EPA Has Developed Guidance 

for Disaster Debris 

but Has Limited Knowledge 

of State Preparedness

Report No. 16-P-0219 June 29, 2016

 

U.S. ENVIRONMENTAL PROTECTION AGENCY

OFFICE OF INSPECTOR GENERAL

Enforcement and Compliance
This is one of our products associated with EPA oversight of states authorized to 

implement environmental programs. The Office of Inspector General cited absence of 

robust oversight of states as one of the EPA’s key fiscal year 2015 management 

challenges. For details go to our report on management challenges.

Report Contributors: Alisha Chugh

Steve Hanna

Tina Lovingood

Nirvair Stein

Abbreviations

C&D Construction and Demolition 

EPA U.S. Environmental Protection Agency

ESF Emergency Support Function

GAO U.S. Government Accountability Office

OIG Office of Inspector General

OLEM Office of Land and Emergency Management

ORCR Office of Resource Conservation and Recovery

USACE U.S. Army Corps of Engineers

Cover photo: Aftermath of the May 22, 2011, tornado in Joplin, Missouri. (EPA photo)

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 16-P-0219

June 29, 2016

Why We Did This Review

We evaluated whether the 

U.S. Environmental Protection 

Agency’s (EPA’s) Office of 

Land and Emergency 

Management (OLEM) has 

worked with appropriate 

federal agencies and verified 

states have planned for 

disaster debris management.

The EPA published Planning 

for Natural Disaster Debris

guidance in 2008 in response 

to a U.S. Government 

Accountability Office report 

recommendation. The

document was developed to 

provide detailed guidance to 

state and local entities 

involved with managing debris 

disposal after a disaster, to 

better ensure protection of 

public health and the 

environment, and to prevent 

the creation of future 

Superfund sites. 

This report addresses the 

following EPA goals or 

cross-agency strategies:

 Addressing climate 

change and improving air 

quality.

 Cleaning up communities 

and advancing 

sustainable development.

 Ensuring the safety of 

chemicals and preventing 

pollution.

Send all inquiries to our public

affairs office at (202) 566-2391

or visit www.epa.gov/oig.

Listing of OIG reports.

EPA Has Developed Guidance for Disaster Debris but 

Has Limited Knowledge of State Preparedness 

 What We Found

The EPA has worked with other 

federal agencies in response to 

natural disasters. However, according 

to EPA staff, the agency has limited 

information on the types of, volumes

of and disposal sites for disaster 

debris that is not hazardous waste. 

Disaster debris can contain an 

unsegregated mixture of hazardous 

and solid waste debris that may ultimately fall under EPA regulatory authority. By 

obtaining information on the types of, volumes of and disposal sites for disaster 

debris, the EPA is positioned to communicate and help guide the management of 

potential risks to humans and the environment. 

OLEM has not determined that states have planned for disaster debris 

management consistent with EPA guidance. Based on interviews with all 10 EPA 

regional offices, we found that, except for Regions 4 and 5, EPA regions are 

unaware of the status or content of state disaster debris plans, and do not know 

whether the plans address the components defined in the EPA’s 2008 guidance. 

According to the EPA, states are not federally required to develop debris 

management plans, and the EPA has no authority to ensure that states have 

adequate plans or that they follow their plans during a disaster response.

However, without determining the adequacy of state plans, the EPA cannot assess 

states’ readiness to manage disaster debris, and scenarios where disaster debris 

is not managed or disposed of in an environmentally sound manner could result. 

The EPA’s effectiveness in helping communities to become more resilient to the 

effects of climate change and extreme weather events could be impacted, which is 

also an element of the agency’s climate change adaptation plans. 

EPA Regions 4 and 5 have examples of good practices for disaster debris 

management. Region 4 established a team to provide disaster debris assistance to 

states. Region 5 developed a disaster debris website that includes links to state 

plans and guidance within the region.

 Recommendations and Planned Agency Corrective Actions 

We recommended that OLEM establish procedures for EPA regions to obtain 

available information for the types, volumes and disposal sites for disaster debris 

in future disasters. We also recommended that OLEM develop a plan to provide 

assistance to states to address the major elements identified in EPA guidance.

