IG-01-007

AUDIT

REPORT COST SHARING FOR ENVIRONMENTAL CLEANUP

EFFORTS

December 8, 2000

National Aeronautics and

Space Administration

OFFICE OF INSPECTOR GENERAL
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Acronyms

CERCLA Comprehensive Environmental Response, Compensation, and Liability

Act of 1980

CoE Corps of Engineers

DoD Department of Defense

ECRP Environmental Compliance and Restoration Program

EPA Environmental Protection Agency

FUDS Formerly Used Defense Site

GAO General Accounting Office

IPO Institutional Program Office

NIP NASA Industrial Plant

NPG NASA Procedures and Guidelines

NPL National Priorities List

OIG Office of Inspector General

PRP Potentially Responsible Party

RCRA Resource Conservation and Recovery Act of 1976
SSFL Santa Susana Field Laboratory
W December 8, 2000

TO: A/Administrator

FROM: W/Inspector General

SUBJECT: INFORMATION: Cost Sharing for Environmental Cleanup Efforts

Report Number IG-01-007

The NASA Office of Inspector General (OIG) has completed an audit of NASA's

implementation of the requirements of NASA Procedures and Guidelines (NPG) 8850.1,1

“Environmental Investigation and Remediation - Potentially Responsible Party (PRP)

Identification and Analysis.” The NPG established requirements, responsibilities, procedures,

and guidelines for identifying PRP's and for developing cost sharing or cost recovery

arrangements between responsible parties. We found that the Agency has made considerable

progress in meeting the NPG requirements which was not the case when we began our field

work. During this audit, many of the reviewed Centers and component facilities accelerated

their planned or ongoing efforts to identify PRP's for sharing environmental costs with the

Agency, which has led to NASA establishing cost sharing arrangements. However, NASA has

at least 44 contaminated sites that require a preliminary PRP analysis that has yet to be either

started or completed and two additional sites that require the completion of a full PRP analysis.2

Until NASA completes the preliminary and/or full PRP analysis for all these sites, management

cannot determine the extent to which it should be seeking cost sharing or cost recovery

arrangements with PRP's for about $140.7 million that will be required to clean up these sites.

We estimated that NASA may be able to avoid as much as $37.9 million in cleanup costs

through cost sharing agreements for these sites. We also found that the NASA Centers and

component

 

1

 Examples of PRP’s include past owners and operators of NASA-owned facilities, as well as transporters of hazardous

waste to and from the facilities.

2

 A preliminary PRP analysis identifies PRP's, the contaminates, general causes for the contamination, and when it

occurred. A full PRP analysis is conducted for any site for which the PRP is known to be an entity other than NASA

and includes PRP searches and cost sharing or cost recovery evaluations of PRP's. Details on both analyses are in

Appendix F.
2

facilities audited did not always coordinate the PRP analysis and subsequent actions with the

Institutional Program Offices (IPO's)3 who provide the key management control in ensuring

compliance with the NPG.

Background

NASA established NPG 8850.1 in response to a General Accounting Office report4 that

concluded NASA needed such a policy because the Agency was not adequately determining

which PRP's should be sharing in the costs of cleaning up NASA contaminated sites. The NPG

established requirements, responsibilities, procedures, and guidelines for identifying PRP's and

for developing cost sharing or cost recovery arrangements between responsible parties.

Recommendation

NASA management should ensure that all preliminary and full PRP analyses are promptly

completed and should clarify existing guidance to better define the types of projects subject to

NPG 8850.1 requirements and to identify Center and component facility IPO's.

Management Response and OIG Evaluation

Management did not concur with our recommendations. Management explained that it could

concur if the first recommendation addressed only those sites with adequate site data to support

the conclusions of the PRP analysis. NASA agreed, however, to send a letter to the affected

NASA Centers/facilities requesting them to submit preliminary PRP analyses within 6 months.

The letter will review the requirements for conducting preliminary PRP analysis for sites

expected to cost $500,000 or more to clean up and for submitting the PRP analysis to the

proper IPO's. Management will send the letter to the responsible IPO's as additional clarifying

guidance in addressing implementation of NPG 8850.1.

Management’s planned actions are responsive to the intent of the recommendations. In making

our recommendations, we did not intend for NASA to expedite the completion of the

preliminary and full PRP analyses in those cases for which schedules already exist or

determinations were pending from regulatory authorities. In such cases, we agree that NASA is

actively working to implement the NPG requirements. Our concern relates to those sites for

which NASA personnel were not gathering sufficient data to complete the required PRP

analysis. The actions NASA planned in response to the recommendations show a strong

 

3

 To ensure alignment between programs and institutional capabilities, the NASA Administrator normally designates

the Enterprise Associate Administrator for the predominant activity at each Center as that Center’s IPO. As an IPO,

the Associate Administrator is responsible for ensuring that the Center has the capability to meet its programmatic and

functional commitments and long-term responsibilities in a safe and effective manner. The IPO is also responsible for

implementation, conformance, and assurance of safe and efficient functional operations.

4

 GAO issued Audit Report GAO/NSIAD-97-98 entitled, "Environmental Cleanup Costs: NASA Is Making Progress

in Identifying Contamination, but More Effort Is Needed," in June 1997.
3

management commitment toward arriving at a final determination for the many sites still requiring

a completed preliminary or full PRP analysis. However, management did not concur with our

estimate of $37.9 million potential cost avoidance by having NASA agree to cost sharing or

cost recovery arrangements with other PRP's for those sites still needing to be cleaned up. We

will continue to work with management to resolve this amount.

Details on the status of the recommendations are in the finding section of the report.

[original signed by]

Roberta L. Gross

Enclosure

Final Report on Audit of Cost Sharing for Environmental Cleanup Efforts
FINAL REPORT

AUDIT OF COST SHARING FOR ENVIRONMENTAL CLEANUP

EFFORTS
W December 8, 2000

TO: J/Associate Administrator for Management Systems

FROM: W/Assistant Inspector General for Auditing

SUBJECT: Final Report on the Survey of Cost Sharing for

Environmental Cleanup Efforts

Assignment Number A9902800

Report Number IG-01-007

The subject final report is provided for your information and use. Please refer to the Executive

Summary for the overall audit results. Our evaluation of your response is incorporated into the

body of the report. The recommendations will remain open for reporting purposes until

corrective action is completed. Please notify us when action has been completed on the

recommendations, including the extent of testing performed to ensure corrective actions are

effective.

If you have questions concerning the report, please contact Mr. Chester A. Sipsock, Program

Director, Environmental and Financial Management Audits, at (216) 433-8960, or Mr.

Fredrick E. Angle, Auditor-in-Charge, at (256) 544-0070. We appreciate the courtesies

extended to the audit staff. See Appendix I for the final report distribution.

