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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON. D.C. 20460
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The CPA audited the adjusted PC&B costs for fiscal 1984 in accordance
with generally accepted auditing standards and the standards for financial
and compliance audits contained in the Standards for Audit of Governmental
Organizations, Programs, Activities, and Functions, Issued by the U.S.
General Accounting Office.The CPA did not examine any other elements or
accounts in the Statements of Obligations and Statements of Disbursements
which were previously reported on. n
RESULTS OF AUDIT
The CPA accepted Region 3's adjusted PC4B costs of $2,334,015 for the
fiscal year ended September 30, 1984. Additional details are contained
in the attached CPA's report.
ACTION REQUIRED
None. In accordance with EPA Directive 2750, you are the designated Action
Official for this report. Since the report contains no recommendations,
a formal written response is not required. We have closed out this audit
in the Audit Tracking and Control System.
Should your staff have any questions, please have them contact Roland W. Cyr
on 382-4930.
Attachment
cc: Tichenor and Eiche, CPAs
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DISTRIBUTION
Copies
A. Office of the Inspector General (A-109) 5
Divisional Inspector General
for Audit - Mid-Atlantic Audit Division (1)
Director, Audit Operations Staff (3)
Chief, Program Analysis Unit (1)
B. Regional Office
Regional Administrator, Region 3 . 2
Audit Follow-up Coordinator 1
C. Headquarters Office
' Comptroller (PM-225) 1
Director, Financial Management Division (PM-226) 2
Chief, Superfund Accounting Branch (PM-226) 1
Agency Follow-up Official (PM-225) 1
Attn: Resources Systems Management Division
Assistant Administrator for Solid Waste and
Emergency Response (WH-562A) 1
Director, Office of Emergency and Remedial
Response (WH-548) 1
Associate Administrator for Regional
Operations (A-101) 1
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UNITED STATES
ENVIRONMENTAL PROTECTION AGENCY
REGION 3
PHILADELPHIA, PENNSYLVANIA
REPORT OF FINANCIAL AND COMPLIANCE AUDIT
PERSONNEL COMPENSATION AND BENEFITS
UNDER THE
COMPREHENSIVE ENVIRONMENTAL RESPONSE,
COMPENSATION, AND LIABILITY ACT OF 1980
FOR THE FISCAL YEAR ENDED
SEPTEMBER 30, 1984
i
HEADQUARTERS LIBRARY
ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON, D.C. 20460
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UNITED STATES
ENVIRONMENTAL PROTECTION AGENCY
REGION 3
PHILADELPHIA, PENNSYLANIA
REPORT OF FINANCIAL AND COMPLIANCE AUDIT
PERSONNEL COMPENSATION AND BENEFITS
UNDER THE
COMPREHENSIVE ENVIRONMENTAL RESPONSE,
COMPENSATION, AND LIABILITY ACT OF 1980
FOR THE FISCAL YEAR ENDED .
SEPTEMBER 30, 1984
TABLE OF CONTENTS
" — -- -\
PAGE
SCOPE AND OBJECTIVES 1
SUMMARY OF AUDIT RESULTS 2
BACKGROUND 3
AUDITORS' REPORT ON PERSONNEL COMPENSATION
AND BENEFITS 5
INTERNAL ACCOUNTING
CONTROL AND COMPLIANCE 7
FINDING
RESULTS OF STATISTICAL ANALYSIS OF PERSONNEL
COMPENSATION AND BENEFITS TRANSACfTO'NS' 10
EXHIBITS
EXHIBIT 1 - PERSONNEL COMPENSATION AND BENEFITS,
FISCAL YEAR ENDED SEPTEMBER 30. T554 11
EXHIBIT 2 - NOTES TO PERSONNEL COMPENSATION AND
BENEFITS, FISCAL YEAR ENDED SEPTEMBER
30. 198412
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UNITED STATES
ENVIRONMENTAL PROTECTION AGENCY
REGION 3
PHILADELPHIA, PENNSYLANIA
REPORT OF FINANCIAL AND COMPLIANCE AUDIT
PERSONNEL COMPENSATION AND BENEFITS
UNDER THE
COMPREHENSIVE ENVIRONMENTAL RESPONSE,
COMPENSATION, AND LIABILITY ACT OF 1980
FOR THE FISCAL YEAR ENDED
SEPTEMBER 30, 1984
SCOPE AND OBJECTIVES
We have performed a financial and compliance audit of Personnel
Compensation and Benefits (PC&B) costs for the portion of the
Hazardous Substance Response Trust Fund (Superfund) reported by
the U.S. Environmental Protection Agency (EPA), Region 3 (Allow-
ance Holder 03), for the fiscal year ended September 30, 1984.