The EPA agreed with all recommendations and provided planned corrective 

actions and completion dates. All recommendations are resolved.

U.S. Environmental Protection Agency

Office of Inspector General

At a Glance

Debris from natural disasters has 

contributed to contamination of at least 

one Superfund site, which has cost the 

EPA an estimated $55 million. The EPA 

can reduce the risk of future unsafe 

debris disposal practices by improving 

its understanding and awareness of the 

quality and completeness of state 

disaster debris management plans.
June 29, 2016

MEMORANDUM

SUBJECT: EPA Has Developed Guidance for Disaster Debris but Has Limited Knowledge 

 of State Preparedness

Report No. 16-P-0219

FROM: Arthur A. Elkins Jr.

TO: Mathy Stanislaus, Assistant Administrator

Office of Land and Emergency Management

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

U.S. Environmental Protection Agency (EPA). The project number for this evaluation was

OPE-FY15-0012. 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.

The Office of Resource Conservation and Recovery within the Office of Land and Emergency 

Management is responsible for the issues noted in this report.

Action Required

In accordance with EPA Manual 2750, your office provided planned corrective actions in response to 

the OIG recommendations. All recommendations are considered resolved. You are not required to 

provide a written response to this final report because you provided agreed-to corrective actions and a 

planned completion date for the report recommendations. Should you choose to provide a final response, 

we will post your response on the OIG’s public website, along with our memorandum commenting on 

your response. Your response should be provided as an Adobe PDF file that complies with the 

accessibility requirements of Section 508 of the Rehabilitation Act of 1973, as amended. The final 

response should not contain data that you do not want to be released to the public; if your response 

contains such data, you should identify the data for redaction or removal along with corresponding 

justification.

We will post this report to our website at www.epa.gov/oig. 

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

WASHINGTON, D.C. 20460

THE INSPECTOR GENERAL
EPA Has Developed Guidance for Disaster Debris but 16-P-0219

Has Limited Knowledge of State Preparedness

Table of Contents

Chapters

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

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

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

Responsible Office ............................................................................................. 4

Scope and Methodology..................................................................................... 4

Prior Report........................................................................................................ 5

2 EPA Has Limited Knowledge of Disaster Debris and State Planning Efforts ...... 6

EPA Coordinates With Other Federal Agencies but Has Incomplete 

Knowledge of the Volume or Disposal of Disaster Debris ............................. 7

EPA Has Not Determined the Existence or Adequacy of 

State Disaster Debris Management Plans.................................................... 8

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

Recommendations.............................................................................................. 11

Agency Response and OIG Evaluation............................................................... 11

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

Appendices

A Agency Response to Draft Report................................................................... 13

B Distribution ....................................................................................................... 16
16-P-0219 1

Chapter 1

Introduction

Purpose

The U.S. Environmental Protection Agency (EPA), Office of Inspector General

(OIG), conducted this evaluation to determine whether the EPA’s Office of Land 

and Emergency Management (OLEM) has worked with appropriate federal 

agencies and verified states have planned for disaster debris management.

Background

Disasters Can Create Large Volumes of Debris

Natural disasters in the United States can create enormous volumes of debris that 

should be rapidly managed. Examples of debris volume include:

 Hurricane Andrew (1992), more than 43 million cubic yards.

 Hurricane Katrina (2005), more than 100 million cubic yards.

 Joplin, Missouri, tornado (2011), more than 1.5 million cubic yards.

 Hurricane Sandy (2012), more than 

5 million cubic yards.

Disaster preparedness and response is performed 

at all levels of government. Federal, state and 

local agencies segregate the debris, to the extent 

feasible, and manage the segregated debris 

through disposal or recycling. Segregated debris 

has been placed into the following categories in 

prior disasters:

 Municipal solid waste (e.g., typical household garbage or 

trash). 

 Construction and demolition (C&D) debris (e.g., building 

materials such as drywall, lumber, carpet and plumbing).

 Vegetative debris (e.g., trees, branches, shrubs and logs).

 Household hazardous waste (e.g., oil, pesticides, paints

and cleaning agents).

 White goods (e.g., refrigerators, freezers, washers, 

dryers, stoves, etc.).

