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12/30/1996 Audit AUDIT REPORT OF MONROE COUNTY ENVIRONMENTAL MANAGEMENT HAZARDOUS WASTE FUNCTION December 30, 1996 -GoUNTy&1 � ,�4t CD �M�c M vG, G Q } �•. OF COUHT1.?," Prepared by: Internal Audit Department Clerk of the Circuit Court Danny L. Kolhage, Clerk Monroe County, Florida 9 GOUNT).1•4 ;a 4J�'%,JAM cup`�OG94y aue� • • Oannp IL 1.oUjage BRANCH OFFICE CLERK OF THE CIRCUIT COURT BRANCH OFFICE 3117 OVERSEAS HIGHWAY MONROE COUNTY- 88820 OVERSEAS HIGHWAY MARATHON, FLORIDA 33050 500 WHITEHEAD STREET PLANTATION KEY, FLORIDA 33070 TEL. (305) 289-6027 KEY WEST, FLORIDA 33040 TEL. (305) 852-7145 TEL. (305) 292-3550 December 30, 1996 The Honorable Danny L. Kolhage Monroe County Clerk of the Circuit Court Re: Audit of Monroe County Environmental Management Hazardous Waste Function Dear Mr. Kolhage: The Clerk's Internal Audit Department has completed the audit of Environmental Management's Hazardous Waste Function. The purpose of the audit was to determine if the Hazardous Waste Function is operating in compliance with established county department policies and procedures and according to Federal and State rules and regulations. Our audit did not address the accuracy of information received at on-site verifications by inspectors since we do not have the expertise and training required of an SQG inspector. I would like to thank the Division Director of Environmental Management and the Hazardous Waste staff for their cooperation while conducting the audit. I would also like to thank the SQG Director of Lee County and Collier County and the State SQG Director for the information they provided. In addition, I thank my staff, Bert Gerez and Laura LeGrand, for their hard work. Our audit revealed that the Monroe County SQG program is not in compliance with Florida Statutes. .Although the state will not assess any penalties on the county, the department should. ensure that the program has County-Specific Standard Operating Procedures which would ensure that the program is efficiently run in compliance with Florida Statutes. Our audit found that verification forms are inconsistent and/or inaccurate and that there are inconsistencies between verification forms and the SQGDMS computer system. Verification forms document the SQG verification process and provide support for the Monroe County assessment roll. Our finding indicated that inspections are not completed on a timely basis, follow-up verifications when indicated are not performed, and there is a lack of support for facilities deleted from the assessment roll. Also, physical files are not maintained in an orderly manner and training of inspectors is lacking. Procedures should be established to ensure that inspections • are completed on a timely basis, follow-up verifications are performed when indicated, there is proper support for facilities deleted from the assessment roll, files are maintained in an orderly manner, the SQG Projector Coordinator has complete knowledge of the SQG program, and inspectors are properly trained.. Our audit revealed that no documents are submitted to support reimbursed meal vouchers and overtime worked, overtime is not pre-approved in writing, and work is not scheduled to eliminate unnecessary overtime and work performed on holidays. To be in accordance with county and department personnel policies and procedures, all overtime should be properly approved in advance, overtime should be kept to a minimum, and working holidays should be disallowed except in usual circumstances. Through our audit we discovered that the SQG Project Coordinator inappropriately requested and was reimbursed for meals. This fact should be investigated by appropriate county personnel and appropriate action should be taken. The County Administrator in his response stated beginning early in the 1997 calendar year the SQG Program will be reorganized. A copy of his response is found at the end of this audit report. The accompanying audit report is provided for your information. Additional copies of the report will be provided upon your request. Sincerely, Cade E. Bamberg, CPA Internal Audit Director cc: Board of County Commissioners (5) James Roberts, County Administrator Clark Lake, Division Director of Environmental Management Mike Lawn, Assistant Director of Environmental Management Ron Stack, SQG Project Coordinator Sandee Carlile, Clerk's Finance Director Marva Green, CPA, External Auditor Jim Hendrick, County Attorney • AUDIT REPORT OF MONROE COUNTY - ENVIRONMENTAL MANAGEMENT HAZARDOUS WASTE FUNCTION TABLE OF CONTENTS Page No.s I. Scope and Objectives 1 II. Methodology 1-2 III. Background 2-8 IV. Conclusions 9 V. Audit Findings: A. County SQG Program is Not in Compliance with the Florida Statutes 10-11 B. No County-Specific Standard Operating Procedures for the SQG Program 12 C. Incomplete, Inaccurate, and/or Inconsistent Verification Forms 13-15 D. Inconsistencies Between the Verification Forms and the SQGDMS Computer System 16-17 E. Incomplete Inspections 18 F. No Follow-Up Verifications Were Performed When Indicated 19 G. No Procedures to Document Facilities that are Deleted from the Assessment Roll 20-21 H. Missing, Misfiled and Incomplete SQG Files 22 I. Inadequate Training of SQG Inspectors 23-24 J. Overtime is Inconsistent with County Policies and No Support for Paid Overtime 25-26 K. Reimbursed Meal Expenditures 1. No Support for Reimbursed Meal Expenditures 27 2. SQG Project Coordinator Inappropriately Requested and was Reimbursed for Meals 28-30 i AUDIT REPORT OF MONROE COUNTY - ENVIRONMENTAL MANAGEMENT HAZARDOUS WASTE FUNCTION TABLE OF CONTENTS Page No.s VI. Exhibits: A. Profile of the SQG Assessment Roll A1-3 B. Monroe County - Hazardous Waste Management Assessment Survey/Verification Form B1-2 C. Lee County - Small Quantity Generators Program On-site Assessment Verification Form C1-2 D. Collier County - Small Quantity Generators On-site Inspection Form D1-2 E. Monroe County - Time Extension Request for the SQG Program (Memo to the State SQG Director) El VII. Auditee Responses: A. County Administrator CA1 ii AUDIT REPORT OF MONROE COUNTY - ENVIRONMENTAL MANAGEMENT'S HAZARDOUS WASTE FUNCTION I. Scope and Objectives: A. At the request of the Monroe County Clerk of the Circuit Court and the County Administrator, the Internal Audit Department conducted an audit of the Environmental Management's Hazardous Waste Function. The Audit Period was be October 1, 1994 through May 31, 1996. B. The purpose of this audit was to determine if Environmental Management's Hazardous Waste Function operates in compliance with established county and departmental policies and procedures, and according to Federal and State rules and regulations. C. Our audit did not address the accuracy of information received at on-site verifications by inspectors. Our audit was limited in this area because we do not have the expertise and training required of an SQG inspector. II. Methodology: A. The Internal Audit Department examined the following documents: 1. Florida Statutes related to Hazardous Material Departments. 2. Monroe County Operations and Training Manual for the Hazardous Material Department. 3. Monroe County Personnel Policies and Procedures Manual 4. Florida Department of Environmental Protection (DEP) agreement for funding of unique and innovative project activities. (i.e., State grant for the Household Hazardous Waste mobile unit.) B. The following county personnel were interviewed to obtain information about operations of the Monroe County Environmental Management's Hazardous Waste Function: 1. Division Director of Environmental Management 2. Assistant Director of Environmental Management 3. Environmental Specialist/Inspector II (County SQG Project Coordinator) 4. Environmental Technician/Inspector 5. Environmental Specialist I 6. Staff Assistant 1 C. We also interviewed the Environmental Specialist III (State SQG Director). This individual is employed by the State Department of Environmental Protection and is responsible for the state-wide SQG program. D. We interviewed the County SQG Coordinators from Lee and Collier Counties. E. We reviewed the assessment roll, and compared the list of facilities entered into the SQGDMS computer system (assessment roll) to the physical files of all facilities during the audit period (hereafter called, the "facilities files"). F. Using a random sample of facilities in the assessment roll, we compared information entered into the SQGDMS computer system to the information on the verification forms in the corresponding facility files. We also questioned inspectors concerning the information in the SQGDMS computer system and verification forms in facilities files for this random sample. III. Background: A. Terms Used in This Report SQG (Small Quantity Generator) - any facility that generates or may generate less than 1,000 kg (2,200 lbs) of hazardous waste materials in a month. Large Quantity Generator - any facility that generates more than 1,000 kg (2,200 lbs) of hazardous waste a month. R-SQG (Regular - Small Quantity Generator) - any facility that generates between 100 kg (220 lbs) to 1,000 kg (2,200 lbs) of hazardous waste in a month. CESQG (Conditionally Exempt Small Quantity Generator) - any facility that generates less than 100 kg (220 lbs) of hazardous waste in a month. Potential SQG - a facility identified as a potential generator of hazardous waste but which has not been verified. SQGDMS (Small Quantity Generator Database Management System) - computer system developed by the State DEP that maintains the assessment roll. Assessment Roll - county list of SQG facilities. 