[original signed by]

Russell A. Rau

Enclosure

cc:

B/Chief Financial Officer

B/Comptroller

BF/Director, Financial Management Division

G/General Counsel

JM/Acting Director, Management Assessment Division

JE/Director, Environmental Management Division
2

ARC/Director, Ames Research Center

GRC/Director, John H. Glenn Research Center
3

GSFC/Director, Goddard Space Flight Center

KSC/Director, John F. Kennedy Space Center

MSFC/Director, Marshall Space Flight Center

MAF/Manager, Michoud Assembly Facility

SSC/Director, John C. Stennis Space Center

WFF/Director, Wallops Flight Facility
4

bcc:

AIGA, IG, Reading Chrons

JE/Director, Environmental Management Division

ARC/Audit Liaison Representative

GRC/Audit Liaison Representative

GSFC/Audit Liaison Representative

KSC/Audit Liaison Representative

MSFC/Audit Liaison Representative

MAF/Audit Liaison Representative

SSC/Audit Liaison Representative

WWF/Audit Liaison Representative

W/GRC/C. Sipsock

W/GSFC/R. Dix

W/MSFC/R. Angle
Contents

Executive Summary, i

Introduction, 1

Finding and Recommendations, 2

Sharing Environmental Cleanup Costs

Appendix A - Objectives, Scope, and Methodology, 8

Appendix B - Summary of Negotiated Cost Sharing Agreements

as of July 31, 2000, 10

Appendix C - Summary of NASA’s Actions as of July 31, 2000, to

Implement the PRP Analysis Requirements of

NPG 8850.1, 12

Appendix D - Summary of Sites Meeting NPG Criteria for PRP

Analysis That Have Not Been Completed as of

July 31, 2000, 13

Appendix E - Summary of Estimated Potential Cost Avoidance, 14

Appendix F - Requirements of NASA Procedures and Guidelines

8850.1, 15

Appendix G - Management's Response, 17

Appendix H - OIG Comments on Management's Response, 23

Appendix I - Report Distribution, 26
NASA Office of Inspector General

IG-01-007 December 8, 2000

 A9902800

Cost Sharing for Environmental Cleanup Efforts

Executive Summary

Background. In 1997, the U.S. General Accounting Office (GAO) reviewed NASA’s

environmental cleanup costs in response to a congressional request.5 GAO reported that

NASA had not developed an overall policy for determining the potential for cost recovery and

that NASA generally had not determined which PRP’s should be sharing cleanup costs. GAO

recommended that NASA issue a policy statement concerning PRP’s and cost recovery. In

June 1997 in response to GAO’s review, NASA issued NPG 8850.1, “Environmental

Investigation and Remediation - Potentially Responsible Party Identification and Analysis,” to be

in effect for 5 years.

Prior to issuance of the NPG, NASA had some success in identifying PRP’s and in successfully

negotiating cost sharing arrangements. For example, in 1994 and 1996, NASA efforts resulted

in the successful negotiation of three cost sharing arrangements with other PRP’s for 27

contaminated sites (see Appendix B). As a result of those arrangements, NASA avoided an

estimated $89.6 million in environmental cleanup costs that were paid by other responsible

parties.

Objectives. The overall audit objective was to determine whether NASA is adequately

implementing the requirements of NPG 8850.1. The specific objectives were:

• to assess whether NASA has ensured that environmental cleanup costs have been and will

be shared among the responsible parties and

• to identify sites for which NASA should be seeking cost sharing or cost recovery

arrangements.

The objectives, scope, and methodology are discussed in detail in Appendix A.

Results of Audit. Although NASA has made some progress in identifying PRP's and in

sharing site cleanup costs, NASA has not fully implemented the requirements of NPG 8850.1.

Specifically, some Centers/facilities audited have not conducted the preliminary analysis

necessary to start the PRP identification and cost sharing agreement process for 44 of 78

contaminated sites that require the preliminary PRP analysis and have not involved IPO’s in the

 

5

 The former Chairman and Ranking Minority Member of the Subcommittee on National Security, International Affairs,

and Criminal Justice Committee on Government Reform and Oversight, House of Representatives, requested the GAO

review.
ii

process, as required by the NPG. Also, one Center had not completed a full PRP analysis for

two contaminated sites. As a result, NASA has not identified all contaminated sites for which it

should be seeking cost sharing or cost recovery arrangements. Foster Wheeler6 estimated the

cleanup costs to total about $140.7 million7 at sites for which a preliminary or full PRP analysis

has not yet been completed. We estimated that NASA may be able to avoid up to $37.9

million in cleanup costs through cost sharing agreements for those sites.

Recommendations. NASA management should ensure full implementation of NPG 8850.1

by:

• expediting the completion of the preliminary and full PRP analyses;

• providing guidance supplementing NPG 8850.1 to better define the types of projects

subject to NPG requirements and to identify the IPO's for each NASA Center/facility; and

• emphasizing to the IPO's the Agency's policy regarding their responsibilities to ensure

completion of the PRP analyses for their Centers, review the PRP analyses, approve the

proposed agreements, and coordinate review of proposed agreements with the appropriate

Headquarters offices.

 

6

 Foster Wheeler is an environmental consulting firm under contract to the NASA Environmental Management Division,

Office of Management Systems. One of the contract tasks was for Foster Wheeler to determine the estimated cost to

clean up NASA-owned contaminated sites and to help NASA comply with environmental laws and regulations.

7

This estimate includes Foster Wheeler’s estimates totaling $129.7 million to clean up 44 sites that require a

preliminary PRP analysis and estimates totaling $11.0 million to clean up 2 sites that require a full PRP analysis.

Completion of the PRP analysis for all 46 sites should identify how much of the total cost of clean up could be avoided

through cost sharing negotiations or cost recovery actions. See Appendix D.
Introduction

NASA is responsible for compliance with Federal environmental laws, including the Resource

Conservation and Recovery Act (RCRA) of 1976 and the Comprehensive Environmental

Response, Compensation, and Liability Act (CERCLA) of 1980, as amended.8 RCRA

regulates the generation, transportation, storage, disposal, and cleanup of hazardous wastes.

Both laws impose a responsibility for site cleanup on the owner and/or operator of a facility.

Under CERCLA, the party carrying out a cleanup may seek cost reimbursement from other

parties the law would hold liable. These parties include past owners, operators, contractors,

and a broad range of other PRP’s. A Federal agency can use the provisions for cost recovery

under CERCLA to recover costs from PRP’s for an RCRA9 site. However, NASA

Environmental Management Division officials stated that the ability for cost recovery under

RCRA has several substantial limitations.

 

8

 The CERCLA applies to contaminated sites identified by the Environmental Protection Agency (EPA) on the

National Priorities List (NPL). The EPA generally includes sites that have been abandoned and sites that pose the most

severe environmental threat on the NPL. The RCRA generally applies to sites that are not identified by EPA on the

NPL.

