U.S. ENVIRONMENTAL PROTECTION AGENCY

OFFICE OF INSPECTOR GENERAL

EPA Could Improve 

Contingency Planning for 

Oil and Hazardous 

Substance Response 

Report No. 13-P-0152 February 15, 2013 

Scan this code to 

learn more about 

the EPA OIG. 
 

	 

Report Contributors: Patrick Gilbride

 Erin Barnes-Weaver 

 Mary Anne Strasser 

 Stephanie Wake 

Abbreviations 

ACP Area Contingency Plan 

CERCLA Comprehensive Environmental Response, Compensation, and Liability Act 

CWA Clean Water Act 

EPA U.S. Environmental Protection Agency 

NCP National Oil and Hazardous Substances Pollution Contingency Plan 

NRT National Response Team 

OEM Office of Emergency Management 

OIG Office of Inspector General 

OPA Oil Pollution Act 

OSC On-Scene Coordinator 

OSWER Office of Solid Waste and Emergency Response 

RCP Regional Contingency Plan 

RRT Regional Response Team 

USCG U.S. Coast Guard 

Cover photo:	 August 1, 2010, photo of EPA’s research vessel MudPuppy II on Michigan’s 

Morrow Lake as part of EPA’s response to the Enbridge oil spill. (EPA photo) 

Hotline 

To report fraud, waste, or abuse, contact us through one of the following methods: 

e-mail: OIG_Hotline@epa.gov write: EPA Inspector General Hotline 

phone: 1-888-546-8740 1200 Pennsylvania Avenue, NW 

fax: 202-566-2599 Mailcode 2431T 

online: http://www.epa.gov/oig/hotline.htm Washington, DC 20460 
 


 

U.S. Environmental Protection Agency 13-P-0152 

February 15, 2013 Office of Inspector General 

At a Glance
 

Why We Did This Review 

The National Oil and 

Hazardous Substances 

Pollution Contingency Plan 

(NCP) establishes federal roles 

for oil spill response and 

requires area and regional 

planning by the U.S. 

Environmental Protection 

Agency (EPA) and other 

stakeholders. A prior audit on 

the 2010 Deepwater Horizon oil 

spill in the Gulf of Mexico noted 

that some contingency plans 

were out of date. We initiated 

this review to determine 

whether the contingency 

planning structure for 

responding to oil spills and 

hazardous substance releases 

is effective, and whether plans 

are updated to reflect lessons 

learned from recent major 

events and new developments 

or industry trends. 

This report addresses the 

following EPA Goal or 

Cross-Cutting Strategy 

 Cleaning up communities 

and advancing sustainable 

development 

For further information, contact 

our Office of Congressional and 

Public Affairs at (202) 566-2391. 

The full report is at: 

www.epa.gov/oig/reports/2013/ 

20130215-13-P-0152.pdf 

EPA Could Improve Contingency Planning for 

Oil and Hazardous Substance Response 

What We Found 

EPA regions have expanded contingency planning by creating additional 

plans and materials, but regions cannot maintain this large volume of 

information with their limited resources. Regions have created subarea 

contingency plans, geographic response plans and strategies, and various 

web-based tools. This structure exceeds the three levels of plans 

established in the Oil Pollution Act, which revised the NCP to expand the 

response system. The NCP requires national planning in the form of an 

NCP, regional planning by each Regional Response Team in the form of 

Regional Contingency Plans, and area planning by Area Committees in the 

form of Area Contingency Plans. Regions developed additional plan 

materials because regional On-Scene Coordinators find them necessary to 

respond to incidents. Some written plans miss some NCP requirements, 

contain duplicative information, and are out-of-date. Technological 

methods—instead of revising written plans—would enable EPA to maintain 

current information needed to efficiently respond to spills. 

 Recommendations and Planned Agency Corrective Actions 

We recommend that the Assistant Administrator for Solid Waste and 

Emergency Response (1) issue guidance to regions on working with their 

Regional Response Teams and Area Committees to use the most efficient 

method available to address NCP requirements, (2) require regions to keep 

critical planning information up-to-date and avoid unnecessary duplication, 

(3) work through the office’s National Response Team capacity to develop a 

process to regularly incorporate lessons learned from national exercises into 

contingency plan reviews and updates, and (4) assess the resources 

necessary to develop and maintain contingency plans and use the results to 

develop a workforce plan to distribute contingency planning resources. The 

Agency agreed with our recommendations and plans to address them by the 

end of fiscal year 2013.

 Noteworthy Achievements 

EPA regions apply an inclusive approach toward contingency planning by 

working closely with other federal agencies, states, tribes, and industry 

representatives. Regions also use technological methods—such as 

Geographic Information Systems maps, web-based lists, and electronic 

tools—to address some NCP requirements. 
 

 

 

	 

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

WASHINGTON, D.C. 20460 

THE INSPECTOR GENERAL 

February 15, 2013 

MEMORANDUM 

SUBJECT:	 EPA Could Improve Contingency Planning for 

Oil and Hazardous Substance Response 

 Report No. 13-P-0152 

FROM: Arthur A. Elkins Jr. 

TO: Mathy Stanislaus 

Assistant Administrator for Solid Waste and Emergency Response 

This is our report on the subject review 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. 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 audit resolution procedures. 

Action Required 

Your response to the draft report included proposed corrective actions and completion dates. As 

such, we are closing this report upon issuance. We have no objections to the further release of 

this report to the public. We will post this report to our website at http://www.epa.gov/oig. 

If you or your staff have any questions regarding this report, please contact Melissa Heist, 

Assistant Inspector General for Audit, at (202) 566-0899 or heist.melissa@epa.gov; or 

Patrick Gilbride, Director for Risk and Program Performance, at (303) 312-6969 or 

gilbride.patrick@epa.gov. 
 