2 SQG Facility Status Codes: P Potential - a facility that may generate hazardous waste, verification has not been performed. A Active - a facility that generates hazardous waste. I Inactive - a facility that formerly generated hazardous waste but does not do so now. N Non-generator - a facility that is known not to generate hazardous waste. SQG Verification Type Codes: ✓ An on-site verification was performed. P Phone call follow-up was the primary source of information. S Data in the SQGDMS computer system is based on survey data received; there was no on-site verification. L Facility information came from the Department of Labor; no on-site verification was performed. (These were identified as potential SQGs.) C Facility information came from a county source, such as occupational licenses and building permits; no on-site verification was performed. (These were identified as potential SQGs.) E Facility information came from the state EPA/DER notification files; no on-site verification was performed. (These were identified as potential SQGs.) SQG Follow-Up Codes: N No follow-up is needed. V The facility needs a follow-up inspection because a violation or some other problem was discovered during the on-site verification. (i.e., has questionable disposal practices.) R There has been no response to the survey. S The facility has not been surveyed. B. Organization of the Hazardous Waste Function: The Hazardous Waste Function is responsible for operating two (2) programs in accordance with the State Department of Environmental Protection (DEP) and the Florida Statutes. The programs and related Florida Statutes are listed below: (1) Small Quantity Generator (SQG) program rules and regulations are provided under Florida Statutes §403.7234 - 403.7225 (16) Notification, Assessment and Verification of Hazardous Waste Generators. (2) Household Hazardous Waste (HHW) program rules and regulations are provided under Florida Statute §403.7265 and Rule Chapter 17-735 Florida Administrative Code. 3 Four individuals are employed to administer and operate both programs. Their job titles and job descriptions are provided below: Environmental Specialist II / SQG Project Coordinator Designated County Project Coordinator of the SQG program and designated County Project Manager for the HHW program. Responsibilities for the SQG program include communicating information about the County SQG program to the state DEP; supervising and assisting in the inspection and training of small businesses on appropriate regulatory rules and regulations concerning hazardous materials; maintaining current and accurate records of inspectors; converting information to the "Small Quantity Generator Database Management System" (SQGDMS) and reporting the information to the state DEP; and educating the public and private sectors on alternatives for hazardous waste reduction and/or elimination. Responsibilities for the HHW program include managing two (2) temporary hazardous waste storage facilities as required by regulatory agency rules and regulations and maintaining accurate records; preparing Requests for Proposal's (RFP's) for hazardous waste removal by licensed transporters according to requirements of environmental agencies and Monroe County; and supervising all contract transporters in the identification, segregation, packaging, and removal of all hazardous materials from the county. Environmental Specialist I Responsibilities for the SQG program include assisting in the inspection and training of small businesses regarding the appropriate regulatory rules and regulations concerning hazardous material; educating the public and private sectors on alternatives for hazardous waste reduction and/or elimination; performing on-site inspections of businesses that generate small quantities of hazardous waste; and verifying assessments and accurately preparing information for conversion to the SQGDMS computer system. Responsibilities for the HW program include operating two (2) temporary hazardous waste storage facilities as required by regulatory rules and regulation and maintaining accurate records; and assisting contract transporters in the identification, segregation, packaging and removal of all hazardous materials from Monroe County. Environmental Technician / Inspector Responsibilities include assisting the Environmental Specialist in conducting field inspections as directed by the SQG program; analyzing field inspection reports and converting information into DEP format; entering data into the SQGDMS computer system and maintaining the computer system; and interpreting rules, regulations and policies established by the Environmental Regulatory and Enforcement Agencies for the public and other government agencies. 4 Staff Assistant Responsibilities include entering data into the SQGDMS computer system, and providing administrative staff support and other clerical functions for the Hazardous Waste Function. C. Small Quantity Generators (SQG) Program SQG Program Authority Florida Statutes §403.7234 and §403.7225 provides the rules and regulations for the Small Quantity Generator (SQG) program. According to these statutes the purpose of the SQG program is to identify and notify facilities that may generate or generates less than 1,000 kg (2,200 lbs) of hazardous waste a month. The two major goals of the assessment, notification and verification program are: 1. to inform SQGs of their legal responsibility in proper management of hazardous waste materials; and 2. to update the list of facilities identified as SQGs. This list is known as the "assessment roll." Enforcement is not the focus of the program. It is the responsibility of the Department of Environmental Protection (DEP) to enforce proper disposal practices. Counties are required to inform the DEP of facilities that fail to cooperate in the program and/or continue questionable disposal practices. Five Year Cycle The program operates on a five (5) year cycle. Each year a minimum of 20% of the SQGs on the assessment roll will be notified, surveyed and verified; thus, within the five (5) year cycle all facilities on the assessment roll should be verified. Also, during the cycle, facilities not on the assessment roll and identified as potential SQGs will also be notified, surveyed and verified, and if applicable, added to the assessment roll. Potential SQGs are to be identified through a search of "occupational licenses, building permits, and not less than one complete survey of the business pages of the county local telephone system" (FS §403.7225 (11)). Monroe County's first five (5) year cycle ended December 31, 1995. According to FS §403.7236 the county shall submit to the Department of Environmental Regulation the following information: "(1) A summary of the information gathered during its local hazardous waste management assessment; (2) Information gathered from each small quantity generator not notified previously; and (3) Onsite information gathered from each existing small quantity generator verification. " The Department of Environmental Regulations requests that surveyed information be submitted on a diskette due to the volume of paper work involved with the SQG program. 5 SOG Verification Procedures The Florida Department of Environmental Regulations provided each county with a manual titled, "Small Quantity Generators of Hazardous Waste: Assessment, Notification, Verification Program, 1992". This manual provides guidelines for the county program. On-site verification should be made of all facilities that generate or may generate small quantities of hazardous waste, i.e., Regular SQG (R-SQG), Conditionally Exempt SQG, and Potential SQG. Inappropriate facilities such as stockbrokers and real estate agencies are exempted from the verification process. For potential SQGs, a survey can be mailed before the on-site verification. Then during the on-site verification, the inspector verifies the information provided in the survey. If the survey is not returned or not mailed ahead of time, the inspector completes the survey while performing the on-site verification. For R-SQGs and CESQGs, only one on-site verification is required every five (5) years unless an inspector determines that a follow-up inspection is warranted for questionable disposal practices. The information obtained from the on-site verification is entered into the SQGDMS computer system (assessment roll). The assessment roll houses all current verification information of R-SQGs, CESQGS and some non-generators. Non-generators that use up, recycle or reclaim their hazardous waste materials should not be deleted from the assessment roll. Facilities that have SIC codes listed in the manual should also not be deleted from the assessment roll. See Exhibit A for a profile of Monroe County's "Assessment Roll" and Exhibit B for a copy of the verification form used by Monroe County. D. Household Hazardous Waste (HHW) Program The purpose of the Household Hazardous Waste (HHW) program is to provide private residences and small businesses a collection site for proper disposal of small quantities of hazardous waste materials. A $100,000 grant was used to build the two (2) holding stations located in Cudjoe Key and Long Key. Residences and small businesses can drop off their hazardous waste to a holding station on designated days. Drop off days for Cudjoe Key are the first and third Wednesday of each month and for Long Key it is the first and third Friday of each month. The second Wednesday of each month the program offers a pick up in Key Largo. Other drop offs are allowed if prearranged and/or if the Environmental Specialist is at the holding station. Elderly and handicapped individuals can request the department to pick up their materials. The department is currently in the process of converting a used ambulance to a mobile unit that will be used to increase the number of locations for pickup service of household hazardous waste in Monroe County. The cost of the project is estimated at $96,000. 