U.S. ENVIRONMENTAL PROTECTION AGENCY 

OFFICE OF INSPECTOR GENERAL 

Catalyst for Improving the Environment 

Site Inspection Report 

American Recovery and 

Reinvestment Act Site Inspection 

of Sewer Pump Station 

Rehabilitation and Improvements, 

Town of Ball, Louisiana 

 Report No. 11-R-0014 

 November 9, 2010 
Report Contributors: Richard Howard 

 Richard Valliere 

 Michael Rickey 

Cover photo: American Recovery and Reinvestment Act of 2009 project sign at the 

Paradise Road construction site, Town of Ball, Louisiana. (EPA OIG photo) 
 

 

U.S. Environmental Protection Agency 11-R-0014 

November 9, 2010 Office of Inspector General 

At a Glance 

Catalyst for Improving the Environment 

Why We Did This Review 

The U.S. Environmental 

Protection Agency’s Office of 

Inspector General conducts 

site visits of American 

Recovery and Reinvestment 

Act of 2009 (Recovery Act) 

clean water and drinking water 

projects. We selected a project 

in the Town of Ball, 

Louisiana, for review. 

Background 

The town received $1 million 

in Recovery Act funds from 

the Louisiana Department of 

Environmental Quality under 

the Clean Water State 

Revolving Fund program. The 

town will use these funds for 

sewer pump station 

rehabilitation and 

improvements. 

For further information, 

contact our Office of 

Congressional, Public Affairs 

and Management at 

(202) 566-2391. 

To view the full report, 

click on the following link: 

www.epa.gov/oig/reports/2011/ 

20101109-11-R-0014.pdf. 

American Recovery and Reinvestment Act 

Site Inspection of Sewer Pump Station Rehabilitation 

and Improvements, Town of Ball, Louisiana

 What We Found 

We conducted an unannounced site inspection of the sewer pump station 

rehabilitation and improvements project in the Town of Ball, Louisiana, in 

May 2010. We toured the project, interviewed town representatives and 

engineering and contractor personnel, and reviewed documentation related to 

Recovery Act requirements. At the time of our inspection, the construction 

contractor had suspended work while waiting for American made materials and 

parts. 

Based upon our site inspection, nothing came to our attention that would require 

action from the town, the State of Louisiana, or the U.S. Environmental Protection 

Agency. 
 

 

 

 

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

WASHINGTON, D.C. 20460 

THE INSPECTOR GENERAL 

November 9, 2010 

MEMORANDUM 

SUBJECT:	 American Recovery and Reinvestment Act 

Site Inspection of Sewer Pump Station 

Rehabilitation and Improvements, 

Town of Ball, Louisiana 

Report No. 11-R-0014 

FROM: Arthur A. Elkins, Jr. 

 Inspector General 

TO:	 Al Armendariz 

Regional Administrator, Region 6 

U.S. Environmental Protection Agency 

This is our report on the subject site visit conducted by the Office of Inspector General of the 

U.S. Environmental Protection Agency. The report summarizes the results of our site inspection 

of the town of Ball, Louisiana, sewer pump station rehabilitation and improvements project. 

We performed this site inspection as part of our responsibility under the American Recovery and 

Reinvestment Act of 2009. The purpose of our site inspection was to determine the town’s 

compliance with selected requirements of the Recovery Act pertaining to the Clean Water State 

Revolving Fund program. The Louisiana Department of Environmental Quality approved the 

town’s project. The town received a $1 million loan in Recovery Act funds. 

The estimated cost of this report—calculated by multiplying the project’s staff days by the 

applicable daily full cost billing rate in effect at the time—is $108,895. 

Action Required 

Because this report contains no recommendations, you are not required to respond to this report. 

The report will be made available at http://epa.gov/oig. If you or your staff have any questions 

regarding this report, please contact Robert Adachi at (415) 947-4537 or adachi.robert@epa.gov, 

or Michael Rickey at (239) 240-9161 or rickey.michael@epa.gov. 
 

 

Purpose 

The purpose of our unannounced site inspection was to determine the Town of Ball, Louisiana’s, 

compliance with selected requirements of the American Recovery and Reinvestment Act of 

2009, P.L. 111-5 pertaining to the Clean Water State Revolving Fund program. 

Background 

The town received a $1 million loan from the Louisiana Department of Environmental Quality 

under the Clean Water State Revolving Fund program for sewer pump rehabilitation and 

improvements. The state used Recovery Act funds to offset 100 percent of the town’s 

indebtedness through loan forgiveness. 

Scope and Methodology 

Due to the time-critical nature of Recovery Act requirements, we did not perform this site 

inspection in accordance with generally accepted government auditing standards. Specifically, 

we did not perform certain steps that would allow us to obtain information to assess the town’s 

internal controls and any previously reported audit concerns. As a result, we do not express an 

opinion on the adequacy of the town’s internal controls or compliance with all federal, state, or 

local requirements. 

We conducted an unannounced site inspection at the town during May 3-5, 2010. During our 

inspection, we: 

1.	 Toured the project 

2.	 Interviewed town, engineering, and contractor personnel 

3.	 Reviewed documentation maintained by the town, its engineer, and its contractor on 

the following matters: 

a.	 Buy American requirements under Section 1605 of the Recovery Act 

b.	 Davis-Bacon Act wage requirements under Section 1606 of the Recovery Act 

c.	 Contract procurement 

d.	 Use of funds and reporting requirements under Sections 1604 and 1512 of the 

Recovery Act 

Results of Site Inspection 

Based upon our site inspection, nothing came to our attention that would require action from the 

U.S. Environmental Protection Agency, the State of Louisiana, or the town. We have 

summarized our results below. 