 

 


 


 


 

EPA Could Improve Contingency Planning for 13-P-0152 

Oil and Hazardous Substance Response 

Table of Contents 

Chapters 

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

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

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

 Noteworthy Achievements ........................................................................... 4 

Scope and Methodology.............................................................................. 5 

2 Contingency Planning Could Be More Effective ............................................. 6
 

EPA Regions Expanded Contingency Planning to Include 

 Additional Plans and Technological Tools ......................................... 6 

EPA Regions Cannot Regularly Update and Maintain All Plans 

Given Limited Resources .................................................................. 8 

EPA Could Use Technology to Streamline Contingency Planning .............. 11 

Conclusion................................................................................................... 12 

Recommendations ...................................................................................... 12 

Agency Comments and OIG Evaluation ...................................................... 13 

Status of Recommendations and Potential Monetary Benefits .............................. 14
 

Appendices 

A NCP Requirements for RCPs and ACPs .......................................................... 15
 

B Details on Scope and Methodology.................................................................. 16 

C Agency Response to the Draft Report ............................................................. 18 

D Distribution ......................................................................................................... 23 
 

 

Chapter 1

Introduction 

Purpose 

On August 25, 2011, the U.S. Environmental Protection Agency (EPA) Office of 

Inspector General (OIG) issued the report Revisions Needed to National 

Contingency Plan Based on Deepwater Horizon Oil Spill (Report No. 11-P-0534). 

Our report noted that some contingency plans were out of date at the time of the 

April 2010 Deepwater Horizon oil spill in the Gulf of Mexico and did not reflect 

deepwater drilling trends, lessons learned, and past major oil spills. Additionally, 

the volume of contingency plans made it difficult to determine how plans related 

to one another and whether they contained duplicative information. 

We initiated this review on EPA’s contingency planning for emergency response 

to determine whether the contingency planning structure for responding to oil 

spills and hazardous substance releases is effective, and whether plans are updated 

to reflect lessons learned from recent major events and new 

developments/industry trends, including deepwater drilling. 

Background 

Oil Spill Contingency Planning Response Authorities 

There are a number of laws requiring contingency planning for oil and hazardous 

substance spills. The Clean Water Act (CWA) established the basic structure for 

regulating discharges of pollutants into the waters of the United States. CWA 

Section 311 provides EPA and the U.S. Coast Guard (USCG) with the authority 

to establish a program for preventing, preparing for, and responding to spills that 

occur in navigable waters of the United States. 

The CWA (formerly called the Federal Water Pollution Control Act) also 

established requirements for the preparation and publication of the National 

Contingency Plan (National Oil and Hazardous Substances Pollution Contingency 

Plan, or NCP). The NCP serves as the federal government’s blueprint for 

responding to oil spills and hazardous substance releases. The NCP outlines the 

National Response System, which is the mechanism of coordinating response 

actions by all levels of government. The system is composed of the National 

Response Team (NRT), Regional Response Teams (RRTs), On-Scene Coordinators 

(OSCs), Area Committees, state and local governments, and certain vessels and 

facilities. The NCP describes 5 required elements to be included in an RCP and 

10 elements in an ACP. (See appendix A for requirements of RCPs and ACPs.) 

13-P-0152 1 
 

 

 

	 

	 

Releases of oil and hazardous materials are regulated separately under the Oil 

Pollution Act (OPA) and the Comprehensive Environmental Response, 

Compensation, and Liability Act (CERCLA). 

	 CERCLA, commonly known as Superfund, provided the government with 

authority to compel persons to clean up releases of hazardous substances 

for which they are responsible. CERCLA enabled the revision of the NCP 

to establish procedures and standards for responding to releases of 

hazardous substances, pollutants, or contaminants. 

	 The OPA improved the nation’s ability to prevent and respond to oil spills 

by establishing provisions that expanded the federal government’s ability, 

and provided monetary and other resources necessary, to respond to oil 

spills. The OPA provided new requirements for contingency planning both 

by government and industry. More specifically, it required the 

establishment of Area Committees comprised of federal, state, and local 

governments that made up a spill preparedness and planning body. The 

OPA also required the NCP to be revised to expand the response system 

into a three-tiered approach providing additional response requirements 

for the federal government, as well as additional planning requirements for 

Area Committees and owners and operators of vessels or certain facilities, 

such as onshore or offshore buildings, equipment, or pipelines. 

Contingency Planning Requirements 

The NCP requires contingency planning at the national, regional, and area levels. 

There are no specific requirements for updating contingency plans after major 

events. However, the NCP requires that RRTs “meet at least semiannually to 

review response actions carried out during the preceding period, consider changes 

in RCPs, and recommend changes in ACPs.” Additionally, the CWA requires 

Area Committees to periodically update ACPs. 

The NCP also outlines facility and vessel response plans that are required by the 

CWA. Tank facilities, offshore facilities, and onshore facilities that could cause 

substantial harm to the environment with a discharge into navigable waters must 

prepare and submit a plan for responding to a worst case discharge or substantial 

threat of such a discharge. Additionally, the NCP addresses the requirement by 

local governments to prepare local emergency response plans. 

The following figure describes the relationship between the plans. 

13-P-0152 2 
 

 

Figure 1: Relationship of Plans within the NCP 

Source: Figure 4 in Section 300.205 of the NCP. 

As demonstrated in figure 1, there are various levels of plans with many 

stakeholders involved at each level, resulting in a complex, interconnected 

system. The complexity of the contingency planning system necessitates close 

and continued coordination across agencies and among all levels of government. 

Additionally, active and effective participation by states is integral to the effective 

working of this complex National Response System. 

EPA’s Office of Solid Waste and Emergency Response 

EPA’s Office of Solid Waste and Emergency Response (OSWER) provides 

policy, guidance, and direction for the Agency’s emergency response and waste 

programs. Within OSWER, the Office of Emergency Management (OEM) works 

with other federal partners to prevent accidents as well as to maintain response 

capabilities. OEM’s National Planning and Preparedness Division is responsible 

for ensuring national EPA readiness to respond to incidents involving hazardous 

chemicals, oil, and biological/radiological contamination resulting from terrorist 

attacks or accidents. Each of EPA’s 10 regional offices has staff responsible for 

13-P-0152 3 
 

 

	 

	 

	 

oil pollution prevention and emergency response, including OSCs responsible for 

directing responses to incidents. The NCP requires that an EPA representative 

chairs the NRT and co-chairs all RRTs in each of the 10 regional offices and 

Alaska, Oceana, and the Caribbean. Each EPA region we reviewed took a 

different approach to regional contingency planning depending on the unique 

needs of the region. In a 1992 Federal Register Notice, EPA’s Administrator 

designated the 13 individual RRTs as the initial Area Committees. As a result, 

EPA regions have combined their RCPs and ACPs into one planning document. 