Superfund was established under the Comprehensive Environmental
Response, Compensation, and Liability Act of 1980 (CERCLA).
CERCLA [section lll(K)] states that the Inspector General shall
audit as appropriate all payments, obligations, reimbursements,
or other uses of Superfund to assure that Superfund is being
properly, administered and that claims are being appropriately and
expeditiously considered.
The audit was performed in accordance with generally accepted
auditing standards and the standards for financial and compliance
audits contained in the Standards for Audit of Governmental Orga-
nizations, Programs, Activities, and Functions,issuedb~ythe
U. S. General Accounting Office. Accordingly, the examination
included such tests of the accounting records and such other
auditing procedures as we considered necessary in the circum-
stances. Audit fieldwork was performed from August 10, 1987
through August 21, 1987.
We made a study and evaluation of internal accounting controls
related to PC&B costs as well as an audit of PC&B costs obligated
and disbursed under the Superfund appropriation for the fiscal
year ended September 30, 1984. Our scope was limited to the
audit of the adjusted PC&B costs and related internal controls
for the fiscal year ended September 30, 1984.
As part of the audit, PC&B costs disbursed for Superfund activi-
ties were selectively tested. The audit objectives were to
determine if:
(1) The Personnel Compensation and Benefits costs are pre-
sented fairly in accordance with applicable laws, regu-
lations, and guidelines;
(2) EPA management complied with laws and regulations
which, if not followed, might have a material effect
upon the Personnel Compensation and Benefits costs; and
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SCOPE AND OBJECTIVES (CONTINUED)
(3) EPA established an adequate system of internal account-
ing control to ensure the reliability of accounting and
management records for PC&B costs.
We previously performed a financial and compliance audit of the
portion of Superfund reported by the U.S. Environmental Pro-
tection Agency (EPA), Region 3 (Allowance Holder 03), for the
fiscal years ended September 30, 1984 and 1983, and issued our
Auditors' Report on Financial Statements dated April 30, 1985.
We expressed no opinion on the Statements of Obligations and
Statements of Disbursements presented in that report due to
errors in personnel compensation costs, internal control weak-
nesses and lack of identification of support services costs. Due
to the questioned and set-aside PC&B costs resulting from the
audit, EPA Region 3 conducted a review of PC&B costs for fiscal
1984 and made adjustments to the previously reported amounts.
SUMMARY OF AUDIT RESULTS
FINANCIAL RESULTS OF AUDIT
The financial result of our audit are summarized below and de-
tailed in the Exhibits.
Description
Personnel Compensation
Personnel Benefits
Total Personnel Com-
pensation and Benefits
Total
$2,098,510
235.505
$2.334,015
Accepted
$2,098,510
235,505
$2.334.015
RESULTS OF STATISTICAL ANALYSIS OF PERSONNEL COMPENSATION AND
BENEFITS TRANSACTIONS
We performed a statistical analysis of the adjusted Superfund
Personnel Compensation costs for the fiscal year ended September
30, 1984. Based upon the results of our testing of a random
sample of disbursement transactions, we are 95Z confident that
the Superfund Personnel Compensation costs were no greater than
$2,241,719 and no less than $2,001,101, with a precision of
$120,309. The recorded disbursements for Personnel Compensation
costs for fiscal 1984 were $2,098,510, which falls within the
upper, and lower limits. Consequently, we accepted the recorded
Personnel Compensation costs for fiscal 1984. Additionally,
based upon our review of Personnel Benefits for fiscal 1984, we
accepted the recorded amount of $235,505.