 Electronic waste (e.g., computers, televisions, stereos, 

etc.).

Searching for hazardous containers 

among Hurricane Sandy’s debris. 

(EPA photo)

Household hazardous waste. 

(EPA photo)
16-P-0219 2

Instructions for separation of debris appear in the following infographic.

FEMA debris removal guidance distributed after the Joplin, Missouri, tornado

Source: Federal Emergency Management Agency.

EPA’s Responsibilities for Coordinating Disaster Debris Management 

The EPA has a role in responding to certain types of natural disasters. Information 

found on the EPA’s web page titled “EPA’s Role in Emergency Response” states: 

EPA’s emergency response program responds to chemical, oil, 

biological, and radiological releases and large-scale national 

emergencies, including homeland security incidents. EPA provides 

support when requested or when state and local first responder 

capabilities have been exceeded. Through coordinating and 

implementing a wide range of activities, EPA conducts removal 

actions to protect human health and the environment. This is done 

by either funding response actions directly or overseeing and 

enforcing actions conducted by potentially responsible parties. 

States, not the EPA, have primary responsibility for managing nonhazardous solid 

waste. According to the EPA’s Resource Conservation and Recovery Act (RCRA)

Orientation Manual 2014, “EPA regulates hazardous solid wastes and may 

authorize states to do so. Nonhazardous solid waste is predominately regulated by 

state and local governments.”
16-P-0219 3

In addition, the U.S. Department of Homeland Security’s National Response 

Framework serves as a guide to how the nation responds to all types of disasters 

and emergencies. This framework defines 15 emergency support functions (ESFs). 

The federal government and many state governments organize their response 

resources and capabilities under the ESF system. Each ESF is composed of a 

department or agency that has been designated as the ESF coordinator, along with a 

number of primary and support agencies. Following a natural disaster, the EPA can 

have responsibilities for disaster debris response under two of the following ESFs:

 ESF #3, Public Works and Engineering. Addresses managing contaminated 

debris and waste through debris removal and disposal operations. The 

U.S. Army Corps of Engineers (USACE) is the ESF coordinator for this 

function, with the EPA serving as a supporting agency. The EPA’s role 

includes providing assistance to state solid waste agencies regarding 

municipal solid waste landfills and C&D landfills.

 ESF #10, Oil and Hazardous Materials Response. Addresses the cleanup of 

oil and hazardous materials. According to the EPA, this role includes storage, 

treatment and disposal of oil and hazardous materials, including contaminated 

debris. It also includes monitoring debris disposal. The EPA is the ESF 

coordinator for this function. EPA responsibilities under this ESF include: 

o Coordinating support in response to an actual or potential discharge 

and/or release of oil or hazardous materials. 

o Environmental assessment of the nature and extent of oil and

hazardous materials contamination.

o Environmental decontamination and cleanup.

EPA Includes Disaster Debris Management in Its Climate Change 

Adaptation Plans

In the EPA’s 2014 Climate Change Adaptation Plan, the agency specifically 

recognized disaster debris management as a potential vulnerability in its climate 

change planning efforts by stating: “Increased frequency and intensity of extreme 

weather events may affect EPA’s capacity to manage debris and respond to 

emergencies.” 

Draft climate change adaptation plans have been developed by OLEM and all 

EPA regions. The OLEM plan, and many of the regional plans, also identify 

potential disaster debris issues or vulnerabilities associated with climate change 

and identify actions to address the issues. Observations of vulnerabilities 

identified in these climate change adaptation plans include:

 More powerful storms may increase debris volumes.

 Current waste management capacity may be inadequate for both 

hazardous and solid wastes.
16-P-0219 4

 Current regional debris management plans may rely on historical climate 

assumptions and may not address the increasing uncertainty in climatic 

extreme events.

 Siting of staging areas for debris management and segregation may be 

difficult due to flooding and other conditions that may affect usable 

land space.

Actions proposed to address the vulnerabilities identified in climate change 

adaptation plans are to:

 Finalize a Four-Step Waste Management Planning Process document.

 Incorporate climate change impacts into debris management plans.

 Develop a database/resource guide for reuse and recycling of disaster 

debris.

