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Chapter 3 DIVERSION GRANT PROGRAM <br />• Contract No. 000317 for the semi - annual period January 1, 2005 to June 30, 2005, was not <br />signed until April 22, 2005. However, documentation attached to invoices shows that work <br />was being performed without an executed contract from January 1, 2005 to April 21, 2005. <br />See above query. <br />4. Contract copy in DEM program file is incomplete. <br />• The copy of Contract No. 000301 in DEM files is incomplete as to Page 2. Possible issues of <br />legality and enforceability may arise, if the contract is, in fact, incomplete, or a complete copy <br />of the contract cannot be located. <br />5. DEM estimates of County waste streams and required budgets for diversion are inaccurate. <br />• Supplemental contracts were issued due to the inaccuracy of DEM's initial estimates of <br />volumes to be processed. <br />6. Guidance on disclosure documentation and reporting requirements relating to "conflict of <br />interest" and "related parties" is insufficient. <br />• The "sale" of commodities by a contractor to a "related party" end -user increases the risk of <br />contractor abuse or fraud, particularly when combined with the lack of verifiable <br />documentation of incoming volumes and sources of commodities. <br />7. Diversion Grant Program Guidelines do not include sufficient operational controls and <br />reporting procedures. <br />• Grant Guidelines require documentation as to "source" of collected and diverted materials, <br />but do not require "weights by source ". Therefore, documentation provided by contractors is <br />inconsistent and cannot be reconciled. <br />• BSH documents only weights of collections from transfer station sources. <br />• Atlas Recycling does not provide weights by source, and its only documentation as to <br />"source" is typically a handwritten note on the Diversion Grant Claim Form. <br />8. Diversion Program Grant Guidelines do not include requirements for standardized scale <br />ticket data. <br />• Scale weight tickets reviewed did not routinely include tare weights of trucks. Some tickets <br />included only gross weights of trucks and loads. How tonnage of commodities was <br />determined using only gross weights on scale tickets without an established standard tare <br />weight for each vehicle is unclear. <br />• Scale tickets included handwritten tare weights that could not be verified. How tonnage of <br />commodities was verified using handwritten tare weights is unclear. <br />23 <br />