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BACKGROUND
The "Superfund" program was established by the Comprehensive En-
vironmental Response, Compensation and Liability Act of 1980
(CERCLA), Public Law 96-510, enacted on December 11, 1980. The
Superfund program was created to protect public health and the
environment from the release, or threat of release, of hazardous
substances from abandoned hazardous waste sites (sites) and other
sources where response was not required by other Federal laws. A
Trust Fund was established by CERCLA to provide funding for
responses ranging from control of emergency situations to
provision of permanent remedies at uncontrolled sites. CERCLA
authorized a $1.6 billion program financed by a five-year
environmental tax on industry and some general revenues. CERCLA
requires that response, or payment for response, be sought from
those responsible for the problem, including property owners,
generators and transporters.
The basic regulatory blueprint for the Superfund Program is the
National Oil and Hazardous Substances Contingency Plan (NCP), 40
CFR Part 300. The NCP was first published in 1968 as part of the
Federal Water Pollution Control Plan, and has been substantially
revised to meet CERCLA requirements. The NCP lays out two broad
categories of response: removals and remedial response. Re-
movals are relatively short-term responses, and modify an earlier
program under the Clean Water Act. Remedial response is long-
term planning and action to provide permanent remedies for seri-
ous abandoned or uncontrolled sites.
CERCLA recognizes that the Federal Government can only assume
responsibility for remedial response at a limited number of sites
representing the greatest public threat. It therefore requires
the maintaining of a National Priorities List (NPL), which must
be updated at least annually. The NPL is composed primarily of
sites which have been ranked on the basis of a standard scoring
system which evaluates their potential threat to public health.
In addition, each State was allowed to name its highest priority
site without regard to the ranking system.
CERCLA section 104(c)(3) provides that no remedial actions shall
be taken unless the State in which the release occurs enters into
a contract or cooperative agreement with EPA to provide certain
assurances, including cost-sharing. At most sites, the State
must pay 10 percent of the costs of remedial action. Preremedial
activities (preliminary assessments, site inspections), remedial
planning (remedial investigations, feasibility studies, remedial
designs) and removals may be funded 100 percent by EPA. For fa-
cilities operated by a State or political subdivision at the time
of disposal of hazardous substances, the State must pay at least
50 percent of all response costs, including removals and remedial
planning previously conducted.
i
CERCLA was revised and expanded by the Superfund Amendments and
Reauthorization Act of 1986 (SARA), Public Law 99-499, enacted on
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BACKGROUND (CONTINUED)
October 17, 1986. SARA reinstituted the environmental tax and
expanded the taxing mechanisms available for a five-year period.
It authorized an $8.5 billion program for the 1987-1991 period.
The Trust Fund was renamed the Hazardous Substance Superfund.
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TICHENOR & EICHE
CERTIFIED PUBLIC ACCOUNTANTS
THE SUMMIT, SUITE 200
4J50 BROWNSBORO ROAO
LOUISVILLE. KENTUCKY 40207
<502) 893-0700
Mr. Kenneth D. Hockman
U.S. Environmental Protection Agency
Divisional Inspector General for Audit
Internal Audit Division
Office of Inspector General
Washington, D.C. 20460
AUDITORS' REPORT ON PERSONNEL COMPENSATION AND BENEFITS
We have examined the Personnel Compensation and Benefits (PC&B)
costs of the U.S. Environmental Protection Agency (EPA), Region 3
(Allowance Holder 03) portion of the Hazardous Substance Response
Trust Fund (Superfund) for the fiscal year ended September 30,
1984, as presented in Exhibit 1. Our examination was performed
in accordance with generally accepted auditing standards and the
standards for financial and compliance audits contained in the
Standards for Audit of Governmental Organizations, Programs, Ac-
tivities, and Functions, issued By the U.S. Genera1 Account ing
Office.Additionally,the U.S. Environmental Protection Agency
Hazardous Substance Response Trust Fund Audit Guide (revised Feb-
ruary 23, 1987) was used as a guide in our examination. Accord-
ingly, our examination included such tests of the accounting re-
cords and such other auditing procedures as we considered neces-
sary in the circumstances.
