a

GAO

United States Government Accountability Office

Report to Congressional Committees

June 2007 HURRICANE 

KATRINA

EPA’s Current and 

Future Environmental 

Protection Efforts 

Could Be Enhanced by 

Addressing Issues and 

Challenges Faced on 

the Gulf Coast

GAO-07-651
What GAO Found

United States Government Accountability Office

Why GAO Did This Study

Highlights

Accountability Integrity Reliability

June 2007

HURRICANE KATRINA

EPA’s Current and Future Environmental 

Protection Efforts Could Be Enhanced by 

Addressing Issues and Challenges Faced 

on the Gulf Coast 

Highlights of GAO-07-651, a report to 

congressional committees 

In 2005, Hurricane Katrina’s impact

on the Gulf Coast included damage

to the environment from chemical

and hazardous materials releases. 

Also, the widespread demolition 

and renovation activities still under 

way in New Orleans may release

asbestos fibers into the air, posing

a potential additional health risk.

This report, conducted at the 

Comptroller General’s initiative, 

addresses (1) the Environmental

Protection Agency’s (EPA) actions

to assess and mitigate Katrina’s 

environmental impacts, (2) the 

extent to which EPA has assurance 

that public health is protected from 

asbestos inhalation risks in New 

Orleans, (3) the extent to which

EPA’s environmental health risk 

communications provided useful 

information to the public, and (4) 

challenges EPA faces in addressing

environmental impacts. 

What GAO Recommends

GAO recommends that EPA 

develop an asbestos air monitoring

plan for New Orleans, improve its

communications on environmental 

risks for future disasters, and take 

steps to address several challenges

EPA has faced. EPA agreed with all 

but one recommendation,

commenting that other agencies

should address the challenge of

obtaining timely funding for the 

removal of hazardous materials 

from federal lands after disasters.

GAO modified its recommendation 

to include additional relevant

agencies with which EPA should 

work to address the problem GAO 

identified. 

Under challenging circumstances, EPA worked with federal and state 

partners to respond to chemical and oil spills, collect abandoned chemical 

containers, coordinate recycling of damaged appliances, and collect and 

recycle electronic waste. EPA also conducted air, water, sediment, and soil 

sampling; helped assess drinking water and wastewater infrastructures; and 

issued timely information to the public on a variety of environmental health 

risks. 

 

However, as cleanup continues, EPA’s assurance that public health is 

protected from risks associated with inhalation of asbestos fibers is limited 

because the agency has not deployed air monitors in and around New 

Orleans neighborhoods where demolition and renovation activities are 

concentrated. While EPA took steps to monitor asbestos after the hurricane 

—for example, more than doubling the number of ambient (outdoor) air 

monitors and monitoring emissions at debris reduction sites—monitors were 

not placed in areas undergoing substantial demolition and renovation, such 

as the Ninth Ward. This is problematic because monitors effectively detect 

releases of asbestos from demolition activities only if they are located 

immediately adjacent to demolition sites. Further, many thousands of homes 

being demolished and renovated by or for individual homeowners are 

generally not subject to EPA’s asbestos emissions standards aimed at 

limiting releases of fibers into the air. 

 

While EPA provided useful environmental health risk information to the 

public via flyers, public service announcements, and the EPA Web page, the 

communications were at times unclear and inconsistent on how to mitigate 

exposure to some contaminants, particularly asbestos and mold. Further, the 

usefulness of three key reports on EPA’s environmental sampling in New 

Orleans—developed with, among others, the Louisiana Department of 

Environmental Quality to address potential health risks from exposure to 

floodwaters, sediments, and air—was limited by a lack of timeliness and 

insufficient disclosures about EPA’s sampling program. For example, EPA 

did not state until August 2006 that its December 2005 report—which said 

that the great majority of the data showed that adverse health effects would 

not be expected from exposure to sediments from previously flooded 

areas—applied to short-term visits, such as to view damage to homes. 

Mitigating several challenges EPA faces addressing Hurricane Katrina could 

better protect the environment in the future. First, EPA did not remove 

hazardous materials from national wildlife refuges in a timely manner as part

of its response in part because disaster assistance funding generally is not 

used for debris cleanups on federal lands. Second, because states generally 

have authority over landfill decisions, EPA does not have an effective role in 

emergency debris disposal decisions that could cause pollution. Finally, lack 

of clarity in federal debris management plans and protocols precluded the 

timely and safe disposal of some appliances and electronic waste. 

www.gao.gov/cgi-bin/getrpt?GAO-07-651.

