OFFICE OF INSPECTOR GENERAL 

Catalyst for Improving the Environment 

 Evaluation Report 

EPA Should Continue to 

Improve Its National 

Emergency Response Planning 

 Report No. 08-P-0055 

 January 9, 2008 
Report Contributors: Carolyn Copper 

 Steve Hanna

 Denise Rice

 Anne Emory 

Abbreviations 

DHS Department of Homeland Security 

EPA U.S. Environmental Protection Agency 

INS Incident of National Significance 

LEPC Local Emergency Planning Committee 

NAR National Approach to Response 

OEM Office of Emergency Management 

OIG Office of Inspector General 

Cover photo: Setting up for air sampling at Capitol Hill following the 2001 anthrax attacks 

in Washington, DC (EPA photo). 
U.S. Environmental Protection Agency 08-P-0055 

Office of Inspector General January 9, 2008

At a Glance


Catalyst for Improving the Environment 

Why We Did This Review 

We evaluated the U.S. 

Environmental Protection 

Agency’s (EPA’s) Emergency 

Response Business Plan (the Plan) 

to determine: (1) how the Agency 

estimated resource needs for 

national emergencies; (2) how the 

resource estimates considered the 

use of State and local government 

agency resources in national 

emergencies; and (3) how EPA 

used existing data on chlorine 

volumes to guide plans for 

responding to a chemical attack. 

Background 

EPA developed the Plan in 2006 

as the framework for emergency 

response to national-level 

incidents while maintaining an 

effective day-to-day emergency 

response and removal program. 

The Plan identifies EPA’s 

resource needs to respond to three 

distinct national emergency 

situations (scenarios). These 

scenarios involve various 

combinations of radiological, 

biological, and chemical attacks. 

For further information, contact 

our Office of Congressional and 

Public Liaison at (202) 566-2391. 

To view the full report, click on 

the following link: 

www.epa.gov/oig/reports/2008/ 

20080109-08-P-0055.pdf 

EPA Should Continue to Improve Its 

National Emergency Response Planning

 What We Found 

We found that EPA’s Emergency Response Business Plan did not disclose the 

basis for EPA’s resource estimates. Additionally, EPA management stated 

they did not consider State and local resources in their resource estimates 

because they believed they would be working with the affected State and local 

governments in a unified command structure. EPA considered past experience 

in estimating the activities they would be asked to perform. Also, EPA did not 

use existing data on chlorine storage volumes because it was attempting to 

develop a national scenario applicable to any chemical. 

The Plan does not satisfy EPA’s need for a framework to respond to incidents 

of national significance. While EPA has a proven track record of responding 

effectively to serious environmental situations, those situations are limited in 

scope and severity when compared to suggested incidents of national 

significance. EPA’s initial effort is too limited and unstructured to prepare the 

Agency for an effective response. Assumptions are undocumented, resource 

requirements unsupported, and internal and external coordination of response 

planning minimal. As a result, the Plan may focus EPA’s preparation for 

emergency response on the wrong resource allocations, leaving the Agency 

unprepared. EPA intends to address some of these issues as the Plan is 

revised; the plan is evolving as EPA continues to make progress and 

improvements. 

What We Recommend 

We recommend that EPA revise the Plan to incorporate the methodology and 

assumptions used to develop all personnel and resource estimates, the rational 

for the selection of the incidents of national significance, lessons learned from 

past incidents, logistics of resource deployment, and risk communications. 

EPA should update key milestones and expand coordination with other EPA 

offices and relevant Federal agencies in revising the Plan. EPA concurred 

with our recommendations. 
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

WASHINGTON, D.C. 20460 

OFFICE OF 

INSPECTOR GENERAL 

January 9, 2008 

MEMORANDUM 

SUBJECT: EPA Should Continue to Improve Its 

National Emergency Response Planning 

Report No. 08-P-0055 

FROM: Wade T. Najjum 

Assistant Inspector General 

Office of Program Evaluation 

TO: Susan Parker Bodine 

Assistant Administrator 

Office of Solid Waste and Emergency Response 

Tom Dunne

 Associate Administrator 

 Office of Homeland Security 

This is our report on the subject evaluation conducted by the Office of Inspector General (OIG) 

of the U.S. Environmental Protection Agency (EPA). This report contains findings that describe 

the problems the OIG has identified and corrective actions the OIG recommends. The OIG 

responded to the Agency’s draft report comments by making changes to the report and providing 

responses to EPA, as appropriate. This report represents the opinion of the OIG and does not 

necessarily represent the final EPA position. Final determinations on matters in this report will 

be made by EPA managers in accordance with established resolution procedures. 

The estimated cost of this report – calculated by multiplying the project’s staff days by the 

applicable daily full cost billing rates in effect at the time – is $136,702. 

Action Required 

In accordance with EPA Manual 2750, you are required to provide a written response to this 

report within 90 calendar days. Your response should include a corrective action plan for agreed 

upon actions for Recommendations 2-5 through 2-8, including milestone dates. Please email an 
electronic version of your response to Steve Hanna at hanna.steve@epa.gov. Since you 

concurred with our recommendations and agreed to implement corrective actions for 

Recommendations 2-1 through 2-4, a report of action is not required for those recommendations. 

We will close these recommendations in our tracking system when you provide evidence that 

they are included in the June 2008 National Approach to Response Implementation Plan. 

We will follow up on EPA’s completion of the recommendations. We have no objections to 

the further release of this report to the public. This report will be available at 

http://www.epa.gov/oig. 