Noteworthy Achievements 

Many EPA regions have taken steps toward providing planning resources to 

responders using various technological methods. For example: 

	 Region 5 has developed an Inland Sensitivity Atlas for the entire region 

available on CD-ROMs using Geographic Information Systems 

technology. These maps identify information such as sensitive species, 

natural resources areas, shoreline sensitivity, and boat access ramps. Maps 

incorporate Geographic Information Systems data from local governments 

and a Region 5 contingency planner said that they cover about 40 square 

feet of area at a time. Region 5 response staff stated that these maps are 

one of the first resources they use when responding to an incident. 

	 Region 6 has developed two web-based tools—E-Plan and Response 

Manager—to collect and provide information needed for contingency 

planning and response to all agencies. 

	 The Region 10 RRT developed a website that lists all the equipment 

available within the northwest region. It is updated on an ongoing basis by 

equipment owners. 

Regional emergency management staff and managers in all regions in our review 

understand that contingency planning is an inclusive process involving many 

stakeholders. A number of planners and OSCs expressed the importance of 

outreach during the planning process to provide an effective response to an 

incident. While all regions do this to an extent, we noted that Region 10 does an 

exceptional job in incorporating states, locals, and one tribe into its planning 

process. For example, federal, state, local, and tribal government representatives 

attend Northwest Area Committee meetings held three times per year. 

OEM has also taken steps to address the complexity of the contingency planning 

structure. OEM is currently in the process of finalizing an “ACP Handbook” as a 

guide and reference for the development of ACPs. 

13-P-0152 4 
 

 

Scope and Methodology 

We performed our review from November 2011 to September 2012 in accordance 

with generally accepted government auditing standards. Those standards require 

that we plan and perform our review to obtain sufficient, appropriate evidence to 

provide a reasonable basis for any findings and conclusions based on our 

objectives. We believe that the evidence obtained provides a reasonable basis for 

our findings and conclusions based on our objectives. 

We reviewed laws, regulations, and Agency guidance on contingency planning. 

We focused our review on EPA Regions 5, 6, 8, and 10 (including Alaska) given 

their variation in environmental issues, types of emergencies, and corresponding 

responses. We interviewed EPA staff in headquarters and response staff and 

planners in each of these regions to understand their approach to contingency 

planning. We also reviewed a sample of 16 of 38 Subarea Contingency Plans and 

3 of 27 Geographic Response Plans in our regions of review. Finally, we 

reviewed and analyzed various electronic or web-based tools in two of the 

regions. 

Appendix B includes additional details on our scope and methodology. 

13-P-0152 5 
 

 

	 

	 

	 

Chapter 2

Contingency Planning Could Be More Effective 

EPA regions have expanded contingency planning by creating additional plans 

and materials, but regions cannot maintain this large volume of information with 

their limited funding and personnel. Regions have created subarea contingency 

plans, geographic response plans and strategies, and various web-based tools. 

This structure exceeds the three levels of plans established by the OPA, which 

revised the NCP to expand the response system. The NCP requires national 

planning in the form of an NCP, regional planning by each RRT in the form of 

RCPs, and area planning by Area Committees in the form of ACPs. Regions 

developed additional plan materials because regional OSCs find them necessary 

to respond to incidents. Some written plans miss some NCP requirements, contain 

duplicative information, and are out-of-date. Technological methods—instead of 

revising written plans—would enable EPA to maintain current information 

needed to efficiently respond to spills. 

EPA Regions Expanded Contingency Planning to Include Additional 

Plans and Technological Tools 

The NCP provides the organizational structure and procedures to prepare for and 

respond to discharges of oil and releases of hazardous substances. The NCP 

identifies three levels of contingency planning under the National Response 

System: the NCP, RCPs, and ACPs. 

	 The NRT is responsible for national planning and coordination and 

recommends revisions to the NCP to improve effectiveness. 

	 RRTs are responsible for regional planning and coordination and must 

develop an RCP for their region to ensure that during an actual incident 

the roles and responsibilities of federal, state, local, and other responders 

are clearly defined. 

	 The federal, state, and local agency members of an Area Committee are 

responsible for developing an ACP and working with governments and 

other stakeholders to enhance the contingency planning process. 

EPA’s contingency planning structure has exceeded the three levels of plans 

established by the OPA and outlined by the NCP. Regions 5, 6, 8, 10, and Alaska 

have each taken a different approach to planning. All have one plan that generally 

serves as a guidance document, typically the RCP-ACP for the region. One 

regional response manager described the RCP-ACP as “overarching guidance,” 

and another described it as seen at “the 70,000 foot level.” Four out of the five 

regions in our review also have lower-level operational plans in the form of 

13-P-0152 6 
 

 

 

 

 

subarea contingency plans or geographic response plans. These operational plans 

contain more tactical information in addition to the required RCP and ACP 

elements and are generally the plans used to respond to an incident. Additionally, 

all regions in our review have some type of electronic system or database that 

includes information on contacts, equipment, facilities, and/or sensitive areas that 

are useful during a response. Table 1 below lists the various plans maintained by 

each region in our review and shows how each has taken a different approach to 

planning: 

Table 1: Levels and Numbers of Contingency Plans 

Region 5 Region 6 Region 8 Region 10 Alaska 

Regional Federal 

Region 5 

RCP 

Regional 

Integrated 

Contingency 

Plan -

Interim 

Region 8 

RCP 

Northwest 

Area 

Contingency 

Plan 

Alaska 

Unified Plan 

Area One Gulf 

Plan and 5 

USCG ACPs 

Subarea 19 Subarea 

Contingency 

Plans 

 9 Subarea 

Contingency 

Plans 

 10 Subarea 

Contingency 

Plans 

Geographic 27 

Geographic 

Response 

Plans 

Web-based Inland 

Sensitivity 

Atlas 

(geographic 

maps for 

entire 

region) 

Response 

Manager 

and E-Plan 

Electronic 

Contact List 

Web Based 

Equipment 

List and 

Jurisdictional 

Boundary 

Tool 

Geographic 

Response 

Strategies 

Source: EPA OIG summary of contingency plans. 

