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Environmental Cleanup: Inadequate Army Oversight of Rocky Mountain Arsenal Shared Costs (Letter Report, 01/23/97, GAO/NSIAD/AIMD-97-33).

The Rocky Mountain Arsenal, located on 17,000 acres northeast of Denver,
is one of the Defense Department's most contaminated installations. The
military manufactured chemical weapons there for decades, and the Army
leased part of the arsenal to the Shell Oil Company, which produced
herbicides and pesticides. GAO found that the Army's process for
reviewing claims under its cost sharing for cleanup at the arsenal falls
short in ensuring that costs claimed by Shell are appropriate. The
review process does not always ensure that (1) enough documentation is
available to review claimed costs and (2) formal agreements exist
defining which costs should be shared. The review process generally does
not look at the detailed documentation supporting cost claims. GAO found
that in most cases further information was available, but in some cases,
it was not. Also, the review process lacks effective checks and
balances, such as separation of key duties and responsibilities and
independent review. The combination of limited documentation and
inadequate controls places the government at risk of paying for
unwarranted charges.

--------------------------- Indexing Terms -----------------------------

     TITLE:  Environmental Cleanup: Inadequate Army Oversight of Rocky 
             Mountain Arsenal Shared Costs
      DATE:  01/23/97
   SUBJECT:  Environmental monitoring
             Cost sharing (finance)
             Army facilities
             Accounting procedures
             Internal controls
             Claims processing
             Expense claims
             Claims settlement
             Pollution control
             Waste disposal

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================================================================ COVER

Report to Congressional Requesters

January 1997




Environmental Cleanup


=============================================================== ABBREV

  CERCLA - Comprehensive Environmental Response, Compensation, and
     Liability Act
  DOD - Department of Defense

=============================================================== LETTER


January 23, 1997

The Honorable Ben Nighthorse Campbell
United States Senate

The Honorable Dan Schaefer
The Honorable John D.  Dingell
House of Representatives

As you requested, we examined cleanup costs claimed by Shell Oil
Company and shared by Shell and the U.S.  Army at Rocky Mountain
Arsenal, Colorado.  Specifically, we assessed selected aspects of the
processes that the Army uses to review cost claims under its
settlement agreement with Shell.  This report discusses the adequacy
of these processes. 

------------------------------------------------------------ Letter :1

The Army's current mission at Rocky Mountain Arsenal is to clean up
the contaminated soils, structures, and groundwater there.  The
arsenal, established in 1942, occupies 17,000 acres northeast of
Denver, Colorado, and is contaminated from years of chemical and
weapons activities.  The Army manufactured chemical weapons, such as
napalm bombs and mustard gas, and conventional munitions until the
1960s and destroyed weapons at the arsenal through the 1980s.  In
addition, it leased a portion of the arsenal to Shell from 1952 to
1987 to produce herbicides and pesticides. 

In 1983, the United States sued Shell Oil Company for its share of
the cleanup costs.  In February 1989, after extended litigation, the
Army and Shell signed the Rocky Mountain Arsenal Settlement Agreement
and the related Rocky Mountain Arsenal Federal Facility Agreement.\1
The agreements apportion cleanup costs to be paid by each party and
costs to be shared by both, direct that environmental legislation be
complied with, and provide a procedure for resolving disputes.  An
additional document, the Army/Shell Rocky Mountain Arsenal Financial
Manual, provides an overview of financial, accounting, and auditing
policies for costs related to the cleanup.  Descriptions of the
agreements and cost categories and guidance are contained in
appendixes I and II. 

Shell uses contractors for cleanup activities.  Two primary contracts
provide for studies and cleanup activities and cover about 86 percent
of Shell's shared costs.  A third contract provides for public
affairs support.  Each quarter, Shell provides the Army a claim for
its allocable, or shared, costs.  After review, the Army generates a
quarterly statement, from which the Army determines how much each
party owes.  Under the agreements, the shared cost to be borne by
each party is a percentage of the total shared costs (see table 1). 