 Conduct outreach with states and municipalities to encourage development 

of disaster debris management plans.

 Work with states to assess landfill capacity for surges in disposal of 

hazardous and municipal waste generated by extreme storm events.

 Maintain and improve available information on managing disaster debris 

to support planning and emergency response.

Responsible Office

The Office of Resource Conservation and Recovery (ORCR) within OLEM is 

responsible for the subjects covered in this report. 

Scope and Methodology

We conducted our work from December 2014 to April 2016. We conducted this 

performance audit in accordance with generally accepted government auditing 

standards. Those standards require that we plan and perform the audit to obtain 

sufficient, appropriate evidence to provide a reasonable basis for our findings and 

conclusions based on our audit objectives. We believe that the evidence obtained 

provides a reasonable basis for our findings and conclusions based on our audit 

objectives. 

We reviewed the EPA’s March 2008 guidance, Planning for Natural Disaster

Debris. We also reviewed the climate change adaptation plans for OLEM and all 

EPA regions. In addition, we reviewed the EPA’s 2014 Policy Statements on 

Climate Change Adaptation. Further, the National Response Framework was 

reviewed, as well as other reports and documents on natural disasters, including 

Hurricane Katrina; Hurricane Sandy; and the 2011 Joplin, Missouri, tornado.

We interviewed EPA staff and management in two OLEM offices: ORCR and the 

Office of Emergency Management. We also interviewed EPA emergency response 

staff in all regions, staff of the USACE, and staff from selected state agencies.
16-P-0219 5

Prior Report

The U.S. Government Accountability Office (GAO) identified concerns about 

disaster debris management in its 2007 report, Hurricane Katrina: EPA’s Current 

and Future Environmental Protection Efforts Could Be Enhanced by Addressing 

Issues and Challenges Faced on the Gulf Coast. In the 2007 report, the GAO 

recommended that the EPA:

Provide more detailed guidance to state and local entities on 

managing debris disposal following disasters to better ensure 

protection of public health and the environment and prevent the 

creation of future Superfund sites. This guidance should address 

the selection of landfill sites for disaster debris, including advance 

selection of potential landfill sites, and practices to consider when 

making special accommodations for debris disposal in emergency 

situations.

In response to the GAO recommendation, the EPA published Planning for 

Natural Disaster Debris in 2008. The guidance identified possible components of 

a debris management plan, including:

 Identify debris types and forecast amounts.

 Identify inventory of current capacity.

 Develop debris tracking mechanisms.

 Pre-select debris storage sites.

 Create a communication plan.

 Create a debris prevention and removal strategy.
16-P-0219 6

Chapter 2

EPA Has Limited Knowledge of Disaster 

Debris and State Planning Efforts

The EPA has worked with other federal agencies in responses to natural disasters. 

However, according to EPA staff, the agency has limited information on the types

of, volumes of and disposal sites for disaster debris that is not hazardous waste. 

Disaster debris can contain an unsegregated mixture 

of hazardous and solid waste debris that may 

ultimately fall under EPA regulatory authority. 

By obtaining information on the types of, volumes of 

and disposal sites for disaster debris, the EPA is 

positioned to communicate and help guide the 

management of potential risks to humans and the 

environment. 

OLEM has not determined that states have planned 

for disaster debris management consistent with EPA 

guidance. Based on our interviews with all 10 EPA 

regional offices, we found that, except for Regions 4 

and 5, EPA regions are unaware of the status or 

content of state disaster debris plans, and do not know 

whether the plans address the components defined in 

the EPA’s 2008 guidance. 

According to the EPA, states are not federally 

required to develop debris management plans, and the 

EPA has no authority to ensure that states have 

adequate plans or that they follow their plans during a 

disaster response. However, without determining the 

adequacy of state plans, the EPA cannot assess states’ 

readiness to manage disaster debris, and scenarios 

where disaster debris is not managed or disposed of in 

an environmentally sound manner could result. The 

EPA’s effectiveness in helping communities become 

more resilient to the effects of climate change and 

extreme weather events could be impacted, which is also an element of the EPA’s 

climate change adaptation plans. 