Table 1 demonstrates that all regions have an overarching regional plan to meet 

NCP requirements for an RCP-ACP. Region 10 and Alaska RRTs incorporate 

additional requirements into their regional plans. The Northwest Area 

Contingency Plan contains the Region 10 RCP, 2 USCG ACPs, EPA’s Inland 

ACP, and state plans for Washington and Oregon in one plan for the northwest 

area. The Alaska Unified Plan combines the RCP and ACP, and includes 

additional requirements for Alaska’s State Master Plan.1 At the area planning 

level, the Region 6 RRT maintains the One Gulf Plan, which is an overarching 

document that contains USCG ACPs and geographic plans for the Gulf region. 

Regions 5, 8, 10, and Alaska have a number of subarea plans or geographic 

1

 The State of Alaska passed legislation in 1980 requiring the Alaska Department of Environmental Conservation 

to develop, annually review, and revise, as necessary, the State Oil and Hazardous Substance Contingency Plans 

(State Master Plan and Regional Plans). 

13-P-0152 7 
 

 

	 

	 

	 

	 

	 

response plans that contain more detailed information than regional plans. Finally, 

all regions have developed web-based planning tools that they use for response. 

Regions have expanded their contingency planning structure beyond the three 

requirements under the NCP because they find the additional materials necessary 

and useful for a response. Regional response personnel said that developing these 

materials is often more valuable than a written plan. 

	 Region 5 developed geographic mapping in the form of an Inland 

Sensitivity Atlas covering the entire region. A number of Region 5 OSCs 

stated that mapping is the most important resource for response. 

	 Region 6 maintains a contact list because responders believe contact 

information is one of the most important functions to retain for responding 

to an incident. 

	 Region 8 developed an OSC phone book for every federal, state, and local 

representative. A Region 8 OSC stated that contact information on whom 

to contact during a response is more useful than an actual plan. 

	 Region 10 has 27 geographic response plans that include tactical 

information intended to assist responders in the first 24 hours of a spill 

response. A Region 10 OSC stated that if a spill is located in an area with 

a geographic response plan it is the first resource they review. 

	 Alaska has 10 subarea contingency plans that include geographic 

resources and strategies that provide a platform for incident response. 

EPA Regions Cannot Regularly Update and Maintain All Plans 

Given Limited Resources 

Regions have difficulty updating and maintaining the various levels of plans. 

Operational information, such as equipment lists or contact numbers, can change 

frequently while policy and guidance in the overarching RCPs-ACPs rarely 

change. Updating contingency plans, especially RCPs and ACPs, is a timeconsuming and costly process. Revisions to RCPs-ACPs take time because an 

agency must vet changes through the remaining RRT federal agencies and states 

for review and most RRTs only meet semiannually. It took one region more than 

a year to update its RCP-ACP. Additionally, one regional OSC estimated that the 

cost to maintain and exercise plans for their region was a half-million dollars or 

greater. 

Furthermore, regions have limited planning resources—both funding and 

personnel—to maintain this volume of plans and other tools. Each of EPA’s 

10 regions has OSCs who have primary planning roles in guiding Area 

Committees in the development of ACPs. EPA evaluated the distribution of OSCs 

13-P-0152 8 
 

 

	 

	 

	 

	 

in 2001 following the Agency’s response to terrorist attacks, and the distribution 

may not address the planning requirements OSCs have for oil and hazardous 

substance spills. Regional response and planning staff in all regions we reviewed 

stated that they do not have enough resources to maintain plans, and that they 

spread resources to a variety of competing preparedness activities. Moreover, an 

OEM Director said that EPA never properly funded planning and there are 

continual budget cuts to the oil program. In its response to our draft report, 

OSWER provided additional clarification and noted that “funding for area 

contingency planning is not sufficient to meet its broad based goals and 

coordination needs.” OEM recently established a workgroup to review regional 

OSC allocations. 

The various levels of plans have resulted in a large volume of information that 

regions cannot regularly update and maintain. As a result, RCPs-ACPs miss some 

required NCP elements, and some contingency plans are duplicative and out of 

date. 

Missing Requirements in RCPs-ACPs 

Appendix A lists required elements for RCPs and ACPs, and we noted the 

following in the five RCPs-ACPs we reviewed: 

	 Three were missing a list of equipment, dispersants, or other mitigating 

substances and devices, as well as personnel available. 

	 Three did not address areas of economic or environmental importance for 

the area covered by the RCP-ACP. 

	 Two did not include detailed worst case discharge information in the 

public version of the plan for security reasons. 

	 Two did not discuss procedures for use of volunteers. 

While required information may be missing in an RCP-ACP, we found that 

regions may include it in a different planning mechanism. For example, while 

three of the five RCPs-ACPs we reviewed did not include detailed information on 

economic and environmental importance as a part of their geographical location, 

this information was available in a subarea contingency plan, geographic response 

plan, or other planning tool. Region 5 includes the environmentally and 

economically sensitive areas in their Inland Sensitivity Atlas that contains maps 

using Geographic Information System technology. 

13-P-0152 9 
 

 

 

	 

	 

	 

	 

Duplicative Information in Plans 

In developing the additional plans and planning materials, regions have duplicated 

some information. For example: 

	 Both Region 5 and Region 8 have large sections on relationships to other 

contingency plans and oil spill response, respectively, repeated in multiple 

sub-area plans. 

	 Region 6’s RCP includes the same information as the NCP, such as 

responsibilities of the NRT, RRTs, OSCs, and Incident and Unified 

Commands. 

	 Much of the information in Alaska’s Unified Plan is repetitive from the 

NCP, such as the listed requirements for ACPs and information on the 

Unified Command. 

	 The Region 8 sub-area plans contain contact information but the region 

also maintains an electronic contact list. 

While this provides for some consistency throughout the plans, it may not be 

necessary to include the same information multiple times; it adds repetitive text to 

already lengthy planning documents. RCPs-ACPs we reviewed averaged more 

than 575 pages. 

Some Plans Are Out-of-Date 

With limited resources for updating plans, regions have not updated some plans 

for many years. Several subarea contingency plans in Regions 5 and 8, as well as 

Alaska, are outdated, with some not being updated since the late 1990s. 

In addition, we could not determine whether regions updated plans based on 

lessons learned. One method to evaluate lessons learned is through Spills of 

National Significance2

 exercises held approximately every 3 years. Table 2 

summarizes recommendations raised during three Spills of National Significance 

exercises preceding the 2010 Deepwater Horizon oil spill,3

 the nation’s first actual 

Spill of National Significance. 

