A government contract awarded to a Kansas company after "persistent" efforts by the office of Senate Minority Leader Robert J. Dole (R-Kan.) is "replete with appearances of improper activities," and the company was not qualified to be considered for the $26 million job, a preliminary investigation by a House committee concluded.

Rep. John J. LaFalce (D-N.Y.), chairman of the House Small Business Committee, said yesterday that "criminal laws may have been violated" in the granting of the three-year, no-bid contract to EDP Enterprises, which is owned by former Dole aide John Palmer.

Committee aides said the investigatory file on the matter will be turned over to the Justice Department, the U.S. attorney in Missouri and the inspector general of the Small Business Administration, the agency that certified EDP eligible for the Army contract. The Federal Bureau of Investigation last week questioned officials and examined documents at SBA regional headquarters in Kansas City, Mo.

LaFalce said that interviews and documents have produced "nothing that suggests Bob Dole was personally involved in any questionable event or occurrence."

However, the committee staff's report to LaFalce showed that Dole's one-time close Kansas political ally David C. Owen profited more than previously disclosed from Palmer's contract, after personally lobbying for it. In 1986, Palmer's firm paid Owen $149,000 in consulting fees, and Owen and his company together borrowed and repaid $131,500 from EDP, the report said.

Owen resigned Jan. 14 as a national finance chairman of the Dole for President campaign, amid disclosures that he may have benefited financially from his position as investment counselor to the blind trust of Elizabeth Hanford Dole, the senator's wife. The report released yesterday provided new details about financial transactions among the trust, Owen and Palmer's firm.

Owen, a businessman who ran Dole's Senate reelection campaigns in 1974 and 1980, wrote to then-SBA Administrator James C. Sanders on Oct. 3, 1984, saying in part:

"I would appreciate anything you can do to help this situation along and to obtain the contract for John. He can be a real asset to the Republican Party, and I know Senator Dole is supportive of his endeavors." The letter was written on stationery of the Kansas Republican Party, which Owen, a former lieutenant governor, chaired at the time.

Sanders responded to Owen on Dec. 13, 1984, that the SBA had certified Palmer's company as eligible for a special government contract set aside for minority-owned firms. Palmer, who is black, subsequently was awarded the contract to supply the mess halls at Fort Leonard Wood, Mo. That was the largest food-service contract ever granted under the minority program.

The report documented meetings and phone calls by Dole aides on behalf of Palmer dating to November 1983. That month Dole's administrative assistant, Mitchell (Mike) Pettit, accompanied by Owen and Palmer, met with SBA officials at the agency's Washington headquarters to "get him {Palmer} started."

Palmer's application for the minority program, which had been rejected once, was again turned down June 1984. However, a month later the SBA reversed itself after an SBA employee in Washington received a phone call from an official in the Kansas City office who "advised that 'the senator' had a special interest in Palmer's application," according to the report to LaFalce. The "senator" was not identified.

An SBA employee interviewed by the House investigators described the efforts of Dole's administrative assistant Pettit on behalf of Palmer as "persistent."

The report raised several key questions about the contract to Palmer's firm. Even after certifying the firm for the program, the SBA recommended that awards to it not exceed $50,000 a year. The reason cited was Palmer's lack of financial assets and business experience. Nevertheless, in January 1986, the company began the first year of the Army base contract worth $10.5 million.

This was $1.8 million more than the previous contractor had been paid. The Army attributed the difference to "changes in the scope of work and labor rates."

The report detailed 13 specific financial connections between Owen and his businesses and Palmer's firm. In addition to receiving consulting fees and loans from EDP, Owen also sold EDP a half-interest in an airplane worth at least $97,773, arranged financing for Palmer from a bank of which he was a director and set up a company that supplied EDP with $160,969 worth of goods.

Besides Palmer, the other two members of the EDP board of directors were closely associated with Owen or his companies. The House committee staff said this raised questions as to whether Palmer actually controlled his own company.

"The pattern of common associations and financial interests between EDP and Mr. Owen suggests that a 'front company' affiliation may have been involved in this whole affair from the very beginning," LaFalce said.

According to a chronology released by the committee, Palmer borrowed $150,000 from the Dole trust in April 1986 and used the money to buy a three-eighths interest in a mortgage-finance company located in the same Overland Park, Kan., office building as Palmer, Owen and the Dole campaign.

Palmer wrote in a Jan. 27 letter to SBA regional headquarters that he did this on the advice of Owen, whom he referred to elsewhere as his "long-time friend, Mr. David C. Owen." Palmer subsequently borrowed money from an unidentified person to pay off the note and is currently attempting to sell the stock.

Palmer did not return a phone call. In his Jan. 27 letter, however, he denied that Owen ever had controlled his company. Palmer disclosed that he was in the process of ending his financial relationship with Owen.