To view the full product, including the scope 

and methodology, click on the link above. 

For more information, contact John

Stephenson at (202) 512-3841 or

stephensonj@gao.gov. 
Page i GAO-07-651 Hurricane Katrina

Contents

Letter 1

Results in Brief 4

Background 9

EPA Has Taken Numerous Actions to Mitigate and Assess the 

Environmental Impacts of Katrina 11

EPA’s Air Monitoring for Releases of Asbestos Fibers in New Orleans 

Does Not Adequately Address Neighborhoods with Substantial 

Building Demolition and Renovation Activities 21

Some Shortcomings in EPA’s Communications on Environmental 

Health Risks Have Limited the Communications’ Usefulness to 

the Public 33

EPA Faced Challenges in Assessing and Mitigating Some 

Environmental Impacts of the Gulf Coast Hurricanes 42

Conclusions 56

Recommendations for Executive Action 58

Agency Comments and Our Evaluation 59

Appendixes

Appendix I: Objectives, Scope, and Methodology 63

Appendix II: Comments from the Environmental Protection Agency 66

GAO Comments 84

Appendix III: GAO Contact and Staff Acknowledgments 97
Contents

Page ii GAO-07-651 Hurricane Katrina

Abbreviations

C&D construction and demolition

CDC Centers for Disease Control and Prevention

CERCLA Comprehensive Environmental Response, Compensation, and 

Liability Act

Corps U.S. Army Corps of Engineers

DHS Department of Homeland Security

EPA Environmental Protection Agency

FEMA Federal Emergency Management Agency

NIOSH National Institute for Occupational Safety and Health

OSHA Occupational Safety and Health Administration

RCRA Resource Conservation and Recovery Act

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Page 1 GAO-07-651 Hurricane Katrina

United States Government Accountability Office

Washington, D.C. 20548

A

June 25, 2007 Letr

Congressional Committees

The scope and severity of the destruction that Hurricane Katrina caused on 

the Gulf Coast in 2005 are staggering. More than 1,600 people lost their lives 

and more than a million were driven from their homes, many still unable to 

return. Moreover, tens of thousands of homes in New Orleans were 

flooded, many requiring either demolition or gutting before reconstruction. 

This natural disaster affected an area of over 90,000 square miles, 

destroying or severely damaging not only countless buildings but also 

bridges, roads, and the area’s power and communications infrastructures. 

Hurricane Katrina severely damaged the environment as well: Millions of 

gallons of oil and unknown quantities of potentially hazardous chemicals 

were released into the environment.1

 Hazardous materials—such as 

industrial drums containing toxic and flammable chemicals, asbestoscontaining materials, household chemicals, paints, pesticides, and propane 

tanks—were commingled with the storm’s unprecedented levels of other 

debris, slowing its collection and disposal. The environmental 

contamination caused by this natural disaster could have both short- and 

long-term effects on the health of residents in affected areas, as well as on 

workers, volunteers, and wildlife.

The Robert T. Stafford Disaster Relief and Emergency Assistance Act 

establishes programs and processes for the federal government to provide 

major disaster and emergency assistance to states, local governments, 

tribal nations, individuals, and qualified private nonprofit organizations. 

Under the Stafford Act, state governors may request assistance from the 

federal government when an incident overwhelms state and local 

resources. Such assistance has been—and to some extent continues to 

be—provided to the Gulf Coast under the Department of Homeland 

Security’s (DHS) National Response Plan. This plan serves as a basis for 

how federal departments and agencies are to work together with state, 

local, and tribal governments and the private sector in managing incidents 

requiring a coordinated federal response, including a major disaster such 

as Hurricane Katrina that was determined to be an “incident of national 

1

Unless otherwise noted, this report addresses EPA’s response to Hurricane Katrina, the 

storm that caused the bulk of the hurricane-related damage to the Gulf Coast in 2005. Other 

storms, in particular Hurricane Rita, also caused significant damage to the region in 2005, 

some in the same areas hit by Katrina. 
Page 2 GAO-07-651 Hurricane Katrina

significance.” Key federal agencies with responsibilities for supporting and 

implementing state and local recovery efforts in the Gulf Coast include 

DHS’s Federal Emergency Management Agency (FEMA), the 

Environmental Protection Agency (EPA), the U.S. Coast Guard, and the 

U.S. Army Corps of Engineers. 