If you or your staff have any questions regarding this report, please contact Carolyn Copper, 

Director for Program Evaluation, Hazardous Waste Issues, at (202) 566-0829 or 

copper.carolyn@epa.gov; or Steve Hanna, Project Manager, at (415) 947-4527 or 

hanna.steve@epa.gov. 
EPA Should Continue to Improve Its 

National Emergency Response Planning 

Table of Contents 

Chapters 

1 Introduction ........................................................................................................... 1 

Purpose .......................................................................................................... 1 

Background .................................................................................................... 1 

 Noteworthy Achievements.............................................................................. 2 

 Scope and Methodology................................................................................. 3 

 Prior Evaluation Coverage ............................................................................. 4 

2 Planning Processes Could Be Improved ............................................................ 5 

Plan Assumes No Participation of State and Local Government 

 Emergency Response Resources in National Emergencies .................. 5 

Existing Data on Chemical Threats Not Used in Planning ............................. 6 

Rationale for Planning for Multiple Simultaneous Incidents 

Not Provided........................................................................................... 7 

 Plan Has Inconsistencies ............................................................................... 7 

Some NAR Milestones Have Not Been Met................................................... 8 

Plan Documents Little EPA Internal Federal Coordination............................. 8 

Lessons Learned from Past National Emergency Incidents 

 Not Included in Plan ............................................................................... 9 

Logistics of Resource Deployment Not Accounted for in Plan ....................... 9 

Plan Does Not Account for Key Issues in EPA’s 

 Risk Communications with the Public..................................................... 9 

Conclusions.................................................................................................... 10 

 Recommendations ......................................................................................... 10 

Agency Comments and OIG Evaluation......................................................... 11 

Status of Recommendations and Potential Monetary Benefits................................. 12 

Appendices 

A Prior Reports ......................................................................................................... 14 

B Agency Response to Draft Report and OIG Evaluation..................................... 15 

C Distribution ............................................................................................................ 21 
Chapter 1

Introduction 

Purpose 

The purpose of this review was to evaluate the U.S. Environmental Protection 

Agency’s (EPA’s) progress in preparing to respond to Incidents of National 

Significance (INSs). EPA’s Office of Emergency Management (OEM), within 

the Office of Solid Waste and Emergency Response, developed the Emergency 

Response Business Plan (the Plan) as the framework for emergency response to 

national-level incidents while maintaining an effective day-to-day emergency 

response and removal program. We addressed the following questions: 

• How did EPA calculate the staff and equipment estimates? 

• How did EPA incorporate local and State government staff and equipment 

resources in their need estimates? 

• How did EPA incorporate information on existing chlorine tanks into their 

planning assumptions and need estimates? 

Background 

OEM published the Emergency Response Business Plan in June 2006. The Plan 

provides a framework for EPA’s emergency response program to address overall 

readiness for five simultaneous INSs while maintaining an effective day-to-day 

emergency response and removal program. The Department of Homeland 

Security (DHS) defines an INS as 

“an actual or potential high-impact 

event that requires robust coordination 

of the Federal response in order to 

save lives and minimize damage, and 

provide the basis for long-term 

community and economic recovery.” 

The plan supports EPA goals to 

implement its own “National 

Approach to Response” (NAR) and 

be responsive to government-wide 

national response objectives as 

outlined in the National Response 

Plan and National Incident 

Management System. 

The Plan provides resource estimates 

(i.e., staff, equipment, and lab Source: DHS National Planning Scenarios 

Table 1.1: 

DHS Incident of National Significance Scenarios 

Scenario Description 

1: Nuclear Detonation 10-Kiloton Improvised 

Nuclear Device 

2: Biological Attack Aerosol Anthrax 

3: Biological Disease 

Outbreak 

Pandemic Influenza 

4: Biological Attack Plague 

5: Chemical Attack Blister Agent 

6: Chemical Attack Toxic Industrial Chemicals 

7: Chemical Attack Nerve Agent 

8: Chemical Attack Chlorine Tank Explosion 

9: Natural Disaster Major Earthquake 

10: Natural Disaster Major Hurricane 

11: Radiological Attack Radiological Dispersal 

Devices 

12: Explosives Attack Bombing Using Improvised 

Explosive Device 

13: Biological Attack Food Contamination 

14: Biological Attack Foreign Animal Disease 

(Foot and Mouth Disease) 

15: Cyber Attack Cyber Attack 

1 
capacity) needed to respond to five simultaneous INSs and an analysis of resource 

gaps. EPA used 3 of the 15 DHS INS scenarios1 for its Plan. Table 1.1 lists the 

15 DHS scenarios and highlights the 3 included in EPA’s Plan. EPA’s Plan 

provides estimates for three distinct scenarios. One scenario includes five 

simultaneous radiological incidents; a second includes five simultaneous 

biological incidents; and a third includes a combination of one radiological, one 

biological, and three chemical incidents. 

OEM management said they intend to revise the Plan, in coordination with current 

planning efforts of EPA’s Office of Homeland Security. That office’s efforts 

remain focused on preparing EPA to respond to five simultaneous incidents. 

Noteworthy Achievements 

OEM demonstrated initiative as it developed EPA's first business plan for 

responding to INSs. It is a noteworthy step in the process to develop the Agency's 

capabilities to respond to national level incidents while maintaining control over 

normal operations. The plan provides a good beginning to a deliberate planning 

process that should continuously improve as EPA broadens participation and 

coordination. Since the development of the Plan, EPA has made significant 

progress in addressing the Agency’s NAR priorities. According to OEM 

management, they: 

• Established a Steering Committee to provide oversight and leadership to 

the numerous workgroups that support the NAR. The committee has met 

several times to review and assess NAR priority project workplans. 

• Developed a draft Incident Management Handbook that provides guidance 

on organizational structure and outlines the communications flow during 

an INS. This handbook was finalized in November 2007. 

• Developed and delivered a training course for senior managers about 

emergency response and the use of the Incident Command System to 

assure that roles and responsibilities are well understood. This course has 

already been delivered in all of the regions and two Headquarters offices. 

• Developed and implemented an Information Technology Strategy to move 

data and information seamlessly from field tools to enterprise data storage, 

where it can be shared with EPA partners through the Emergency 

Management Portal, and with the general public from EPA's public 

Website. The strategy will link prevention and preparedness data to actual 

field response data. This portal, which is central to the strategy's 

implementation, creates a single point of entry to reach all site-specific 

data, asset management tools, and emergency management information. 

1

 In this document, “incident” refers to the occurrence of a single event, while “scenario” refers to specific single or 

multiple incidents used for planning purposes. 

