AUDIT OF THE INDEPENDENCE OF 

CENTRAL ARTERY/TUNNEL PROJECT 

INSPECTION CONTRACTORS 

Federal Highway Administration 

Report Number: MH-2007-039 

March 27, 2007 
U.S. Department of The Inspector General Office of Inspector General 

Transportation Washington, DC 20590

Office of the Secretary 

of Transportation 

March 27, 2007 

The Honorable Michael E. Capuano 

Member, U.S. House of Representatives 

Washington, D.C. 

 

Dear Representative Capuano: 

This report responds to your request that the Office of Inspector General (OIG) 

review any independence concerns posed by contractors who were performing 

recent remediation (repairs or retrofits) inspection work on the Boston Central 

Artery/Tunnel (CA/T) Project. 

In light of the tragic accident that occurred in one of the tunnels on July 10, 2006, 

the Federal Highway Administration (FHWA) and OIG agreed that it was 

imperative that safety reviews and remediation work be conducted independently 

of contractors who performed the original work or oversight. This is necessary to 

provide assurance to the driving public that the CA/T system is safe. In late 

October 2006, media reports revealed that employees of the CA/T Project’s longtime oversight contractor—a joint venture of Bechtel Corporation and Parsons 

Brinckerhoff Quade & Douglas, Inc. (B/PB)—were conducting inspections of 

remediation work. 

On October 24, 2006, the Boston Herald reported that a few employees of B/PB 

had been conducting daily field inspections of remediation work inside the I-90 

connector tunnel. The tunnel was closed to traffic after the ceiling collapse, 

pending safety reviews and remediation work to address any problems that may 

have been identified during these reviews. The involvement of B/PB employees 

in such work could undermine the public’s confidence that the Commonwealth’s 

efforts to ensure the safety of the tunnels were truly independent. The thenMassachusetts Secretary of Transportation ordered B/PB employees to be 

removed from inspections or remediation work. Similar questions about 
independence arose regarding two other firms that were involved in remediation 

inspection work-Keville Enterprises and HNTB Corporation (HNTB). 

Based on the results of our reviews, which we have enclosed, we have concluded 

that contractors with potential independence issues have been removed from CNT 

remediation work and that the Commonwealth has sufficiently mitigated any risks. 

According to Commonwealth documentation, seven BIPB employees had been 

conducting inspections before the Commonwealth directed them to stop on 

October 24, 2006, and these employees were removed from remediation work. 

We confirmed that the Commonwealth performed 193 re-inspections on the work 

of the seven BPB employees. We reviewed a sample of 30 re-inspections that the 

Commonwealth conducted, and found that the Commonwealth followed its reinspection procedures for all 30 cases. After reviewing this sample, we concluded 

that the Commonwealth sufficiently mitigated the risks posed by BPB's 

involvement in earlier remediation work. We informed FHWA and 

Commonwealth officials of the results of our review. FHWA informed us that, in 

conducting its own assessment, it was also satisfied with the Commonwealth's 

efforts to deal with any independence concerns. 

Accordingly, based on the interviews we conducted and the documentation we 

reviewed, we concluded that the Commonwealth took sufficient steps to mitigate 

any risks posed by BPB's prior inspection work. In addition, we concluded that 

the Commonwealth has taken sufficient steps to evaluate whether or not other 

contractors, such as Keville Enterprises and HNTB, may lack sufficient 

independence due to previous involvement in the design or construction of the 

CNT Project. 

If I can answer any questions or be of further assistance on this matter, please feel 

fiee to call me at (202) 366-1 959, or my Deputy, Todd Zinser, at (202) 366-6767. 