9

Pursuant to 42 United States Code 9607 (a), Subsection (4), a Federal agency can recover cleanup costs for removal or

remedial actions for contaminated sites not listed on the NPL. EPA regulations for cost recovery are found in 40 Code

of Federal Regulations 300.
2

Finding and Recommendations

Sharing Environmental Cleanup Costs

NASA has not fully implemented the requirements of NPG 8850.1. Specifically, some NASA

Centers/facilities have not conducted the preliminary analyses to start the PRP identification and

cost sharing agreement process and have not involved IPO’s in the process, as required by the

NPG. These conditions occurred primarily because the Agency has not emphasized completion

of PRP analyses and because Agency policy does not identify the IPO's for each of the

Centers/facilities. Consequently, NASA has not initiated cost sharing or cost recovery

arrangements with other parties who share responsibility for cleanup costs at 46 of 78 sites

estimated to total about $140.7 million (see Appendix D). With cost sharing or cost recovery

arrangements, NASA may be able to avoid up to $37.9 million of the total costs (see Appendix

E).

NPG 8850.1 Requirements

NPG 8850.1 contains two important requirements that must be complied with in order to meet

the objectives of identifying PRP’s and developing cost sharing or cost recovery arrangements

with the PRP’s. One requirement is for Center Environmental Office officials to conduct

preliminary PRP analyses for contaminated sites that are expected to result in projects under the

Environmental Compliance and Restoration Program (ECRP).10 The preliminary PRP analysis

is a critical first step in the PRP identification and cost sharing agreement process. Appendix F

describes NPG requirements for preliminary and full PRP analysis and for cost sharing/cost

recovery agreements.

Another requirement is for Center Environmental Office officials to provide a preliminary and full

PRP analysis and proposed cost sharing or cost recovery agreements to the IPO’s for review

and approval. The IPO’s are responsible for (1) ensuring completion of the PRP analyses at

the Centers, (2) reviewing the PRP analyses, (3) approving proposed agreements, and (4)

 

10 The Facilities Project Implementation Handbook, NPG 8820.2C, addresses ECRP. Chapter 8 of the NPG states the

following concerning NASA’s ECRP:

• The ECRP provides field installations with the necessary resources to plan,

develop, and execute required environmental studies and projects to achieve and

maintain compliance with environmental laws and regulations in conformance

with NASA’s environmental policy.

• The ECRP is a separate program within the NASA Construction of Facilities

Program.

• An ECRP project in the NASA Construction of Facilities Program either

addresses (1) the construction or modification of facilities, as required for

environmental compliance; (2) the cleanup and remediation of hazardous

substance contaminated sites; or (3) a single environmental study effort or a

study necessary to support a planned environmental project and study

estimated to cost $500,000 or more.
3

coordinating review of proposed agreements with appropriate Headquarters officials. The

IPO’s provide the key management control to ensure that the NPG requirements are followed.

While the NPG requires preparation of a preliminary PRP analysis for contaminated sites

expected to result in projects under the ECRP, the NPG does not explain that an analysis is to

be prepared for sites expected to cost $500,000 or more to clean up. Also, although the NPG

requires NASA to provide PRP analyses and proposed cost sharing or cost recovery

agreements to the IPO’s, the policy does not provide a link to existing Agency policy that

identifies the IPO’s for each NASA Center/facility.11

NPG 8850.1 Implementation

Since issuance of NPG 8850.1 in June 1997, some NASA Centers and facilities have made

progress in implementing the new policy requirements. At the same time, however, other

Centers and facilities have not completed a preliminary PRP analysis for many qualifying

contaminated sites, and most Centers and facilities have excluded the IPO’s from the PRP

analysis and cost sharing/cost recovery agreement process.

Preliminary PRP Analysis. As of July 31, 2000, Environmental Office officials at 6 of the 12

NASA Centers/facilities we reviewed had completed a preliminary PRP analysis for 34 (43.6

percent) of the 78 contaminated sites expected to result in projects (see

Appendix C). NASA determined it was the sole responsible party for 26 of the 34 sites.

NASA negotiated cost sharing arrangements with other PRP’s for six of the remaining eight

sites. As a result of these efforts, NASA has avoided an estimated $39.0 million in

environmental cleanup costs (see Appendix B). For two sites, NASA has started a full PRP

analysis to determine how cost sharing or cost recovery arrangements should proceed.

Although NASA's efforts are commendable, NASA has not begun a preliminary PRP analysis

for 44 eligible sites. In its August 1999 cost study, Foster Wheeler estimated the costs to clean

up the 44 sites at about $129.7 million. The 44 sites involve 6 of the 12 NASA

Centers/facilities reviewed (see Appendix C). In addition, another two sites with an estimated

cleanup cost of $11.0 million require completion of a full PRP analysis based on the results of

previously completed preliminary analyses. Until the preliminary and full PRP analyses are

completed for these sites, NASA cannot determine how much of the cleanup costs can be

shared with other responsible parties. Appendix D shows the NASA Centers/facilities that

need to complete the PRP analyses.

Environmental officials at most of the locations reviewed stated that completing the requirements

of NPG 8850.1 has been a low priority. At some of the locations, officials said they did not

 

11 Our review included work at seven NASA Centers and five NASA component facilities. Examples of component

facilities are the Michoud Assembly Facility (Michoud) and the Wallops Flight Facility (Wallops). The NASA Centers

and component facilities are identified in Appendix A.
4

prepare preliminary PRP analyses for contaminated sites because they knew NASA was the

sole PRP for site clean up. Additionally, one Center responsible for

a contractor-operated facility believed that the contractor had complied with the NPG

requirements. However, contractor officials stated they had not complied with the NPG

because they believed that NASA had already done so.

IPO Role in the PRP Process. Involvement of the IPO’s during the PRP process is a key

management control mandated by NPG 8850.1. Chapter 2 of NPG 8850.1 requires the IPO’s

to review the preliminary and full PRP analyses and to review and approve any cost sharing or

cost recovery agreements. However, environmental officials did not involve the IPO’s in the

PRP identification and cost sharing agreement process.

Since the NPG was issued in June 1997, NASA has completed a preliminary PRP analysis for

34 sites and a full PRP analysis for 5 sites and has negotiated 3 cost sharing agreements. Only

five preliminary analyses and one proposed cost sharing agreement were coordinated with the

responsible IPO.

The primary reason for the exclusion of the IPO’s from the PRP process was confusion over

who is to fulfill the role of the IPO. In some cases, the environmental officials believed they

were to function as the IPO. Almost no one interviewed knew who the IPO was for their

location.

NPG 1000.2, “NASA Strategic Management Handbook,” issued February 2000, discusses

IPO responsibilities. Paragraph 2.3.1.6 of the NPG states that the Enterprise12 Associate

Administrator for the predominant activity at each Center is normally designated as the IPO for

that Center. For example, since the predominant activity at Kennedy is Space Flight, the

Associate Administrator for the Office of Space Flight would serve in an IPO capacity, unless

the NASA Administrator chose to designate another Enterprise Associate Administrator to

assume the IPO responsibilities. NPG 8850.1 does not identify the IPO and does not provide

a cross-reference to NPG 1000.2.