2 
It is currently under development and is scheduled for completion by the 

end of 2009. 

• Completed the equipment module of the Emergency Management Portal 

in January 2007. Equipment from each region is being renamed according 

to the new standard terms. As this is completed for each region, the data 

are being loaded into the database. Over the next several months, each 

region is to receive training on the new system, check its data to ensure the 

accuracy of the data migration, and transition to using the new system. 

• Formed an Administrative and Finance Workgroup to address 

procurement, property tracking, and pay issues. To date, the workgroup 

has helped to publish the EPA Disaster Response Guidebook for Personal 

Property Management (during emergency/disaster responses), and a 

Pocket Guide on Pay and Leave Issues during emergencies and disaster 

responses. 

Scope and Methodology 

We completed our work in accordance with generally accepted government 

auditing standards, except that we did not assess internal controls because they 

were not germane to our review objectives. We assessed the data quality of the 

resource estimates and assumptions used by EPA for the INS scenarios. We did 

not verify the noteworthy achievements, which were supplied by OEM 

management. We performed our review from February to March 2007, at EPA 

Headquarters and EPA Regions 3 and 9. 

To address our first question, we analyzed spreadsheets from EPA that detailed 

the resource requirements for the three INS scenarios. For our second question, 

we reviewed the Plan for evidence of internal and external coordination with other 

Federal agencies, as well as State and local emergency response agencies. For 

our third question, we performed analysis of the potential number of facilities 

with chlorine tanks. We estimated this number by using data from the EPA Toxic 

Release Inventory to identify the number of facilities with high volumes of 

chlorine stored on-site. In answering all of our evaluation questions, we reviewed 

the contents of the Plan and interviewed OEM staff as well as emergency 

response staff in EPA Regions 3 and 9. 

We also reviewed the following criteria documents and information: 

• EPA’s National Approach to Response. 

• DHS’s National Planning Scenarios. 

• EPA’s Homeland Security Strategy (2004). 

• EPA’s Future Years Homeland Security Workplan (2007, 2008, 2009). 

• EPA lessons learned from the World Trade Center attacks, Space Shuttle 

Columbia accident, and Hurricane Katrina. 

3 
• EPA’s Radiological Emergency Response Plan. 

• EPA’s Radiological Response Guidelines. 

• EPA’s National Incident Management Implementation Plan. 

• Office of Solid Waste and Emergency Response National Program 

Manager Guidance. 

• EPA’s emergency response performance goals. 

• Homeland Security Presidential Directives 5 and 8. 

• National Incident Management System. 

• The Emergency Planning and Community Right-to-Know Act Fact Sheet. 

• Clean Air Act Section 112(r) - Risk Management Plans. 

• National Contingency Plan. 

• National Response System. 

• National Response Plan and Emergency Support Functions. 

Prior Evaluation Coverage 

In 2006, the OIG evaluated a draft version of the Plan. The evaluation ended after 

the preliminary research phase. The Exit Memorandum for Preliminary Research 

of the Effectiveness of EPA’s Emergency Response Activities, Report No. 2006-

M-000004, February 24, 2006, included four observations: 

1. The Plan provided no rationale for INS scenario selection. 

2. Strategic Goals 1 and 2 conflict and may not reflect the most effective or 

efficient strategy. 

3. NAR work plans do not specifically address activities EPA would take 

on-scene during an emergency response. 

4. The Plan’s strategy for monitoring performance does not rely on outcomebased measurements. 

In the current review, we found that the Agency has not yet taken action to 

address our prior observation 1; it has addressed observation 3; and it is working 

to address observation 4. We did not follow up in the current review on EPA’s 

actions to address observation 2. 

In addition, we reviewed three prior OIG reports and four Government 

Accountability Office reports. A listing of those reports is in Appendix A. 

4 
Chapter 2

Planning Processes Could Be Improved 

The Emergency Response Business Plan (the Plan) does not satisfy EPA’s need 

for a framework to respond to INSs. While EPA has a proven track record of 

responding effectively to serious environmental situations, those situations were 

limited in scope and severity when compared to suggested INSs. The existing 

planning process represents an effort by EPA to address multiple INSs. 

However, this initial effort is too limited and unstructured to prepare the Agency 

for an effective response. Assumptions are undocumented, requirements 

unsupported, and internal and external coordination of response planning minimal 

or undocumented. As a result, the process may focus EPA’s preparation for 

emergency response on the wrong resource allocations, leaving the Agency 

unprepared. EPA intends to address some of these issues as the Plan is revised. 

Plan Assumes No Participation of State and Local Government 

Emergency Response Resources in National Emergencies 

The Plan does not incorporate or reflect the significant resources that State and 

local emergency response organizations contribute to emergency events. OEM 

management stated they relied on “best professional judgment” for their resource 

estimates. Also, EPA lacks the data needed to know who may be locally available 

and ready to assist. Consequently, EPA’s planned needs and resource 

requirements may be unreliable. 

In accordance with the Emergency Planning and Community Right to Know Act 

of 1986, States and local government agencies have organizations in place to 

address emergency response. Under this Act, the governor of each State has 

designated a State Emergency Response Commission responsible for its 

implementation. These commissions have designated approximately 3,500 Local 

Emergency Planning Committees (LEPCs). LEPCs maintain an emergency plan 

for their jurisdictions. These plans reflect and incorporate information that 

LEPCs get from businesses in their jurisdictions, such as the amount and location 

of chemicals at a business. The first responders in an emergency, such as fire 

departments or emergency management organizations, are members of the 

LEPCs. State and Federal resources typically respond only when the magnitude 

of an emergency overwhelms local resources. 