6 The department requested and was approved by the Department of Environmental Protection for a grant of $48,000. E. Small Quantity Generators (SQG) Program in Other Counties Lee County Lee County operates their SQG program through their Natural Resources Management Division. The department employees 3.5 individuals to operate the program (Director, two (2) Inspectors and part-time data entry person). The county has between 12,000 and 14,000 facilities on their assessment roll. All are inspected at least once during the five (5) year assessment period. Only facilities with questionable hazardous waste disposal practices are inspected more than once. Facilities are charged an annual fee of$20. This fee is collected when businesses renew or purchase their occupational licenses. The County Department of Revenue keeps 20% to cover the cost of collection. The remaining 80% is used to fund the program. Facilities may be exempt from the fee by going to the Hazardous Waste Department and completing a questionnaire and verbally answering questions about their business. This information documents the fact that the facility does not now, and because of the nature of their business, should never generate hazardous waste. An exemption is granted for the life of the business. Facilities such as law firms and real estate offices receive such an exemption. Each inspector is assigned an area, within Lee County, based on zip codes. This enables each inspector to become fluent in their area. While conducting the on-site verification, the inspector completes a two-page verification form titled "Small Quantity Generators Program On-Site Assessment/Verification Form". This form provides the following information: general information about the facility, site information, types and amounts of waste generated, haulers of the facility's hazardous waste, and miscellaneous information. (See Exhibit C for a copy of this form.) Upon completion of the inspection, this form is dated and signed by the inspector and the facility's representative. A copy of the form is given to the facility representative before the inspector leaves. The Director reviews all verification forms for completeness, and then gives them to the data entry person. The Director randomly selects verification forms and calls the facility representative to verify that the inspection did actually occur and to ensure that the facility representative understands the program. Most professional facilities such as medical and dental offices are contacted before the inspection to arrange a convenient time. Unannounced inspections are performed for most other facilities. But it is at the discretion of the inspector whether the inspection will be prearranged or unannounced. If the inspector arrives and the facility does not want to be inspected, the inspector will either arrange another time then or call later to schedule the inspection. If after repeated attempts a facility does not allow the county to perform an inspection, the State Department of Environmental Protection is notified and they then pursue the necessary actions. The department does not have formal procedures for facilities that require a follow-up inspection. It is the inspector's responsibility to ensure that timely follow-up verifications are performed on facilities identified as having questionable practices. Collier County Collier County's SQG program is patterned after Lee County. This department employs a Director, four (4) inspectors, and a part-time data entry person. The county has approximately 8,000 facilities on their assessment roll. Facilities do not directly pay for the program. The program is funded through ad valorem taxes. On-site verifications are performed in the same manner as Lee County. Each inspector is assigned an area, within Collier County, based on zip codes. A two-page verification form is completed and signed by both the inspector and facility representative at the end of the inspection. The Director reviews all verification forms for completeness and randomly calls facility representatives to confiiiii inspections. (See Exhibit D for a copy of Collier County's verification form.) Collier County never has facilities complete a written survey before the on-site verification. All generators and potential generators are inspected at least once during the five (5) year cycle. Most potential generators are identified through county occupational licenses and building permits. Inspectors also perform a "sweep" of areas. A "sweep" is where the inspector performs brief, on-site verifications of all businesses in a specific area. The purpose of the "sweep" is to identify previously missed potential generators and perform on-site verifications when necessary. 8 IV. Conclusions: A. The Monroe County SQG program is not in compliance with the Florida Statutes. Although the state will not assess any penalties on the county, henceforth, the department should make an effort to ensure that the program is run in accordance with Florida Statutes. To efficiently run the SQG program, the department should develop County-Specific Standard Operating Procedures. B. Verification forms used for data entry into the SQGDMS computer system are inconsistent, inaccurate and/or incomplete. Also, there are inconsistencies between information on the verification forms and in the SQGDMS computer system. Verification forms document the SQG verification process and provide support for the Monroe County SQG assessment roll. If verification forms are incomplete, inaccurate and/or inconsistent, then the assessment roll too will be incomplete, inaccurate and/or inconsistent. C. Procedures should be established to ensure that inspections are completed on a timely basis; that follow-up verifications, where indicated are performed and on a timely basis; and that facilities deleted from the SQGDMS computer system are appropriate. D. Physical files are not maintained in an organized manner. These files provide back up for the information in the SQGDMS computer system and provide a history for each facility on the assessment roll. Therefore, procedures should be established to ensure that there is only ONE file for each facility and files are arranged in an organized manner. E. Training of inspectors is lacking. Proper training begins with the SQG Projector Coordinator who should have a complete knowledge of the SQG program. Also, an appropriate person should ensure that all inspectors have a total understanding of the verification process and required information obtained at facility on-site verification. F. No documents are submitted with reimbursed meal vouchers to support the request. Calendars and route sheets are prepared by the department to support the work performed. These documents should be submitted with the reimbursed meal vouchers to support reimbursement requests. G. Overtime is inconsistent with County policies, they are not pre-approved in writing, no documents are submitted with time sheets to support the overtime, and work is not scheduled to eliminate unnecessary overtime and work performed on holidays. To follow county and department personnel policies and procedures, all overtime should be properly approved in advance, overtime should be kept to a minimum, and working holidays should be disallowed except in unusual circumstances. 9 V. Audit Findings: A. County SQG Program is Not in Compliance with the Florida Statutes: Finding(s): The County SQG program is not in compliance with the Florida Statutes. Within the five (5) year cycle the Florida Statutes require each county SQG program to: 1. verify 100% of the assessment roll, and 2. update the assessment roll. The cycle for Monroe County ended December 31, 1995. An analysis of the assessment roll and discussions with the SQG Project Coordinator reveal that both verifications and updates for the county are incomplete. 1. Verify 100% of the Assessment Roll: Florida Statute §403.7234(4) states: "Annually, each county shall verify the management practice of at least 20 percent of its small quantity generators. " An analysis of the assessment roll in the SQGDMS computer system reveals that only 69.6% (691 of 1,007) of the assessment roll was verified during the five (5) year cycle. In the first three (3) years, less than 5% of the assessment roll was verified. In year four (4), 37.4% were verified and in year five (5), 26.3% were verified. During the extension period, less than 1% have been verified. As of June 26, 1996, 6.3% of the assessment roll had incomplete inspections and 24.5% had not been verified. (See Exhibit A-3 for a profile of the assessment roll by year verified.) Per the SQG Project Coordinator, those businesses not verified were identified by the Department of Labor as potential generators and the Inspectors determined that most of these are either non- generators, out of business, or operate outside the county. However, there is no documentation to support this statement. 2. Update the Assessment Roll: Florida Statute §403.7225(11) states: "The assessment rolls shall be brought up to date annually before the end of the 5-year interval by including the applicable names from department sources, occupational licenses, building permits, and from not less than one complete survey of the business pages of the county local telephone systems. The roll shall be updated continuously thereafter in the same manner. " The SQG Project Coordinator stated that, for this first five-year cycle, the department did not search for potential generators through county occupational licenses or building permits. The department sporadically searched the county yellow pages. Per the SQG Project Coordinator, most of these potential generators were non-generators. However, the department's notes are disorganized, incomplete and do not substantiate their work. In January and February of 1996 the department staff identified 600 to 800 new potential SQGs using a list of county occupational licenses. The county occupational licenses list used for the identification of potential SQGs is outdated (May 24, 1995 list). These efforts are for the next five (5) year cycle which began January 1, 1996. 