EPA serves as the coordinator of emergency support for the oil and 

hazardous materials response, 1 of 15 emergency support functions 

identified in the National Response Plan. When the National Response Plan 

is activated, EPA and the Coast Guard are the primary agencies that 

provide federal support in response to actual or potential discharges of oil 

or hazardous materials, including assessments and cleanups. The National 

Response Plan incorporates many aspects of the National Contingency 

Plan, a plan for responding to releases of oil or hazardous materials.2

 This 

plan implements provisions of the Clean Water Act and the Comprehensive 

Environmental Response, Compensation and Liability Act of 1980 

(CERCLA, also called the Superfund law).Under the Superfund law, EPA 

conducts short-term cleanups to address immediate threats to 

communities from actual or potential releases of hazardous substances and 

conducts or oversees long-term cleanups of the nation’s Superfund sites. 

EPA also has a role in assisting other agencies that are coordinating other 

emergency support functions under the National Response Plan, including 

public works and engineering (assisting with such tasks as contaminated 

debris management) and public health and medical services response 

(providing such support as technical assistance in assessing the health 

aspects of situations involving hazardous materials). Aside from the 

emergency support roles defined in the plan, EPA enforces key 

environmental laws, such as the Clean Air Act. To facilitate the removal of 

the extraordinary amounts of debris in Louisiana and Mississippi after 

Hurricane Katrina, EPA is not enforcing certain Clean Air Act emissions 

standards for asbestos in the case of government-ordered demolitions of 

homes. In addition, these emissions standards generally do not apply to the 

demolition or renovation of homes by or for individual homeowners. 

Nevertheless, because asbestos inhaled into the lungs can cause cancer, it 

is important for EPA to ensure that public health risks are minimized 

during the demolition and renovation of buildings containing asbestos, 

activities that can release asbestos fibers into the air.

2

Under the National Contingency Plan, EPA and the Coast Guard also serve as primary 

responders. 
Page 3 GAO-07-651 Hurricane Katrina

In this context, we (1) reviewed EPA’s actions under the National Response 

Plan to assess and mitigate the environmental impacts of Hurricane 

Katrina, (2) determined the extent to which EPA has assurance that public 

health in New Orleans is being protected from asbestos inhalation health 

risks posed by extensive demolition activities, (3) determined the extent to 

which EPA’s communications on environmental health risks posed by 

Hurricane Katrina have provided useful information to the public, and (4) 

identified challenges EPA has faced in addressing environmental impacts 

of Hurricane Katrina that, if mitigated, could enable EPA to better protect 

the environment in future disasters. Because of the widespread 

congressional interest in these subjects, we are conducting this work at the 

Comptroller General’s initiative. 