OEM management told us they intend to revisit the Plan’s resource estimates. In 

addition, they continue to expand their Response Support Corps, which consists 

of EPA staff who volunteer for deployment in an emergency and receive a 

required amount of training. We believe that EPA should identify LEPC and 

State resources for assistance in an emergency. These first responders, from 

5 
agencies other than those in the impacted areas, could represent a significant 

trained resource to aid in emergency response. EPA’s consideration of these 

existing resources would better define the capabilities EPA will need to provide, 

resulting in a capability-based resource effort and improved resource 

management. EPA management stated they did not consider State and local 

resources in their resource estimates because they believed they would be 

working with the affected State and local governments in a unified command 

structure. EPA management considered past experience in estimating the 

activities they would be asked to perform. However, the 2006 Plan does not 

clearly state this assumption, and the next iteration should do so. Further, EPA 

should consider incorporating existing State and local resources into their future 

regional planning efforts. 

Existing Data on Chemical Threats Not Used in Planning 

EPA’s planning scenario for chlorine (i.e., chemical tank explosion) is a general 

theoretical scenario and not based on a past incident or derived from information 

on chlorine tank locations and volumes. The DHS planning scenario for a 

chlorine tank explosion is also not based on actual tank locations and volumes. 

However, data are available on the locations of facilities with large chlorine 

volumes, from sources such as the Toxic Release Inventory, Risk Management 

Plans, and LEPCs. For example, 2004 Toxic Release Inventory data show that 

265 facilities report a maximum on-site chlorine volume greater than 100,000 

pounds. Of those 265 facilities, 15 reported on-site chlorine volumes greater than 

10,000,000 pounds. This type of information could assist EPA with developing 

realistic planning scenarios for chlorine-related emergency events. 

OEM management said that they did not focus on existing chlorine stores because 

they were only using chlorine as an example of a chemical incident. OEM 

management also said they did not consider existing chlorine tanks because they 

were developing a national scenario that would be applicable to a general 

chemical event rather than just chlorine. EPA comments also stated that they 

might not include a chlorine scenario in their next plan. This is because they 

believe it would not strain resources, EPA has experience with chlorine events, 

and the duration of the response would not be lengthy. We believe EPA should 

incorporate its knowledge of major repositories of existing chemicals, to include 

chlorine when appropriate, in its future regional planning efforts for chemicalspecific events. This especially applies to those repositories in proximity to 

populated areas. This could include a review of the Risk Management Plan 

submittals from high-volume facilities. EPA has stated that regional offices 

currently work with Risk Management Plan implementing agencies on facility 

planning to prevent and respond to chemical releases. 

6 
Rationale for Planning for Multiple Simultaneous Incidents 

Not Provided 

The Plan does not state the rationale for the goal of being ready for five 

simultaneous incidents (as opposed to more or fewer incidents), nor why these 

particular scenarios were chosen. The scenarios selected were radiological 

(a dirty bomb), biological (anthrax), and a chemical explosion (chlorine tank). 

These represent 3 of the 15 DHS INS scenarios. EPA would also likely have a 

role in other DHS scenarios, including a blister agent, toxic industrial chemicals, 

a nerve agent, and a major earthquake or hurricane. 

OEM management told us that senior Office of Solid Waste and Emergency 

Response officials defined the scenario of five simultaneous incidents as a 

planning assumption. EPA staff indicated they selected the three specific 

scenarios because they would involve a high degree of EPA involvement. EPA 

selected the chlorine scenario because of EPA’s experience with chemical cleanup 

as a core program activity. Staff selected a radiological scenario because they 

thought they had little experience in this area and thus needed additional planning. 

According to EPA staff, EPA selected the anthrax scenario because it seemed 

especially relevant due to the 2001 anthrax attacks on Capitol Hill in Washington. 

EPA believes that planning for multiple incidents rather than a single event is 

more realistic, because past terrorist attacks have often involved multiple targets. 

However, planning for multiple incidents significantly expands the scope of the 

planning and resource requirements. The basic assumptions and rationales should 

be identified so that leadership can make informed resource decisions. 

Plan Has Inconsistencies 

EPA’s Plan scenarios are inconsistent with DHS scenarios or other parts of the 

Plan: 

• The DHS chlorine tank scenario assumes the detonation of a 60,000-

gallon chlorine tank (approximately 480,000 pounds), situated in an urban 

center with other industrial and residential land use nearby. EPA’s 

chlorine scenario identifies a 60-ton chlorine cylinder (approximately 

120,000 pounds), a quarter of the size of the DHS tank. 

• The Plan’s radiological scenario assumes five simultaneous radiological 

attacks, in five different EPA regions, using dirty bomb dispersal devices. 

However, the DHS radiological scenario involves three simultaneous dirty 

bombs in cities close to one another. EPA’s scenario assumes more 

incidents involving a larger geographic area. 

• The Plan’s biological scenario has an internal inconsistency. The Plan 

states the anthrax assessment phase would take approximately 6 months 

while the cleanup phase would take upwards of 8 months, for a total 

response action lasting 14 months. However, the Plan’s general planning 

7 
assumptions indicate that, for all scenarios, EPA activity will continue for 

26 weeks (approximately 6 months). 

EPA’s Plan does not acknowledge or explain these apparent differences, which 

has an impact on the scale of the planned response and the resources required. 

EPA told us that DHS had not completed its scenario descriptions at the time EPA 

was developing the Plan, which may explain differences between the EPA and 

DHS assumptions. 

Some NAR Milestones Have Not Been Met 

EPA has not met some of the NAR work plan dates, and many of the work plans 

do not identify a lead person. EPA has identified the NAR as its mechanism for 

managing emergency response assets in a coordinated manner during an INS. 

EPA has recognized that certain activities, such as putting contracts in place, must 

be completed in order to respond effectively during an INS. These activities are 

detailed in a list of NAR work plans. The Plan includes 93 NAR work plans, and 

EPA has identified 14 as priority work plans that have estimated completion 

dates. EPA has emphasized the importance of the NAR. The Assistant 

Administrator for Solid Waste and Emergency Response testified at a Senate 

hearing to the fact that the NAR provides EPA with the ability to respond 

whenever and wherever needed. OEM management has indicated they are 

working on updating these plans, and that additional work plans will address 

administration, logistics, and property management. 