10 The SQG Project Coordinator requested, from the state, a six-month extension to complete the county's five-year cycle. This extension ended June 30, 1996. The auditors requested but have not received a copy of this extension. The State SQG Director stated that the department can request, in writing, an additional extension which will expire on November 15, 1996. The SQG Project Coordinator requested this second extension on August 19, 1996. (See Exhibit E for a copy of this second extension request.) Since the department did not complete the required work, the department is in violation of the Florida Statutes. To comply with the Florida Statutes the department is required, by November 15, 1996: 1. to complete the assessment roll verifications which requires performing and completing inspections of 316 facilities (i.e., 30.4% of the assessment roll), and 2. to update the assessment roll for potential generators in accordance with Florida Statute §403.7225(11). The SQG Project Coordinator assured the auditors that this will be accomplished. However, with three months remaining the auditors question its feasibility. The State SQG Director said that no penalties will be assessed to the county since this program, state-wide, is in the start-up stages. However, he also stated that henceforth, the department should make an effort to ensure that the program is run in accordance with Florida Statutes. Recommendation(s): 1. The Division Director of Environment Management should have appropriate personnel establish Standard Operating Procedures (SOPs) that ensure the department conducts the program in accordance with the Florida Statutes with approval by the Division Director. 2. The Division Director of Environmental Management should require that appropriate personnel review the department's work on a periodic basis (monthly or quarterly) to ensure that the program is operating efficiently and according to the Florida Statutes. Auditee's Response(s): See Section VII, Auditee Responses. 11 B. No County-Specific Standard Operating Procedures for the SQG Program: Finding(s): Interviews with the SQG Project Coordinator, SQG inspectors, and a review of the SQG manual reveal that there are no specific "County" Standard Operation Procedures (SOPs) for the SQG program. The manual provided by the Florida Department of Environmental Regulations provides legal requirements, goals of the program, a sample notification letter, and general procedures for the SQG program. The State SQG Director stated that the individual counties are responsible for the specific administration of the program. The state department provides seminars for the counties to explain the program and provide an opportunity for counties to share ideas. Monroe County SQG inspectors have attended these seminars. Established county SOPs for conducting SQG on-site verifications would provide a standard for evaluating the accuracy and completeness of all inspections. The SOPs should include: set procedures for conducting on-site verifications; type of advance notice provided to facilities, if any; signatures required on the verification form (other counties require the facility representative to sign the verification form and be given a copy); a review process by which an individual at a level above the inspectors reviews all inspection reports for completeness and accuracy; procedures for handling unusual situations (i.e., what to do when a facility does not cooperate); follow-up procedures for facilities with questionable practices; and periodic review of department work for compliance with Florida Statutes. Recommendation(s): 1. The Division Director of Environment Management should have appropriate personnel establish SOPs for the SQG program with approval by the Division Director These procedures should address the issues listed above and elsewhere in this report. Auditee's Response(s): See Section VII, Auditee Responses. 12 C. Incomplete, Inaccurate, and/or Inconsistent Verification Forms: Finding(s): Our audit revealed that most verification forms are incomplete, inaccurate and/or inconsistent. The following are some examples: Discussions with SQG inspectors reveal that they consider a "ride by" an on-site verification of potential SQGs. A "ride by" is where the inspector determines from looking at the outside of the facility that it is not an SQG. The State SQG Director stated that this is inappropriate. The nature of the business determines if a facility is a "potential" SQG. All "potential" SQGs should then be verified by an on-site inspection. Discussions with SQG inspectors reveal that sometimes, if the facility is busy or if the facility does not want to be bothered, the inspector will leave the verification survey form with the facility representative. The inspector instructs the facility representative to complete the survey and return it to the county department. Without further inspection the inspectors will consider the returned survey an on-site verification. The State's manual states that surveyed information is to be verified with an on-site inspection. A review of completed verification forms reveals that several verification forms contain more than one date. The inspectors were unable to say with certainty which date represents the day of the on-site verification. Information entered into the SQGDMS computer system includes the date of the on-site verification. This date is used to determine if the county has verified 20% of the assessment roll in a given year. A review of the completed verification forms reveals that "Status" is left blank on most forms. Codes for "Status" are P (potential), A (active), I (inactive) and N (non- generator). Facilities on the assessment roll, that have not been inspected, are coded with a "P" which indicates that the facility is a potential generator. If the inspector does not provide the information on the verification form, the data entry person will not change the "P" to the appropriate status: active, inactive, or non-generator. The state ignores all facilities with the status of "P" because they assume no inspection has occurred. A review of completed verification forms reveals that when the "Status"of the facility is indicated, the inspectors inconsistently and inaccurately use the terms potential, inactive and non-generator. For example, inspected facilities found not to generate any hazardous waste were incorrectly coded as potential generators rather than inactive generator or non-generator. One reason for this inconsistency is that the inspectors stated that they do not know the difference between a potential, inactive and non-generator. The State SQG Director stated that these codes have been explained at the seminars and they are defined in the SQGDMS manual; therefore, county inspectors should know their meaning. 13 A review of completed verification forms reveals that "Generator Status" is left blank on most forms. The codes for this second status type are N (non-generator), C (CESQG), R (R-SQG) or L (large generator). If the generator status field is blank, the SQGDMS computer system can determine and enter the appropriate response based on the types and quantities of hazardous waste (i.e., waste records) entered into the system. This code can and has at times been overridden by the data entry person. The state uses this information to profile the county and compare it to other counties. The state also informs appropriate state personnel of facilities listed as large generators which are required to be inspected by the state. Therefore, to ensure accuracy of generator status information in the SQGDMS, the inspectors should enter this code on every verification form so that the data entry person does not have to use his/her judgement in determining the appropriate code. In the past the data entry person has not always been the person who performed the verification and the current data entry person is not a trained inspector. One inspector stated that he only completes the front of the verification form. The back of the form requires the inspector to list waste records for the facility. The sum of these waste records determines the "Generator Status". Facilities with questionable disposal practices should also be noted on the back of the form to identify facilities requiring a follow-up inspection by the county. This information is also entered into the SQGDMS computer system and is used by the state to profile the county. A review of completed verification forms reveals that "Follow-Up" is left blank on most forms. This code indicates the need for a follow-up inspection. Follow-up inspections should be indicated when the inspector fmds questionable disposal practices. Discussions with the inspectors reveal that the inspectors do not know the follow-up codes. The State SQG Director stated that these codes have been explained in seminars and are defined in the SQGDMS manual; therefore, inspectors should know their meaning. Our audit sample of 32 active generators reveals that 31 verification forms stated that the inspection was by on-site verification when, as confirmed by discussions with the inspectors, in fact seven (22.6%) were verified by phone or survey and not on-site. The program manual states that facilities that generate hazardous waste should be inspected by on-site verification. A review of completed verification forms reveals that some forms did not contain the initials of the inspector. All forms should be signed by the inspector. The initials of the inspector are entered into the SQGDMS computer system. Discussions with SQG inspectors reveal that when a verification form is incomplete, the data entry person has to ask the inspector for a clarification and/or determine the proper codes based on the inspector's written comments. The current data entry person is not a trained inspector and should not be determining codes based on inspectors' written comments. 