                                Table 1
                Shared Costs to Be Paid by the Army and
                           Shell Oil Company

                                                        Percen  Percen
                                                          t of    t of
                                                         total   total
                                                         to be   to be
                                                          paid    paid
Cumulative total of allocable costs (Army and Shell         by      by
combined)                                                 Army   Shell
------------------------------------------------------  ------  ------
Up to $500,000,000                                          50      50
$500,000,000 to $700,000,000                                65      35
Over $700,000,000                                           80      20
As we previously reported, when the Army negotiated the settlement
agreement, it estimated the shared cleanup cost would be less than
$700 million, which would not have breached the demarcation between
the 65/35 percent split and the 80/20 percent split.\2 The Department
of Defense (DOD) currently estimates the cost for arsenal cleanup at
$2.1 billion.\3

As of December 1995, the Army's quarterly statement showed shared
costs of $656 million.  Army officials stated that shared costs
reached $700 million in November 1996, and thus, the Army would begin
80 percent of the shared costs.  According to Army officials, as of
December 1995, the Army had incurred $308 million in costs not shared
by Shell.  Shell officials told us Shell's nonallocable costs
amounted to $95 million for studies, cleanup activities, and program
management costs, including litigation. 

\1 Other signatories were the Departments of Interior, Justice, and
Health and Human Services, and the Environmental Protection Agency. 

\2 Environmental Cleanup:  Progress in Resolving Long-standing Issues
at the Rocky Mountain Arsenal (GAO/NSIAD-96-32, Mar.  29, 1996). 

\3 Defense Environmental Restoration Program Annual Report to
Congress, dated May 15, 1996, for fiscal year 1995. 

------------------------------------------------------------ Letter :2

The process the Army uses to review claims under its cost sharing for
cleanup at the arsenal has not been sufficient to ensure that costs
claimed by Shell are appropriate.  Specifically, the review process
does not always ensure that (1) sufficient documentation is available
to review claimed costs and (2) formal agreements exist to define
which costs should be shared.  The review process generally does not
look at the detailed documentation supporting cost claims.  Our work
showed in most cases further information was available, but in some
cases, it was not. 

Also, the review process does not have effective checks and
balances--such as separation of key duties and responsibilities and
independent reviews.  For example, staff associated on a daily basis
with the shared cost system also conduct the annual assessment of the
shared costs.  The combination of limited documentation and
inadequate controls places the government at the risk of paying for
unwarranted charges. 

------------------------------------------------------------ Letter :3

The Army's process to review cost sharing claims under its settlement
agreement with Shell is insufficient to ensure that costs are
documented and appropriate.  Weaknesses in the process involve (1)
documentation to support claims, (2) agreements to define which costs
should be shared, (3) separation of duties for recording and
reviewing shared costs, and (4) documentation of decisions on the
treatment of capital assets and disposition of real estate.  Federal
standards require that, among other elements, internal control
systems provide reasonable assurance that assets are safeguarded and
that revenues and expenditures are recorded and accounted for

\4 The Federal Managers' Financial Integrity Act of 1982 (31 U.S.C. 
3512) requires that agencies' systems must comply with internal
control standards prescribed by the Comptroller General.  Standards
for Internal Controls in the Federal Government were issued in 1983
by us as required by the act. 

---------------------------------------------------------- Letter :3.1

The Arsenal Financial Manual allows costs to be disputed on several
grounds.  Specifically, costs can be disputed if:  the work was not
supported by a task plan, the work was not performed or the costs
were not incurred, duplicate charges were made, or the costs were
arbitrary and capricious in comparison with normal commercial
practices.  However, the Army's review of the costs to be shared with
Shell has been minimal.  Our work showed that additional
documentation is available in most cases and could have been reviewed
by the Army.  In some cases, however, more documentation would have
been needed to perform detailed reviews. 

We examined 153 randomly selected summary vouchers covering $31
million of Shell's allocable costs incurred from January 1988 to
February 1995.  As part of this examination, we reviewed
documentation that Shell had provided the Army in support of its
quarterly cost claim.  We also reviewed secondary documentation
maintained by the primary contractor.  Based on these examinations
and additional data later provided by Shell, we stated in our draft
report that 31 entries for items totaling $3.1 million lacked the
documentation needed for the Army to review the appropriateness of
the cost claims.  In some cases, the claims were partially
documented, and in others, there was no documentation provided. 