Plan Documents Little EPA Internal Federal Coordination 

OEM management indicated that, with the exception of the Office of Air and 

Radiation and the Office of Acquisition Management, they did not coordinate the 

Plan with other EPA program offices. OEM also did not document any 

coordination or consultation with other Federal agencies to determine their 

possible roles and/or availability of resources from other Federal agencies. 

However, OEM consulted with emergency response staff in the EPA regions on 

the Plan and incorporated their input. Examples of expertise and possible 

resources available in other EPA offices or Federal agencies include: 

• The EPA Office of Drinking Water and Ground Water has experience 

with planning for bioterrorism. 

• The Centers for Disease Control and Prevention have experience with 

biological disasters. DHS’s anthrax planning scenario clearly states that 

the Centers for Disease Control and Prevention and EPA would be 

working and making decisions together during such a scenario. 

• The Department of Energy has experience dealing with radiological 

disasters and is usually the first responder for a radiological incident. 

8 
OEM management indicated that they did not coordinate with other agencies 

because they wanted to test and verify the Plan internally before discussing with 

other agencies, and that they developed the Plan to show how OSWER activities 

had changed. Without coordination with other agencies, EPA risks duplication or 

conflict in its emergency response. OEM managers have indicated they are 

coordinating with other Agency offices as they move forward with the new NAR 

implementation plan, and they coordinate their planning efforts with other Federal 

agencies through existing planning frameworks. 

Lessons Learned from Past National Emergency Incidents 

Not Included in Plan 

The Plan acknowledges the importance of lessons learned from national 

emergency events, yet these lessons were either not incorporated or explicitly 

identified in the Plan. In the past several years, the United States has experienced 

several national emergency events, such as the World Trade Center attacks, 

Capitol Hill anthrax incident, Space Shuttle Columbia accident, and Hurricane 

Katrina. Lessons learned from these incidents can provide useful information in 

planning for future incidents by identifying which activities work and which need 

to be improved. OEM management stated they are adding work plans to address 

specific issues that came up during Hurricane Katrina, such as administration, 

logistics, and property management. According to EPA, lessons learned from 

past national incidents were incorporated into their NAR priorities, to include 

“Administrative Issues” and “Crisis Communications.” OEM management has 

also indicated that lessons learned will be identified and included in the next 

version of the Plan, which OEM expects to finalize no earlier than March 2008. 

Logistics of Resource Deployment Not Accounted for in Plan 

The Plan does not specifically identify logistics as an issue or identify 

mechanisms to ensure logistics requirements do not limit EPA’s response actions. 

Emergency planning requires planning for the transportation, housing, and other 

support (e.g., food) of the personnel involved. Transportation, housing, and 

feeding responders were significant activities in EPA’s response to Hurricane 

Katrina. Without addressing logistics in the Plan, EPA may encounter difficulties 

in implementing its response plans due to problems that can arise in transporting, 

housing, and supporting responders. OEM management indicated that logistics 

issues were not included in the plan because their importance was not recognized 

until Hurricane Katrina, which occurred after the initial draft of the Plan. OEM 

plans to address logistics in the next version of the Plan. 

Plan Does Not Account for Key Issues in EPA’s Risk Communications 

with the Public 

The NAR communication work plans identified in the Plan do not explicitly 

address EPA’s role or responsibilities in deciding and communicating what risks 

9 
the public faces when returning to or staying in an affected area. Both the World 

Trade Center attacks and Hurricane Katrina demonstrated the public’s expectation 

that EPA has a lead role in clearly communicating risks to the public regarding 

the safety of contaminated disaster areas. This includes communicating what the 

risks are to residents who return to contaminated disaster areas. EPA’s Plan 

includes two NAR communication work plans, to: 

1. Develop specialized communication tools to support outreach and risk 

communication. 

2. Develop training to support outreach and risk communication. 

This has proven to be a critical activity for EPA to manage and respond to in 

recent national emergencies. EPA officials told us they are currently participating 

with the White House Office of Science and Technology Policy to develop a 

methodology for deciding how to determine when it is safe to return. While this 

is an important step, it is also necessary for EPA to identify methodologies it will 

use to determine and communicate risk. Also, EPA needs to know in each 

scenario what its role will be in advising decision authorities and the public, 

especially displaced residents and businesses, on the risks of returning to 

impacted areas. 

Conclusions 

The current Plan does not satisfy EPA’s need for a framework to respond to INSs. 

The existing planning process is too limited and unstructured to prepare the 

Agency for an effective response. Assumptions are undocumented, requirements 

unsupported, and internal and external coordination of response planning 

minimal. As a result, the process may focus EPA’s preparation for emergency 

response on the wrong resource allocations, leaving the Agency unprepared. 

Recommendations 

We recommend the Director of EPA’s Office of Emergency Management, in 

cooperation with the Associate Administrator for EPA Homeland Security, 

incorporate revisions to the Plan or any follow-on planning documents (such as 

implementation plans) that: 

2-1 Include the methodology and assumptions used to develop all personnel and 

resource estimates, including the potential availability of other Federal, 

State, or local resources. 

2-2 Include information from existing chemical inventory data and risk 

management plans when planning for chemical incidents, such as chlorine 

tank explosions when appropriate, at the regional level. This could include 

a review of the Risk Management Plan submittals from high-volume 

facilities. EPA has stated that regional offices currently work with Risk 

10 
Management Plan implementing agencies on facility planning to prevent 

and respond to chemical releases. 

2-3 Document the rationale for the selection of the INS scenarios addressed, 

including: 

a. EPA’s anticipated role in each of the INS scenarios. 

b. The need to plan for five simultaneous incidents. 

c. The reasons for differences between EPA’s and DHS’s chlorine and 

radiological scenarios, where they remain. 

2-4 Update NAR milestones and progress indicators for milestone completion. 

2-5 Expand internal EPA coordination and coordination with other relevant 

Federal, State, and local emergency response agencies. 

2-6 Incorporate lessons learned from past incidents, such as the World Trade 

Center attacks, Capitol Hill anthrax incident, and Hurricane Katrina. 

2-7 Incorporate logistics of resource deployment, such as transportation, 

housing, and feeding of EPA responders. 