14 Discussions with the SQG Project Coordinator reveal that there is no review of completed verification forms, for quality assurance, before information is entered into the SQGDMS computer system. The verification form is used to determine data entry into the SQGDMS computer system. The SQGDMS computer system is used to track the assessment roll. Inspectors should know all the codes and apply them accurately and consistently to all inspections. In addition, verification forms should be reviewed by an individual at a level above the inspector for completeness, accuracy, and consistency before the form is given to the data entry person. If the verification form is incomplete, inaccurate and/or inconsistent, then the assessment roll too will be incomplete, inaccurate and/or inconsistent. Because of the scope limitation of our audit, we were not able to determine if the information on the verification forms was correct. Based on the many inconsistences observed, we question the accuracy of the information. Recommendation(s): 1. The Division Director of Environment Management should have appropriate personnel establish SOPs that ensure complete, accurate, and consistent verification forms. The procedures should address the above concerns. 2. For quality assurance, the Division Director of Environmental Management should require an appropriate personnel to review inspection reports for completeness, accuracy and consistency before the information is given to the data entry person. Auditee's Response(s): See Section VII, Auditee Responses. 15 i- : D. Inconsistencies Between the Verification Forms and the SQGDMS Computer System: Finding(s): Our audit revealed a number of inconsistencies between the information provided on the verification forms and the information entered into the SQGDMS computer system. The following are some examples: A review of completed verification forms reveals that most verification forms are incomplete (see Finding B Incomplete, Inaccurate, and/or Inconsistent Verification Forms). Our audit sample of 32 active generators and 27 potential generators revealed one (3%) active and 21 (78%) potential generators with no waste records. However, these facilities were considered CESQG. Facilities with no waste records should be considered non-generators. In most cases the verification form did not state if it was a non- generator or a CESQG. Our audit sample of 32 active generators revealed one (3%) facility with waste records on the verification form but none entered into the SQGDMS 'computer system; and seven (22%) facilities had waste records entered into the computer but no waste records were listed on the verification form. In an additional 12 (38%) cases, some aspect of the waste record(s) did not correspond between the computer and the verification form. This accounts for a total of 63% inaccuracy (i.e., computer versus verification form information) for facilities considered active generators. Information entered into the SQGDMS computer system should be backed up with information on a verification form and all information on the verification form should be accurately entered into the SQGDMS computer system. Our audit sample of 27 potential generators revealed three (11%) facilities with waste records on the verification form but none were entered into the computer; and one (4%) facility had waste records entered into the computer but none listed on the verification form. This accounts for a total of 15% inaccuracy for facilities considered potential generators. If a facility has one or more waste records, they are considered an active generator. Therefore, these four (4) facilities may be active and not potential generators. In addition, information entered into the SQGDMS computer system should be backed up with information on a verification form and all information on the verification form should be accurately entered into the SQGDMS computer system. A comparison of completed verification forms and data entered into the SQGDMS computer system reveals two (2) facilities with comments on their verification forms stating the facilities are large generators; however, in the SQGDMS computer system one was coded as an R-SQG and the other as a CESQG. The DEP relies, in part, on the information in the SQGDMS computer system to identify facilities that are large generators of hazardous waste and, thus, require a follow-up inspection by the state. 16 Because of this inconsistency, the DEP may not be aware of a facility identified as a large generator. Our audit sample of 59 active and potential generators, revealed that for nine (15%) the inspection dates entered into the computer system represent the date the survey was received or the date the information was entered into the system and not the date of the on-site verification. The date entered should represent the date of the on-site verification. This date is used to determine if the county has verified 20% of the assessment roll in a given year. A review of all facility files in the file cabinet reveals 27 facilities where an inspection has been completed; but, the facility is not on the assessment roll. All facilities inspected and which meet the criteria of a reportable SQG should be included on the assessment roll. Also observed were several instances in which questionable disposal practices were noted in the computer but this was not noted on the verification form. The verification forms document the accuracy of information in the SQGDMS computer system which generates the assessment roll. Inspectors should ensure that verification forms are complete and accurate prior to data entry. A review of each verification form for accuracy, consistency and completeness of information should be conducted and documented by someone above the inspector level prior to computer data entry. Recommendation(s): 1. The Division Director of Environment Management should have appropriate personnel established SOPs that ensure information entered into the SQGDMS computer system is accurate and complete. 2. The Division Director of Environmental Management should require that appropriate personnel review inspection reports for completeness before the information is entered into the SQGDMS computer system. 3. The Division Director of Environmental Management or his designee should review the information entered into the SQGDMS on a periodic basis to ensure the information is complete and accurate Auditee's Response(s): See Section VII, Auditee Responses. 17 E. Incomplete Inspections: Finding(s): A review of 42 verification forms in a "pending file" and 41 verification forms in a "hold file" reveals that not all inspections are completed in a timely manner. These two files were located at the Cudjoe Key Waste Station. All of these inspections were started in 1994 and to date have not been completed. The reason these inspections were not completed is unclear. A review of the verification forms reveals a lack of written documentation to explain problems encountered with the inspections. For most of the verification forms, inspectors did not clearly state why the inspections were not completed. Procedures should be established which ensure that inspections are completed on a timely basis. All communications concerning problems with on-site verifications should be documented and resolved in a timely manner. Also, all files should be maintained in the Hazardous Waste office located on Stock Island. Recommendation(s): 1. The Division Director of Environment Management should have appropriate personnel establish SOPs that ensure all inspections are completed on a timely basis with approval by the Division Director. 2. The department should have procedures that ensure files are not lost or misplaced. 3. An appropriate personnel should periodically review the "pending file" and "hold file" to ensure that all inspections are completed on a timely basis. Auditee's Response(s): See Section VII, Auditee Responses. 18 F. No Follow-Up Verifications Were Performed When Indicated: Finding(s): Our audit sample of active and potential generators revealed seven (7) of 59 verification forms noted that a follow-up verification was warranted. In all seven (7) instances, no follow-up was performed during the audit period. The purpose of the SQG program is to inform SQGs of their legal responsibility in proper management of hazardous waste. The state is then responsible for enforcement. However, if through the on-site verification it is determined that the facility's disposal practices are not proper, a follow-up verification should be performed by the county. The purpose of the follow-up verification is to decide if the facility has established and implemented proper disposal practices. If the follow-up verification reveals that the facility continues their questionable practices, the county is obligated to inform the state. The state then enforces compliance on the facility. The SQG Projector Coordinator stated that there are no procedures to ensure that follow-up inspections are performed. Procedures should be established which ensure that when a follow-up is indicated or where there are questionable practices, a follow-up inspection is performed in a timely manner. Recommendation(s): 1. The Division Director of Environment Management should have appropriate personnel establish SOPs that ensure that required follow-up inspections are performed on a timely basis with approval by the Division Director. 2. The Division Director of Environmental Management should require appropriate personnel to periodically review verification forms that indicate a follow-up inspection is warranted, and confirm that a follow-up verification has been performed in a timely manner. Auditee's Response(s): See Section VII, Auditee Responses. 