We previously examined the Statements of Obligations and the
Statements of Disbursements of the U.S. EPA, Region 3 portion of
Superfund for the fiscal years ended September 30, 1984 and 1983,
and issued our Auditors' Report on Financial Statements dated
April 30, 1985. We expressed no opinion on the Statements of
Obligations and Statements of Disbursements presented in that
report due to errors in personnel compensation costs, internal
control weaknesses, and lack of identification of support ser-
vices costs. Subsequent to the issuance of our report, Region 3
conducted a review of PC&B costs for fiscal 1984 and made adjust-
ments to the previously reported amounts. At EPA's request, we
have examined Region 3's adjusted PC&B costs for fiscal 1984. We
did not examine any other elements or accounts in Statements of
Obligations and Che Statements of Disbursements which were pre-
viously reported on. This report does modify our report on those
statements dated April 30, 1985, as indicated in the fourth para-
graph.
The Statements of Obligations and the Statements of Disbursements
were prepared for EPA use by EPA's Financial Management Division
based upon Allowance Holder financial information contained in
the Financial Management System (Superfund Status Reports, dated
September 30, 1984 and 1983. The Personnel Compensation and
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AUDITORS' REPORT ON PERSONNEL COMPENSATION AND BENEFITS
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Benefits costs referred to in the first paragraph were prepared
by EPA based upon adjusted financial information contained in the
Financial Management System (PAYMERGE, as of August 13, 1987).
The statements and the PC&B costs referred to above are not
intended to present either the financial position or the
financial results of operations in conformity with generally
accepted accounting principles in that allowable costs and EPA
accounting policies and practices are legislatively established
and promulgated through various Federal and EPA policy and
procedural standards.
In our opinion, the Personnel Compensation and Benefits costs
referred to in the first paragraph and presented in Exhibit 1,
present fairly the PC&B costs of the U.S. EPA, Region 3 portion
of Superfund in accordance with applicable Federal laws, regula-
tions, policies, and program guidelines for the fiscal year ended
September 30, 1984.
This report is intended. for use in connection with the statements
and PC&B' costs to which it refers and should not be used for any
other purpose.
TICHENOR & EICHE
Louisville, Kentucky
August 21, 1987
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TlCHENOR & ElCHE
CERTIFIED PUBLIC ACCOUNTANTS
THE SUMMIT. SUITE 200
4350 BROWNSBORO ROAD
LOUISVILLE. KENTUCKY 40207
(502) 893-0700
Mr. Kenneth D. Hockman
U.S. Environmental Protection Agency
Divisional Inspector General for Audit
Internal Audit Division
Office of Inspector General
Washington, D.C. 20460
AUDITORS' REPORT ON INTERNAL ACCOUNTING CONTROL AND COMPLIANCE
We have examined the Personnel Compensation and Benefits (PC&B)
costs of the U.S. Environmental Protection Agency (EPA), Region 3
(Allowance Holder 03), portion of the Hazardous Substance Re-
sponse Trust Fund (Superfund) for the fiscal year ended September
30, 1984, and issued our Auditors' Report on Personnel Compen-
sation and Benefits thereon dated August 21, 1987. As part of
our examination, we made a study and evaluation of EPA, Region 3,
portion of Superfund system of internal accounting control for
PC&B costs to the extent we considered necessary to evaluate the
system,as required by generally accepted auditing standards and
the standards for financial and compliance audits contained in
the the Standards for Audit of Governmental Organizations, Pro-
grams, Activities, and Functions,issuedEytheU.S.General
AccountingOffice.Forthepurpose of this report, we have
classified the significant internal accounting controls into the
following transaction category:
Personnel compensation disbursements.
Our study included only the transaction category listed above.
The purpose of our study and evaluation was to determine the na-
ture, timing, and extent of the auditing procedures necessary for
the expressing an opinion on the Personnel Compensation and Bene-
fits costs. Our study and evaluation was more limited than would
be necessary to express an opinion on the system of internal ac-
counting control taken as a whole or on the category of control
identified above.