2

 Spills of National Significance are designated as such due to their severity, size, location, actual or potential impact 

on the public health and welfare or the environment, or the complexity of the necessary response effort. 3

 In April 2010, the Deepwater Horizon unit exploded and sank in the Gulf of Mexico. The event lasted 87 days and 

spilled an estimated 4.9 million barrels of oil, making it the largest marine oil spill in U.S. history. 

13-P-0152 10 
 

 

	 

Table 2: Recommendations from Spills of National Significance Exercises 

Spills of National 

Significance Exercise Contingency Plan Recommendations 

1998 – Prince William 

Sound and 

Western Gulf of Alaska 

ACPs should incorporate local issues and inform the 

regional plan holders and responders of the response 

structure and procedures that will be used. 

2004 – California The current ACP guidance does not include five elements 

related to Endangered Species Act: wildlife, historical 

properties, resource identification, fish habitat, and waste 

management plans. 

2007 – Great Lakes 

and Upper Mississippi/ 

New Madrid Fault 

Review current status of ACPs and RCPs to ensure they 

are being regularly updated. Many participants and 

evaluators observed that response plans were not 

immediately available or used in decisions-making. 

Informational gaps in response plans were exposed, with 

latest updates to such plans often not fully disseminated. 

Source: Lessons learned and after action reports from USCG and EPA. 

Similar issues and recommendations raised from the past three Spills of National 

Significance exercises came to fruition during the Deepwater Horizon spill. For 

example, the National Commission on the BP Deepwater Horizon Oil Spill and 

Offshore Drilling recommended that EPA and USCG bolster state and local 

involvement in oil spill contingency planning and create a mechanism for local 

involvement in spill planning and response. This recommendation is similar to the 

recommendation that arose in the 1998 exercise, yet we could not determine 

whether this recommendation was implemented in plans prior to the 2010 

Deepwater Horizon spill. In its response to our draft report, OSWER noted that 

the 1998 exercise in Alaska represented a totally different scenario (ice) than the 

Deepwater Horizon spill (warm weather/water). While we agree with OSWER 

that some of the recommendations from the Alaska exercise would not translate to 

the Deepwater Horizon spill, the recommendation we noted in Table 2 on 

contingency planning was generic in nature and should be considered nationally. 

If applied, knowledge gained from major spills and these exercises can improve 

preparedness. 

EPA Could Use Technology to Streamline Contingency Planning 

Most of the regions we reviewed already have or are in the process of moving 

toward maintaining plan requirements and other response information using 

technological methods, as Region 5 has done with its geographical mapping. 

Other examples include: 

	 Region 6 developed two response tools—E-Plan and Response Manager— 

to collect and provide information needed for contingency planning and 

response. These searchable databases collate information from multiple 

sources. E-Plan focuses on chemicals and Response Manager focuses on 

facilities and response data. 

13-P-0152 11 
 

 

	 

	 

 The Region 10 RRT developed a website that lists all equipment available 

within the northwest region. It is updated on an ongoing basis and 

maintained by all equipment owners. 

Regions can use these technological methods to keep information more current 

rather than in lengthy, written plans. Additionally, regions can update lower-level, 

tactical information as needed without having to vet changes through the 15 RRT 

federal agencies for approval, as necessary for making changes to an RCP-ACP. 

All regions stated that using technology or web-based planning could help 

streamline the contingency planning process. Furthermore, several regional 

contingency planning personnel said that the process of planning is often more 

important than the plan itself. Planning is inclusive of many players—federal, 

state, and local—and regional OSCs and planners expressed the importance of 

outreach to build relationships with these groups. Using technological methods to 

streamline contingency planning would allow regions to focus on aspects of 

planning and preparedness that are most important to them. 

Conclusion 

EPA expanded contingency plans beyond the three levels of plans established by 

the OPA and outlined by the NCP because regional response staff said additional 

plans are necessary and useful for responding to incidents. However, this has 

resulted in a large volume of information that regions cannot regularly update and 

maintain with their limited resources. EPA could more efficiently address some 

NCP requirements by using technological tools rather than by updating or 

revising written plans. The NCP—most recently revised in 1994—does not 

incorporate improved technological methods for data collection and information 

delivery. The concept of a written plan could become obsolete when better 

technological methods, such as web databases, serve as more efficient methods 

for information delivery. Regions have already taken steps to use technological 

methods and acknowledged that they could make contingency planning more 

efficient. EPA could make it easier for regions to maintain current, complete, and 

accurate information by investing in technology and using the most effective 

information retention and delivery method as a single source to address the NCP 

requirements. 

Recommendations 

We recommend that the Assistant Administrator for Solid Waste and Emergency 

Response: 

1.	 Issue guidance to regions on working with their RRTs and Area 

Committees to use the most efficient method available to collect, maintain, 

and deliver RCP/ACP-required elements outlined in the NCP, which may 

mean using technological tools in lieu of written plans. 

13-P-0152 12 
 

 

 

	 

	 

	 

2. Require regions to keep critical planning information up to date using the 

most effective method available and avoid unnecessary duplication. 

3.	 Have the Director of OEM work through the office’s NRT capacity to 

develop a process to regularly incorporate lessons learned from national 

exercises into contingency plan reviews and updates. 

4.	 Assess the resources, including OSCs, necessary to develop and maintain 

contingency plans. Use the results of this analysis to develop a workforce 

plan to distribute contingency planning resources. 

Agency Comments and OIG Evaluation 

OSWER generally agreed with our report recommendations and indicated that the 

recommendations parallel efforts OSWER is undertaking. OSWER’s response 

noted two key obstacles that must be overcome before successful implementation 

of planned corrective actions can be achieved: limited involvement by other 

agencies and stakeholders, and limited resources. OSWER’s response noted that, as 

the designated lead for inland areas, EPA must ensure compatibility with USCGled plans for coastal zones. While OSWER’s response stated that “EPA strives to 

ensure high quality contingency plans,” the Agency “is limited in its authority to 

require other agencies to update their critical planning information. 

We made minor revisions to our final report text, as appropriate, based on 

OSWER’s responses, including revising our third recommendation after additional 

correspondence with OSWER. Appendix C contains the Agency’s full responses to 

our draft report and planned actions by OSWER to address our recommendations. 