Sincerely, 

Calvin L. Scovel I11 

Inspector General 

Enclosure (Report Number MH-2007-039) 

cc: James Ray, Chief Counsel, FHWA 
AUDIT OF THE INDEPENDENCE OF 

CENTRAL ARTERY/TUNNEL PROJECT 

INSPECTION CONTRACTORS 

(Report No. MH-2007-039) 

Table of Contents 

Transmittal Letter 

Introduction................................................................................2 

Results.......................................................................................3 

Conclusion..................................................................................6 

Exhibit A: Summary Matrix of Actions Taken by Massachusetts and 

OIG Activities to Address Them.....................................................7 

Exhibit B: Inspection Contractors’ Involvement in Remediation 

Work.........................................................................................11 

Exhibit C: Objectives, Scope, and Methodology.............................13 

Exhibit D: Major Contributors to This Report.................................15 
2

Independence of Central Artery/Tunnel Project 

Inspection Contractors 

(Report No. MH-2007-039) 

Introduction 

Since the July 10, 2006 collapse of overhead panels in one of the Boston Central 

Artery/Tunnel (CA/T) Project tunnels, which killed a motorist, the 

Commonwealth of Massachusetts (the Commonwealth) has been conducting a 

series of safety reviews and remediation work to correct any deficiencies 

identified during the reviews.1

 As a result of the tunnel ceiling collapse and the 

resulting fatality, portions of the CA/T Project were closed to traffic and the 

Commonwealth and the Federal Highway Administration (FHWA) agreed to an 8-

stage reopening process. FHWA is the Federal agency responsible for overseeing 

the CA/T Project and the Office of Inspector General (OIG) has been providing 

independent oversight of the reopenings at the request of the Massachusetts U.S. 

congressional delegation and the U.S. Secretary of Transportation. We have also 

been providing oversight to the Commonwealth’s more comprehensive “Stem to 

Stern” review. Also, in December 2006, the National Transportation Safety Board 

Reauthorization Act of 2006 (Public Law No. 109-443) directed OIG to provide 

oversight related to the CA/T Project. 

It is imperative that, going forward, CA/T Project safety reviews and remediation 

activities are conducted in a rigorous and independent manner to restore public 

confidence and ensure the safety of drivers who use the reopened tunnels. 

Accordingly, contractors including the main joint venture Bechtel Corp. and 

Parsons Brinckerhoff Quade & Douglas, Inc. (B/PB) who were previously 

involved in the design and oversight of the I-90 tunnels, which require 

remediation, should not play a role in the remediation work or inspections related 

to the reopening process. 

On October 24, 2006, the Boston Herald reported that a few employees of B/PB 

had been conducting daily field inspections of remediation work inside the I-90 

connector tunnel. Based on our review, we determined that the B/PB employees 

had apparently been used to supplement Commonwealth inspectors. At that time, 

the Massachusetts Governor’s office stated that it had previously directed the 

Commonwealth’s Executive Office of Transportation (EOT) to ensure that B/PB 

would have no involvement in either the I-90 connector remediation work or the 

more comprehensive “Stem to Stern” safety review. On October 24, 2006, the 

 

1

 The Commonwealth of Massachusetts tunnel safety reviews and remediation work is being directed by 

 the Executive Office of Transportation (EOT) with the support of employees and contractors managed by 

 the Massachusetts Highway Department (MHD), which is part of EOT. 
3

Massachusetts Secretary of Transportation publicly announced that B/PB’s 

involvement in the remediation was an inadvertent oversight and that he ended 

B/PB’s involvement. 

After October 24, 2006, Commonwealth officials informed us that they reviewed 

B/PB’s involvement in tunnel remediation and conducted new inspections of any 

remediation work that B/PB initially inspected (the remediation work itself was 

performed by other firms). Further questions arose regarding the independence of 

two additional firms that the Commonwealth was using in the CA/T Project 

remediation—Keville Enterprises and HNTB Corporation (HNTB). According to 

Commonwealth officials, they vetted and cleared other contractors working on 

remediation to ensure that these firms did not lack independence due to any 

previous involvement with any I-90 work. 

In conducting the audit, we reviewed documentation provided by Commonwealth 

officials. We also conducted interviews with officials from EOT, the 

Massachusetts Highway Department, the Massachusetts Turnpike Authority, 

B/PB, Keville Enterprises, and the National Transportation Safety Board. Exhibit 

A details our analysis of the involvement of B/PB, Keville Enterprises, and HNTB 

in the I-90 remediation work. Exhibit B provides an overview of other contractors 

that are involved in inspection work. We conducted our performance audit work 

from October through December 2006 in accordance with Generally Accepted 

Government Auditing Standards prescribed by the Comptroller General of the 

United States. Exhibit C details our objectives, scope, and methodology. 

RESULTS 

Bechtel Corporation and Parsons Brinckerhoff Quade & Douglas, Inc. 