19 G. No Procedures to Document Facilities that are Deleted from the Assessment Roll: Finding(s): A review of completed verification forms and a review of the lists of facilities to be deleted from the assessment roll reveals a lack of support for facilities deleted from the assessment roll. The list of facilities to be deleted includes pest control services, cleaning services, various types of construction businesses, medical offices, photo services, and marinas. The reason why the facility is to be deleted is non-existent, incomplete or unsubstantiated on the verification form. Also there are no review procedures to support the deletion of a facility from the assessment roll. The purpose of the SQG program is to notify facilities of their legal responsibilities for proper disposal of hazardous waste and to verify their practices. Facilities on the assessment roll will be notified and verified once every five (5) years. Those facilities not on the assessment roll will not be notified and verified unless the facility is first identified as a potential SQG. The definition of an SQG is a facility that generates or may generate small amounts of hazardous waste. The SQG program manual states that facilities that do not currently generate hazardous waste, or that use up, recycle or reclaim their hazardous waste materials should not be deleted from the assessment roll. Discussions with the State SQG Director reveal that it is the nature of the business that determines if a facility should be included on the assessment roll. Monroe County facilities are deleted from the assessment roll simply because the inspector states that they do not generate hazardous wastes. But the nature of the business is what should determine their inclusion or exclusion on the assessment roll. Businesses such as pest control services, cleaning services, marinas and photo services should remain on the assessment roll even though the owner(s) may state they are non-generators. Review procedures should be established requiring a review of facility verification forms before determining if a facility should be deleted from the assessment roll. Such a procedure would provide assurance that all deletions are proper. Because of the scope limitation of our audit, we were not able to determine if the deletions of any facilities were proper. Based on the nature of the businesses, we question the appropriateness of deleting most of these facilities from the assessment roll. Recommendation(s): 1. The Division Director of Environment Management should have appropriate personnel establish SOPs that ensure that facilities deleted and/or not included on the assessment roll are appropriate. 20 2. The Division Director of Environmental Management should require appropriate personnel to review verification forms of facilities to be deleted to determine if the deletion or non- inclusion is appropriate. Auditee's Response(s): See Section VII, Auditee Responses. 1 21 H. Missing, Misfiled and Incomplete SQG Files: Finding(s): A search of all files listed on the assessment roll reveals that the physical files in the file cabinets are not maintained in an orderly manner. Physical files are arranged by location of the facility first with four (4) locations in Monroe County. Within each location, files are arranged alphabetically by facility name. Inconsistencies found include: - Of the 691 completed inspections in the SQGDMS, 60 facilities were missing their physical file. This represents 9% of completed inspections. - A number of files were located in the file cabinet under one name and listed on the assessment roll under another name. - Some facilities had more than one file. This can occur when a facility changes its name or location, is known by more than one name, or other conflicting information about the facility name or location exists. - The file cabinet housed over 50 empty files. We were told that they were empty because the facility was deleted from the assessment roll. Others were empty because the file was a duplicate file (i.e., different name or location). These empty files were pulled during the audit period. In addition, we are unable to determine if facility files contain all verification forms ever completed for each facility. Procedures should be established to ensure that there is only ONE file for each facility and files are in their proper order. Recommendation(s): 1. The Division Director of Environment Management should have appropriate personnel establish procedures that ensure that all verification forms and surveys are maintained properly in each facility's physical file. 2. The Division Director of Environmental Management should require appropriate personnel to organize the current files such that each facility has ONE physical file which consolidates all past and current information and is filed according to current name and location. Auditee's Response(s): See Section VII, Auditee Responses. 22 I. Inadequate Training of Inspectors: Finding(s): Interviews with current SQG inspectors and a review of verification forms reveal that training of inspectors is lacking. The SQG Project Coordinator and other inspectors have stated that they do not know all the codes and their meanings used in the SQGDMS computer system. These codes represent the inspectors' verification process and the state DEP relies on the accuracy of this information to profile and track SQGs. One inspector stated that he was not instructed on how to complete the back of the verification form. The backs of the form record all waste records and note questionable waste management practices. In addition, our audit revealed that verification forms are incomplete, inaccurate and inconsistent. (See Finding C. Incomplete, Inaccurate, and/or Inconsistent Verification Forms) The SQG Project Coordinator, has assembled information in a three-hole binder that includes the manual provided by the Florida Department of Environmental Regulations titled, "Small Quantity Generators of Hazardous Waste: Assessment, Notification, Verification Program, 1992". This manual thoroughly explains the legal requirements for the program, defines all codes, and provides an SQGDMS users manual. The SQG Projector Coordinator requires new inspectors to thoroughly read all information in this binder before observing and/or performing any on-site verifications. New inspectors initially observe on-site verifications with the SQG Project Coordinator. They then perform on-site verifications assisted by the SQG Project Coordinator. Once the SQG Projector Coordinator is confident that a new inspector is properly trained, he will allow the new inspector to independently perform inspections. The SQG Project Coordinator stated that he reviews some of the verification forms of new inspectors. However, there is no evidence of this, such as his initialing reviewed forms. Inspectors also attend conferences sponsored by the Florida Department of Environmental Regulations. These seminars are attended by SQG inspectors from other Florida Counties. The purpose of these seminars is to provide further training to the inspectors, clarify questions and concerns, and provide a network system for inspectors to share ideas about their individual programs. Proper training begins with the SQG Project Coordinator. This individual should have a complete knowledge of the SQG program. This knowledge should include knowing all codes and their meanings required of the SQGDMS computer system. The SQG project Coordinator should ensure that all inspectors have total understanding of the verification process before being allowed to independently conduct on-site verifications. All verification forms should be reviewed by an individual above the inspector level and by someone other than the individual performing the inspection. This review process would 23 provide assurance for the accuracy and completeness of all verification forms. This would also assist in the training process of new inspectors. Recommendation(s): 1. The Division Director,of Environment Management should ensure that the SQG Project Coordinator thoroughly understands all aspects of the SQG program operations or appoint someone with the knowledge to properly train all inspectors. 2. The Division Director of Environmental Management should require an appropriate personnel to review inspection reports for completeness before the information is given to the data entry person. The person reviewing the verification forms should sign the forms to indicate that the review occurred. Auditee's Response(s): See Section VII, Auditee Responses. 24 J. Overtime is Inconsistent with County Policies and No Support for Paid Overtime: Finding(s): A review of time sheets for the period November 1, 1995 through April 13, 1996 reveals that the SQG Projector Coordinator worked 308.5 hours of overtime. Included in overtime hours worked were three holidays (28 hours) and 21 Saturdays (149.5 hours). In discussions with the Acting Division Director, he stated that all the overtime was verbally pre-approved. There is no written documentation pre-approving the overtime and no documentation submitted with time sheets to support the overtime worked. The SQG Project Coordinator stated that overtime is worked when on-site verifications are performed in the Middle and Upper Keys. However, meal vouchers revealed that travel in these regions began at or after 10:00 a.m. A memo from the Division Director of Environmental Management, dated August 18, 1994, states: "Any anticipated hours to be worked in excess of 40 hours must be reported to Division Director of Environmental Management in writing prior to the event. Overtime must be approved in advance. " This memo also points out that it is the department's intent to strictly follow the Monroe County Personnel Policies and Procedures Manual section 5.02 which states: "The employment and work program of each Department should be arranged so as to eliminate the necessity of overtime work except in emergency situations. " The Monroe County Personnel Policies and Procedures Manual Section 6.03 states: "Each employee shall observe all holidays designated in this Section, provided that the work load of the department is, in the discretion of the County Administrator, such that the employee's work load cannot be discontinued without causing hardship to the County. " A review of the information entered on the SQGDMS computer system reveals that during the period January 3, 1996 through April 13, 1996 only six (6) on-site verifications were completed. And during that period the SQG Project Coordinator requested and was paid for 194.5 hours of overtime. To follow county and department personnel policies and procedures, all overtime should be properly approved in advance, overtime should be kept to a minimum, and working holidays should be disallowed except in unusual circumstances. Route sheets should be prepared and kept to support the efficient operations of the program and to document necessary overtime. In addition, when travel to the Middle and/or Upper Keys is required, travel should begin early in the morning to reduce overtime. Recommendation(s): 1. The Division Director of Environment Management should ensure that all overtime is pre-approved and documentation approving the overtime should be maintained. In addition, all documentation supporting overtime should be submitted and reviewed by appropriate personnel, before the time sheet is signed, authorizing payment. 