We believe that OSWER’s planned actions address the intent of our 

recommendations. Our recommendations remain open pending the completion of 

planned corrective actions. 

13-P-0152 13 
 

 

 

 

 

 

 

 

 

 

Status of Recommendations and 

Potential Monetary Benefits 

POTENTIAL MONETARY 

RECOMMENDATIONS BENEFITS (in $000s) 

Planned 

Rec. 

No. 

Page 

No. Subject Status1 Action Official 

Completion 

Date 

Claimed 

Amount 

Agreed-To 

Amount 

1 12 Issue guidance to regions on working with their O Assistant Administrator 09/30/13 

RRTs and Area Committees to use the most for Solid Waste and 

efficient method available to collect, maintain, and Emergency Response 

deliver RCP/ACP-required elements outlined in the 

NCP, which may mean using technological tools in 

lieu of written plans. 

2 13 Require regions to keep critical planning O Assistant Administrator 09/30/13 

information up to date using the most effective for Solid Waste and 

method available and avoid unnecessary Emergency Response 

duplication. 

Have the Director of OEM work through the office’s 3 13 O Assistant Administrator 05/31/13 

NRT capacity to develop a process to regularly for Solid Waste and 

incorporate lessons learned from national Emergency Response exercises into contingency plan reviews and 

updates. 

4 13 Assess the resources, including OSCs, necessary O Assistant Administrator 09/30/13 

to develop and maintain contingency plans. Use for Solid Waste and 

the results of this analysis to develop a workforce Emergency Response 

plan to distribute contingency planning resources. 

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

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

U = recommendation is unresolved with resolution efforts in progress 

13-P-0152 14 
 

Appendix A 

NCP Requirements for RCPs and ACPs 

Table 3: RCP and ACP Requirements 

RCPs shall: 

1. Include all useful facilities and resources in the region, from government, commercial, academic, 

and other sources. 

2. Follow the format of the NCP. 

3. Be coordinated with state emergency response plans, ACPs, and Title III local emergency 

response plans. 

4. Include lines of demarcation between the inland and coastal zones, as mutually agreed upon by 

USCG and EPA. 

5. Specify detailed criteria for activation of RRTs. 

ACPs shall: 

1. Be adequate to remove a worst case discharge and to mitigate or prevent a substantial threat of 

such a discharge from a vessel, offshore facility, or onshore facility operating in or near the area. 

2. Provide for a well-coordinated response that is integrated and compatible with all appropriate 

response plans of state, local, and non-federal entities, and especially with Title III local 

emergency response plans. 

3. Include a description of the area covered by the plan, including the areas of special economic or 

environmental importance that might be damaged by a discharge. 

4. Include a detailed description of the responsibilities of an owner or operator and of federal, state, 

and local agencies in removing a discharge, and in mitigating or preventing a substantial threat of 

a discharge. 

5. Include a list of equipment, dispersants, or other mitigating substances and devices, and 

personnel available. 

6. Include a description of procedures to be followed for obtaining an expedited decision regarding 

the use of dispersants. 

7. Include a detailed description of how the plan is integrated into other ACPs and tank vessel, 

offshore facility, and onshore facility response plans. 

8. Establish procedures to allow for well organized, worthwhile, and safe use of volunteers. 

9. Include a Fish and Wildlife and Sensitive Environments Plan in an annex (this annex has 

13 requirements). 

10. Incorporate technical and scientific information and strategies where effective standard 

techniques are unavailable. 

Source: EPA OIG review of NCP. 

13-P-0152 15 
 

 

Appendix B 

Details on Scope and Methodology 

We conducted our review to determine whether the contingency planning structure for responding to oil 

spills and hazardous substance releases is effective. By “structure” we considered the various levels of 

plans and other planning materials in each region, how they fit together, and how regions utilize them 

during responses to incidents. 

We chose a sample of EPA regions to focus our review: Regions 5, 6, 8, and 10 (including Alaska). 

All of these regions have varying types of environments and potential types of emergencies and 

corresponding responses. We chose Region 5 due to the Enbridge pipeline spill in July 2010 near 

Marshall, Michigan. The release, estimated at 819,000 gallons, entered Talmadge Creek and flowed into 

the Kalamazoo River, a Lake Michigan tributary. We included Region 6 because of the region’s history 

of oil spills and our familiarity with Region 6 plans based on our audit of dispersant use in the 2010 

Deepwater Horizon oil spill. We chose Region 8 due to the media and political attention of the 

TransCanada Keystone pipeline. Region 8 is a contrast to other regions as it is a totally inland zone 

where EPA has response authority for the entire region. We included Region 10 because it has extensive 

oil production in deepwater in both the Pacific and Arctic Oceans as well as onshore. 

To address our objective, we reviewed laws and regulations on contingency planning, including: 

 CWA 

 CERLCA 

 Emergency Planning and Community Right-to-Know Act 

 Executive Order 12777, Implementation of Section 311 of the Federal Water Pollution Control 

Act of October 18, 1972, as amended, and the Oil Pollution Act of 1990 

 Executive Order 13580, Interagency Working Group on Coordination of Domestic Energy 

Development and Permitting in Alaska 

 Executive Order 13547, Stewardship of the Ocean, Our Coasts, and the Great Lakes 

 NCP 

 OPA 

 Spill Prevention Control and Countermeasure Rule 

To understand EPA’s approach to contingency planning and how different plans are used in a response, 

we conducted interviews with: 

 Staff in EPA headquarters, including the OEM Director, OEM Deputy Director, OEM National 

Planning and Preparedness Director, and the Executive Director of the NRT 

 RRT co-chairs, planners, and OSCs in Regions 5, 6, 8, 10 and Alaska 

To gain perspectives of those outside the Agency, we interviewed contingency planning staff in: 

 USCG 

 U.S. Department of the Interior 

 U.S. Department of Transportation 

 States of Alaska, Texas, Utah, and Washington 

13-P-0152 16 
 

 

 

 

 

Regions 5, 6, 8, 10, and Alaska all have several levels of contingency plans and other response 

resources. We reviewed regional RCPs and ACPs to determine whether they met the requirements under 

the NCP. We also reviewed a sample of other contingency plans to determine how regions use various 

plans in a response and how they relate to each other. Table 4 shows the various levels of plans in each 

region, and red font denotes those we reviewed. 

