided, the State believes that there is adequate information available to
support the questioned costs.
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c. The State of Idaho acknowledges that some of the costs identified for the Canyon
Creek project were pre-remedial. However, we firmly believe the June 20, 1997
$53,000 costs associated with the power pole removal by Washington Water and
Power should be counted as match credit. Moving a power pole was clearly part of the
implementation of the project and not part of remedial design. The appropriate way to
view this project is that there were two construction contracts associated with the work.
There was the Canyon Creek project contract, and there was the pole removal contract
that was a necessary part of the remedial project implementation.
As referenced under "Other Matters" (page 6 of the draft report), it is the intention of the
State to file with Region 10 an adjustment increasing the PRP (Hecla in-kind) by the
audited increase of $12,695 for a total of $56,775.
In regard to the recommendations of the report, the State of Idaho has continued to
work with EPA Region 10 on managing project costs. We have signed subsequent
State Superfund Contracts and continue to accrue match through direct state
expenditures and in-kind projects. We expect that the next credit report scheduled for
April 30, 2005 will continue to show the State of Idaho's progress toward meeting the
ten percent match obligation for this site. An issue that we would like to have clarified
by EPA Region 10 over the course of this coming year is the value of the federal
expenses so that we can know the final match amount needed for the site.
Sincerely,
Orville Green, Administrator
Waste Management and Remediation Division
Enclosure
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Appendix C
Distribution
Region 10
Regional Administrator (Action Official)
(responsible for report distribution to recipient.)
Audit Coordinator
Headquarters
Director, Grants Administration Division (3903R)
Agency Followup Official (the CFO) (271 OA)
Agency Audit Followup Coordinator (2724A)
Associate Administrator for Congressional and Intergovernmental Relations (1301 A)
Associate Administrator for Public Affairs (1101 A)
Comptroller (2731 A)
Depute Chief Financial Officer (271 OA)
Office of Inspector General
Inspector General (2410)
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