In commenting on the draft report, Shell stated that in every
instance, adequate information was either already in our possession
or provided to us in meetings during March and April 1996.  Shell
further stated that full support was attached to invoices for each of
three examples cited in our report.  We again met with
representatives of Shell and its principal contractor, Morrison
Knudsen, in November 1996, but most of the documentation was not yet
available and we agreed to examine additional documentation that was
provided to us in December 1996.  As a result of the most recent
data, we revised the examples described below.  The difficulty in
obtaining documentation for the three examples illustrates our point
that the Army needs to have procedures for documentation and the
examination of claims. 

Taking the additional information into consideration, the following
are examples from our sample of selected summary vouchers where
insufficient documentation was available to make an adequate review
of shared costs. 

  -- For a $666,035 line item at first described as "other direct
     costs," support for only $30,125 had been provided to us at the
     time of our draft report.  Shell provided detailed support by
     December 1996 for an additional $479,015.  The detailed support
     indicated that the costs were for contractor studies and left
     $156,895 in need of further documentation. 

  -- $301,977 for brine disposal by a subcontractor did not have, at
     the time of our draft report, information on the quantity to be
     paid for, such as number and size of railroad tank cars.  The
     separate agreements cited in Shell's comments permitted payments
     up to a limit, but data on actual amounts were still needed. 
     Such data were provided for $266,723, but were still lacking for
     the remaining $35,254. 

  -- $187,275 of $326,566 for operations of an incinerator appeared
     to be for incentive awards but was not specified sufficiently,
     such as the number or type, to show the basis for the
     expenditure.  The claim did not actually include awards, and
     support for $166,183 was provided in December 1996, although a
     clear link to invoices was not always shown.  The remaining
     $21,092 lacked sufficient detail. 

Overall, the Army does not have detailed procedures for examining
Shell's shared costs.  In the absence of such procedures, the Army's
examination consists of comparing Shell's monthly costs with the
previous month's costs to look for significant variances. 

We found that the Army has not fully exercised its authority to
review the costs of Shell's contractors and subcontractors.  For
example, the Army shared about $48 million in costs that Shell
claimed for technical studies, but has not examined the relevant
contracts.  Army officials said that they operate with Shell in an
atmosphere of trust.  They also stated that they believe that they
have no right to interfere in Shell's relationship with its
contractors and that standard government contract controls do not
apply to Shell's commercial contracts.  Notwithstanding these points,
the Army is permitted to review Shell's costs under the arsenal
agreements and should do so to ensure that costs being claimed are

---------------------------------------------------------- Letter :3.2

The arsenal agreements require that shared costs be supported by an
approved task plan or other written agreement.  The arsenal's Program
Manager's Office and Shell officials have made numerous agreements
implementing the guidance in the settlement agreement.  However, not
all agreements were written, and written agreements sometimes lacked
approval signatures, estimates of costs to be incurred, clear
descriptions of the tasks to be done, or statements that costs can be
shared.  Of the
153 summary vouchers we reviewed, 48 lacked specific written support,
such as a signed agreement, a statement stipulating that the item was
allocable or reimbursable, or authorization for the task.  In some
cases where signed agreements were lacking, Shell and the Army used
their commercial and government practices as a standard in
determining reasonableness of costs. 

Community relations activities is one area where cost sharing
agreements have not been finalized and documentation was limited,
thus making it difficult to adequately review claims.  A written
agreement was drafted and dated June 1990 (retroactive to January
1988), but was never signed.  Although the unsigned agreement called
for the Army to assume the lead responsibility in this area, Shell
retained a contractor to provide public relations support.  Shell and
Army officials stated that for guidance on community relations
activities, they refer to the requirements of the Comprehensive
Environmental Response Compensation and Liability Act. 

Our random sample included $481,000 in charges for public affairs
activities, and the Army had approved them based on two Shell
statements of allocable costs that gave totals for broad categories. 
Incurred from August 1991 through December 1992, the largest
categories were for public affairs activities regarding the
successful operation of an incinerator ($245,047), public
education/involvement ($120,927), and agency support ($73,864).  Each
category in the statements included a brief summary but no breakout
of amounts for specific activities.  Breakouts were often available
on request, but detailed expense data were incomplete.  For example,
Shell provided additional data to us showing that public
education/involvement included subcategories such as an arsenal
brochure ($19,066), a Fish and Wildlife Service Spring Event
($14,480), and Bald Eagle Day ($15,567).  Further, the detailed data
for Bald Eagle Day showed $4,679 for unspecified labor costs; $4,622
for promotional "eagle pencils;" $3,026 for advertising; $1,278 for
bus service; and other categories of less than $1,000 each for such
items as photographs, videotape, copying, and box lunches. 

