[Decision Concerning Airport Authority's Request for Reimbursement of Oil Spill Clean-Up Expenses]

A city claimed reimbursement for the costs of cleaning up an oil spill that it alleged the Army primarily caused. The Army recommended that GAO favorably consider the claim on a quantum meruit basis, since it would have had to contract to clean up the oil spill had the city not done so. GAO held that: (1) the Army could have contracted for the cleanup work; (2) the Army received a benefit, since it would have had to clean up the oil; and (3) the amount of the claim was reasonable and reflected a competitive value for the services. Accordingly, the claim was allowed.