2-8 Define communication activities that inform the public of risks in 

contaminated disaster areas, including: 

a. Methodologies used to determine and communicate risk to residents 

returning to contaminated disaster areas. 

b. The role of local, State, or Federal agencies in risk communications. 

c. How decisions about risk will be made under specific scenarios. 

d. How risk decisions will be communicated under specific scenarios. 

Agency Comments and OIG Evaluation 

The OIG made changes to the report based on the Agency’s comments where 

appropriate. Appendix B provides the full text of the Agency comments and OIG 

response. 

EPA concurred with all recommendations. EPA initially did not concur with 

Recommendation 2-2, which recommended including existing chemical inventory 

data in planning efforts. We changed this recommendation to address Agency 

concerns, and EPA agreed with the revised recommendation. 

EPA said it will incorporate Recommendations 2-1 through 2-7 into the NAR 

Implementation Plan, which is scheduled for completion by June 2008. 

Recommendation 2-8 is to be addressed by the Crisis Communications Resource 

Guide, which is scheduled for completion in December 2008. 

11 
Status of Recommendations and 

Potential Monetary Benefits 

POTENTIAL MONETARY 

RECOMMENDATIONS BENEFITS (in $000s) 

Rec. 

No. 

Page 

No. Subject Status1 Action Official 

Planned 

Completion 

Date 

Claimed 

Amount 

Agreed To 

Amount 

2-1 

2-2 

2-3 

2-4 

2-5 

2-6 

2-7 

10 

10 

11 

11 

11 

11 

11 

Include the methodology and assumptions used to 

develop all personnel and resource estimates, 

including the potential availability of other Federal, 

State, or local resources. 

Include information from existing chemical 

inventory data and risk management plans when 

planning for chemical incidents, such as chlorine 

tank explosions when appropriate, at the regional 

level. This could include a review of the Risk 

Management Plan submittals from high-volume 

facilities. EPA has stated that regional offices 

currently work with Risk Management Plan 

implementing agencies on facility planning to 

prevent and respond to chemical releases. 

Document the rationale for the selection of the INS 

scenarios addressed, including (a) EPA’s 

anticipated role in each of the INS scenarios; 

(b) the need to plan for five simultaneous incidents; 

and (c) the reasons for differences between EPA’s 

and DHS’s chlorine and radiological scenarios, 

where they remain. 

Update NAR milestones and progress indicators for 

milestone completion. 

Expand internal EPA coordination and coordination 

with other relevant Federal, State, and local 

emergency response agencies. 

Incorporate lessons learned from past incidents, 

such as the World Trade Center attacks, Capitol 

Hill anthrax incident, and Hurricane Katrina. 

Incorporate logistics of resource deployment, such 

as transportation, housing, and feeding of EPA 

responders. 

O 

O 

O 

O 

O 

O 

O 

Director, EPA’s Office of 

Emergency Management, 

in cooperation with the 

Associate Administrator for 

EPA Homeland Security 

Director, EPA’s Office of 

Emergency Management, 

in cooperation with the 

Associate Administrator for 

EPA Homeland Security 

Director, EPA’s Office of 

Emergency Management, 

in cooperation with the 

Associate Administrator for 

EPA Homeland Security 

Director, EPA’s Office of 

Emergency Management, 

in cooperation with the 

Associate Administrator for 

EPA Homeland Security 

Director, EPA’s Office of 

Emergency Management, 

in cooperation with the 

Associate Administrator for 

EPA Homeland Security 

Director, EPA’s Office of 

Emergency Management, 

in cooperation with the 

Associate Administrator for 

EPA Homeland Security 

Director, EPA’s Office of 

Emergency Management, 

in cooperation with the 

Associate Administrator for 

EPA Homeland Security 

June 2008 

June 2008 

June 2008 

June 2008 

June 2008 

June 2008 

June 2008 

12 
RECOMMENDATIONS 

POTENTIAL MONETARY 

BENEFITS (in $000s) 

Rec. 

No. 

Page 

No. Subject Status1 Action Official 

Planned 

Completion 

Date 

Claimed 

Amount 

Agreed To 

Amount 

2-8 11 Define communication activities that inform the 

public of risks in contaminated disaster areas, 

including (a)methodologies used to determine 

and communicate risk to residents returning to 

contaminated disaster areas; (b) the role of local, 

State, or Federal agencies in risk communications; 

(c) how decisions about risk will be made under 

specific scenarios; and (d) how risk decisions will 

be communicated under specific scenarios. 

O Director, EPA’s Office of 

Emergency Management, 

in cooperation with the 

Associate Administrator for 

EPA Homeland Security 

December 

2008 

1 O = recommendation is open with agreed-to corrective actions pending 

C = recommendation is closed with all agreed-to actions completed 

U = recommendation is undecided with resolution efforts in progress 

13 
Appendix A 

Prior Reports 

EPA OIG Reports 

Title Report No. Date 

EPA’s Homeland Security Role to Protect Air from 

Terrorist Threats Needs to be Better Defined 

2004-M-000005 February 20, 2004 

EPA Needs to Better Manage Counter 

Terrorism/Emergency Response Equipment 

2004-P-00011 March 29, 2004 

Lessons Learned: EPA’s Response to Hurricane Katrina 2006-P-00033 September 14, 2006 

Government Accountability Office Reports 

Title Report No. Date 

Anthrax Detection – Agencies Need to Validate Sampling 

Activities in Order to Increase Confidence in Negative 

Results 

GAO-05-251 March 2005 

Critical Infrastructure Protection – Progress Coordinating 

Government and Private Sector Efforts Varies by Sectors’ 

Characteristics 

GAO-07-39 October 2006 

Homeland Security – Preparing for and Responding to 

Disasters 

GAO-07-395T March 2007 

Anthrax Detection – DHS Cannot Ensure That Sampling 

Activities Will Be Validated 

GAO-07-687T March 2007 

14 
Appendix B 

Agency Response to Draft Report 

and OIG Evaluation 

December 5, 2007 

MEMORANDUM 

SUBJECT: Response to OIG Draft Evaluation Report: “EPA Should Continue to 

Improve Its National Emergency Response Planning” Assignment No. 