EPA Regions 4 and 5 have examples of good practices for disaster debris 

management. Region 4 established a team to provide disaster debris assistance to 

states. Region 5 developed a disaster debris website that includes links to state 

plans and guidance within the region.

Hazardous Waste

According to the EPA, hazardous waste 

includes waste that exhibits at least one 

of four characteristics:

 Ignitable – Can readily catch fire.

 Corrosive – Acidic or alkaline.

 Reactive – Unstable under “normal” 

conditions. 

 Toxic – Harmful or fatal when 

ingested or absorbed.

(EPA image)

The EPA also lists specific wastes as 

hazardous, including wastes from 

specific industrial processes, industries, 

and discarded commercial chemical 

products. Treatment, storage and 

disposal of hazardous wastes must be 

managed in facilities permitted by the

EPA or delegated state programs. 
16-P-0219 7

EPA Coordinates With Other Federal Agencies but Has Incomplete 

Knowledge of the Volume or Disposal of Disaster Debris

While the EPA directly oversees the management of hazardous waste from 

natural disasters under ESF #10, the agency has only a support role in the 

management of other debris types under ESF #3. Debris not readily characterized 

as hazardous waste is managed under ESF #3 and has USACE oversight. 

Segregated nonhazardous debris is managed by state and local governments under 

EPA regulations for nonhazardous solid waste, and state regulations for other 

waste such as C&D and vegetative debris. 

However, some debris cannot be readily segregated and is considered mixed 

debris. According to the EPA’s 2008 guidance, “Mixed debris typically includes a 

mixture of all types of debris. Due to its diversity, this debris stream is sometimes 

too mixed for cost-effective 

segregation.” In particularly powerful 

weather events, such as Hurricane 

Katrina, it can be virtually impossible to 

segregate much of the debris. One state 

staff person we interviewed agreed that 

complete segregation of mixed debris is

difficult, as illustrated in the adjacent 

photo.

States may allow the disposal of mixed 

debris in C&D landfills. The regulatory 

requirements for C&D landfills are 

established by states, and criteria vary 

from state to state. For example, some 

states require a synthetic liner at all 

C&D landfills, while other states do not. 

In disaster situations, demands for increased debris disposal capacity may lead to 

emergency siting of C&D landfills, which could be subject to less stringent siting 

requirements. For example, the Mississippi Department of Environmental Quality 

worked with local governments to site 13 new landfills to accommodate 

Hurricane Katrina debris. In addition to requiring a subsequent siting review to 

ensure protection of the environment, the Mississippi Department of 

Environmental Quality installed groundwater monitoring systems to detect the 

contamination of groundwater. 

With the exception of segregated hazardous waste, the EPA has no information on 

the types of, volumes of and disposal sites for disaster debris. EPA regional staff 

we interviewed had no information on debris volumes or disposal sites from 

Hurricane Katrina, Hurricane Sandy, or the Joplin tornado, except for segregated 

hazardous waste. 

A debris field that resulted from a Hurricane Katrina storm surge 

through a residential neighborhood in Waveland, Mississippi. 

(EPA OIG photo)
16-P-0219 8

The EPA does not have primary authority for nonhazardous debris management 

under the National Response Framework, and there are no requirements for the 

agency to track nonhazardous debris. However, the USACE has information 

available on the volumes of nonhazardous debris generated from natural disasters,

and the disposal sites used for such debris. The USACE said it would readily 

provide the information to the EPA, if requested. 

The EPA’s 2014 Policy Statements on 

Climate Change Adaptation states that the 

EPA will coordinate with other federal 

agencies on climate change adaptation 

challenges that cut across agency 

jurisdictions. The policy also states that to 

improve the efficiency and effectiveness of a 

combined federal effort, the EPA will 

coordinate its activities with other federal 

agencies when working in the same 

communities. Coordination with the USACE 

to acquire information on the types, volumes 

and disposal destinations of disaster debris 

facilitates EPA awareness of, and ability to 

manage, potential risks from debris disposal. 

These risks can include groundwater 

contamination.

At least one site on the EPA’s Superfund 

National Priorities List (see sidebar), and one 

contaminated C&D landfill, contain debris 

from natural disasters. In a 2011 report, the 

GAO estimated the EPA had spent about 

$55 million to clean up the Superfund site. 