By excluding the IPO’s from the PRP process, the environmental officials have eliminated the

primary oversight control intended by NPG 8850.1.

Estimate of Cost Avoidance

Until NASA implements the NPG requirements for preliminary and full PRP analyses, NASA

cannot determine what portion of the estimated cleanup costs for the affected sites will be

available for cost sharing or cost recovery.

 

12 The NASA Administrator has divided the Agency into five major functional areas called Strategic Enterprises. The

Strategic Enterprises include Aerospace Technology, Biological and Physical Research, Earth Science, Human

Exploration and Development of Space, and Space Science.
5

Relying on historical data, we attempted to estimate the amount of cost avoidance NASA could

realize from completing the required PRP analyses and negotiating cost sharing or cost recovery

agreements. Environmental Office officials at six NASA Centers/facilities negotiated eight cost

sharing agreements from 1992 through July 31, 2000 (the audit cutoff date), that will result in an

estimated cost avoidance of $128.6 million (see Appendix B) in past and future environmental

cleanup costs (96.9 percent of the total cost to clean up the sites). After the policy was issued,

Environmental Office officials completed preliminary PRP analyses for 34 sites (see Appendix

C). Of the 34 sites, 8 or 23 percent of the sites, required full PRP analyses. The Environmental

Office officials negotiated cost sharing agreements for six of the eight sites that resulted in a cost

avoidance of $39.0 million. The Environmental Office officials are likely to negotiate cost

sharing agreements for the remaining two sites with estimated clean up costs of $11.0 million.

Environmental Office officials did not prepare preliminary PRP analyses for 6 of 44 sites that

were projected to result in projects because the officials concluded that NASA is the PRP for

these sites. We did not verify their conclusions and included only the other 38 sites in the cost

avoidance calculations. The 38 sites are estimated to cost $122.3 million to clean up. In

calculating the potential cost avoidance, we first assumed that NASA would determine that cost

sharing or cost recovery agreements would be indicated for 9 (23 percent) of the 38 sites. We

based this assumption on NASA’s past experience with the 34 sites discussed earlier for which

preliminary PRP analyses had been completed. We then assumed that NASA could arrange

for other PRP’s to pay 96.9 percent of the cleanup costs based on the experience with the eight

cost sharing agreements negotiated from 1992 through July 31, 2000. We estimated that

NASA could experience a cost avoidance of as much as $27.3 million ($122.3 million times 23

percent times 96.9 percent). Appendix E shows the details of our calculations.

Environmental Office officials at one NASA Center have not completed full PRP analyses for

two sites that are expected to result in projects under the ECRP. In the August 1999 cost

study, Foster Wheeler estimated that those sites would cost NASA a total of $11.0 million.

We estimated that NASA could avoid costs of as much as $10.7 million ($11.0 million times

96.9 percent) by completing full PRP analyses and negotiating cost sharing agreements for the

two sites. Appendix E shows the details of our calculations.

We also conducted a Monte Carlo13 simulation analysis to calculate the estimated cost

avoidance from completing the preliminary and full PRP analyses and negotiating the

appropriate cost sharing and cost recovery agreements. The Monte Carlo analysis identified a

cost avoidance that was greater than the cost avoidance identified in the estimate we calculated

 

13 Simulation is any analytical method that is meant to imitate a real-life system. Monte Carlo simulation is a system

that uses random numbers to measure the effects of uncertainty in a spreadsheet model. The software randomly

generates values for uncertain variables over and over to simulate a model. The simulation calculates numerous

scenarios by repeatedly picking values from the probability distribution for the uncertain variables and using those

values to develop a frequency distribution of the results. After hundreds or thousands of trials, you can view sets of

values and the certainty of any particular value.
6

using historical data. To be conservative, we chose to use the historical data calculations for our

estimate.
7

Recommendations, Management's Response, and Evaluation of Response

The Associate Administrator for Management Systems should ensure full

implementation of NPG 8850.1 by:

1. Expediting the completion of the preliminary and full PRP analyses at those

Centers/facilities that have not yet completed the analyses.

2. Providing guidance supplementing NPG 8850.1 to better define the types of

projects subject to NPG requirements and to identify the IPO’s for each NASA

Center/facility.

3. Emphasizing to the IPO’s that NPG 8850.1 requires them to ensure completion

of the PRP analyses for their Centers, review the PRP analyses, approve the

proposed agreements, and coordinate review of proposed agreements with the

appropriate Headquarters offices.

Management's Response. Nonconcur. Management explained that it could concur if the

first recommendation addressed only those sites with adequate site data to support the

conclusions of the PRP analysis. However, NASA agreed to send a letter to five

Centers/component facilities14 requesting submittal of the preliminary PRP analyses within 6

months for the sites with enough information to prepare the analyses. The letter will review the

requirements for conducting preliminary PRP analyses for sites expected to cost $500,000 or

more to clean up and for submitting the PRP analyses to the respective IPO's. The letter will

also request that Centers identify those sites for which sufficient data has not yet been obtained

to complete the PRP analysis. Management will also send another letter and a copy of this

report to the IPO's.

Management disagreed with our estimated potential cost avoidance of $49.5 million and

believed that $7.5 million was a more accurate amount. Management also provided various

other comments for improving report accuracy and presentation.

The complete text of management's response is in Appendix G.

Evaluation of Response. We believe the planned actions are responsive to the intent of the

recommendations and show a strong management commitment toward arriving at a final

determination for the many sites still requiring a completed preliminary or full PRP analysis. In

making our recommendations, we did not intend for NASA to expedite the completion of the

preliminary and full PRP analyses in those cases where schedules already existed or

 

14 The five Centers/component facilities receiving letters are the John H. Glenn Research Center at Lewis Field, the

Goddard-Space Flight Center Wallops Flight Facility, the Lyndon B. Johnson Space Center, the John F. Kennedy

Space Center, and the Michoud Assembly Facility.
8

determinations were pending from regulatory authorities. For those cases, we agree that NASA

is actively working toward implementing the requirements of NPG 8850.1. However, our audit

work provided strong evidence that not all NASA Centers were aggressively working toward

gathering the data necessary to move the PRP process forward in a timely manner for certain

sites. Consequently, we reaffirm our conclusion that NASA cannot determine the extent to

which it should seek cost sharing or cost recovery arrangements with affected PRP's until

management makes a final determination for these sites.