2007-00573 

FROM: Susan Parker Bodine/s/ 

 Assistant Administrator 

 Office of Solid Waste and Emergency Response 

Thomas P. Dunne/s/ 

 Associate Administrator 

 Office of Homeland Security 

TO: Bill A. Roderick 

 Acting Inspector General 

Thank you for the opportunity to comment on this draft report. We also appreciate the 

meetings we have had with your staff to discuss our planning efforts. We are providing a 

response to your draft recommendations followed by some specific comments on the draft report. 

Response to Recommendations 

2-1. Include the methodology and assumptions used to develop all personnel and resource 

estimates, including the potential availability of other Federal, State, or local resources. 

Response: We agree with this recommendation. We are currently revising the estimates 

regarding the resources that are required for EPA to respond to five Incidents of National 

Significance (INS). This will be part of an agency-wide National Approach to Response (NAR) 

Implementation Plan. This plan will document planning assumptions and to the extent possible, 

we will address how we considered the availability of other Federal, State, or local resources. 

We expect that this NAR Implementation Plan will be completed by June 2008. 

2-2. Include information from existing chemical inventory data and risk management plans when 

planning for chemical incidents, such as chlorine tank explosions, at the regional level. 

15 
Response: We do not agree with this recommendation. In fact, we are currently considering not 

including the chlorine scenario in the new NAR Implementation Plan. EPA has responded to 

numerous chemical incidents in recent years. Even though a release of a substantial amount of 

chlorine would be considered a major incident, we believe that it would not strain Agency 

resources because we have experience with this type of response and the duration of the response 

would not be lengthy. 

EPA regional offices work with Risk Management Program State implementing agencies 

regarding facility planning to prevent and respond to releases of chlorine and certain other 

chemicals. Further, DHS works with these facilities regarding site security issues. 

OIG Response 

Based on EPA’s response, we changed Recommendation 2-2 and statements in the report as indicated 

in the following paragraphs. EPA concurred with the amended recommendation. 

We changed Recommendation 2-2 on page 10 of our report to read as follows: “Include information from 

existing chemical inventory data and risk management plans when planning for chemical-specific 

incidents, such as chlorine tank explosions, at the regional level. This could include a review of the Risk 

Management Plan submittals from high-volume facilities. EPA has stated that regional offices currently 

work with Risk Management Plan implementing agencies on facility planning to prevent and respond to 

chemical releases.” 

We also changed on page 6 of our report to read as follows: “EPA comments also stated that they might 

not include a chlorine scenario in their next plan. This is because they believe it would not strain 

resources, EPA has experience with chlorine events, and the duration of the response would not be 

lengthy. We believe EPA should incorporate its knowledge of major repositories of existing chemicals, to 

include chlorine when appropriate, in its future regional planning efforts for chemical-specific events. This 

especially applies to those repositories in proximity to populated areas. This could include a review of the 

Risk Management Plan submittals from high-volume facilities. EPA has stated that regional offices 

currently work with Risk Management Plan implementing agencies on facility planning to prevent and 

respond to chemical releases.” 

2-3. Document the rationale for the selection of the INS scenarios addressed, including: 

a. EPA’s anticipated role in each of the INS scenarios. 

b. The need to plan for five simultaneous incidents. 

c. The reasons for differences between EPA’s and DHS’s chlorine and radiological 

scenarios, where they remain. 

Response: We agree with this recommendation and will provide the appropriate documentation 

in the NAR Implementation Plan that is described in response to Recommendation 2-1 above. 

2-4. Update NAR milestones and progress indicators for milestone completion. 

Response: We agree with this recommendation and will include the NAR milestones and 

progress for milestones completion in the NAR Implementation Plan that is described in 

response to Recommendation 2-1 above. There are currently 14 NAR priorities for which work 

is underway. 

16 
2-5. Expand internal EPA coordination and coordination with other relevant Federal, State, and 

local emergency response agencies. 

Response: As mentioned in response to Recommendation 2-1, the new NAR Implementation 

Plan will be agency-wide. To gather more input from across the program offices in EPA, we 

asked National Incident Coordination Team (NICT) members to provide representatives to work 

with OSWER on the revision to what is needed for five INS. Additionally the NICT will have 

an opportunity to review and provide comments on the draft plan. 

EPA is a member of the DHS Incident Management Planning Team and will use that opportunity 

to coordinate certain aspects of this plan. Additionally, EPA coordinates planning efforts with 

other federal agencies through work on emergency support functions. 

While EPA coordinates routinely with State and local emergency response agencies, and we will 

continue to do so, we do not foresee including State and local capability in this plan. The issue 

here is that state and local capability varies widely across the country. In preparing national 

planning estimates, it is very difficult to generalize how States and locals will participate and to 

what degree. However, our Regional offices will continue to coordinate with the States and 

locals at their level and as they do more specific planning for their geographical areas. We did 

consider generally what we would do recognizing that we would be working with affected state 

and local governments in a unified command structure. 

2-6. Incorporate lessons learned from past incidents, such as the World Trade Center attacks, 

Capitol Hill anthrax incident, and Hurricane Katrina. 

Response: As we have mentioned in discussions with OIG representatives, lessons learned from 

all of these past incidents are already incorporated in the NAR priorities. For example, as a result 

of Hurricane Katrina, two new NAR priorities were identified: Administrative Issues and Crisis 

Communication. We are currently using experience from Hurricane Katrina in the revision of 

estimated resources required for five INS. 

OIG Response 

We added the following sentence to page 9 of our report: “According to EPA, lessons learned from past 

national incidents were incorporated into their NAR priorities, to include ‘Administrative Issues’ and ‘Crisis 

Communications.’” 

2-7. Incorporate logistics of resource deployment, such as transportation, housing, and feeding of 

EPA responders. 