Employees Have Been Removed from the CA/T Project Remediation 

Work 

According to Commonwealth documentation, seven B/PB employees were 

conducting inspection activities before B/PB was directed to stop on October 24, 

2006. The records also show that the Commonwealth removed these employees 

from remediation work by that same date. The Commonwealth identified 193 

inspections that required an independent re-inspection.2

 The initial inspections in 

question were conducted between September 21, 2006 and October 24, 2006, the 

date of B/PB’s removal from remediation work. Between September 21st and 

October 24th, the seven B/PB employees were used to supplement the 

Commonwealth’s other inspection staff. The Commonwealth was relying on 

inspections performed by seven B/PB employees during this period of time. They 

 

2

 Exhibit A provides additional details about the Commonwealth’s inspection process and procedures. 
4

were tasked to conduct inspections on their own and not as part of inspection 

teams using Commonwealth employees. The Commonwealth reported to us that, 

after October 24th, it conducted independent re-inspections on all of B/PB’s 193 

inspections. 

The Commonwealth removed the B/PB employees in question to ensure that no 

B/PB employees continued to conduct inspection work. In addition to reviewing 

the Commonwealth’s re-inspection records, we interviewed four of the seven 

B/PB employees to verify the Commonwealth’s claims that these employees were 

no longer conducting inspections. 

Commonwealth officials identified a total of 193 B/PB inspections that required a 

re-inspection. We obtained the Commonwealth’s list of the 193 inspections and 

reviewed in detail a sample of 30 B/PB inspections to verify that re-inspection 

forms were completed properly. Our review determined that the Commonwealth’s 

re-inspection procedures were followed in these 30 cases. Accordingly, based on 

the documentation we reviewed and our interviews, we concluded that the 

Commonwealth took sufficient steps to evaluate B/PB’s work, thereby mitigating 

potential risks posed by B/PB’s involvement in remediation. 

The Commonwealth also decided to remove an additional 63 B/PB employees 

who were performing mostly administrative duties. For example, some of these 

employees were classified under categories such as traffic support and secretarial. 

The Commonwealth identified these 63 employees by reviewing joint venture 

billing records to determine who had charged the CA/T Project for remediation–

related work. According to the Commonwealth, removing all B/PB employees 

from any remediation-related work was justified to further avoid the appearance 

that the remediation work lacked independence from the contractors responsible 

for the design and construction of the I-90 tunnels. During the period of July 16, 

through October 22, 2006, the Commonwealth reported that approximately $1.2 

million was invoiced by B/PB for staff that worked on remediation-related 

activities, which includes the 63 administrative employees and seven inspectors. 

We interviewed 17 of the 63 B/PB employees and determined that their 

responsibilities matched the documentation provided by the Commonwealth and 

that they had been removed from any remediation-related duties. We also 

assessed whether any B/PB administrative staff had performed any duties that 

would have precipitated the need for re-inspections. Based on the documentation 

we reviewed and our interviews, we concluded that the Commonwealth took 

sufficient steps to ensure that B/PB employees were removed from any 

remediation-related activities and no additional re-inspections were required. 
5

Other Contractors with Independence Concerns Have Been 

Sufficiently Vetted or Removed from Remediation Inspection Work 

Questions were also raised regarding the independence of two other contractors 

that had been involved in the CA/T Project remediation inspection work─Keville 

Enterprises and HNTB Corporation. First, 27 Keville Enterprise employees 

conducted remediation-related inspections and other technical support for the 

Commonwealth. This presented a potential independence concern because Keville 

previously had a subcontractor relationship with B/PB on the CA/T Project. 

In reviewing Keville’s independence, Commonwealth officials told us that they 

took the following facts into consideration: 1) Keville was not a partner in the 

B/PB joint venture; 2) at the time the Commonwealth was using these inspectors, 

Keville was not in a subcontractor relationship with B/PB; and 3) Keville was 

sufficiently independent in this case, because none of the Keville inspectors had 

previously been involved with oversight of the I-90 tunnel panels. 