With regard to our estimated potential cost avoidance, we revised our original estimate of $49.5

million to $37.9 million based on updated information in management's response. For example,

we were able to verify management's position that the Stennis Space Center had completed

negotiations for a cost sharing agreement with the Air Force in July 2000. Absent any

additional data that we could readily verify and relying on data obtained from NASA's

environmental consulting firm, we believe that our revised potential cost avoidance of $37.9

million, which is based on NASA's historical experience, is more realistic at this time than the

$7.5 million being advocated by management. We reaffirm that a better estimate of a cost

avoidance cannot be known until NASA completes all the PRP analyses required by NPG

8850.1.

Appendix H contains our detailed responses to the additional comments made by NASA

management.
9

Appendix A. Objectives, Scope, and Methodology

Objectives

The overall audit objective was to determine whether NASA was adequately implementing the

requirements of NPG 8850.1. The specific objective was to assess whether NASA

Environmental Office officials were ensuring that environmental cleanup costs have been and will

be shared among the PRP’s and were identifying sites where NASA should be seeking cost

sharing or cost recovery arrangements.

Scope and Methodology

We selected 12 NASA Centers/facilities for review: Ames Research Center (Ames), John H.

Glenn Research Center at Lewis Field (Glenn), Goddard Space Flight Center (Goddard),

Lyndon B. Johnson Space Center (Johnson), John F. Kennedy Space Center (Kennedy),

George C. Marshall Space Flight Center (Marshall), Michoud Assembly Facility (Michoud),

NASA Industrial Plant (NIP), Yellow Creek Production Facility (Yellow Creek), John C.

Stennis Space Center (Stennis), Wallops Flight Facility (Wallops), and White Sands Test

Facility (White Sands). We selected Ames, Stennis, Marshall, Kennedy, and White Sands

because Foster Wheeler's estimates of cleanup costs for those sites were significant. We

included the NIP and Wallops at the request of management. We reviewed Michoud and

Yellow Creek because Marshall is responsible for those facilities. We reviewed Johnson and

Goddard because those Centers are responsible for work at the NIP, White Sands, and

Wallops. We reviewed Glenn in order to increase the coverage of the sites expected to result in

projects. We did not include the Jet Propulsion Laboratory or the Santa Susana Field

Laboratory (SSFL) in the review because we had previously reviewed those facilities and

issued separate reports on cost sharing activities at those facilities.15 Marshall is responsible for

the SSFL engine testing facility.

From the 12 NASA Centers/facilities, we selected 78 sites for review that were projected to

cost $500,000 or more each to clean up as noted in the August 1999 Foster Wheeler cost

study (see footnote 5). Foster Wheeler estimated the cleanup costs for the 78 sites to total

about $603.6 million (see Appendix C).

We provided questions addressing the requirements of NPG 8850.1 to the Environmental

Office managers at each of the NASA Centers/facilities identified above. Each of the managers

responded and provided documentation supporting (1) preliminary and full PRP analyses of

NASA contaminated sites and (2) cost sharing and/or cost recovery agreements with the PRP’s

for the sites. We then made follow-up visits to five locations

 

15 The NASA Inspector General issued report IG-97-024, “Cost Sharing For Cleanup Activities at JPL [Jet Propulsion

Laboratory],” dated June 6, 1997; and report IG-98-024, “Cost Sharing for Santa Susana Field Laboratory Cleanup

Activities,” dated August 18, 1998.
10

Appendix A

to conduct survey work. We verified compliance with NPG 8850.1 by reviewing the answers

to the questions and supporting documentation and by discussions with NASA officials.

Management Controls Reviewed

We reviewed management controls related to (1) the preparation and completion of preliminary

and full PRP analyses for NASA-owned facilities and (2) the negotiation of cost sharing or cost

recovery agreements for the contaminated sites requiring such agreements. Management

control weaknesses are addressed in the finding section of this report.

Computer-Processed Data

Computer-processed data did not play a significant role in this review relative to the

development of the audit findings. Therefore, the validity and reliability of such data is not an

issue for this report.

Audit Field Work

We conducted field work from September 1999 through June 2000 at the NASA Centers/

facilities identified in the scope section. We performed this audit in accordance with generally

accepted government auditing standards.
11

Appendix B. Summary of Negotiated Cost Sharing Agreements

as of July 31, 2000

Centers/Facilities

Year of Cost

Sharing

Agreement

No.

of

Sites

Estimated Total

Cost for Site

Clean Up

NASA’s Share

of Cleanup

Cost

Estimated Cost

Avoidance for

NASA

Cost Sharing Agreements Negotiated after NPG 8850.1 Was Issued in June 1997

Ames Research Center11992 & 1998 2 $30,000,000 $0 $30,000,000

Kennedy Space Center21998 1 $3,181,739 $1,306,739 $1,875,000

Stennis Space Center32000 1 $8,470,000 $2,795,100 $5,674,900

Wallops Flight Facility41998 2 $1,500,000 $0 $1,500,000

Total cost avoidance

negotiated after policy

issued 6 $43,151,739 $4,101,839 $39,049,900

Cost Sharing Agreements Negotiated before NPG 8850.1 Was Issued

Glenn Research Center51996 8 $76,600,000 $0 $76,600,000

Marshall Space Flight

Center6

1994 13 $10,000,000 $0 $10,000,000

Yellow Creek71994 6 $3,000,000 $0 $3,000,000

Total cost avoidance

negotiated before

policy was issued 27 $89,600,000 $0 $89,600,000

Total cost avoidance

negotiated both

before and after

policy was issued

33 $132,751,739 $4,101,839 $128,649,900

Cost sharing

percentages

100% 3.1% 96.9%

In summary, NASA officials at six NASA Center/facilities negotiated eight cost sharing arrangements from 1992

through July 31, 2000. These cost sharing arrangements were negotiated at (1) Ames in 1992 and 1998; (2) Kennedy in

1998; (3) Stennis in 2000; (4) Wallops in 1998; (5) Glenn in 1996; and (6) Marshall in 1994 for sites at Marshall and

Yellow Creek. These cost sharing arrangements will allow NASA to avoid $128.6 million of past and future

environmental cleanup cost (96.9 percent of the total cost to clean up the sites of $132.8 million).

1Ames officials negotiated cost sharing agreements with the Navy in 1992 and with the Navy and a contractor in 1998.

These agreements covered the same two sites. The officials stated that they did not provide copies of the preliminary

or full PRP analyses to the IPO for Ames. The officials did provide a copy of the proposed 1998 cost sharing

agreement to the Environmental Management Division, Office of Management Systems, and to the IPO for Ames.

Based on input from the Navy, Ames officials estimated that the agreements will save NASA $30 million.

2Kennedy officials negotiated a cost sharing agreement with the Air Force in 1998. Based on input from the Air Force,

Kennedy officials estimated that this agreement will save NASA $1.9 million. The officials did not provide a PRP

analysis or the proposed cost sharing agreement to the IPO for Kennedy.

