UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON, D.C. 204«0
0,,,cto,
THE INSPECTOR GENERAL
MEMORANDUM
SUBJECT: Report of Financial and Compliance Audit
of Region 4's Adjusted Personnel Compensation
and Benefits Under CERCLA for the Fiscal Year
Ended September 30, 1983
Audit Report No. P5EH7-11-0034-80612
EH7-11-0034-80612
7] o™n&
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The CPA audited the adjusted PC4B costs for fiscal 1983 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 CPAdid not examine any other elements or
accounts in the Statements of Obligations and Statements of Disbursements
which were previously reported on.
RESULTS OF AUDIT
The CPA accepted Regions 4's adjusted PC4B costs of $1,657,878 for the
fiscal year ended September 30, 1983. Additional details are contained
1n 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
A. Office of the Inspector General (A-109)
Divisional Inspector General
for Audit - Southern Division (1)
Director, Audit Operations Staff (3)
Chief, Program Analysis Unit (1)
B. Regional Office
Regional Administrator, Region 4
Audit Follow-up Coordinator
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: Resource 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 4
ATLANTA, GEORGIA
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, 1983
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UNITED STATES
ENVIRONMENTAL PROTECTION AGENCY
REGION A
ATLANTA, GEORGIA
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, 1983
TABLE OF CONTENTS
PAGE
SCOPE AND OBJECTIVES 1
SUMMARY OF AUDIT RESULTS 2
BACKGROUND 3
AUDITORS' REPORT ON PERSONNEL COMPENSATION
AND BENEFITS5
AUDITORS' REPORT ON INTERNAL ACCOUNTING
CONTROL AND COMPLIANCE7
FINDING
RESULTS OF STATISTICAL ANALYSia .,F PERSONNEL
COMPENSATION AND BENEFITS TRANSACTIONS10
EXHIBITS
EXHIBIT 1 - PERSONNEL COMPENSATION AND BENEFITS,'
FISCAL YEAR ENDED SEPTEMBER 30, T9%3 12
EXHIBIT 2 - NOTES TO PERSONNEL COMPENSATION AND
BENEFITS, FISCAL YEAR ENDED SEPTEMBER
30, 198313
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UNITED STATES
ENVIRONMENTAL PROTECTION AGENCY
REGION 4
ATLANTA, GEORGIA
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, 1983
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 4 (Allow-
ance Holder 04), for the fiscal year ended September 30, 1983.
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, ActTyities, and Functions,issuedb~ythe
U.S.GeneralAccountingOffice.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, 1983. Our scope was limited to the
audit of the adjusted PC&B costs and related internal controls
for the fiscal year ended September 30, 1983.
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 4 (Allowance Holder 04), for the
fiscal years ended September 30, 1984 and 1983, and issued our
Auditors' Report on Financial Statements dated May 23, 1985. We
qualified our opinion on the Statements of Obligations and State-
ments of Disbursements presented in that report due to errors in
recording personnel compensation costs, inadequate justification
and documentation for Superfund charging, and errors in calcula-
ting support services cost allocations. Due to the questioned
and set-aside PC&B costs resulting from the audit, EPA Region 4
conducted a review of PC&B costs for fiscal 1983 and made adjust-
ments to the previously reported amounts.
SUMMARY OF AUDIT RESULTS
FINANCIAL RESULTS OF AUDIT
The financial results of our audit are summarized below and de-
tailed in the Exhibits.
Description Total Accepted
Personnel Compensation $1,500,504 $1,500,504
Personnel Benefits 157.374 157,374
Total Personnel Compen-
sation and Benefits $1,657,878 $1,657,878
RESULTS OF STATISTICAL ANALYSIS OF PERSONNEL COMPENSATION AND
BENEFITS TRANSACTORS
We performed a statistical analysis of the adjusted Superfund
Personnel Compensation costs for the fiscal year ended September
30, 1983. Based upon the results of our testing ~f a random
sample of disbursement transactions, we are 95Z confident that
the Superfund Personnel Compensation costs were no greater than
$1,542,452 and no less than $1,361,899, with a precision of
$90,276. The recorded disbursements for Personnel Compensation
costs for fiscal 1983 were $1,500,504, which falls within the
upper and lower limits. Consequently, we accepted the recorded
Personnel Compensation costs for fiscal 1983. Additionally,
based upon our review of Superfund Personnel Benefits for fiscal
1983, we accepted the recorded amount of $157,374.