The Commonwealth provided us a list of the Keville employees assigned to 

inspection work, which we verified with Keville officials. Further, we interviewed 

several members of the Keville staff to verify their role and employment history 

on the CA/T Project. Based on our review and interviews, we determined that 

these employees were sufficiently independent. Nonetheless, on October 26, 

2006, Commonwealth officials removed Keville inspectors from remediation work 

to avoid any appearance of a lack of independence due to the firm’s previous 

involvement in the CA/T Project. 

Second, although HNTB performed remediation-related inspections and other 

technical support on I-90, the Commonwealth concluded that the work of the 

seven HNTB employees in question was sufficiently independent because HNTB 

did not previously perform work on the I-90 tunnel ceiling system. Specifically, 

Gannett Fleming used a ceiling panel design in the I-90 tunnel that HNTB 

developed for the I-93 tunnel, but HNTB was not involved in the I-90 work. To 

verify the Commonwealth’s claims, we also consulted with the National 

Transportation Safety Board (NTSB), which is conducting an independent 

investigation of the July 10, 2006 tunnel incident in which a passenger was killed. 

We confirmed that B/PB and Gannett Fleming were the firms involved in the I-90 

tunnel work—not HNTB. Further, B/PB and its subcontractor, Gannett Fleming, 

revised parts of HNTB’s panel design and Gannett Fleming independently 

designed all of the hanger systems for the I-90 connector tunnels. Accordingly, 

we concluded that HNTB did not have any independence issues in working on I90 remediation. 
6

Remaining Contractors Conducting Inspections Have Been Vetted 

and Cleared to Ensure Their Independence 

Several firms, aside from B/PB, Keville and HNTB, have been involved in 

remediation work. The Commonwealth is using the following design and 

inspection consultants─TranSystems; Transportation Engineering and 

Construction, Inc.; Charles H. Sells, Inc.; Diversified Technology Consultants; and 

Purcell Associates. According to the Commonwealth, these contractors have been 

vetted to ensure they had no significant prior involvement in the I-90 tunnel. To 

ensure their independence, the Commonwealth requested that each firm provide, 

in writing, (1) involvement with the design or construction of the CA/T Project 

before July 10, 2006; (2) contractual agreements with B/PB; and (3) names of 

employees involved in the remediation who were previously employed by B/PB, 

any B/PB subconsultants on the CA/T Project, or any section design consultants 

on the CA/T Project. The Commonwealth obtained and reviewed the requested 

information along with each firm’s written assurance that it had no conflicts of 

interest in conducting remediation work. 

Although no questions had been raised as to the independence of these five firms, 

we interviewed Commonwealth officials to assess their vetting and clearance 

process, and reviewed the engineering firms’ written assertions and responses to 

MHD’s follow-up questions. Based on the results of our interviews and document 

reviews, we determined that the Commonwealth performed due diligence in 

assessing these firms’ independence. Exhibit B provides additional information 

on the current involvement of these firms in I-90 remediation work and the vetting 

process. 

CONCLUSION 

We informed FHWA of the results of our review and provided them with a draft 

of our report. FHWA informed us that, based on its own review, it was satisfied 

with the corrective actions taken by the Commonwealth. We make no 

recommendations to FHWA and accordingly no reply is required. 
EXHIBIT A: SUMMARY MATRIX OF ACTIONS REPORTED BY MASSACHUSETTS 

ACTIVITIES TO ADDRESS THEM 

Firm No. of Employees with Potential Independence Concerns Activity Performed Mitigation Actions Taken by the Commonwealth of Massachusetts Bechtel/ Parsons Brinckerhoff Quade & Douglas, Inc. (B/PB) 7 Inspectors 5 full time 2 part time 

Inspected the two hanger systems: the new Hilti bolt system and the existing Unistrut hanger system on I90 Westbound and Ramp D tunnels 

1. Hilti Bolt System 

• Completed an inspection 

form while observing: 

• Drilling of holes for bolts 

Installation of Hilti bolts 

• Load tests (also reported 

by an independent pulltest firm) 

• Bracket installation • Torque setting of first nut • Tightening of second nut 

• The Commonwealth removed B/PB inspectors from remediation work on Octob• The Massachusetts Highway Department (MHD) identified 193 inspections per

employees from September 21st through October 24th that required an independB/PB inspections performed before September 21 were redundant and not relied performed independent inspections using its own employees.) See the note at thmore information on the 193 inspections. 

