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.

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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

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                               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

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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 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

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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,  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

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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 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-

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                           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-

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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.
                               -4-

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      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-

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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-

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      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-

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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-

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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-

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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  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-

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                       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-

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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.
                              -12-

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                          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-

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