Region 5 Oversight of PRP-lead Remedial Design and Remedial Action

	Office of Inspector General Audit Report
Region 5 Oversight of PRP-lead Remedial Design and Remedial Action
E1SGF8-05-0035-8100208
August 17, 1998

EXECUTIVE SUMMARY

INTRODUCTION

The Office of Inspector General (OIG) performed an audit of Region 5's management of potential responsible party (PRP) lead remedial design and remedial action activities (remedial construction projects). We selected this audit because PRPs perform the majority of Superfund cleanup activities and many of these are in the remedial design and action phases. When the PRPs conduct the cleanup, the Environmental Protection Agency's (EPA) role is to ensure that the PRP complies with all applicable laws, regulations, and requirements; and meets all performance standards in the settlement agreement or order.

OBJECTIVES

The objectives of the audit were to determine, for PRP lead sites in the remedial design and action phases:

if Region 5 was effectively overseeing responsible parties and
the impact of the Superfund Administrative Reform on reducing oversight for cooperative responsible parties.

RESULTS IN BRIEF

Region 5 provided effective oversight of PRPs. Regional project managers (RPMs) ensured that remedies were being completed in accordance with the record of decision and that time schedules in the settlement agreement or order were met. The RPMs accomplished effective oversight by establishing good working relationships with the PRPs. This included open communication and working through issues as they occurred, before they turned into major problems. More frequent use of independent quality assurance teams is one area where Region 5 could improve its oversight of PRPs.

The impact of the reduced oversight administrative reform in Region 5 was difficult to measure due to (a) the inherent nature of the oversight process and (b) cost savings from reductions in oversight not being computed. As a result, for fiscal years (FY) 1996 and 1997, the Agency could not determine the extent of the impact of this reform and whether it was successful in Region 5. For FY 1998, the Agency has developed an evaluation form that, when completed, may provide management with the information it needs to evaluate the impact of the reform.

RECOMMENDATIONS

We recommend that the Acting Regional Administrator, Region 5, take the following actions.

Require the Superfund division to (1) use independent quality assurance teams for PRP lead remedial construction projects, and (2) verify that independent quality assurance teams are being used appropriately. When independent quality assurance teams are not used, the reasons for not using them should be documented.
Ensure the Superfund division yearly completes the evaluation form for sites in the reduced oversight administrative reform in order to compute costs savings.

AGENCY COMMENTS AND ACTIONS

Region 5 agreed to take action to address the findings and recommendations in the report.

Starting October 1, 1998, the RPM will evaluate the appropriateness of using an independent construction quality assurance team for each workplan received for PRP remedial construction projects performed pursuant to an EPA settlement or order. In any case where such a team will not be used, the RPM will document the reasons in a memorandum.
The evaluation form for sites in the reduced oversight reform will be completed and submitted to EPA Headquarters by October 10, 1998.

OIG EVALUATION

Region 5's actions, when completed, will address the findings and recommendations in the report.

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