Federal and congressional investigators are examining whether the Federal Emergency Management Agency violated personnel rules by hiring a number of retired military policemen with ties to the agency's top officials.

At least a dozen current and former employes served in military or civilian life with top agency officials, particularly FEMA Director Louis O. Giuffrida, a brigadier general in the Army reserve, and former No. 3 official Fred J. Villella, a retired lieutenant colonel.

The list includes FEMA's executive administrator, deputy associate director, former deputy director and a number of Giuffrida's assistants. It also includes several who were given FEMA contracts or were provided jobs by two of the agency's consulting firms.

The Justice Department, the FEMA inspector general and the House Science and Technology investigations subcommittee are examining waste and mismanagement at the six-year-old disaster-planning agency. One of the issues under investigation is the extent to which a network of former Army policemen is involved in running FEMA.

FEMA spokesman James L. Holton called the allegations unfounded. "The taxpayer is better served if someone in a government agency hires people whose qualities he's familiar with, rather than taking some political hack," he said. "I do not see this as something that's terribly wrong."

Holton said the military police "is a fairly small, parochial group of people where everyone gets to know one another, especially at military schools . . . . It was natural that [Giuffrida] looked for people he could trust. This is done in every agency of the government."

Other officials disagree. "It's cronyism," said Donna Darlington, a branch chief who was moved to a lesser job after clashing with her superiors. "It's a lot of men with a military mentality who have come to the big city and now have all this new money and prestige."

Agency sources said they repeatedly questioned whether top officials circumvented government rules in providing jobs and consulting fees. According to personnel rules, career jobs must be openly competitive, job descriptions cannnot be written for specific individuals and officials cannot influence a contractor's hiring.

Most of the allegations focus on the National Emergency Training Center, which occupies a former college campus in Emmitsburg, Md.

Duane Murray, FEMA's assistant associate director, said in an affidavit that Villella ordered him to hire several "old military friends" as employes and consultants. Murray said jobs often had to be created when there were no openings.

"Many of these people had salary histories of only $25,000 to $30,000 per year, but were nonetheless expecting to receive $57,500, which was then the current maximum rate," Murray said in the statement. He also said it was improper for FEMA to "dictate" whom the agency's consulting firms should hire.

One agency official familiar with personnel matters said that job descriptions often were tailored to associates of Giuffrida and Villella. "There was no question that pre-selections had been made," the official said. "Most of them were military policemen . . . . You could walk out on the street and find people just as qualified."

Villella said through his attorney that, although some of his acquaintances were hired, "in all cases they were hired for the abilities or skills they had that seemed compatible with the mission" of FEMA. He said he "never directed" FEMA's consulting firms to hire anyone, although he "may have referred" some prospective employes.

Villella also said "very emphatically that no jobs were created for individuals." He said all new hires and their salaries "were properly cleared" through the agency's personnel office.

Giuffrida's first personnel director took early retirement, and his successor, a 20-year personnel veteran, was transferred to the nuclear war division. The job was given last year to a finance officer with no personnel experience.

Giuffrida, 64, known as "the general" to most subordinates, is the undisputed commander of the agency's 2,600 employes. During a career as an Army policeman that took him to the rank of lieutenant colonel, Giuffrida served at Fort Gordon, Ga., at the Army staff college at Fort Leavenworth, Kan., and at the Army War College at Carlisle, Pa.

A longtime associate of Edwin Meese III, Giuffrida became the first head of the California Specialized Training Institute, a disaster-training agency created in 1971 by then-governor Ronald Reagan. A decade later, White House counselor Meese helped bring Giuffrida to Washington.

Though it is not unusual for top federal officials to bring along a few old associates, investigators have questioned the extent of the practice at FEMA. For example:

* Villella, 51, FEMA's executive deputy director until he resigned, served with Giuffrida at Fort Gordon and Fort Leavenworth, and also saw duty in Panama and Vietnam. The retired lieutenant colonel later became Giuffrida's chief of staff at the California Specialized Training Institute (CSTI), and was earning $69,900 when he left FEMA.

* Gerald Martin, 57, FEMA's executive administrator ($69,900), is a retired military policeman who worked under Giuffrida for eight years at CSTI.

* Frank Payne, 60, deputy associate director ($61,615), is a much-decorated retired colonel who also served at Fort Gordon and Fort Leavenworth.

* George H. Smith, 55, special assistant to Giuffrida ($56,703), is a retired sergeant who served under Villella at Fort Carson, Colo., in the 1970s.

* Ronald P. Face, 44, emergency management officer ($44,359), is a retired major who served at Fort Gordon and with Payne in Vietnam.

* Frank C. Sidella, assistant associate director ($61,615), served with Villella in Panama and with Giuffrida at Fort Gordon.

* Fred A. Newton III, director of evaluation ($66,400), is a retired lieutenant who served with Giuffrida at Fort Gordon.

* Army Gen. Bennett L. Lewis, 58, Giuffrida's first executive deputy director before moving to the Pentagon, served with Giuffrida at Fort Leavenworth and at the war college in Carlisle.

Holton said Giuffrida brought in his own team because FEMA was "a zoo" when he took over in 1981. He said there still is "a hell of a lot of resentment" among officials from the five agencies that were folded into FEMA.

FEMA's top officials "were used to getting things done in the military," Holton said. "The civilian red tape was mind-boggling."

When these officials needed someone to help run the Maryland training center, they turned to John Collins, a retired Army colonel.

Collins and Giuffrida served together at the staff college in Fort Leavenworth. Collins also served in Panama with Villella and in Vietnam with Payne, Giuffrida's executive assistant.

"We were all in the service together," Collins said. "I called Villella and offered my services. You hire the people you know who can do the job."

In 1982, Villella referred Collins to an agency contractor, the IMR Corp., where vice president William Elsey hired him. Elsey's wife, Paula Smith-Elsey, had been Giuffrida's special assistant at the California institute and at FEMA.

Collins later was given two 90-day consulting contracts. When Villella's staff balked at approving a third, Collins was made a special assistant to Payne. Collins moved to Triton Corp., another FEMA contractor, before resigning last fall.

Some of the investigators are looking into allegations that Collins often left work Friday mornings and returned Monday afternoons after visiting his home in Columbus, Ohio. Collins disputed this, saying, "I've never worked less than 40 hours a week in my life."

Investigators also are examining whether it was improper for Collins to live rent-free at the training center for much of the period from 1982 to 1984. Collins said that it was cheaper than living in a motel, that dozens of other consultants lived at the center and that FEMA had approved the arrangement. But FEMA's general counsel ruled in 1983 that such employes and consultants should pay a $5 nightly charge.

Villella also lived at the training center for several months in 1981 and 1982; he later agreed to repay $772 for his stay.

Villella's departure followed disclosures that he spent $170,000 to turn the center's Building G into a residence with an $11,000 stove, fireplace, wet bar, microwave, cherrywood cabinets and remodeled bathroom.

Murray told investigators that Villella told him the stove and other amenities were for Giuffrida, a gourmet cook. FEMA officials denied this, although Giuffrida had sought approval to live at the residence.

Villella's chauffeur, a security guard at the Emmitsburg campus, also alleged last summer that Villella had sexually harassed her and used her to run numerous personal errands. Villella said through his lawyer that he "specifically denies any harassment" of the guard.