25 Auditee's Response(s): See Section VII, Auditee Responses. 26 K. Reimbursed Meal Expenditures: 1. No Support for Reimbursed Meal Expenditures: Finding(s): A review of reimbursed meal vouchers reveals that there are no documents to support reimbursed meal expenditures. Our audit compared dates of on-site verifications entered into the SQGDMS computer system to dates of reimbursed meal vouchers for the period June 1994 through March 1996. Our audit revealed the following inconsistencies: - 28 times reimbursed meal vouchers indicated that inspectors performed on-site verifications in a region other than that documented in the SQGDMS computer system. For example, reimbursed meal vouchers indicated that travel was in Key Largo and the SQGDMS computer system indicated on-site verifications in an area other than Key Largo. - On 75 different days reimbursed meal vouchers showed that an "SQG inspection" occurred and the SQGDMS computer system showed that no inspections were performed - on those days. - On 10 different days there were no requests for meals when the SQGDMS computer system showed that an inspection occurred above Cudjoe Key. - For the period January 1996 through March 15, 1996, the SQGDMS computer system shows that only six (6) on-site verifications were performed (three (3) above Cudjoe Key) and there are 19 days where an inspector requested reimbursed meals, stating SQG inspections on his reimbursed meal voucher. The SQG Project Coordinator, stated that he documents his travel on a calendar and on route sheets. However, he was unable to produce the calendar or any route sheets. Documents supporting reimbursed meal expenditures should accompany the request. This support should be reviewed by appropriate persons before the reimbursement is approved. If calendars and route sheets are used, then the originals or copies should be maintained, filed and kept in an organized manner. Recommendation(s): 1. The Division Director of Environment Management should instruct appropriate personnel on proper review procedures for approving reimbursed meals. These procedures should include a review of appropriate documents to verify the reimbursement as legitimate and appropriate. Auditee's Response(s): See Section VII, Auditee Responses. 27 2. SQG Project Coordinator Inappropriately Requested and was Reimbursed for Meals: Finding(s): A comparison of employee time sheets to travel reimbursement vouchers for the period November 1994 through April 1996 revealed 25 instances where the- SQG Project Coordinator inappropriately requested and was reimbursed for meals. The SQG Project Coordinator did not provide any other information to support the reimbursement of these expenses. The total cost to the county for these expenses is $252. On 15 different days the SQG Project Coordinator requested and was reimbursed for dinner because the travel reimbursement voucher indicated that travel time ended after 8:00pm. However, the corresponding employee time sheet stated the SQG Project Coordinator completed work on or before 8:00pm. Florida Statutes §112.061(5)(b) states that an employee will be reimbursed for dinner when travel begins before 6:00pm and extends beyond 8:00pm. Total cost to the county for these expenses is $180. A list of these 15 discrepancies comparing time sheet information to the travel reimbursement voucher is presented below. Employee Date Time Sheet Travel Reimbursement Voucher In Out Depart Return Amount Purpose 11/4/94 8:30am 5:00pm 4:00pm 9:00pm $12.00 SQG Program- Plantation 2/14/95 8:30am 5:00pm 3:00pm 9:00pm 12.00 Inspection Complaint - Key Largo 2/23/95 8:30am 5:00pm 3:00pm 9:00pm 12.00 SQG - Key Largo 3/8/95 8:30am 5:00pm 11:00am 8:30pm 18.00* SQG Inspections - Key Largo 3/25/95 8:00am 7:00pm 10:30am 8:30pm 18.00* SQG Inspections - Key Largo 4/1/95 8:00am 7:00pm 9:00am 8:30pm 18.00* SQG Inspections - Key Largo 5/16/95 8:30am 5:00pm 10:30am 9:30pm 18.00* Inspection - Key Largo 6/7/95 8:30am 5:00pm 2:30pm 8:30pm 12.00 SQG Complaint - Key Largo 6/12/95 9:30am 5:00pm 11:00am 8:30pm 18.00* SQG Complaint - Key Largo 8/15/95 8:30am 5:00pm 10:30pm 8:30pm 18.00* HHW SQG - Marathon 10/13/95 8:30am 5:00pm 3:30pm 9:00pm 12.00 Inspect - Key Largo 11/14/95 8:30am 5:00pm 4:00pm 8:30pm 12.00 Haz Mat Storage Check - Long Key 12/20/95 7:00am 8:00pm 10:45am 8:15pm 18.00* SQG Program - Key Largo 3/12/96 7:30am 8:00pm 11:00am 8:30pm 18.00* Inspections - Key Largo 3/21/96 7:30am 8:00pm 3:00pm 8:30pm 12.00 Complains and Inspect - Ocean Reef (*) Requested reimbursement for lunch and dinner; lunch reimbursement was consistent with employee time sheets. On six (6) different Saturdays the SQG Project Coordinator requested and was reimbursed for lunch because the travel reimbursement voucher indicated that there was travel on those days. However, the corresponding employee time sheet did not indicate that the SQG Project Coordinator worked on those days. Total cost to the county for these expenses is $36. A list of these six (6) discrepancies comparing employee time sheet information to the travel reimbursement voucher is presented on the next page. 28 Employee Date Time Sheet Travel Reimbursement Voucher Depart Return Amount Purpose 6/24/95 no time 1:00pm 2:30pm $6.00 HHW SQG - Marathon 7/8/95 no time 9:00am 3:00pm 6.00 Hazardous Material Storage - Long Key 9/9/95 no time 10:30am 3:30pm 6.00 Long Key 9/23/95 no time 10:30am 3:00pm 6.00 Inspect SQG - Marathon 10/21/95 no time 10:00am 2:30pm 6.00 Check Storage Facility - Long Key 2/17/96 no time 10:30am 3:00pm 6.00 SQG Inspection - Marathon On three (3) different days the SQG Project Coordinator requested and was reimbursed for lunch or dinner because the travel reimbursement voucher indicated he traveled on those days. However, the corresponding employee time sheet stated the SQG Project Coordinator was on vacation those days. Total cost to the county for these expenses is $30. A list of these three (3) discrepancies comparing employee time sheet information to the travel reimbursement voucher is presented below. Employee Date Time Sheet Travel Reimbursement Voucher Depart Return Amount Purpose 9/12/95 vacation 3:30pm 8:45pm $12.00 SQG Inspection - Key Largo 9/27/95 vacation 10:30am 3:00pm 6.00 SQG Complaint - Marathon 9/29/95 vacation 4:00pm 8:30pm 12.00 Check Containers - Marathon On one (1) day the SQG Project Coordinator requested and -was reimbursed for lunch because the travel reimbursement voucher indicated that travel time ended at 3:30pm. However, the corresponding employee time sheet stated that the SQG Project Coordinator went home sick at 2:00pm. Total cost to the county for this expense is $6. Information about this discrepancy comparing employee time sheet to the travel reimbursement voucher is presented below. Employee Date Time Sheet Travel Reimbursement Voucher In Out Depart- Return Amount Purpose ' 12/7/95 8:30am 12:00pm 10:30am 3:30pm $ 6.00 SQG Inspection - Long Key 1:00pm 2:00pm 2:00pm 5:00pm (sick) All travel reimbursement vouchers were signed by the SQG Project Coordinator's supervisor, however, no support was provided with the vouchers when payment was requested. The SQG Project Coordinator stated to the auditors that he "throws away" travel records after he submits his travel vouchers. Therefore, in the absence of additional information, the auditors used employee time sheets to determine travel time. 29 Concerning fraudulent claims of travel expenditures, Florida Statute §112.061(10) states: "... any person who willfully makes and subscribes any such claim which he or she does not believe to be true and correct as to every material matter, or who willfully aids or assists in, or procures, counsels, or advises the preparation or presentation under the provisions of this section of a claim which is fraudulent or is false as to any material matter, whether or not such falsity or fraud is with the knowledge or consent of the person authorized or required to present such claim, is guilty of a misdemeanor of the second degree, punishable as provided in s. 775.082 or s. 775.083. Whoever shall receive an allowance or reimbursement by means of a false claim shall be civilly liable in the amount of the overpayment for the reimbursement of the public fund for which the claim was paid. " Recommendation(s): 1. The County Administrator and the Division Director of Environment Management should inquire as to the appropriateness of these expenses. 2. If the above meal reimbursements are determined to be inappropriate, the County Administrator should require the SQG project Coordinator to reimburse the county for the expenses and the information concerning these expenses should be given to the County Attorney for his review. Auditee's Response(s): See Section VII, Auditee Responses. 