11-R-0014 1 
 

Buy American Requirements 

We did not identify any issues of concern. The procedures in place, if followed, should 

assure the use of American made products, as required by Section 1605 of the Recovery 

Act. 

The town assigned all project management responsibilities to its engineering firm. The 

procedure to assure Buy American compliance required the construction contractor to 

provide “Submittal Identification Sheets” to the engineering firm for review and 

approval. The contractor certified on the “Submittal Identification Sheet” that the listed 

items intended for use on the project met the Buy American requirements and included 

the manufacturer’s certification that the materials were made in the United States. The 

engineering firm used a “Submittal Control Log” to notify the contractor of its 

determination. Items that were not adequately supported as meeting Buy American 

requirements were not accepted for use on the project until adequate documentation was 

provided. 

At the time of our visit, the contractor had installed some force main pipe. We were not 

able to inspect the installed pipe because the contractor filled in the trench with dirt. 

However, we reviewed the contractor’s and manufacturer’s certifications and concluded 

that the pipe met Buy American requirements. 

The contractor stopped work on March 15, 2010, to wait for a pump station assembly — 

a major piece of equipment being manufactured off site. On June 24, 2010, the town 

approved Change Order No. 2 to add 60 days to the construction period because of a 

delay attributed to the manufacturer’s requirement to meet Buy American provisions of 

the contract. The pump station is expected to be delivered in mid September 2010. 

According to the engineer, once the pump station is delivered, it will take approximately 

60 days of good weather to complete construction. 

Davis-Bacon Act 

We did not note any issues regarding Davis-Bacon Act wage requirements. The town’s 

engineering firm handled all project management responsibilities. To comply with DavisBacon requirements, the contractor signed weekly payrolls certifying compliance with 

Davis-Bacon Act wage rates and submitted them to the engineer for review and approval. 

We reviewed the certified payrolls and verified that the contractor was paying its 

employees wages that were higher than Davis-Bacon rates. 

The construction contractor did not have Form I-9 Employment Eligibility Verification 

Forms completed and on file for its employees, as required by federal law. The contractor 

was unaware of the form or the requirement to prepare them for each employee hired 

after November 6, 1986. The contractor’s vice president stated that the company was 

formed in 1988, and he would need to complete an I-9 Form for every employee. 

Subsequently, we confirmed that the contractor completed the I-9 Forms for its 

employees. No further action is necessary. 

11-R-0014 2 
 

 

Contract Procurement 

We did not identify any issues of concern. The town used the sealed bid method to select 

the lowest of three bidders. Because the lowest bid exceeded the engineer’s estimate and 

available Recovery Act funds, the award of the contract was contingent upon successfully 

negotiating a change order for a lower amount. The engineer reduced the scope of the 

project by removing tasks and the associated bid amounts. After state approval, the town 

awarded the contract and the deduct change order simultaneously. We reviewed the bids 

for all three contractors and concluded that the original low bidder was still the lowest 

bidder for the reduced project. Also, we contacted the two unsuccessful bidders and did 

not find any issues. 

The town hired its engineering firm without seeking competition. The town had used the 

engineering firm for other projects. The state, which was responsible for the Clean Water 

State Revolving Fund and the associated Recovery Act projects, reviewed and approved 

the engineering firm’s contract. Accordingly, we took no exception with the procurement 

of the engineering contract. 

Use of Funds and Reporting 

We did not identify any issues of concern. We reviewed the town’s loan documentation 

and visited the site to ensure that the town complied with Section 1604 of the act, which 

states that no Recovery Act funds can be used for any casino, other gambling 

establishment, aquarium, zoo, golf course, or swimming pool. 

We obtained copies of quarterly reports prepared by the town’s engineering firm and 

submitted to the state. Based on our review of the reports, the information met Recovery 

Act requirements. Therefore, we concluded that the town was in compliance with Section 

1512(c) of the Recovery Act. 

Recommendations 

We have no recommendations. 

Town’s Response and Office of Inspector General Comment 

Since there were no recommendations, we did not require or receive comments to the draft 

report. We held an exit conference on October 28, 2010. 

11-R-0014 3 
 

 

 

 

 

 

 

 

Status of Recommendations and 

Potential Monetary Benefits 

POTENTIAL MONETARY 

RECOMMENDATIONS BENEFITS (in $000s) 

Planned 

Rec. Page Completion Claimed Agreed To 

No. No. Subject Status1 Action Official Date Amount Amount 

No recommendations 

1 O = recommendation is open with agreed-to corrective actions pending 

C = recommendation is closed with all agreed-to actions completed 

U = recommendation is undecided with resolution efforts in progress 

11-R-0014 4 
 

Appendix A 

Distribution 

Office of the Administrator 

Regional Administrator, Region 6 

Director, Grants and Interagency Agreements Management Division, 

Office of Administration and Resources Management 

Agency Followup Official (the CFO) 

Agency Followup Coordinator 

General Counsel 

Associate Administrator for Congressional and Intergovernmental Relations 

Associate Administrator for External Affairs and Environmental Education 

Audit Followup Coordinator, Region 6 

Public Affairs Officer, Region 6 

Mayor, Ball, Louisiana 

Secretary, Louisiana Department of Environmental Quality 

11-R-0014 5