• MHD created a spreadsheet detailing the 193 inspections, which we obtained. • MHD conducted re-inspections of the Unistrut and Hilti system brackets and ide

independent load tests for Hilti bolts. 

• We interviewed the MHD Chief Engineer, the MHD Director of Construction, t

Turnpike Authority Chief of Staff, and the CA/T Project Director regarding the B/PB and the process they used to identify potentially compromised inspections

• We examined the MHD’s spreadsheet of the initial 193 inspections. We also ob

summary of B/PB billings for remedial work as additional verification. 

• We interviewed 4 of the 7 B/PB inspectors to independently verify the number o

MHD and to confirm that B/PB is no longer involved in tunnel remediation wor

• Based on our review, we concluded that the Commonwealth’s process provided 

B/PB inspectors were taken off the job and inspections performed solely by B/Pselected for re-inspection. 

• MHD examined all inspection forms and identified the specific inspections cond

21 by the seven B/PB inspectors. MHD identified a total of 193 inspections perinspectors. 

• MHD reported that it had completed a re-inspection process for each of the 193 
EXHIBIT A: SUMMARY MATRIX OF ACTIONS REPORTED BY MASSACHUSETTS 

ACTIVITIES TO ADDRESS THEM (Cont.) 

Firm No. of Employees with Potential Independence Concerns Activity Performed Mitigation Actions Taken by the Commonwealth of Massachusetts 

2. Unistrut System • Completed an inspection 

form while observing: 

• Disassembly of old 

bracket 

• Checking the Unistrut for 

damage 

• Checking bracket for 

damage 

• Replacement of existing 

or new bracket and new spring nuts 

• Replacement of new bolts • Use of metal shims, if 

needed 

• Torque setting of bolts 

• We obtained a list of the 193 initial inspections from which we selected a sampl

corresponding re-inspection records for review. We then analyzed the re-inspectthe associated records were complete and accurate. We found no significant prointerviewed the MHD Chief Engineer to obtain further clarification of the re-ins

• Based on our review and interviews, we concluded that MHD’s documentation 

complete and it took sufficient steps to re-inspect B/PB’s work, thereby mitigatirelated to B/PB’s prior involvement in tunnel remediation work. 

B/PB 63 employees with multiple job titles related to technical and administrative 

After the July 2006 tunnel ceiling collapse, B/PB assisted the Commonwealth with technical support, electric support (electrical shutdown and identification of embedded conduits), procurement support, safety monitoring, mechanical engineering, and ceiling 

• Based on OIG discussions with Commonwealth transportation officials, we lear

removing the 7 inspectors, the Commonwealth also removed all 63 B/PB emploremediation related work on October 24, 2006. 

• The Commonwealth reported to us that it conducted its own inspections before 

any B/PB inspections before that date were not used by the Commonwealth for openings. MHD re-inspected all 193 B/PB inspections conducted after Septemb

• B/PB employees had performed administrative and technical support to assist M

The Commonwealth supplied OIG with a list of all B/PB workers based on hourpay periods ended July 16 through October 22, 2006, which we reviewed. 
EXHIBIT A: SUMMARY MATRIX OF ACTIONS REPORTED BY MASSACHUSETTS 

ACTIVITIES TO ADDRESS THEM (Cont.) 

Firm No. of Employees with Potential Independence Concerns Activity Performed Mitigation Actions Taken by the Commonwealth of Massachusetts support. condition inspections after the 

accident. • We interviewed 17 of the 63 B/PB employees to independently verify their role

• Based on our review, we concluded that the Commonwealth removed all B/PB s

remediation program as officials had stated, thereby mitigating questions about working on remediation activities. 

Keville Enterprises, Inc. 7 Inspectors 20 other employees 

Keville employees provided some tunnel remediation inspections and technical support to MHD. 

• Based on OIG discussions with Commonwealth transportation officials, we lear

Enterprises was a sub-consultant to B/PB prior to the July 10, 2006 accident. 

• The Commonwealth took the position that the Keville staff had no independenc

assigned inspectors did not have a prior role in the I-90 tunnel connector system

• We requested EOT to provide a listing of Keville staff assigned to tunnel remed• We contacted Keville officials directly to verify the names of listed staff. We 

information to confirm that Keville employees assigned to tunnel inspections diI-90 tunnel ceiling inspections. 