Response: Lessons learned on the above mentioned logistic issues were added to the NAR 

Administrative priority and also the Contracts priority work. In this way, they will be included 

in the NAR Implementation Plan described in response to recommendation 2-1 above. However, 

the specific details for these issues will need to be described as part of the actual incident action 

plan as they will be dependent on a number of factors that can only be known when the incident 

occurs. 

17 
2-8. Define communication activities that inform the public of risks in contaminated disaster 

areas, including: 

a. Methodologies used to determine and communicate risks to residents returning to 

contaminated disaster areas. 

b. The role of local, State, or Federal agencies in risk communications. 

c. How decisions about risk will be made under specific scenarios. 

d. How risk decisions will be communicated under specific scenarios. 

Response: These activities will be addressed in the NAR Crisis Communications priority. A 

Crisis Communications Resource Guide with information about the above activities will be 

prepared by the Crisis Communications Workgroup which is chaired by the Office or Public 

Affairs, OEM and Region 1. This Resource Guide is scheduled for completion in December 

2008. 

Specific Comments on the Draft Evaluation Report 

At a Glance, first paragraph and Page 6, first paragraph. We disagree with the statement that 

EPA did not consider State and local resources because we assumed that they would be 

overwhelmed or unavailable. EPA routinely works with State and local governments on 

responses to incidents of all sizes. While we realize that the capabilities vary, we did consider 

generally what we would do recognizing that we would be working with the affected State and 

local governments in a unified command structure. We considered past experience in estimating 

the activities that we would be asked to perform. 

OIG Response 

We changed text in the At A Glance and page 6 of our report to read as follows: “EPA management 

stated they did not consider State and local resources in their resource estimates because they believed 

they would be working with the affected State and local governments in a unified command structure. 

EPA considered past experience in estimating the activities they would be asked to perform.” 

Page 2, second bullet under Noteworthy Achievements. The Incident Management Handbook 

was finalized in November. 

OIG Response 

We added the following statement to page 2 of our report: “This handbook was finalized in November 

2007.” 

Page 5, first paragraph. – We disagree with the conclusion that EPA is unprepared. As we 

discussed during our meetings with OIG representatives, the Emergency Response Business Plan 

was intended to show how the emergency response and preparedness activities changed since the 

events of September 11. Estimating resources for 5 INS was a planning exercise in an effort to 

begin to identify the personnel, equipment and contractor resources that may be required for 

multiple incidents. We realized at the time that we cannot predict what scenarios will occur. 

18 
EPA does extensive planning and coordination with State and local officials at the regional level. 

In both Headquarters and the regions, EPA staff work under the National Response Plan 

emergency support function framework to coordinate planning efforts. Additionally, EPA 

coordinates these efforts through the National Response Team and Regional Response Teams 

that were created under the National Contingency Plan. 

OIG Response 

The report states that EPA may be unprepared if the issues we have identified are not addressed. As 

documented in its response to the draft report, EPA intends to address or has addressed most of the 

issues we have identified. In subsequent discussions, EPA indicated that, in context, it does not disagree 

with the report conclusions. No change made in the final report. 

Page 5, third paragraph. Local Emergency Planning Committees (LEPCs) are planning entities. 

They are not the first responders in an emergency. We suggest that you replace LEPCs with 

local responders. Also, although EPA works with States, LEPCs, and other local officials on a 

routine basis and therefore has some information on local capabilities, EPA regions do not 

conduct surveys to quantify the local resources available. The NAR implementation planning 

effort will not enumerate the capabilities of each local emergency planning district. Such efforts 

would not only vary given specific scenarios, but they would need to be updated regularly. We 

suggest that the last sentence in this paragraph be deleted to avoid confusion. 

OIG Response 

We changed text on page 5 of our report to read as follows: “The first responders in an emergency, such 

as fire departments or emergency management organizations, are members of the LEPCs.” The last 

sentence in the paragraph was deleted. 

We will however continue to work through the regions to better document our interaction with 

State and local responders and assess their capabilities. We understand that some States and 

localities have mutual aid agreements in place. We will continue to explore whether that mutual 

aid should be expanded nationally. 

Page 8, last two paragraphs. Regarding internal federal coordination, as we discussed in 

meetings with OIG representatives, the Emergency Response Business Plan was originally 

developed to show how the OSWER activities had changed. As we move forward with the new 

NAR implementation plan we are working through the NICT to involve other Agency offices. 

Also, as we have indicated earlier, we coordinate our planning efforts with other federal agencies 

through the NRP and NRT frameworks. 

19 
OIG Response 

We changed the section heading on page 8 of our report to read as follows: “Plan Documents Little EPA 

Internal Federal Coordination.” We changed text on page 8 of our report to read as follows: “OEM also 

did not document any coordination or consultation with other Federal agencies to determine their possible 

roles and/or availability of resources from other Federal agencies.” We changed text on page 9 of our 

report to read as follows: “OEM management indicated that they did not coordinate with other agencies 

because they wanted to test and verify the Plan internally before discussing with other agencies, and that 

they developed the Plan to show how OSWER activities had changed. Without coordination with other 

agencies, EPA risks duplication or conflict in its emergency response. OEM managers have indicated 

they are coordinating with other Agency offices as they move forward with the new NAR implementation 

plan, and they coordinate their planning efforts with other Federal agencies through existing planning 

frameworks.” 

Thank you again for the opportunity to comment on the draft report. Please do not 

hesitate to contact us if you have questions or would like to discuss our comments. 

20 
Appendix C 

Distribution 

Office of the Administrator 

Assistant Administrator, Office of Solid Waste and Emergency Response 

Associate Administrator, Office of Homeland Security 

Principal Deputy Assistant Administrator, Office of Solid Waste and Emergency Response 

Associate Assistant Administrator, Office of Solid Waste and Emergency Response 

Director, Office of Emergency Management, Office of Solid Waste and Emergency Response 

Agency Followup Official (the CFO) 

Office of General Counsel 

Agency Followup Coordinator 

Associate Administrator for Congressional and Intergovernmental Relations 

Associate Administrator for Public Affairs 

Audit Followup Coordinator, Office of Solid Waste and Emergency Response 

Deputy Inspector General 

21