United States General Accounting Office

GAO Report to Congressional Requesters

January 1997 ENVIRONMENTAL

CLEANUP

Inadequate Army

Oversight of Rocky

Mountain Arsenal

Shared Costs

GAO/NSIAD/AIMD-97-33

GAO United States

General Accounting Office

Washington, D.C. 20548

National Security and

International Affairs Division

B-270287 

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.

Background 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.

1

Other signatories were the Departments of Interior, Justice, and Health and Human Services, and the

Environmental Protection Agency.

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B-270287 

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

Cumulative total of allocable costs (Army and Shell

combined)

Percent of

total to be

paid by

Army

Percent of

total to be

paid by

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 paying 

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.

Results in Brief 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

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.

Page 2 GAO/NSIAD/AIMD-97-33 Environmental Cleanup
B-270287 

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.

The Army’s Process to

Control Cost Sharing

Has Weaknesses

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 properly.4

Insufficient Review of

Documentation for Shared

Cost Claims

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

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.

Page 3 GAO/NSIAD/AIMD-97-33 Environmental Cleanup
B-270287 

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.

Page 4 GAO/NSIAD/AIMD-97-33 Environmental Cleanup
B-270287 

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 appropriate.

Lack of Agreement to

Authorize Tasks and Costs

to Be Shared

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.

Page 5 GAO/NSIAD/AIMD-97-33 Environmental Cleanup
B-270287 

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.

Undocumented Treatment

of Capital Assets and Real

Estate

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 estate.

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.

Page 6 GAO/NSIAD/AIMD-97-33 Environmental Cleanup
B-270287 

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

Property to be retained by Shell Oil Company

76

270

Denver


International


Airport

Commerce


City

Rocky


Mountain


Arsenal

96th Av

88th Av Tower Rd

Pena Blvd. ~

Proposed

Watkins

E 128th Ave

Henderson

Dupont

120th Av

Northglenn

104 Av

44

2

265

470

DENVER

N

70

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

Page 7 GAO/NSIAD/AIMD-97-33 Environmental Cleanup
B-270287 

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 stored.

Inadequate Separation of

Duties and Independent

Reviews

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 costs.

Recommendations 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 individuals.

DOD’s and the Shell

Oil Company’s

Comments and Our

Evaluation

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.

Page 8 GAO/NSIAD/AIMD-97-33 Environmental Cleanup
B-270287 

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 report.

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.

Scope and

Methodology

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.

Page 9 GAO/NSIAD/AIMD-97-33 Environmental Cleanup
B-270287 

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.

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

Page 10 GAO/NSIAD/AIMD-97-33 Environmental Cleanup
Page 11 GAO/NSIAD/AIMD-97-33 Environmental Cleanup
Contents

Letter 1

Appendix I 

Description of

Agreements Between

the Army and Shell

Regarding Rocky

Mountain Arsenal

14

The Rocky Mountain Arsenal Settlement Agreement 14

The Rocky Mountain Arsenal Federal Facility Agreement 14

The Army/Shell Rocky Mountain Arsenal Financial Manual 14

Appendix II 

Description of Cost

Categories and

Guidance

15

Allocable Costs 15

Shell-Only Costs 15

Army-Only Costs 15

Appendix III 

Department of

Defense Comments

17

Appendix IV 

Shell Oil Company

Comments

20

Appendix V 

Major Contributors to

This Report

22

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

Company

2

Figure Figure 1: Rocky Mountain Arsenal and Surrounding Area 7

Abbreviations

CERCLA Comprehensive Environmental Response, Compensation,

and Liability Act

DOD Department of Defense

Page 12 GAO/NSIAD/AIMD-97-33 Environmental Cleanup
Page 13 GAO/NSIAD/AIMD-97-33 Environmental Cleanup
Appendix I 

Description of Agreements Between the

Army and Shell Regarding Rocky Mountain

Arsenal

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.

The Rocky Mountain

Arsenal Settlement

Agreement

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.”

The Rocky Mountain

Arsenal Federal

Facility Agreement

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.”

The Army/Shell Rocky

Mountain Arsenal

Financial Manual

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.

Page 14 GAO/NSIAD/AIMD-97-33 Environmental Cleanup
Appendix II 

Description of Cost Categories and

Guidance

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.

Allocable Costs 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 boundaries;

• 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.

Shell-Only Costs 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 Agreement;

• 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.

Army-Only Costs 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 ordnance;

Page 15 GAO/NSIAD/AIMD-97-33 Environmental Cleanup
Appendix II 

Description of Cost Categories and

Guidance

• 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 Facility;

• 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.

Page 16 GAO/NSIAD/AIMD-97-33 Environmental Cleanup
Appendix III 

Department of Defense Comments

Page 17 GAO/NSIAD/AIMD-97-33 Environmental Cleanup
Appendix III 

Department of Defense Comments

Page 18 GAO/NSIAD/AIMD-97-33 Environmental Cleanup
Appendix III 

Department of Defense Comments

Page 19 GAO/NSIAD/AIMD-97-33 Environmental Cleanup
Appendix IV 

Shell Oil Company Comments

Page 20 GAO/NSIAD/AIMD-97-33 Environmental Cleanup
Appendix IV 

Shell Oil Company Comments

Page 21 GAO/NSIAD/AIMD-97-33 Environmental Cleanup
Appendix V 

Major Contributors to This Report

National Security and

International Affairs

Division

Brad Hathaway, Associate Director

Uldis Adamsons, Assistant Director

Accounting and

Information

Management Division

Lisa Jacobson, Director

Denver Field Office 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

Office of General

Counsel

Margaret Armen, Senior Attorney

(709127) Page 22 GAO/NSIAD/AIMD-97-33 Environmental Cleanup
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