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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 rr !. Hazardous Substances Contingency PI?- (NCP), 40
CFR Part 300. The NCP was first published in 1968 S.L . i«:t 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.
CERCLA was revised and expanded by the Superfund Amendments and
Reauthorization Act of 1986 (SARA), Public Law 99-499, enacted o
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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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TlCHENOR & ElCHE
CERTIF/ED I'UBLIC ACCOUNTANTS
THE SUMMIT. SUITE 200
4350 BROWNS8ORO 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 PERSONNEL COMPENSATION AND BENEFITS
We have examined the Personnel Compensation and Benefits (PC&B)
costs of the U.S. Environmental Protection Agency (EPA), Region 4
(Allowance Holder 04) portion of the Hazardous Substance Response
Trust Fund (Superfund) for the fiscal year ended September 30,
1983, 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 b~y the 0". S. General Accounting
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 '~.S. EPA, Region 4 portion
Superfund for the fiscal years ended September 3n ^84 and 19o^,
and issued our Auditors' Report on Financial Statements dated May
23, 1985. We qualified our ooinion on the Statements of Obliga-
tions and Statements of Disbursements presented in that report
due to errors in personnel compensation costs, inadequate justi-
fication and documentation for Superfund charging, and errors in
calculating support services cost allocations. Subsequent to the
issuance of our report, Region 4 conducted a review of PC&B costs
for fiscal 1983 and made adjustments to the previously reported
amounts. At EPA's request, we have examined Region 4's adjusted
PC&B costs for fiscal 1983. We did not examine any other ele-
ments or accounts in the Statements of Obligations and Statements
of Disbursements which were previously reported on. This report
does modify our report on those statements dated May 23, 1985 as
indicated in the fourth paragraph.
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 Ben-
efits costs referred to in the first paragraph were prepared
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AUDITORS' REPORT ON PERSONNEL COMPENSATION AND BENEFITS
CONTINUE!)) — ~~~ -
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 4 portion
of Superfund in accordance with applicable Federal laws, regula-
tions, policies, and program guidelines for the fiscal year ended
September 30, 1983.
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
CEKHFl ED PUBLIC ACCOUNTANTS
THE SUMMIT. SUITE 200
4J50 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 4
(Allowance Holder 04), portion of the Hazardous Substance Re-
sponse Trust Fund (Superfund) for the fiscal year ended September
30, 1983, 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 4,
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.issuedBytheU.S.General
Accounting Office. For tKipurpose 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 State-
ments of the Disbursements of the U.S. EPA, Region * 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 May 23, 1985. Subsequent to the issuance of our
reports, Region 4 conducted a review of PC&B costs for fiscal
1983 and made adjustments to the previously reported amounts. At
EPA's request, we have examined Region 4's adjusted PC&B costs
and related internal controls for fiscal 1983. This report does
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AUDITORS' REPORT ON INTERNAL ACCOUNTING CONTROL AND COMPLIANCE
(CONTINUED)
modify our reports on the statements and internal accounting
control and compliance dated May 23, 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 judgements 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 ~bese factors necessarily requires e?-''rates 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 in-
structions, mistakes of judgment, carelessness, or other personal
factors. Control procedures whose effectiveness depend on segre-
gation of duties can be circumvented by collusion. Similarly,
control procedures can be circumvented intentionally by manage-
ment, either with respect to the execution and recording of
transactions or with respect to the estimates and judgments re-
quired 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 first 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 4, 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 4, portion of Superfund.
The U.S. Environmental Protection Agency Hazardous Substance Re-
sponse Trust Fund Audit Guide, (revised February 23, 1987) re-
quires areview and evaluationof the adequacy ofthe internal
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REPQRT ON INTERNAL ACCOUNTING CONTROL AND COMPLIANCE
(CONTINUED)
accounting controls of EPA, Region 4, 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 4, 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 4, 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, 1983. Based upon the results of our testing of a random
sample of disbursement transactions, we are 952 confident that
the Superfund Personnel Compensation costs were no greater than
$1,542,452 and no less than $1,361,899, with a precision of
$90,276. The recorded disbursements for Personnel Compensation
costs for fiscal 1983 were $1,500,504, which falls within the
upper and lower limits. Consequently, we accepted the recorded
Personnel Compensation costs for fiscal 1983. Additionally,
based upon our review of Personnel Benefits for fiscal 1983, we
accepted the recorded amount of $157,374.