In conducting our work, we reviewed relevant laws and regulations, DHS’s 

National Response Plan, federal and state protocols related to the 

hazardous materials response to Katrina, and evaluations of the federal 

government’s Katrina response actions. We also reviewed, for example, 

EPA planning documents, environmental risk assessment summaries and 

related communications, and federal guidance to state and local agencies 

related to the 2005 hurricane response. We interviewed officials from EPA’s 

Office of Emergency Management, Office of Enforcement and Compliance 

Assurance, Office of Water, Office of Air and Radiation, and Office of Solid 

Waste, among other headquarters offices. We met with EPA officials in 

Regions 4 and 6 in Mississippi and Louisiana, visited EPA’s Incident 

Command Centers in Mississippi and Louisiana, and toured affected areas 

in both states. We also interviewed federal officials from FEMA, the 

Department of Health and Human Services’ Agency for Toxic Substances 

and Disease Registry and Centers for Disease Control and Prevention 

(CDC), the Army Corps of Engineers, and the Department of the Interior’s 

U.S. Fish and Wildlife Service. In addition, we interviewed state and local 

officials involved with EPA’s response efforts from the Louisiana and 

Mississippi Departments of Environmental Quality and from Jefferson, 

Plaquemines, Orleans, and St. Bernard Parishes in Louisiana and from 

Jackson, Hancock, and Harrison Counties in Mississippi. We also spoke 

with national and regional stakeholder groups, including the Natural 

Resources Defense Council, the Lake Pontchartrain Basin Foundation, the 

Louisiana Environmental Action Network, the Louisiana Mid-Continent Oil 

and Gas Association, the Mississippi Environmental Recovery Alliance, the 

Mississippi Power Company, and Sierra Club chapters in Louisiana and 

Mississippi. In determining the extent to which EPA’s communications on 

Hurricane Katrina’s environmental health risks provided useful information 

to the public, we focused on the communications themselves and did not 
Page 4 GAO-07-651 Hurricane Katrina

evaluate the agency’s environmental risk assessment methodology. (See 

app. I for a more detailed description of the scope and methodology of our 

review.) We conducted our work from November 2005 through June 2007 in 

accordance with generally accepted government auditing standards.

Results in Brief Under challenging circumstances, EPA conducted a wide variety of 

activities to assess and mitigate the environmental impacts of Hurricane 

Katrina. As of December 2006, EPA had spent an estimated $416 million on 

its hurricane response and, at its peak, employed about 1,600 staff and 

contractors on response activities. For example, EPA and its contractors, 

along with other federal and state partners, have responded to chemical 

and oil spills at industrial facilities; have collected over 200,000 large 

abandoned containers, such as drums and tanks; and continue to oversee 

cleanup of a million-gallon oil spill at a facility in St. Bernard Parish, 

Louisiana, that affected neighboring homes. EPA has also coordinated 

recycling efforts for damaged refrigerators and other appliances (referred 

to as “white goods”) to remove chlorofluorocarbons and other refrigerants 

that are harmful to the environment from 380,000 abandoned refrigerators, 

freezers, and air conditioners. In addition, EPA helped collect and recycle 

over 660,000 units of electronic waste and removed and safely disposed of 

almost 5 million household hazardous waste containers, such as paint cans 

and propane tanks. Because of the extensive number of home demolitions 

and renovations that have yet to be completed in the New Orleans area, 

debris removal from uninhabited residences is far from complete. 

Regarding assessing the environmental contamination caused by the 

hurricane, EPA conducted air, water, and sediment and soil sampling for 

chemicals of potential concern in Louisiana and Mississippi. In particular, 

EPA reports having collected about 1,800 sediment and soil samples since 

September 2005 in and around New Orleans. EPA has analyzed most of 

these samples for over 200 potentially harmful metals and organic 

chemicals. In coordination with state and local partners, including the 

Louisiana Department of Environmental Quality, EPA concluded that, in 

general, the sediments left behind by the flooding are not expected to cause 

adverse health impacts to individuals returning to New Orleans. In 

addition, EPA helped both the Louisiana and Mississippi Departments of 

Environmental Quality perform 4,000 drinking water and wastewater 

infrastructure assessments to help bring these facilities back online as 

quickly as possible. 

However, as cleanup continues, EPA’s assurance that the public health is 

being protected from the risks associated with the inhalation of asbestos 
Page 5 GAO-07-651 Hurricane Katrina