We did not review the appropriateness of individual cost claims. 
However, the above examples further demonstrate that the Army has not
ensured it has sufficient information to review shared costs.  The
arsenal's Director of Public Affairs stated that he would require
supporting documentation on such claims in the future. 

---------------------------------------------------------- Letter :3.3

Federal standards require that internal control systems provide
reasonable assurance that expenditures are documented, recorded, and
accounted for properly.  We found that the Army has not adequately
documented its decisions concerning some capital assets and real

For example, as part of interim response activities, Shell had to
vacate an office building it owned and occupied on the arsenal.  The
Army provided land on the arsenal for Shell to build a replacement
building.  The Army also reimbursed Shell for the full $670,000 cost
of construction.  Several provisions in the arsenal agreements could
allow construction to take place on the arsenal.  Depending on the
circumstances that caused the building to be vacated and a
replacement built, the construction might have been an Army-only
cost, a Shell-only cost, or a shared cost.  In this case, the
building was treated as an Army-only cost, but the reasons for this
treatment were not documented. 

In another instance, the Army did not document the basis for a
transaction with Shell.  Shell purchased property located just
outside the arsenal's north boundary for about $4 million.  The Army
needed access to the land to conduct offsite groundwater treatment
activities.  The groundwater treatment was a shared cost.  Shell
purchased the land because it was able to do so more quickly than the
Army would have been able to, according to Army and Shell officials. 
For its use of the property, the Army paid Shell about $2 million
through transaction adjustments--half the purchase price.  The land
is well situated for commercial and industrial development as it is
near an interstate highway and the new Denver International Airport
(see fig.  1).  Shell will retain the land when cleanup is complete. 

   Figure 1:  Rocky Mountain
   Arsenal and Surrounding Area

   (See figure in printed

Another instance involved capital assets purchased by Shell and
charged as an allocable cost.  The Army could receive a proportionate
credit for such assets as vehicles, office equipment, and furniture,
when they are disposed of or sold.  However, the identification and
disposition of the allocable assets was not documented.  In
discussing this issue, Army and Shell officials did not provide
detailed documentation, but described the disposition of a large set
of assets relating to an incinerator.  They stated that the Army had
received a credit for items sold and that other items were being

---------------------------------------------------------- Letter :3.4

Because the same Army staff members record, review, and audit Shell's
allocable costs, the Army does not have adequate control over the
shared cost process.  Federal internal control standards require that
key duties and responsibilities such as recording and reviewing
transactions be separated systematically among individuals to protect
the government against error, waste, and wrongful acts. 

Moreover, the Army and Shell staff who conduct the day-to-day
operation of the shared cost system also review the shared costs
annually.  In 1988 and 1989, the Army Audit Agency reviewed Shell's
costs and found numerous problems, including insufficient
documentation and costs claimed without a task plan.  Although the
annual reviews by operating staff continue, there have been no other
independent verifications or follow-on audits of Shell's shared

------------------------------------------------------------ Letter :4

The Army will be paying 80 percent of millions of dollars in shared
costs for the cleanup of Rocky Mountain Arsenal.  Strengthening its
review process for shared cost claims is key to ensuring appropriate
sharing of costs.  Thus, we recommend that the Secretary of the Army

  -- establish specific procedures for the examination of Shell's
     cost claims and documentation, including costs of its
     contractors and subcontractors;

  -- establish standard procedures for the approval and documentation
     of supplementary agreements regarding the allocability of costs
     and treatment of capital assets and real estate; and

  -- require that such key duties and responsibilities as recording
     and reviewing transactions be performed by different

------------------------------------------------------------ Letter :5

Both DOD and Shell provided written comments on a draft of this
report (see apps.  III and IV).  DOD concurred with our
recommendations regarding procedures for documentation of costs and
agreements, but noted that adequate documentation exists for most
shared cost claims.  In its comments, Shell did not agree that
documentation it made available was insufficient to review the
appropriateness of the cost claims. 