EPA Has Not Determined the Existence or Adequacy of State 

Disaster Debris Management Plans

The EPA has published disaster debris management guidance and has identified 

disaster debris management as a potential vulnerability in its climate change 

planning efforts. According to the EPA, states are not federally required to 

develop debris management plans, and the EPA has no authority to ensure that 

states have adequate plans or that they follow their plans during a disaster 

response. However, despite the recognition of the importance of planning for 

disaster debris management, OLEM has not determined that states have planned 

for disaster debris management consistent with EPA guidance.

Agriculture Street Landfill 

Superfund Site

According to the EPA:

“The Agriculture Street Landfill 

site is located in New Orleans, 

Louisiana. A dump began 

operating on site in 1909, when 

the City of New Orleans phased 

out the dumping of municipal 

wastes and trash into various 

nearby canals and the 

Mississippi River. The landfill 

remained in use until the city 

constructed its Florida Avenue 

and Seventh Street incinerators 

in 1957. The landfill reopened in 

1965 for one year for use as a 

burning and disposal area for 

debris from Hurricane Betsy. 

Facility operations contaminated 

soil and groundwater with 

hazardous chemicals. Following 

cleanup, operation and 

maintenance activities and 

monitoring are ongoing.” 
16-P-0219 9

EPA Has Not Determined the Adequacy of State Disaster Debris 

Management Plans

During interviews with staff from all 10 EPA regions, we found that most EPA 

regions were unaware of the status of debris management plans for all of the 

states in their regions, and were unaware of any existing plans to address the 

criteria defined in the 2008 EPA guidance. One exception was Region 5 staff, 

who had knowledge of planning efforts for all of the states in the region. In 

addition, Region 4 staff stated that although all of the states in the region may not 

have formal disaster debris plans, the states have done some form of disaster 

debris planning.

OLEM issued the disaster debris guidance in 2008, but it has not determined or 

requested that EPA regions verify the status of state disaster debris management 

plans. OLEM could provide no documentation of directions given to EPA regions 

accompanying the 2008 guidance. Further, several staff we interviewed in EPA 

regions could not recall receiving any OLEM communications meant to verify the 

existence and adequacy of state disaster debris management plans.

EPA Regions 4 and 5 Have Established Good Practices to 

Assist States With Their Management of Disaster Debris

Region 4 staff said all of their states have done some form of disaster debris 

planning, although the states may not have formal debris management plans.

Region 4 staff also said they have knowledge of some of their states’ disaster debris 

management programs, such as the one in Florida. In the aftermath of Hurricane 

Katrina, the region developed a Landfill Specialty Team consisting of 11 Region 4 

Resource Conservation and Recovery Act staff. The purpose of the team is to 

provide assistance to state and local governments, and assure proper management 

and disposition of disaster debris with a focus on proper segregation and land 

disposal practices. The team provides pre-incident support that includes training, 

evaluation of states’ needs, and sharing of pertinent information. The team also 

provides post-incident support, including assistance with hydrogeologic assessments 

of proposed landfill sites and establishing monitoring protocols. The team provides 

additional hands-on EPA assistance through the team’s support of ESF #3.

EPA Region 5 staff also addressed disaster debris management with states in the 

region. Region 5’s Disaster Debris Management website includes links to disaster 

debris management information for all states in Region 5. In addition, Region 5 

has identified more than 3,700 facilities within the region that could receive 

disaster debris. These facilities include hazardous waste, solid waste and C&D 

landfills, as well as haulers, composters and demolition contractors. The 

following state plans and guidance appear as links on Region 5’s website:

 Illinois Disaster Recovery Plan, September 2011.

 Indiana Disaster Mitigation and Recovery.
16-P-0219 10

 Michigan Disaster Debris Management Plan, April 2008; and Local 

Disaster Debris Management Planning Handbook, April 2008.

 Minnesota Disaster Management Handbook, March 2010.

 Ohio Debris Management.

 Wisconsin - Coping with Cleanup.

Region 5 also developed an interactive mapping tool that can be used to identify 

the closest facilities in the event of a disaster, as shown in the following image.