3

Stennis officials negotiated a cost sharing agreement with the Air Force on July 19, 2000. We estimated that this

agreement will result in cost avoidance for NASA of $5.7 million based on the agreement and Foster Wheeler's August

1999 estimate of the cost to cleanup this site. The agreement requires NASA to pay one third of the cleanup cost and

the Air Force to pay two thirds for this site. We computed the cost avoidance for NASA by multiplying the Air

Force's share (67 percent) times Foster Wheeler's estimate of $8.5 million to clean up this site.
12

Appendix B

4Wallops officials negotiated a cost sharing agreement with the Corps of Engineers (CoE) in 1998. However, the

officials did not get CoE officials to sign the agreement because they agreed to fund cleanup of this site with Formerly

Used Defense Site (FUDS) program funds. The Congress approved FUDS program funds to clean up formerly

Department of Defense (DoD)-owned facilities that were contaminated by the DoD. Based on input from the Air

Force, Wallops officials estimated that this agreement will save NASA $1.5 million. Wallops officials did not provide

PRP analyses or the proposed cost sharing agreement to the IPO for Wallops.

5Glenn officials negotiated a cost sharing agreement with the CoE for eight Glenn sites at Plum Brook, Ohio, in 1996.

However, the officials did not get CoE officials to sign the agreement because CoE officials agreed to fund cleanup of

these sites with FUDS funds. Based on input from the CoE, Glenn officials estimated that this agreement will save

NASA $76.6 million.

6Marshall officials negotiated a cost sharing agreement with the Army in 1994. Based on input from the Army,

Marshall officials estimated that this agreement will save NASA $10 million.

7Marshall officials negotiated a cost sharing agreement with the Tennessee Valley Authority in 1994. Based on input

from the Tennessee Valley Authority, MSFC officials estimated that this agreement will save NASA $3 million.
Appendix C. Summary of NASA’s Actions as of July 31, 2000, to Implement

the PRP Analysis Requirements of NPG 8850.1

The dollar amounts shown are in millions.

ARC GRC GSFC JSC KSC MSFC MAF NIP YC SSC WFF WS TOTAL

No. of sites meeting NPG criteria for

a preliminary PRP analysis

12 1 5 3 24 3 6 0 0 12 10 2 78

Estimated cleanup costs for sites that

need a preliminary PRP analysis

$53.6 $.8 $8.4 $4.3 $92.1 $3.1 $15.4 $0 $0 $50.3 $18.6 $357 $603.6

No. of sites where a preliminary PRP

analysis was not completed

0 1 0 3 23 3 6 0 0 0 8 0 44

Estimated cleanup costs for sites

where preliminary PRP analysis was

not completed

$0 $.8 $0 $4.3 $89 $3.1 $15.4 $0 $0 $0 $17.1 $0 $129.7

No. of sites with preliminary PRP

analyses since issuance of NPG

8850.1

12 0 5 0 1 0 0 0 0 12 2 2 34

No. of sites with preliminary PRP

analyses since issuance of NPG

8850.1 where it was determined that

a full PRP analyses was not needed

10 0 5 0 0 0 0 0 0 9 0 2 26

No. of sites with preliminary PRP

analyses since issuance of NPG

8850.1 where full PRP analyses

were completed and cost sharing

arrangements were negotiated

2 0 0 0 1 0 0 0 0 0 2 0 5

Estimated cost avoidance where cost

sharing arrangements were

negotiated since issuance of NPG

$30 $0 $0 $0 $1.9 $0 $0 $0 $0 $0 $1.5 $0 $33.4

No. of sites with preliminary PRP

analyses since issuance of NPG

8850.1 where cost sharing

arrangements should be negotiated

0 0 0 0 0 0 0 0 0 2 0 0 2

Estimated costs to clean up sites

where cost sharing arrangements

may be negotiated

$0 $0 $0 $0 $0 $0 $0 $0 $0 $11.0 $0 $0 $11.0

No. of preliminary PRP analyses 0 0 5 0 0 0 0 0 0 0 0 0 5

12
provided to IPO

Legend

ARC - Ames Research Center GRC - Glenn Research Center GSFC - Goddard Space Flight Center JSC - Johnson Space Center

KSC - Kennedy Space Center MSFC - Marshall Space Flight Center MAF - Michoud Assembly Facility NIP - NASA Industrial Plant

YC - Yellow Creek SSC - Stennis Space Center WFF - Wallops Flight Facility WS - White Sands
13

Appendix D. Summary of Sites Meeting NPG Criteria for PRP

Analysis That Have Not Been Completed as of July 31, 2000

Sites Meeting NPG Criteria for a Preliminary PRP Analysis:

Centers/Facilities

Number

of Sites

Sites that Require

Completion of PRP

Analysis

Estimated Site

Cleanup Costs

Glenn Research Center 1 Preliminary PRP Analysis $799,000

Johnson Space Center 3 Preliminary PRP Analysis $4,345,000

Kennedy Space Center 23 Preliminary PRP Analysis $88,958,000

Marshall Space Flight Center 3 Preliminary PRP Analysis $3,089,000

Michoud Assembly Facility 6 Preliminary PRP Analysis $15,405,000

Wallops Flight Facility 8 Preliminary PRP Analysis $17,122,000

Total Sites Requiring

Preliminary PRP Analyses 44 $129,718,000

Sites Requiring Completion of a Full PRP Analysis:

Stennis Space Center 2 Full PRP Analysis $11,015,000

Total Sites Requiring Full

PRP Analyses 2 $11,015,000

Total Sites Requiring

PRP Analyses

46 $140,733,000
14

Appendix E. Summary of Estimated Potential Cost Avoidance

Recommendation 1 results in as much as $37.9 million in funds put to better use.

Center

Type of PRP

Analysis

Required or

Negotiations

No.

of

Sites

Estimated Total

Cleanup Cost

Estimated

Sites Where

Preliminary

PRP Analyses

Will Require

Full PRP

Analysis

(23%)

NASA’s

Share of

the Cost to

Clean Up

(3.1%)1

Estimated Cost

Avoidance for

NASA

(96.9%)2

Require Preliminary and, if Necessary, Full PRP Analysis3:

KSC

Preliminary

and Full 23 $88,958,000 $20,460,340 $634,271 $19,826,069

WFF

Preliminary

and Full 8 $17,122,000 $3,938,060 $122,080 $3,815,980

MAF

Preliminary

and Full 6 $15,405,000 $3,543,150 $109,838 $3,433,312

GRC

Preliminary

and Full 1 $799,000 $183,770 $5,697 $178,073

Subtotals4

38 $122,284,000 $28,125,320 $871,886 $27,253,434

Require Full PRP Analysis5:

SSC Full 2 $11,015,000 $10,673,535

Total Estimated Cost

Avoidance

40 $133,299,000 $37,926,969

Legend

GRC - Glenn Research Center SSC - Stennis Space Center

KSC - Kennedy Space Center WFF - Wallops Flight Facility

MAF - Michoud Assembly Facility 

1See percentage under the “NASA’s Share of Cleanup Cost” column in Appendix B.