• We also interviewed of 5 of the 27 Keville staff to verify that they did not have 

inspection of I-90 tunnel panel installations. 

• On October 26, 2006, the Commonwealth removed Keville inspectors from the 

program to avoid any potential questions about the firm’s independence. 

HNTB Corporation (HNTB) 7 employees 

HNTB employees conducted tunnel remediation inspections and provided technical support to MHD. 

• Based on OIG discussions with Commonwealth officials, we learned that EOT h

that the HNTB staff was independent because the assigned inspectors did not hatunnel connector system. 

• We verified that Gannett Fleming used the panel design developed by HNTB fo

and Gannett Fleming revised parts of the panel design and independently designI-90. Thus, HNTB was not involved in the original I-90 work. 

• Based on our review, we concluded that HNTB does not have independence con
EXHIBIT A: SUMMARY MATRIX OF ACTIONS REPORTED BY MASSACHUSETTS 

ACTIVITIES TO ADDRESS THEM (Cont.) 

Firm No. of Employees with Potential Independence Concerns Activity Performed Mitigation Actions Taken by the Commonwealth of Massachusetts 

did not contract for any part of the original I-90 tunnel connector work. 
EXHIBIT B: OTHER INSPECTION CONTRACTORS’ INVOLVEMENT IN REMEDIATI

Firms Responsibilities Assessment1TranSystems Designing all remedial ceiling hanger 

connections, excluding I-90 Tunnel Connector Eastbound temporary shoring towers. 

Assertions on all three criteria support the firm’s independence. 

Transportation Engineering and Construction, Inc. (TEC) 

Designing temporary shoring in the I-90 Tunnel Connector Eastbound and temporary jet fan supports for Ramps A and F. 

Four TEC staff members were previously involved with the CArtery/Ted Williams Tunnel (CA/T) Project design for the Leverett Storrow Drive Connector. However, its staff was not involved wdesign of the I-90 Connector Tunnels. Assertions on all three criteria and above review of prior participatthe CA/T project support the firm’s independence. 

Chas. H. Sells, Inc. (Sells) Performing Level 1 inspections 

throughout the I-90 Connector Tunnels and the Ted Williams Tunnel.2

Sells performed some aerial mapping for work on the Boston Company in the early 1990s that included the CA/T Project. Also, onemployee had limited experience on the project related to loop rampof the Charles River, Fort Point Channel (exclusive of design of finishes), and in administrative duties. However, Sells staff w

involved with the design of the I-90 Connector Tunnels. 

Assertions on all three criteria and above review of prior participatthe CA/T project support the firm’s independence. 

Diversified Technology Consultants 

Performing Level 1 inspections throughout the I-90 Connector Tunnels.2

One DTC engineer performed minimal design support work on the project. He was involved with temporary excavation support criteria, inspection and repair design for wall leakage, and collectconstructed details for atypical tunnel finish and platform areas. Ho

the DTC engineer was not involved with the design of the I-90 Con
EXHIBIT B: OTHER INSPECTION CONTRACTORS’ INVOLVEMENT IN REMEDIATI

(Cont.) 

Firms Responsibilities Assessment1

Tunnels. Assertions on all three criteria and above review of prior participatthe CA/T project support the firm’s independence. 

Purcell Associates Performing Level 1 inspections 

throughout the I-90 Connector Tunnels and the Ted Williams Tunnel.2

Two engineers worked for section design consultants on other areas CA/T Project. The engineers worked on the bridges at Massachusettinterchange, pavement quantity calculations, and traffic manag

schemes. However, the Purcell engineers were not involved wdesign of the I-90 Connector Tunnels. 

Assertions on all three criteria and above review of prior participatthe CA/T Project support the firm’s independence. 

Note 1:

To ensure independence, the Commonwealth asked each of the above design and inspection firms to disclose in writing the following item of disclosure (assertion criteria): 1. Prior involvement (before July 10, 2006) with the design or construction of the Central Artery/Ted Williams Tunnel (CA/T) Projec2. Contractual agreements with Bechtel Corporation and Parsons, Brinckerhoff, Quade & Douglas, Inc.; and 

3. Individual employees involved in the remediation who were previously employed by Bechtel Corporation; Parsons, Brinckerhoff, 

Bechtel/Parsons Brinckerhoff subconsultant on the CA/T Project; or a Section Design Consultant on the CA/T Project. 