In its comments concerning our two recommendations for procedures to
ensure documentation of costs and agreements, DOD stated that most
claims were documented.  However, we identified cases where
documentation for summary vouchers and cost sharing agreements for
the tasks involved was lacking.  We continue to believe that these
conditions represent weaknesses in the Army's review process. 

With regard to Shell documentation, we do not recommend action on
individual items, but focus on the Army's review process.  We agree
that Shell provided records, but the amounts did not always support
the summary vouchers we examined.  We believe that our comments
regarding the weaknesses in the review process are correct, but
revised our report to reflect the additional information provided by
Shell and its contractor.  Our initial review raised questions about
support for 55 of 153 items.  After discussing the 55 with Shell and
its contractor and examining additional contractor documents during
March and April 1996, we reduced the number of items with questions
to the 31 cited in our draft report, including the 3 examples. 
Following Shell's written comments, we met again in November and
December regarding the examples.  A substantially greater amount is
now supported, but gaps remain in each example, as described in this

Finally, DOD partially concurred with our recommendation for
separation of duties, stating that it complies with requirements
under procedures now in place.  We recognize that internal controls
are adapted to the risks being faced and the resources available. 
DOD has attempted to address such control issues by designating one
person in a two-person group to be a staff accountant to review data
and the other to make sure data are generally complete.  We believe
controls could be further strengthened by having others--who do not
conduct the day-to-day operation--be responsible for the annual
review of shared costs.  This is a particular issue where only one
external review has been made of transactions, and that was just
after the settlement agreement was put in place 8 years ago. 

------------------------------------------------------------ Letter :6

We interviewed officials at, and reviewed documentation provided by
the arsenal Program Manager; Shell Oil Company, Denver, Colorado, and
Houston, Texas; the Defense Contract Audit Agency, Boise, Idaho;
Morrison Knudsen and Holme Roberts Owen, Denver, Colorado; and the
state of Colorado. 

We obtained and reviewed Army and Shell shared cost documentation,
but we did not verify the total reported costs.  We reviewed 153
randomly selected items from Shell's journal entries for allocable
and reimbursable costs incurred from January 1988 to February 1995. 
We also reviewed all monthly invoices for allocable costs from the
Shell contractors Morrison Knudsen and Holme Roberts Owen incurred
for the fourth quarter, ending November 1988, through the third
quarter 1995.  We examined supporting documents provided by Shell and
its contractors.  We did not review the appropriateness of individual
cost claims.  Although we examined additional documentation provided
by shell and its contractor for 3 examples in our report, we did not
pursue additional documentation for the remaining 28 of the 31 sample
items cited in the report. 

We conducted our review from April 1995 to December 1996 in
accordance with generally accepted government auditing standards. 

---------------------------------------------------------- Letter :6.1

Unless you publicly announce its contents earlier, we plan no further
distribution of this report until 30 days from its issue date.  At
that time, we will send copies to appropriate congressional
committees.  We will also make copies available to others on request. 

If you or your staff have any questions concerning this report,
please contact me on (202) 512-8412.  Major contributors to this
report are listed in appendix V. 

David R.  Warren, Director
Defense Management Issues

=========================================================== Appendix I

The Army and Shell formalized their agreements and guidance regarding
activities and costs for environmental cleanup at the Rocky Mountain
Arsenal in the Rocky Mountain Arsenal Settlement Agreement, the
Federal Facility Agreement, and the Financial Manual. 

--------------------------------------------------------- Appendix I:1

The Settlement Agreement establishes a mechanism for apportioning
cleanup responsibilities and costs between the Army and Shell.  The
agreement defines allocable costs and includes lists of Shell-only
and Army-only costs.  Under this agreement, Shell may hire
contractors "subject to the approval of the Army."