2See percentage under the “Estimated Cost Avoidance for NASA” column in Appendix B.

3Using historical data, we calculated the estimated cost avoidance of $27.3 million that would result from completing the

preliminary PRP analyses for the 38 NASA sites identified and from necessary full PRP analyses and cost sharing

negotiations. We used the cost sharing agreements NASA negotiated from 1992 through 2000 (see Appendix B) and the

results of preliminary analyses conducted after NPG 8850.1 was issued for 34 NASA-owned sites. We used the

following assumptions:

• cost sharing agreements for the 38 sites will result in savings comparable to the amount realized through

agreements that were negotiated from 1992 through 2000 (NASA will realize a cost avoidance of about 96.9

percent of the total cleanup costs) (see Appendix B) and

• results of preliminary PRP analyses of sites at other Centers will be similar to the findings for the preliminary PRP

analyses conducted for 34 NASA-owned sites (about 23 percent of the sites will be candidates for cost sharing)

(see Appendix C).

4The subtotals do not include six sites that meet the criteria for preparing preliminary PRP analyses because NASA

Environmental Office officials have determined that NASA is the PRP without input from the IPO’s.

5We identified two sites at Stennis for which Environmental Office officials should complete full PRP analyses and

provide them to the IPO for Stennis. Stennis should complete negotiations of cost sharing agreements with the Army
15

for the two sites after receiving instructions from the Stennis IPO. We calculated the estimated cost avoidance of $10.7

million for these sites by multiplying 96.9 percent times the total $11.0 million estimated clean-up costs for these sites.
16

Appendix F. Requirements of NASA Procedures and Guidelines

8850.1

This appendix summarizes NASA's general requirements for PRP analyses and cost sharing or

cost recovery agreements.

Preliminary PRP Analysis. NPG 8850.1 requires Center Environmental Office officials to

conduct preliminary PRP analyses for contaminated sites that are expected to result in projects

under the ECRP. The preliminary analysis includes identifying PRP’s, the contaminates, the

general causes for the contamination, and when the contamination occurred. While conducting

the preliminary analysis, Center officials may find that some of the contaminated sites are the

result of direct actions by NASA or of past actions by unknown parties. Further PRP analysis

is not required when NASA is clearly the only responsible party for contaminated sites or when

there is no information available to identify other PRP’s. NPG 8850.1 requires Center

Environmental Office officials to document determinations that no further PRP analysis is

warranted and to report the results to their IPO’s. For sites that do not warrant a further PRP

analysis, Center officials are required to furnish copies of the determination and supporting

documentation to the NASA Office of General Counsel, the Office of Management Systems,

and the Office of Inspector General. NPG 8850.1 requires the IPO to review each

determination to ensure that (1) a further PRP analysis is not warranted and (2) there are no

conflicts of interest with the support contractors or NASA officials conducting the preliminary

PRP analysis.

Full PRP Analysis. NPG 8850.1 requires Center Environmental Office officials to conduct a

full PRP analysis for any site for which the PRP is known to be someone other than NASA.

Full PRP analyses include PRP searches and cost sharing or cost recovery evaluations of the

PRP’s. NPG 8850.1 requires the Center Environmental Office officials to provide the results of

a full PRP analysis to the cognizant IPO, the Chief Financial Officer, the Office of General

Counsel, the Office of Procurement, and the Office of Management Systems at NASA

Headquarters. The IPO’s are required to review the information to determine whether to

pursue negotiations of a cost sharing arrangement based on the full PRP analysis. The IPO’s

must provide instructions to the Center Environmental Office officials (as to whether to begin

negotiations) within 30 days of receipt of results on a full PRP analysis.

Cost Sharing or Cost Recovery Agreements. NPG 8850.1 requires Center Directors to

designate Center officials to lead negotiations with PRP’s when appropriate. The lead

negotiators are to negotiate (1) cost sharing agreements so that future environmental cleanup

costs are shared among the PRP’s and (2) cost recovery agreements so that past environmental

cleanup costs are shared among the PRP’s. The NPG allows the Center/facility lead

negotiators to begin negotiations if their IPO's have not given contrary direction after 30 days.

These negotiations may result in proposed cost sharing or cost recovery agreements. The NPG

requires Center Directors to submit proposed cost
17

Appendix F

sharing agreements to their IPO’s for approval. It also requires the IPO to coordinate the

proposed cost sharing agreements with the Chief Financial Officer, the Office of General

Counsel, the Office of Procurement, and the Office of Management Systems for concurrence.

Depending on the circumstances of the proposed agreements and pursuant to the advice of the

Office of General Counsel, the IPO’s may be required to request concurrence from the

Department of Justice. The IPO’s are required to publish Notices of Proposed Settlements in

the Federal Register. The Center Directors may enter into agreements for NASA only after

the IPO’s have fulfilled these requirements.
18

Appendix G. Management's Response
19

Appendix G

See Appendix H,

OIG Comment 1
20

Appendix G
21

Appendix G

See Appendix H,

OIG Comment 3

See Appendix H,

OIG Comment 2
22

Appendix G

See Appendix H,

OIG Comment 2

See Appendix H,

OIG Comment 3

See Footnote 16

See Appendix H,

OIG Comment 3
23

Appendix G
24

Appendix H. OIG Comments on Management's Response

In addition to providing comments on the OIG recommendations in this report, NASA commented

on the validity of our estimated potential cost avoidance. NASA also provided other comments to

improve report accuracy or presentation. We have incorporated management's comments into the

report as necessary. The following presents management's comments and our evaluation of those

comments for those matters that we consider significant and for which we did not make a change to

the report.

Management's Comment. NASA management believes the OIG potential cost avoidance

estimate of $49.5 million is incorrect. Management stated that this estimate is based on 41 sites

located at the John F. Kennedy Space Center (Kennedy), Wallops Flight Facility (Wallops),

Michoud Assembly Facility (Michoud), John H. Glenn Research Center at Lewis Field (Glenn), and

John C. Stennis Space Center (Stennis), of which 23 sites are at Kennedy. The estimate for those

sites is based on past experience, where a different set of 32 sites were reviewed and analyzed. Of

the 32 sites for which cost sharing arrangements were negotiated, NASA clearly had minimal

responsibility. In contrast, with reference to the 41 sites in Appendix E, Kennedy, Glenn, and

Michoud environmental officials believe that NASA has significant responsibility for the sites located

on those facilities and do not anticipate pursuing other PRP’s. At Wallops, the Corps of Engineers

is already conducting remedial activities at sites for which it is the responsible entity. Only Stennis

has concluded that it has a basis to pursue PRP’s. Stennis has negotiated an agreement with a PRP

for one of the sites and is preparing a full PRP analysis for the other two sites. The cost avoidance

at those sites is estimated at $7.5 million. Therefore, the $7.5 million represents the potential cost

avoidance available to NASA and the final report should reflect only the $7.5 million as a legitimate

cost avoidance.