Note 2:A Level 1 inspection is a safety review of the entire tunnel covering all elements, including ceiling and hangers, suspended lights, signs

Control System (IPCS) equipment, as well as elements around the roadway. 
EXHIBIT C: OBJECTIVES, SCOPE, AND METHODOLOGY 13

We performed this performance audit from October 2006 through December 2006. 

It was conducted in accordance with Generally Accepted Government Auditing 

Standards as prescribed by the Comptroller General of the United States. The 

objective of this audit was to determine what actions the Commonwealth of 

Massachusetts took to identify and remove any contractors that lacked 

independence in performing CA/T Project inspection duties. We conducted audit 

procedures that were considered necessary to achieve this audit objective. In 

addition, we evaluated the Commonwealth’s efforts to mitigate any risks posed by 

prior remediation work performed by firms that may lack sufficient independence. 

Due to the specificity of the audit objective and the ongoing CA/T Project criminal 

and civil investigations by Federal and state agencies, we did not perform audit 

procedures designed to evaluate potential internal control deficiencies, fraudulent 

and illegal acts, and violations of contract provisions. 

In carrying out this audit we obtained relevant documentation from the 

Commonwealth, such as inspection reports. We also interviewed officials from 

EOT, MHD, and the CA/T Project. We evaluated the process EOT used to ensure 

the independence of contractors that have continued to work on the I-90 tunnel 

remediation design and inspection work since October 2006. 

In order to further evaluate the independence of the inspection firms we conducted 

interviews with B/PB and Keville Enterprise employees to determine their current 

and prior relationship with the CA/T Project. We also analyzed the written 

representations provided by other firms with regard to their independence. 

Additionally, we assessed the remedial actions the Commonwealth took to correct 

any non-compliant services provided by B/PB related to the planned phased 

openings in the I-90 tunnels. We identified the rework steps that the 

Commonwealth used on the tunnel brackets, and identified and assessed the 

corrective steps taken. 

The Commonwealth’s remediation work involved inspections of the installation of 

ceiling hanger brackets that were fastened (1) to the Unistrut or (2) with new Hilti 

anchors. In the case of the Unistrut system, one or more inspections with several 

installation steps (installing multiple spring nuts, attaching the base plate, and 

torquing the bolts) were recorded on a single inspection report form. In the case of 

installing the new Hilti anchor system, a separate inspection was performed for 

each step, which included each hole drilling, each bolt installation, each load test, 

and the attachment of a new base plate bracket. As a result, the Hilti 

system would involve 13 inspection reports for each installation. All of the 

Unistrut system installations inspected by B/PB were subjected to a re-inspection. 

However, per MHD’s re-inspection procedures of B/PB work, only the Hilti load 

test results and the base plate installation were subjected to a re-inspection. MHD 
14 

determined that if the existing Hilti system installations were disassembled, it 

would have required new Hilti anchors, nuts, and washers; and each anchor would 

have to be load tested once again. Further, the initial installation of these Hilti 

systems were put through load tests conducted by an independent testing firm. 

Successful load tests provide assurance that the mechanical anchors, which are 

embedded into the ceiling and are unique to the Hilti system, were fastened 

properly. Therefore, MHD determined that it would limit its re-inspection efforts 

to the external, non-imbedded components and/or verifying that the initial load test 

had been successfully performed by the independent testing firm. Based on its reinspection procedures, MHD identified 193 total instances that required a reinspection (138 Unistrut and 55 Hilti) 

We selected and analyed a sample of 30 B/PB inspections from the 193 

inspections that MHD identified as requiring remedial work and determined 

whether each had received corrective actions. 
EXHIBIT D: MAJOR CONTRIBUTORS TO THIS REPORT 15

THE FOLLOWING INDIVIDUALS CONTRIBUTED TO THIS REPORT.

Name Title 

Thomas Yatsco Program Director 

Peter F. Babachicos Project Manager 

John M. Hannon Senior Analyst 

William R. Lovett Senior Auditor 

Paul D. McBride Analyst