UNITED STATES ENVIRONMENTAL PROTECTION AGENCY WASHINGTON, D.C. 20460 FEB 161988 OFFICE OF 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. P5EH7-11-0034-80012 FROM: Kenneth D. Hockman fi c Divisional Inspector General for Audit Internal Audit Division (A-109) TO: Lee A. DeHihns III Acting Regional Administrator Region 4 0612 rfVc Attached are two copies of a Report of Financial and Compliance Audit of Region 4's adjusted Personnel Compensation and Benefits (PC&B) Under CERCLA for the Fiscal Year Ended September 30, 1983. We have no objection to the further release of this report at your discretion. SCOPE AND OBJECTIVES The firm of Tichenor and Eiche, Certified Public Accountan.. (UPA) previously examined the Statements of Obligations and the Statements of Disbursements of the U.S. EPA, Region 4's portion '-..' Sijperfund for the Fiscal Years ended September 30, 1984 and 1983. We transmitted the CPA's previous report to the Regional Administrator on June 19, 1986 (Audit Report No. P5EH5-11-0022- 61094). In that report, the CPA qualified their opinion on the Statements of Obligations and Statements of Disbursements presented due to errors in personnel compensation costs, inadequate justification and documentation for Sjpjrfund charging, and errors in calculating support services cost allocations. Subsequently, Region 4 personnel reviewed PCAB costs for fiscal 1983 and adjusted the previously reported amounts. ------- The CPA audited the adjusted PC&B costs for fiscal 1983 1n 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. RESULTS OF AUDIT The CPA accepted Regions 4's adjusted PCAB costs of $1,657,878 for the fiscal year ended September 30, 1983. 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 ------- DISTRIBUTION Copies A. Office of the Inspector General (A-109) 5 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 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: 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 ------- 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 ------- 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 TABLE OF CONTENTS PAGE SCOPE AND OBJECTIVES 1 SUMMARY OF AUDIT RESULTS 2 BACKGROUND 3 ————-^——- j AUDITORS' REPORT ON PERSONNEL COMPENSATION AND BENEFITS5 AUDITORS' REPORT ON INTERNAL ACCOUNTING CONTROL AND COMPLIANCE7 FINDING RESULTS OF STATISTICAL ANALYSIS OF PERSONNEL COMPENSATION AND BENEFITS TRANSACTIONS. 10 EXHIBITS EXHIBIT 1 - PERSONNEL COMPENSATION AND BENEFITS,' FISCAL YEAR ENDED SEPTEMBER 30, l"9"53 12 EXHIBIT 2 - NOTES TO PERSONNEL COMPENSATION AND BENEFITS, FISCAL YEAR ENDED SEPTEMBER 30, 198313 ------- 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, Ac"tlvities, and Functions, issued b~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, 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 ------- 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 TRANSACTlO'Ng 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 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. -2- ------- BACKGROUND The "Superfund" program was established by Che 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 rri Hazardous Substances Contingency Plan (NCP), 40 CFR Part 300. The NCP was first published in 1968 as pa^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>. -3- ------- 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. -4- ------- TICHENOR & 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 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 5y the U.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 'U.S. EPA, Region 4 portion of Superfund for the fiscal years ended September 30. 7 984 and 1983, and issued our Auditors' Report on Financial Statements dated May 23, 1985. We qualified our opinion 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 -5- ------- AUDITORS' REPORT ON PERSONNEL COMPENSATION AND BENEFITS CONTINUED! 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 -6- ------- TlCHENOR & EICHE 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 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,issued5ytheU.S.General Accounting Office. For the purpose 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 4 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 -7- ------- AUDITORS' REPORT ON INTERNAL ACCOUNTING CONTROL AND COMPLIANCE (CONTINUEDT ' 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 these factors necessarily requires es.t.urates 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 oftheinternal -8- ------- AUDITORS' REPORT 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 -9- ------- 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 95% 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 5.0%, as follows: Attribute Sample Size Employees signature 136 Time & attendance report agrees with payroll records (FMS) 209 Time & attendance report agrees with timesheet 136 Exceptions In Sample 24(a) 13(b) 23(0 Percent Of Exceptions 17.7% Upper Precision Limit 23.0%, 6.2% 16.9% 9.0% 22.2% 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 -10- ------- FINDING (CONTINUED) RESULTS 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 r.ource document in determining the proper charging in 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. -11- ------- 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. -12- ------- UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION 4 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 A so that adjustments could be made to correct these ap- parcr.t errors. Due to the immateriality, .of the a- mounts, these transactions were not questioned 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%). -13- ------- |