1. OIG Comments. We based our estimated potential cost avoidance of $49.5 million on

NASA's historical experience in negotiating cost sharing agreements for other Agency facilities. We

revised this estimate to $37.9 million based on new information NASA provided after the draft

report was issued.16 We continue to believe that the Agency’s past record of accomplishments

provides a sound basis for estimating future potential cost avoidances. As discussed in the report,

we purposely adopted a conservative approach to developing our estimate as the application of a

sophisticated mathematical analysis resulted in an even higher estimate of cost avoidance. NASA’s

opposition to our estimate of cost avoidance is based on management’s perception that NASA will

have the significant responsibility for the cleanup costs for those sites still requiring a completed

preliminary PRP analysis. While this position eventually may prove valid, we continue to believe

that the true potential for cost avoidance cannot be known until NASA determines which sites will

require a preliminary and full PRP analyses and then completes the required analyses, as required

under the Agency’s existing PRP policy.

 

16 We revised our estimate based on the results of the completed preliminary PRP analysis for two White Sands Test

Facility sites in New Mexico and on a completed full PRP analysis for one of the Stennis sites.
25

Appendix H

Preliminary PRP analyses still need to be completed for the Kennedy, Wallops, and Michoud sites,

and a full PRP analysis needs to be completed for the two Army sites at Stennis. By negotiating

cost sharing agreements, NASA should be able to avoid costs of about $11 million for clean-up for

the two sites at Stennis that were contaminated by the Army. We base this estimate on Foster

Wheeler's August 1999 cost estimates and NASA's historical experience with cost sharing

agreements. We reaffirm our cost avoidance estimate of $37.9 million and the need to complete the

preliminary and full PRP analyses in a timely manner.

Management's Comment. The report concludes that the Centers/facilities have excluded the

IPO's from the PRP analysis and cost sharing/cost recovery agreement process. We believe that

the report overstates this limited problem. NASA personnel submitted the preliminary PRP

analyses completed by Dryden Flight Research Center, Goddard Space Flight Center, Marshall

Space Flight Center and Langley Research Center to the IPO as required. Although Ames

Research Center and Stennis Space Center did not submit their preliminary PRP analyses directly to

the IPO, both of those Centers have negotiated cost sharing agreements that had been coordinated

with their IPO’s. The Wallops Flight Facility cost sharing agreement with the Corps of Engineers

did not require a signed agreement, thus it did not require IPO coordination. In any case, the

Environmental Management Division will send a letter to several Centers where coordination may

be an issue. This letter will be similar to the one that the Office of Space Flight recently sent to the

Centers under its jurisdiction regarding the requirements of the NPG.17 In addition, management

will send this OIG report and the follow-up correspondence to the IPO's.

2. OIG Comments. We did not include Dryden and Langley in our review of 12 NASA

Centers/facilities and cannot comment on whether they properly coordinated with their respective

IPO's. As discussed in the report, our conclusions concerning the lack of coordination with IPO's

for the locations reviewed were supported by discussions with Center environmental officials. For

example, officials at Glenn, Kennedy, Marshall, and Wallops stated that they did not provide copies

of PRP analyses or proposed cost sharing agreements for their sites to their IPO because they did

not know who the IPO's were for those sites. Although Ames officials stated that they provided a

copy of the proposed cost sharing agreement to their IPO, the IPO for Ames could not remember

receiving and approving the agreement. We discussed IPO responsibilities with representatives

from the Office of Space Flight and the Office of Aerospace Technology. As a result of those

discussions, we concluded that representatives from the Office of Space Flight were knowledgeable

of IPO responsibilities. However, representatives from the Office of Aerospace Technology were

not as knowledgeable. We commend the Office of Space Flight for sending a clarification letter to

its Centers as a result of discussions with the OIG auditor. We also believe that the corrective

actions planned by management should improve the level of coordination originally intended by the

NPG.

 

17 This letter was sent to five locations -- the Lyndon B. Johnson Space Center, John F. Kennedy Space Center, George C.

Marshall Space Flight Center, John C. Stennis Space Center, and White Sands Test Facility.
26

Appendix H

Management's Comment. The reported value of $506.2 million should be revised to reflect the

later comment (on Appendixes C and D) regarding completion of the preliminary PRP analysis by

Marshall and the White Sands Test Facility.

3. OIG Comment. We revised Appendixes C and D and other portions of the report as

appropriate based on the completed preliminary PRP analyses provided for the White Sands Test

Facility sites. However, we did not change any data in the appendixes related to the Marshall sites

because the new information provided by NASA management addressed sites that differed from the

ones referenced in the appendixes.
27

Appendix I. Report Distribution

National Aeronautics and Space Administration (NASA) Headquarters

A/Administrator

AI/Associate Deputy Administrator

B/Chief Financial Officer

B/Comptroller

BF/Director, Financial Management Division

G/General Counsel

H/Associate Administrator for Procurement

HK/Director, Contract Management Division

HS/Director, Program Operations Division

J/Associate Administrator for Management Systems

JM/Acting Director, Management Assessment Division

L/Associate Administrator for Legislative Affairs

M/Associate Administrator for Space Flight

R/Associate Administrator for Aerospace Technology

Y/Associate Administrator for Earth Science

NASA Centers

Director, Ames Research Center

Director, John H. Glenn Research Center

Director, Goddard Space Flight Center

Director, John F. Kennedy Space Center

Director, George C. Marshall Space Flight Center

Manager, Michoud Assembly Facility

Director, John C. Stennis Space Center

Director, Wallops Flight Facility

Non-NASA Federal Organizations and Individuals

Assistant to the President for Science and Technology Policy

Deputy Associate Director, Energy and Science Division, Office of Management and

 Budget

Branch Chief, Science and Space Programs Branch, Energy and Science Division, Office

 of Management and Budget

Associate Director, National Security and International Affairs Division, Defense

 Acquisitions Issues, General Accounting Office

Professional Assistant, Senate Subcommittee on Science, Technology, and Space
28

Appendix I

Chairman and Ranking Minority Member – Congressional Committees and

Subcommittees

Senate Committee on Appropriations

Senate Subcommittee on VA, HUD, and Independent Agencies

Senate Committee on Commerce, Science, and Transportation

Senate Subcommittee on Science, Technology, and Space

Senate Committee on Governmental Affairs

House Committee on Appropriations

House Subcommittee on VA, HUD, and Independent Agencies

House Committee on Government Reform and Oversight

House Subcommittee on Government Management, Information, and Technology

House Subcommittee on National Security, Veterans Affairs, and International Relations

House Committee on Science

House Subcommittee on Space and Aeronautics, Committee on Science

Congressional Member

Honorable Pete Sessions, U.S. House of Representatives
NASA Assistant Inspector General for Auditing

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