--------------------------------------------------------- Appendix I:2

The Federal Facility Agreement ensures compliance with environmental
legislation, including the Comprehensive Environmental Response,
Compensation, and Liability Act (CERCLA) of 1980 (42 U.S.C.  9601),
and establishes a procedure that allows the various participants to
cooperate in environmental cleanup at the arsenal.  It "provides the
process for the planning, selection, design, implementation,
operation, and maintenance of response actions taken pursuant to
CERCLA as the result of the release or threatened release of
hazardous substances, pollutants or contaminants at or from the
arsenal, including the public participation process."

--------------------------------------------------------- Appendix I:3

The Financial Manual describes the financial, accounting, and
auditing procedures to be used for shared costs incurred in
connection with arsenal cleanup.  It describes primary and secondary
documentation for allocable costs and includes examples of some
documentation.  It provides procedures under which cost-related
disputes between the Army and Shell are to be settled, but it does
not include procedures for examining and accepting shared costs.  The
Manual stipulates that the procedures described in it will be
conducted in accordance with generally accepted accounting principles
consistently applied. 

========================================================== Appendix II

The following material summarizes cost definitions found in the Rocky
Mountain Arsenal Settlement Agreement, which provides guidance
regarding allocable, reimbursable, Shell-only, and Army-only costs. 
The Army and Shell supplement this guidance with agreements on the
specific tasks to be included in each category. 

-------------------------------------------------------- Appendix II:1

The Settlement Agreement defines allocable costs as

  -- all response costs, excluding Army-only and Shell-only costs;

  -- all response costs for activities outside the arsenal

  -- associated costs for involvement of the Environmental Protection
     Agency, the Agency for Toxic Substances and Disease Registry,
     and the Department of the Interior;

  -- all natural resource damage assessment costs; and

  -- other costs agreed on in writing by the Army and Shell as
     allocable costs. 

-------------------------------------------------------- Appendix II:2

Exhibit D of the Settlement Agreement describes Shell-only costs as
those pertaining to the following actions: 

  -- demolition, removal, and disposal of all buildings and
     structures owned by Shell or its predecessor company (includes a
     list of the structures);

  -- demolition, removal, and disposal of all equipment in
     Shell-owned structures and in buildings leased by Shell
     immediately before the effective date of the Settlement

  -- assessment activities associated with the two above activities;

  -- Shell staff at the Central Repository and the Joint
     Administrative Record and Document Facility;

  -- Shell activities associated with dispute resolution, judicial
     review, and the Technical Review Committee; and

  -- Shell's program management, including labor, materials,
     supplies, and overhead for Shell's Denver Project Site Team,
     litigation support, legal fees, and auditing expenses. 

-------------------------------------------------------- Appendix II:3

Exhibit C of the Settlement Agreement describes Army-only costs as
those pertaining to the following actions: 

  -- assessment, demolition, removal, and disposal of all buildings,
     structures, and equipment not listed as Shell-only in Exhibit D;

  -- assessment, identification, removal, and disposal of unexploded

  -- assessment, decontamination, removal, treatment, and/or disposal
     of all soil, excluding soil that includes a Shell compound, in
     specified areas;

  -- Army staff, and all facilities and equipment, for the Central
     Repository and the Joint Administrative Record and Document

  -- Army activities associated with dispute resolution, judicial
     review, and the Technical Review Committee;

  -- Army program management, including labor, materials, supplies,
     and overhead for the Army's arsenal Program Manager's Office and
     its divisions, litigation support, legal fees, and auditing
     expenses; and

  -- other specific miscellaneous actions, such as emergency action
     responses to a release of pollutants or contaminants. 

(See figure in printed edition.)Appendix III
========================================================== Appendix II

(See figure in printed edition.)

(See figure in printed edition.)

(See figure in printed edition.)Appendix IV
========================================================== Appendix II

(See figure in printed edition.)

=========================================================== Appendix V


Brad Hathaway, Associate Director
Uldis Adamsons, Assistant Director


Lisa Jacobson, Director


Lowell Hegg, Assistant Director, AIMD
Suzanne Macfarlane, Evaluator-in-Charge, NSIAD
John Furutani, Evaluator, AIMD
Lori Hendrickson, Evaluator, AIMD
C.  Robin Hodge, Evaluator, AIMD
Tony Leonard, Evaluator, AIMD
Wendy Matthews, Evaluator, AIMD


Margaret Armen, Senior Attorney

*** End of document. ***