We previously examined the Statements of Obligations and
Statements of Disbursements of the U.S. EPA, Region 3 portion of
Superfund for the fiscal years ended September 30, 1984 and 1983
and issued our Auditors' Report on Financial Statements and
Auditors' Report on Internal Accounting Control and Compliance,
both dated April 30, 1985. Subsequent to the issuance of our
reports, Region 3 conducted a review of PC&B costs for fiscal
1984 and made adjustments to the previously reported amounts. At
EPA's request, we have examined Region 3's adjusted PC&B costs
and related internal controls for fiscal 1984. This report does
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4HPI.I9R.S.'.REPORT ON INTERNAL ACCOUNTING CONTROL AND COMPLIANCE
(CONTINUES)~
modify our reports on the statements and internal accounting
control and compliance dated April 30, 1985, as indicated in the
sixth paragraph.
EPA management is responsible for establishing and maintaining a
system of internal accounting control. In fulfilling this re-
sponsibility, estimates and judgments by management are required
to assess the expected benefits and related costs of control pro^
cedures. The objectives of internal accounting control are to
provide reasonable, but not absolute, assurance that assets are
safeguarded against loss from unauthorized use or disposition,
and that transactions are executed in accordance with manage-
ment's authorization and recorded properly to permit preparation
of financial reports in accordance with applicable Federal laws
and regulations. The concept of reasonable assurance recognizes
that the cost of a system of internal accounting control should
not exceed the benefits derived and also recognizes that the
evaluation of these factors necessarily requires estimates and
judgments by management.
There are inherent limitations that should be recognized in con-
sidering the potential effectiveness of any system of internal
accounting control. Because of inherent limitations in any sys-
tem of internal control, errors or irregularities may neverthe-
less occur and not be detected. In the performance of most
control procedures, errors can result from misunderstanding
instructions, mistakes of judgment, carelessness, or other
personal factors. Control procedures whose effectiveness depend
on segregation of duties can be circumvented by collusion.
Similarly, control procedures can be circumvented intentionally
by management, either with respect to the execution and recording
of transactions or with respect to the estimates and judgments
required in the preparation of financial statements. Further,
projection of any evaluation of internal accounting control to
future periods is subject to the risks that the procedures may
become inadequate because of changes in conditions and that the
degree of compliance with procedures may deteriorate.
Our study and evaluation, made for the limited purpose described
in the firfit paragraph, would not necessarily disclose all mate-
rial weaknesses in the system. Accordingly, we do not express an
opinion on the system of internal accounting control of EPA, Re-
gion 3, portion of Superfund taken as a whole or on the category
of control identified in the first paragraph. However, our study
and evaluation disclosed no condition that we believed to be a
material weakness in relation to the Personnel Compensation and
Benefits costs of EPA, Region 3, portion of Superfund.
The U.S. Environmental Protection Agency Hazardous Substance Re-
sponse" Trust Fund Audit Guide, (revised February 23, 1987) re-
quires areview andevaluation ofthe adequacy of the internal
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REpORT ON INTERNAL ACCOUNTING CONTROL AND COMPLIANCE
(CONTINUED) '
accounting controls of EPA, Region 3, portion of the Superfund as
a basis for reliance thereon and for the determination of the
resultant extent of the tests to which auditing procedures are to
be restricted. The audit guide also requires a review of CERCLA,
other regulations, policies, and guidelines to determine if Fed-
eral funds are being expended in accordance with provisions of
CERCLA, other regulations, policies, and guidelines.
The result of our tests indicate that for the items tested, EPA,
Region 3, complied with the provisions of CERCLA, other regu-
lations, policies, and guidelines except for the conditions de-
scribed in the Finding and Exhibits. Further, for the items not
tested, based upon our examination and the procedures referred- to
above, nothing came to our attention which indicated that EPA,
Region 3, had not complied with the provisions of CERCLA, other
regulations, policies, and guidelines referred to above, beyond
the conditions described in the Finding and Exhibits.
This report is intended .solely for the use of the EPA management
and should not be used for any other purpose.