30 VI. EXHIBITS EXHIBIT A Profile of the Monroe County "Assessment Roll" Exhibit A - 1 Profile of the Monroe County "Assessment Roll" MONROE COUNTY "ASSESSMENT ROLL" (59.2%) —On the assessment roll,completed inspection ▪On the assessment roll,completed inspection,missing file 6gy us On the assessment roll,completed inspection,not in computer (� (1.0963 On the assessment roll,incomplete inspection (3.2%) No On the assessment roll,no inspection,no file ▪Should not be on assessment roll;per Program Director (6.0%) —Should not be on assessment roll;out-of-business or duplicate (0.8%) (22.8%) (5.5%) o Other note: Information obtained from the Hazardous Waste Department files.) Current Assessment Roll 596 59.19% On the assessment roll, completed inspection 60 5.96% On the assessment roll, completed inspection, missing file 8 0.79% On the assessment roll, completed inspection, not in computer 55 5.46% On the assessment roll, incomplete inspection 230 22.84% On the assessment roll, no inspection, no file 32 3.18% Should not be on assessment roll; per Program Director 10 0.99% Should not be on assessment roll; out-of-business or duplicate 16 1.59% Other 1007 100.00% Total on the Assessment Roll 27 Not on the assessment roll, completed inspection 1034 A- 1 Exhibit A - 2 Profile of the Monroe County "Assessment Roll" LOCATION OF "ASSESSMENT ROLL" (39.9%) AreaI (12.8%) �Area2 (0.2%) Area 3 o Area 4 Unknown (16.7%) (30.4%) note: Infoemtion obtained from the Hazardous Waste Department,SQODMS computer system.) Location of Businesses on the Assessment Roll 402 39.92% Area 1 -Key West and Stock Island 129 12.81% Area 2 -Boca Chica through Big Pine Key 168 16.68% Area 3 -Marathon Area 306 30.39% Area 4 - Grassy Key through Key Largo 2 0.20% Unknown 1007 100.00% Total on the Assessment Roll A-2 Exhibit A - 3 Profile of the Monroe County "Assessment Roll" YEAR OF VERIFICATION 400 Z / ill a 300 - a 1 ,r, 200 — O :23- z loo — . 111.im, IN Year 1-1991 I.Year 2-1992 •Year 3-1993 i=Year 4-1994 imi Year 5-1995 o Extension Period 1996 note: Information obtained from the Hazardous Waste Department,SQGDMS computer system. VERIFICATION STATUS OF FACILITIES (69.2%) cillEs Completed Inspections o Incomplete Inspections NE No Inspection (24.5%) (6.3%) note:Information obtained from the Hazardous Waste Department,SQGDMS computer system.1 Year Verification Took Place 1 0.1% Year l - 1991 5 0.5% Year 2 - 1992 43 4.3% Year 3 - 1993 377 37.4% Year 4- 1994 265 26.3% Year 5 - 1995 6 0.6% Extension Period 1996 697 69.2% Completed Inspections 63 6.3% Incomplete Inspections 247 24.5% No Inspection 1007 100.0% Total on the Assessment Roll A-3 II - EXHIBIT B Monroe County Hazardous Waste Management Assessment Survey/Verification Form • HAZARDOUS WASTE MANAGEMENT ASSESSMENT SURVEY/VERIFICATION FORM • - The purpose of this assessment is to gather information about the types and amounts of wastes generated by private businesses and public agencies, and the methods used for waste storage and disposal. Please answer all survey questions, completely and accurately, as required by 403.7234, Florida Statutes. Failure to disclose all requested information may subject you to a fine of between S25 and 5100 per day for a maximum of 100 days. • + * • • * • * * * r * • * * + FOR OFFICE USE ONLY Facility Data: * • SQGDMS IDi County EPA• ID* * OTHER IDI (if applicablo) + STATUS (A, P, I, + or N) * FOLLOW-UP (R or V) + VERIFIED * Facility Name * • Mailing" Address * City State Zia • Location Address • * Location City * _ • ocation Zip * - Std. Industrial Classification Code * Number of Full-Time Employees * * GENERATOR STATUS • (C. R, L) ' *.DATA TYPE (V, P, S) ' • DATE MM/DD/YY a ORGANIZATION CONTACT • ORGANIZATION CODE * (County or RPC-Z digit code) * Facility Contact Verson' ' * Title Phone $ ( ) * • * * TRANSACTION CODS. * (A, U, D) • *vson-sits verification * Psphone follow-up * S■survey data * * * • • * * i * * e • * * a • * * * * * * * * * * * • • • • - FOR orrzCE USE ONLY COMMENTS: • • B-1 L.:1ste• Data: !r•.asa review the following information and the waste type code. storage method code. and lsPosal method code descriptions on the enclosed sheets. In the following chart. enter teVappropriate codes, unit types, and number of units for each type of hazardous or other 3.st.:e that is generated at your facility. I Use the following unit type codes: Gagallon L=pound D=full 55 gallon drum U=units (used for batteries & dry cleaning filters ) X=kilograms Y=cubic yards * OFFICE USE • * OMLY Maximum On-Site (0). a******w*wwwwr ,-',aste Storage Disposal Annual Monthly , or * 'TRANS. Ye Method Method * Units s Units Unit Off-Site (F)* CODE VERIF. -ode__ Code Code Disposed Generated Type Disposal • a �. a * • ---__. * --. * --. ' • * • • • * IIMM...• •••••• ••••••=1•••• -�.-.- 1 • a i --- .* �- . * * e * i r _... * XAMPLE: An automotive repair shop disposes of ten 55 gallon drums of spent chlorinated __caveat annually. The maximum amount generated in any month is one 55 gallon drum. The .rums are picked up every three months by th* solvent distributor who transports the spent ,olvent to a permitted hazardous waste facility (solvent reclaimer) for recycling. In addition. 250 gallons of used oil are generated and disposed of off-site -.onthly. A used oil transporter picks up the used oil and takes it to a recycler. Maximum On-Site (0) taste Storage Disposal Annual Monthly or /pe Method Method i Units * Units Unit Off-Site (F) 'ode Code Code Disposed Generated T7ipe Disposal A. = 03 ■ 2. . 1�0.00 1.00 D . F a off-site ;peat s0-SS permitted full olveat gallon hazardous 55 gal. drum waste drum . 1 facility • . 10 s 02 ■ 20 • 3.000.00 250.00 C . r . off-sit• zed tank used gallons it below- oil ground transporter B-2 EXHIBIT C Lee County Small Quantity Generators Program On-Site Assessment Verification Lee County Division of Natural Resources Management Small Quantity Generators Program On-site Assessment/Verification Form 1; Inspection #: Date: SIC Code #: Inspector: FDEP/EPA I.D. #: Last Verification Date: Nearest Intersecting Street: GENERAL INFORMATION: Facility Name: Address: City, State,Zip: Mailing Address: City, State,Zip: Facility Contact: Title: Responsible Person: Title: Facility Phone#: Number of employees: Number of years in business Previous use: Production, Services,Process: SITE INFORMATION: Water Supply: Septic: Sewage Fire District HRS/Utility Permit Sec: Twn: Rng: Drains: Storage area: Container condition: Property Manager/Owner: Address: NPDES: • C-1 Wastes Generated: • _; Waste Maximum Monthly Average Storage Disposal On/Off Code Monthly Amount Annual Code Code Site Letter Quantity in Pounds Quantity Letter Letter Disposal • • • Haulers/Transporters : , Waste Code: Hauler: Waste Code: Hauler: Hazardous Waste Totals: Monthly: lbs. Annual: lbs. Additional Information: Generator Landlord Contractor Other Name Building Maintenance Lighting Pesticide In/Out Doors Lawn Maintenance Vehicle Maintenance Bio-Hazardous Waste Information Supplied to Facility: Merc Rule BMP's Def. of Empty Hauler's List Used Oil Filter Mixing Rule CESQG Coll. SQG Emergency Plan P2 Bio-Haz. Additional Information Requested: Comments: I have reviewed the above information supplied bythis facilityand confirm its' accuracy: pp Date Facility Representative Inspector C-2 EXHIBIT D Collier County Small Quantity Generators On-Site Inspection Form Facility LD.# , Date Entered Collier County Pollution Control Entered By COLLIER COUNTY Health/Comnm Service Bldg.,3rd Floor POLLUTION CONTROL DEPARTMENT 33 Naples,FL 33i 62ail FI..33962 Tel: (941)732-2502 SMALL QUANTITY GENERATORS Sun: (941)751 2502 FAX: (941)774-9222 ON-SITE INSPECTION FORM INSPECT#: Date: SIC Code: Inspector: Fire District: FDEP/EPA#: GENERAL INFORMATION: i FACILITY NAME: i ' STREET ADDRESS: CITY, STATE,ZIP: MAILING ADDRESS: • , SECTION: TOWNSHIP: RANGE: LATITUDE: LONGITUDE: FACILITY CONTACT: TITLE: RESPONSIBLE PERSON: TITLE: FACILITY PHONE NUMBER: NO. OF YEARS: NUMBER OF EMPLOYEES: PREVIOUS USE: -, SITE INFORMATION: PRODUCTION, SERVICES, PROCESS: WATER SUPPLY: SEWAGE: DRAINS: BRIEF DESCRIPTION OF CONDITION OF SITE: NO CESQG SQG LOG December 1995 D-1 WASTES GENERATED: WASTE MAXIMUM AVERAGE STORAGE DISPOSAL ON/OFF HAULER MANIFEST CODE MONTHLY ANNUAL CODE CODE SITE USED LETTER QUANTITY QUANTITY LETTER LETTER DISPOSAL (Y,N) • TOTAL NON REGULATED REGULATED HAZARDOUS WASTE TOTALS-MONTHLY: HAZARDOUS WASTE TOTALS-ANNUAL: COMMENTS: • • RECOMMENDATION(S): I HAVE REVIEWED THE ABOVE INFORMATION AND CONFIRM ITS ACCURACY: DATE RESPONSIBLE PARTY INSPECTOR D-2 VERSION 2 November 1995 EXHIBIT E Monroe County Time Extension Request for the SQG Program (Memo to the State SQG Director) BOAHD OF COUNTY COMMISSIONERS f M 0 N R 0 E �M MAYOR, iirIcy Devitt/in,IAslrica O U NTY c� M rynr l'ro fool,Jack l aiururr.l)slnca 2 ICI Y W',� r. Wdhulrnrnc I Irnvey,Ihclrrcl 1 f ST FLORIDA:1Y040 `I. 'r,i� (J0:,1;va 4�4 t ;�'�' M:uy Kay Reich,Uislrica!) at"._ Kr,ilh Dotiglasrc,Uistricl 4 • . ez, • iiiD .12 • • MEMORANDUM • i l TO: Mr..Glynn Peregrine,Project Director SQG Program FROM: Ron Stack, Environmental Specialist 11/Project Coordinator Monroe County Hazardous Waste DATE: August 19, 1996 • • SURJ: Time extension for submittal of notification, assessment and verification data base. As requested by you in our telephone conversation on August 12, 1996. I am submitting this notice that Monroe County's SQG Data Base will be completed and forwarded to you no later than November 15, 1996. • We realize the importance of this program and regret the delay but due to staffing and other unanticipated problems our schedule had to be revamped. Your cooperation is appreciated and if you need any additional information you can telephone me at 305-292-4439. cc: Clark Lake,Director Mike Lawn,'Assistant Director • • E-1 VII, AUDITEE RESPONSES : - . �+ �_„__ BOARD OF COUNTY COMMISSIONERS — I! ,,-- MAYOR,Shirley Freeman,District 3 C0 U N T 1 o f M 0 N R 0 E �' Mayor Pro Tem,Jack London,District 2 �,' • :j7= • Wilhelmina Harvey,District 1 KEY WEST FLORIDA 33040 . Mary Kay Reich,District 5 1p�"I. I Ml Keith Douglass,District 4 MEMORANDUM/.:1 10 ce, TO: Danny Kolhage Clerk of Court FROM: James L. Roberts County Administrator SUBJECT: Draft Preliminary Audit Report of Hazardous Waste Function DATE: December 23, 1996 In response to the draft audit report of the Hazardous Waste Function, the Administration has reviewed the issues raised and the responses by the Manager of the program and the Director of Solid Waste Management. In addition, there were discussions with representatives of the State office who coordinate these programs . 1 , Please be advised that it is the Administration' s intent to undertake a major reorganization of these func- tions . It is apparent that minor adjustments in the pro- gram will not serve to correct the deficiencies . The reor- ganization effort should begin early in calendar year 1997 . l . tt