Table 4: Levels and Numbers of Contingency Plans in Regions Reviewed 

ACPs and 

RCPs4 

Region 5 

RCP-ACP 

Region 6 

 RCP-ACP 

One Gulf Plan 

Region 8 

RCP-ACP 

Region 10 

 Northwest ACP 

(RCP-ACP) 

Alaska 

Alaska Unified 

Plan (RCP-ACP) 

Sub-ACPs 19 (7) 9 (7) 10 (2) 

Geographic 

Response Plans 

27 (3) 

Electronic or 

Web-Based 

Tools 

Geographic 

Mapping for 

the Region 

Response 

Manager and 

E-Plan 

Electronic 

Contact 

List 

Equipment List 9 Geographic 

Response 

Strategies 

Source: EPA-OIG summary of contingency plans and response resources. 

Prior Audit Coverage 

In April 2010, the Deepwater Horizon unit operated by BP exploded and sank in the Gulf of Mexico. The 

event lasted 87 days and spilled an estimated 4.9 million barrels of oil, making it the largest marine oil 

spill in U.S. history. The OIG reviewed EPA’s role in the use of dispersants during the spill and issued the 

report Revisions Needed to National Contingency Plan Based on Deepwater Horizon Oil Spill (Report 

No. 11-P-0534) on August 25, 2011. We found that contingency plans were out of date at the time of the 

spill and were not updated to reflect deepwater drilling trends, lessons learned, and past major oil spills. 

We recommended that OEM work through its NRT capacity to establish a policy for periodic reviews and 

updates to contingency plans after considering lessons learned from major national and international oil 

spills and/or based on area trends in oil drilling. OSWER agreed with this recommendation. OSWER is 

working with the NRT on a framework for plan reviews and updates in light of lessons learned from the 

Deepwater Horizon spill, and anticipates completing the framework by March 31, 2013. 

Additionally, our office issued the report EPA Should Continue to Improve Its National Emergency 

Response Planning (Report No. 08-P-0055) on January 9, 2008. This report evaluated EPA’s Response 

Business Plan and found that it did not satisfy EPA’s need for a framework to respond to incidents of 

national significance. The report recommended 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 concurred with the recommendations. 

4

 All regions in our review have combined their RCPs and ACPs due to a 1992 Federal Register notice that combined RRTs 

and Area Committees. 

13-P-0152 17 
 

 

 


 


 


 

Appendix C 

Agency Response to the Draft Report 

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

WASHINGTON, D.C. 20460 

OFFICE OF 

SOLID WASTE AND 

EMERGENCY RESPONSE
 

December 10, 2012 

MEMORANDUM 

SUBJECT: Response to OIG’s draft report: “EPA Could Improve Contingency Planning for Oil and 

Hazardous Substance Emergency Response.” Assignment No. OA-FY12-0084 

FROM: Mathy Stanislaus /s/ 

 Assistant Administrator 

TO: Melissa M. Heist 

Assistant Inspector General for Audit 

Thank you for the opportunity to respond to the issues and recommendations in the subject audit report. 

Following is a summary of the agency’s overall views, along with its views on each of the report 

recommendations. The agency agrees with the report recommendations which generally parallel efforts 

we have been addressing. Accordingly, we have provided high-level intended corrective actions and 

estimated completion dates. For your consideration, we have included a Technical Comments 

Attachment to supplement this response. 

AGENCY’S OVERALL VIEWS 

In response to the OIG’s Draft Report, “EPA Could Improve Contingency Planning for Oil and 

Hazardous Substance Emergency Response,” EPA generally agrees with the recommendations in this 

report. Area contingency planning is a coordinated effort among twenty or more federal, state, local and 

tribal agencies; even prior to the passage of the Oil Pollution Act of 1990 (OPA 90), EPA worked on 

area planning, as contingency planning pre-dates OPA 90. EPA works very closely with the U.S. Coast 

Guard (USCG), the designated lead agency for planning and response in coastal zones and certain major 

inland water bodies. 5 EPA is the designated lead agency for inland areas. 6 EPA-lead inland plans 

covering areas adjacent to the coastal zone must ensure compatibility with USCG-lead plans for those 

5

 April 24, 1992 Federal Register Notice (57 FR 15198): Designation of Areas and Area Committees Under the 

Oil Pollution Act of 1990.
 6

 Through Executive Order 12777 (56 FR 54757; October 22, 1991), the President delegated to EPA the 

responsibility for designating the areas and appointing the committees for the “inland zone”. Under the CWA, 

ACPs are developed by Area Committees under the direction of the FOSC for their area.
 

13-P-0152 18 
 

 

zones. In this leadership role, EPA strives to ensure high quality contingency plans for each Area 

Contingency Plan (ACP), to meet the requirements of OPA 90 and the National Oil and Hazardous 

Substances Pollution Contingency Plan (or, “National Contingency Plan” (NCP)). However, with so 

many other agencies also active participants and contributors to the planning process, EPA is limited in 

its authority to require other agencies to update their critical planning information. 

Thus, although we generally agree with the recommendations in this report, and they parallel our efforts, 

two key obstacles, (i.e., limited involvement by other agencies and stakeholders and resources) must be 

overcome for their successful implementation. New incident response techniques, policy changes, 

technological innovations and the work to incorporate lessons learned into area plans makes this a 

continuously improving process and completion very difficult. Thus, EPA is dependent on future years’ 

resources to sustain and expand its current area planning commitments. 

In addition, there are three areas of the report that need clarification. The first, on page 4 of the report, in 

the background discussion of EPA’s Office of Solid Waste and Emergency Response, the drafters state 

that, “[e]ach EPA region we reviewed has taken a different approach to regional contingency planning.” 

It is important to emphasize that regions need to take a tailored approach to regional contingency 

planning in order to meet the unique needs of their region. Because area plans are focused on specific 

geographic domains, with many physical and jurisdictional variables, there can be no “one size fits all” 

plan format. EPA’s OSWER/OEM does ensure national consistency to the extent possible. 