Conclusions

Mixed disaster debris may contain hazardous substances if adequate segregation 

is not done or is not feasible. While the EPA coordinates with USACE to manage 

hazardous waste debris, the agency currently does not track nonhazardous debris. 

Doing so will augment the EPA’s ability to identify, communicate and assist with

managing risks in partnership with states and under the agency’s own authority.

Map image of Region 5 disaster debris facilities derived from mapping tool. Each dot 

represents a facility. (EPA image)
16-P-0219 11

In response to a recommendation from the GAO 2007 report, the EPA invested in 

the development of disaster debris management guidance for states. More recently,

the EPA has recognized the need to include disaster debris as a vulnerability in 

many of the agency’s climate change adaptation plans. For example, OLEM’s draft 

June 2013 Climate Change Adaptation Plan states:

Current waste management capacity, including interim capacity, 

may be insufficient to handle surges in necessary treatment and 

disposal of hazardous and municipal wastes, as well as mixed 

wastes generated from climate events.

Investments and effort by the EPA to develop guidance with the goal of 

enhancing environmental protection, aiding risk management, and increasing the 

public’s ability to effectively adapt and respond to extreme or catastrophic 

weather events will not be effective without an assessment of state progress on 

disaster debris planning. The extent to which states are prepared for a disaster 

could be largely influenced by the completeness of individual state plans.

Recommendations

We recommend that the Assistant Administrator for Land and Emergency 

Management: 

1. Establish and implement procedures for EPA regions to obtain available 

natural disaster debris information from the U.S. Army Corp of Engineers

for future natural disaster responses. Information obtained should include 

the types, volumes and disposal sites for solid waste and mixed disaster 

debris for possible EPA follow-up and monitoring.

2. Develop and implement a plan to provide assistance to all states on 

developing disaster debris management plans that address the major 

elements identified in EPA’s guidance.

Agency Response and OIG Evaluation

The agency agreed with Recommendation 1. The agency initially disagreed 

with Recommendation 2 but agreed to a revised recommendation. All 

recommendations are resolved. The agency provided corrective action plans 

with milestone dates for all recommendations. Based on the agency’s response, 

all recommendations are open with corrective actions underway. Appendix A 

contains the agency’s response to our draft report and planned actions to 

address our recommendations. We reviewed the agency’s technical comments 

and made revisions to the report as appropriate.
16-P-0219 12

Status of Recommendations and 

Potential Monetary Benefits

RECOMMENDATIONS

POTENTIAL MONETARY 

BENEFITS (in $000s)

Rec. 

No.

Page 

No. Subject Status1 Action Official

Planned 

Completion 

Date

Claimed 

Amount

Agreed-To 

Amount

1 11 Establish and implement procedures for EPA 

regions to obtain available natural disaster debris 

information from the U.S. Army Corp of Engineers 

for future natural disaster responses. Information 

obtained should include the types, volumes and 

disposal sites for solid waste and mixed disaster 

debris for possible EPA follow-up and monitoring.

O Assistant Administrator for 

Land and Emergency 

Management

9/30/16

2 11 Develop and implement a plan to provide 

assistance to all states on developing disaster 

debris management plans that address the major 

elements identified in EPA’s guidance.

O Assistant Administrator for 

Land and Emergency 

Management

9/30/17

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.
16-P-0219 13

Appendix A

Agency Response to Draft Report

(Dated May 3, 2016)

MEMORANDUM

SUBJECT: Response to Office of Inspector General Draft Report No. OPE-FY15-0012

“EPA’s Limited Knowledge of Disaster Debris Preparedness Impedes 

Implementation of Effective Risk Management and Climate Change Adaptation 

Plans,” dated April 4, 2016

FROM: Mathy Stanislaus

Assistant Administrator

Office of Land and Emergency Management

TO: Arthur A. Elkins, Jr.

Inspector General

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 position, along with its position on each 

of the report recommendations. For those report recommendations with which the agency agrees, 

we have provided high-level intended corrective actions and estimated completion dates to the 

extent we can. For those report recommendations with which the agency does not agree, we have 

explained our position, and proposed alternatives to recommendations. For your consideration, 

we have included a Technical Comments Attachment to supplement this response.