TICHENOR & EICHE
Louisville, Kentucky
August 21, 1987
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FINDING
RESULTS OF STATISTICAL ANALYSIS OF PERSONNEL COMPENSATION AND
BENEFITS TRANSACTIONS:
We performed a statistical analysis of the adjusted Superfund
Personnel Compensation costs for the fiscal year ended September
30, 1984. Based upon the results of our testing of a random
sample of transactions, we are 95Z confident that the total
Personnel Compensation costs were no greater than $2,241,719 and
no less than $2,001,101, with a precision of $120,309. The
recorded disbursements for Personnel Compensation costs for
fiscal year 1984 were $2,098,510, which falls within the upper
and lower limits. Consequently, we accepted the recorded
Personnel Compensation costs for fiscal 1984. Additionally,
based upon our review of Superfund Personnel Benefits for fiscal
1984, we accepted the recorded amount of $235,505.
We noted improvement in the recording of Superfund personnel
costs as well as implementation of charging policies for
personnel compensation. We tested six key internal control at-
tributes for compliance with EPA policies and procedures. From
these six attributes, our statistical results indicated that the
exception rate in the sample for one attribute was in excess of
our expected error rate of 5.0Z, as follows:
Attribute
Pay rate correct
Note:
Sample
Size
223
Exceptions
In Sample
29(a)
Percent
of
Exceptions
13.OZ
Upper
Precision
Limit
16.11
(a) These errors were primarily errors in the maximum
overtime pay rates and stand-by pay rates for
sample transactions during Pay Periods 19 through
27, under the revised U.S. Office Personnel
Management Salary Table No. 69. These errors were
included- in the audited amounts for our stati-
stical projection and analysis and did not signi-
ficantly affect the results.
We discussed the above errors with Region 3 personnel and they
indicated that the input of pay rates and actual calculations of
pay amounts were made by EPA Headquarters in Washington, D.C.
Since the amounts were insignificant and did not materially
affect our audit results, we did not follow up on these apparent
errors. The additional five attributes tested indicated an
acceptable degree of compliance. Consequently, we make no
recommendations in this report.
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UNITED STATES
ENVIRONMENTAL PROTECTION AGENCY
REGION 3
PHILADELPHIA, PENNSYLVANIA
EXHIBIT 1
HAZARDOUS SUBSTANCE RESPONSE TRUST FUND (SUPERFUND)
PERSONNEL COMPENSATION AND BENEFITS (Note 1)
FISCAL YEAR ENDED SEPTEMBER 30, 1984
Description
Personnel Compensation
Personnel Benefits
Total Personnel Com-
pensation and Benefits
Total
$2,098,510
235.505
$2,334,015
Accepted
$2,098,510
235,505
$2,334,015
Note
2
3
The Notes to Personnel Compensation and Benefits are an integral
part of this statement.
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UNITED STATES
ENVIRONMENTAL PROTECTION AGENCY
REGION 3
PHILADELPHIA, PENNSYLVANIA
EXHIBIT 2
HAZARDOUS SUBSTANCE RESPONSE TRUST FUND (SUPERFUND)
NOTES TO PERSONNEL COMPENSATION AND BENEFITS
FISCAL YEAR ENDED SEPTEMBER 30, 1984
Note 1: Personnel Compensation and Benefits financial inform-
ation was prepared by EPA from information contained in
the Financial Management System (PAYMERGE, as of August
13, 1987).
Note 2: Personnel Compensation costs, from the financial in-
formation provided by EPA, contained 4 transactions
with negative values amounting to $2,991. These trans-
actions were excluded from our random sampling universe
and detailed information was provided to EPA Region'3
so that adjustments could be made to correct these ap-
parent errors. Due to the immateriality of the
amounts, these transactions were not questioned or set
aside.
Note 3: Personnel Benefits costs were examined only to deter-
mine the reasonableness of Region 3's Superfund bene-
fits costs to Superfund compensation costs. This per-
centage, amounting to 11.21, reflected the approximate
percentage of the total EPA's benefits to EPA's to
total compensation for Superfund personnel costs for
fiscal 1984 (10.7Z).
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