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 rates in the sample for three attributes were in excess
of our expected error rates of 5.0Z, as follows:
Percent Upper
Sample Exceptions Of Precision
Attribute Size In Sample Exceptions Limit
Employees signature 136 24<.a) 17.11 23. fl"
Time & attendance
report agrees
with payroll
records (FMS) 209 13(b) 6.22 9.0Z
Time & attendance
report agrees
with timesheet 136 23(c) 16.92 22.22
Notes;
(a) These errors were primarily due to Region 4's inability
to locate the timesheets for certain employees. Howev-
er, we examined time and attendance reports signed by
timekeepers.
(b) Most of these errors were input errors caused by the
double input of data by contract personnel at EPA
Headquarters. Some of the original exceptions were
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FINDING (CONTINUED)
OF STATISTICAL ANALYSIS OF PERSONNEL COMPENSATION AND
BENEFITS TRANSACTIONS (CONTINUED)'
caused by mistakes made by timekeepers in transferring
hours from timesheets. For audit purposes, if a
timesheet was available, it was considered the ource
document in determining the proper charging ..a the
Financial Management System (FMS).
(c) These errors were caused by differences in Superfund
account numbers; the charging of hours between fiscal
years in Pay Period 1; and mistakes in transferring
hours from timesheets to time and attendance reports.
For audit purposes, if the timesheet was available, it
was considered the source document in determining prop-
er charging in the FMS.
We discussed the errors noted above with Region 4 personnel and
they indicated that due to the audit period (fiscal 1983), some
timesheets had not been retained or could not be located. Addi-
tionally, Region 4 personnel stated that many of the errors were
made by contractor personnel at EPA Headquarters during the
input of corrections of payroll data. We were able to satisfy
our audit requirements if the available timesheet or time and
attendance report agreed with the information in the FMS. Since
the combined effect of any unresolved errors did not materially
affect our projected audit dollar results, we did not attempt to
follow up on these apparent errors. Also, the procedures for
recording Superfund hours in the FMS has changed significantly
since fiscal 1983. The additional three attributes tested in-
dicated an acceptable degree of compliance. Consequently, we
make no recommendations in this report.
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UNITED STATES EXHIBIT 1
ENVIRONMENTAL PROTECTION AGENCY
REGION 4
ATLANTA, GEORGIA
HAZARDOUS SUBSTANCE RESPONSE TRUST FUND (SUPERFUND)
PERSONNEL COMPENSATION AND BENEFITS (Note 1)
FISCAL YEAR ENDED SEPTEMBER 30, 1983
Description Total Accepted Note
Personnel Compensation $1,500,504 $1,500,504 2
Personnel Benefits 157,374 157,374 3
Total Personnel Com-
pensation and Benefits $1,657,878 $1,657,878
The Notes to Personnel Compensation and Benefits are an integral
part of this statement.
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UNITED STATES
ENVIRONMENTAL PROTECTION AGENCY
REGION k
ATLANTA, GEORGIA
EXHIBIT 2
HAZARDOUS SUBSTANCE RESPONSE TRUST FUND (SUPERFUND)
NOTES TO PERSONNEL COMPENSATION AND BENEFITS
FISCAL YEAR ENDED SEPTEMBER 30, 1983
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 9 transactions
with negative values amounting to $5,706. These trans-
actions were excluded from our random sampling universe
and detailed information was provided to EPA Region k
so that adjustments could be made to correct these ap-
paror c errors. Due to the immateriality of the a-
mounts, these transactions were not quest.^ned or set
aside.
Note 3: Personnel Benefits costs were examined only to deter-
mine the reasonableness of Region 4's Superfund bene-
fits costs to Superfund compensation costs. This per-
centage, amounting to 10.5%, reflected the approximate
percentage of EPA's total benefits to EPA's total
compensation for Superfund personnel costs for fiscal
1983 (10.4%).
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