AGENCY’S OVERALL POSITION

EPA agrees that natural disaster debris should be managed in a way that protects human health 

and the environment. Therefore, EPA has developed resources to help states plan for disaster 

debris and create pre-incident waste management plans, which should include potential waste 

streams and their volumes and pre-identified waste management sites and facilities. In addition, 

EPA is developing additional resources to encourage and help states plan for disaster debris. 

However, the states are not federally required to develop debris management plans, and EPA has 

no authority to ensure that states have adequate plans or that they follow their plans during a 

disaster response. 
16-P-0219 14

AGENCY’S RESPONSE TO REPORT RECOMMENDATIONS

Agreements

No. Recommendation High-Level Intended 

Corrective Action(s)

Estimated Completion by 

Quarter and FY

1 Establish and implement 

procedures for EPA 

regions to obtain available 

natural disaster debris 

information from the U.S. 

Army Corp of Engineers 

for future natural disaster 

responses. Information 

obtained should include the 

types, volumes and 

disposal sites for solid 

waste and mixed disaster 

debris for possible EPA 

follow-up and monitoring.

ORCR will establish and 

implement procedures to

obtain available natural 

disaster debris information 

(e.g., types, volumes, and 

disposal sites for solid waste 

and mixed disaster debris) 

from the U.S. Army Corp of 

Engineers on future natural 

disasters. Procedures will 

address making this 

information available to the 

regions.

End of 4th Quarter FY16

Disagreements

No. Recommendation Agency Explanation/Response Proposed Alternative 

2 Develop and implement a 

plan to ensure that all 

states have addressed the 

major elements identified 

in EPA guidance.

EPA agrees that states should 

develop adequate debris 

management plans, but EPA 

has no authority to “ensure” 

that states have disaster debris 

management plans or, if the 

plans exist, that they have 

addressed the major elements 

identified in EPA guidance or

are followed during incident 

responses.

By end of 1st quarter 

FY17, EPA will develop 

and implement a plan to 

work with FEMA to 

incorporate EPA 

guidance on disaster 

debris into FEMA’s 

debris management 

guidance and training 

for state and local 

officials. This plan will 

also include how EPA 

will work with 

ASTSWMO to identify 

how ASTSWMO can 

encourage that all states 

have addressed the 

major elements 

identified in EPA 

guidance.
16-P-0219 15

OIG Response: ORCR and OIG have agreed to a revised definition and corrective action for 

Recommendation 2. The revised recommendation is: “Develop and implement a plan to 

provide assistance to all states on developing disaster debris management plans that address 

the major elements identified in EPA’s guidance.” The revised corrective action is: “By end of 

4th quarter FY17, EPA will develop and implement a plan to work with FEMA [Federal 

Emergency Management Agency] to incorporate EPA guidance on disaster debris into 

FEMA’s debris management guidance and training for state and local officials. This plan will 

also include how EPA will work with ASTSWMO [Association of State and Territorial Solid 

Waste Management Officials] to provide assistance to all states to address the major elements 

identified in EPA guidance on disaster debris planning and to increase EPA regional 

awareness of state planning efforts. The plan will also describe how EPA will provide 

assistance to states on pre-incident all-hazards waste management planning as it implements 

assistance on disaster debris planning.”

CONTACT INFORMATION

If you have any questions regarding this response, please have a member of your staff contact 

Kim Kirkland of the Office of Resources Conservation and Recovery on (703) 308-0490.

Attachment

cc: Barry Breen

 Nitin Natarajan

 Barnes Johnson

 Kathleen Salyer

 Ross Elliott

 Kim Kirkland

 Deana Nisbett

 Kecia Thornton
16-P-0219 16

Appendix B

Distribution

Office of the Administrator 

Assistant Administrator for Land and Emergency Management

Agency Follow-Up Official (the CFO) 

Agency Follow-Up Coordinator 

General Counsel 

Associate Administrator for Congressional and Intergovernmental Relations 

Associate Administrator for Public Affairs

Deputy Assistant Administrator for Land and Emergency Management

Director, Office of Resource Conservation and Recovery, Office of Land and 

Emergency Management

Audit Follow-Up Coordinator, Office of Land and Emergency Management