Secondly, on page 9 of the report under the heading, “EPA Regions Cannot Regularly Update and 

Maintain All Plans Given Limited Resources,” the report attributes to “an OEM Director,” that, “EPA 

never properly funded planning and there are continual budget cuts to the oil program.” This statement 

is generalized to “planning” where it is more specific to “area contingency planning.” Therefore, a more 

accurate characterization would be that, “funding for area contingency planning is not sufficient to meet 

its broad based goals and coordination needs” 

Finally, on page 11 of the report, under the heading, “Some Plans are Out-of-Date,” we would like to 

address the statement that it could not be determined that recommendations that arose in the 1998 

exercise (Prince William Sound and Western Gulf of Alaska) were implemented in plans prior to the 

2010 Deepwater Horizon (DWH) spill and that “[i]f applied, knowledge gained from major spills and 

these exercises can improve preparedness.” EPA continuously incorporates local issues and informs its 

regional plan holders and responders of the response structure and procedures that result from lessons 

learned from Spills of National Significance (SONS) exercises and real world spills in order to improve 

preparedness; however, lessons learned in the 1998 exercise in AK represent a totally different scenario 

(ice) than the real world DWH (warm weather/water) spill. Thus the majority of lessons learned from 

the 1998 AK exercise would not translate to the DWH spill. Furthermore, to maximize existing regional 

resources and to comply with the mandated area contingency planning requirements, regional area 

planners are not mostly composed of OSCs. Although, the On-Scene Coordinators (OSCs) are the 

personnel mandated by OPA 90 and the NCP to work on ACPs & Area Committees (ACs), other 

personnel participate as well. 

13-P-0152 19 
 

No. Recommendation High-Level Intended 

Corrective Action(s) 

Estimated Completion by 

Quarter and FY 

1 Issue guidance to regions on 

working with their RRTs and 

Area Committees (ACs) to use 

the most efficient method 

available to collect, maintain, 

and deliver RCP/ACP required 

elements outlined in the NCP, 

which may mean using 

technological tools in lieu of 

written plans. 

OEM will clarify in the 

revisions already 

underway for the ACP 

Handbook and provide 

the updated ACP 

Handbook (guidance) to 

regions. 

4th Quarter of FY 2013 

2 Require regions to keep critical 

planning information up to date 

using the most effective method 

available and avoid unnecessary 

duplication. 

2.1 OEM will inform 

regional offices to avoid 

unnecessary duplication 

through the ACP 

Handbook (guidance). 

4th Quarter FY 2013 

2.2 OSWER/OEM will 

issue guidance and work 

with the Regions on its 

timely implementation. 

4th Quarter FY 2016, and 

continuing 

3 Have the Director of OEM work 

through the office’s NRT 

capacity to incorporate lessons 

learned from national exercises 

in the forthcoming NRT policy 

on periodic contingency plan 

reviews and updates. 

The NRT will continue to 

incorporate lessons 

learned from exercises 

and real world events into 

its purview. 

On-going 

4 Assess the resources, including 

OSCs, necessary to develop and 

maintain contingency plans. Use 

the results of this analysis to 

develop a workforce plan to 

distribute contingency planning 

resources. 

Building on the existing 

workgroup process, 

continue evaluation of 

OSC resources based on 

needs and responsibilities 

of the regions to develop 

the plan to redistribute 

regional OSC allocations. 

Recommendation from 

workgroup by end of 4th 

quarter FY2013. 

Disagreements 

OEM has noted above our concerns with some of the language and provided qualifiers to address the 

fact that EPA is limited in its authority to require other agencies to update their critical planning 

information. 

Thank you for the opportunity to respond to your final findings paper. Should you have any questions 

regarding this memo, please contact Dana Tulis, Deputy Director, Office of Emergency Management at 

202-564-8600. 

Attachment 

13-P-0152 20 

 


 

MEMORANDUM 

BJECT: 

FROM: 

TO: 

Follow-up Response to OIG draft report: ·'EPA Could Improve Contingency 

Planning for Oil and - rd us ubstance Emergency Response: Assignment No. 

0A-FYI2-0084 

Mathy Stanislau 

Assistant Administ at 

Melis aM. Heist 

Assistant Inspector General for Audit 

We concur with the revised recommendation number 3 as stated below and provide our response 

to the recommendation. 

OIG Revised Recommendation 

Have the Director of OEM work through the olTice·s NRT capacity to de elop a process to 

regularly incorporate lessons learned from national exercises into contingency plan reviews and 

updates. 

0 WER Response 

The NRT and RRTs have existing procedures to encourage and ensure that lessons learned from 

responses and exercises are incorporated into contingency plan improvements. The NCP requires 

the RRTs to " ... review response actions carried out during the preceding period, consider 

changes to the RCPs. and recommend changes to the ACPs." This process has carried over to 

experiences gained through large-scale exercises. In addition to the regular RRT meetings, the 

annual NRT/RRT Co-Chair meeting has a standing agenda item to discus the prior year 

responses and exercises. lessons learned, and how those lessons will improve contingency plans. 

The next such national meeting is scheduled for April 2013. and this will be on the agenda. The 

RT will also ensure that thjs agenda item is on the agenda for all annual RT/RRT Co-Chairs 

meeting; the next such meeting will likely be planned for Spring 2014. 

Further, as one example/demonstration of a specific NRT guidance document that resulted from 

a lesson learned (in this case from the Deepwater Horizon oil spill response), OEM will finalize 

the National Response Team's Atypical Dispersant Guidance. This document has been drafted 

and it is currently under re iew by the NRT member agencies. The planned date of completion 

of this guidance is 5/31 /13. 

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

WASHINGTON, D.C. 20460 

OFFICE OF
 

SOLID WASTE AND 

EMERGENCY RESPONSE
 

February 8, 2013 

13-P-0152 21 
13-P-0152 22 
 

Appendix D 

Distribution 

Office of the Administrator 

Assistant Administrator for Solid Waste and Emergency Response 

Agency Follow-Up Official (the CFO) 

Agency Follow-Up Coordinator 

General Counsel 

Associate Administrator for Congressional and Intergovernmental Relations 

Associate Administrator for External Affairs and Environmental Education 

Regional Administrator, Region 5 

Audit Follow-Up Coordinator, Office of Solid Waste and Emergency Response 

Regional Administrator, Region 6 

Regional Administrator, Region 8 

Regional Administrator, Region 10 

Audit Follow-Up Coordinator, Region 5 

Audit Follow-Up Coordinator, Region 6 

Audit Follow-Up Coordinator, Region 8 

Audit Follow-Up Coordinator, Region 10 

13-P-0152 23