fibers is limited because the agency has not deployed air monitors in and 

around neighborhoods in New Orleans where demolition and renovation 

activities are concentrated. EPA took steps to monitor asbestos after 

Hurricane Katrina, initially more than doubling the ambient (outdoor) air 

monitors that were in the area before the storm and then conducting 

emissions monitoring at specific sites, such as landfills, that involve waste 

handling or debris reduction activities—for example, grinding. However, 

EPA has neither conducted emissions monitoring at demolition sites nor 

placed ambient air monitors in neighborhoods with substantial demolition 

and renovation activities. For example, no monitors have been located in 

the Ninth Ward, where flooding was widespread and extensive demolition 

and renovation are occurring. This is problematic because, according to 

officials from EPA’s Office of Research and Development, monitors are 

effective in detecting asbestos emissions from demolitions only if they are 

located immediately adjacent to the sites. Further, in July 2006, the agency 

scaled back its ambient monitoring to the prestorm level and reduced the 

frequency of sampling. EPA said it based this decision, in part, on not 

having found measurable amounts of asbestos in the air samples. However, 

EPA’s expanded monitoring covered only the first few months of 

demolition activities. For these reasons, the results may not be 

representative of asbestos exposures in some neighborhoods. Further, for 

building demolition and renovation activities, EPA regulates asbestos 

emissions by setting standards for work practices. However, EPA’s asbestos 

work practice standards generally do not apply to the demolition or 

renovation of a residential building by or for an individual homeowner. In 

addition, to help expedite cleanup and rebuilding, EPA is not enforcing 

some of the work practice standards for certain residences under 

government demolition orders, although for these demolitions, some work 

practice standards—such as the wetting of materials from before 

demolition through disposal in order to control emissions—are still 

required. The fact that many thousands of demolitions and renovations 

may occur in the same geographic area and in the same general time 

frame—some of which are not subject to the enforcement of certain 

asbestos work practice standards while others are not subject to the 

standards at all—represents a potential health problem that warrants 

monitoring.

In addition, while EPA provided a substantial amount of useful information 

to the public on environmental health risks using reports (environmental 

assessment summaries), flyers, public service announcements, and EPA’s 

Web page, the usefulness of this information was limited in several ways. 

Specifically, some key communications about the environmental 
Page 6 GAO-07-651 Hurricane Katrina

contamination in New Orleans stemming from Hurricane Katrina were not 

timely or complete. For example, EPA’s communications about the 

potential health risks from environmental contamination—three 

environmental assessment summaries prepared with, among others, the 

Louisiana Department of Environmental Quality—were released about 3, 6, 

and 11 months after the hurricane, limiting their usefulness to residents 

who would have benefited from more timely information about the 

environmental health risks they could face when returning home. Further, 

EPA did not disclose until August 2006 that its December 2005 assessment 

summary—which said that the great majority of the data showed that 

adverse health effects would not be expected from exposure to sediments 

from previously flooded areas—applied to short-term visits, such as to 

view damage to homes. In addition, the summaries do not disclose an 

important EPA assumption—that the results of sediment samples from 

streets and other outdoor public access areas can be extrapolated to 

private properties, such as yards and the inside of homes. This is important 

because, for example, environmental contamination levels inside buildings 

can be significantly higher than and different from the contamination 

outside, potentially causing more adverse health effects. Finally, some of 

EPA’s flyers and other public service communications provided unclear and 

inconsistent information on actions residents should take to mitigate 

exposure to contaminants that were likely to be found in many homes. For 

example, the most widely distributed flyer on environmental health risks 

stated that buildings constructed before 1970 are likely to contain asbestos, 

while a document on debris and damaged buildings on EPA’s Web page 

stated that all structures built before 1975 may contain significant amounts 

of asbestos and that structures built after 1975 may also contain asbestos. 

EPA also used varying and confusing terms when identifying the 

respiratory protection that residents should wear in many cases when 

cleaning up their homes.

EPA faced some challenges in addressing the environmental impacts of 

Hurricane Katrina that, if mitigated, could better enable EPA to protect the 

environment in future disasters.

• First, EPA did not remove clearly visible abandoned chemical drums 

and tanks from several national wildlife refuges in Louisiana in a timely 

manner as part of its Katrina response activities in part because FEMA 

disaster assistance funding generally is not used for debris cleanups on 

federal lands. As a result, more than a year later, debris containing 

hazardous materials continued to pose an environmental threat to 

natural resources at several national wildlife refuges, and at least one 
Page 7 GAO-07-651 Hurricane Katrina

major refuge remained closed to the public. While the Fish and Wildlife 

Service obtained funding for this activity as part of a June 2006 

supplemental appropriation and signed interagency agreements with 

EPA and the Coast Guard to obtain these agencies’ assistance in the fall 

of 2006, the delay in removing the debris from this and other wildlife 

refuges complicated and increased the cost of its removal—some of 

which is not yet completed.

• Second, EPA’s debris management role is limited under federal law and 

the National Response Plan; consequently, its guidance to states and 

localities on planning for disposal of disaster debris could be especially 

important in helping ensure that hazardous storm debris is disposed of 

in landfills with appropriate safeguards, thereby preventing 

contaminants from migrating and causing air, soil, or water pollution. 

However, while EPA’s 1995 guide on planning for disposal of disaster 

debris acknowledges that such debris can overwhelm existing landfills 

or force communities to use disposal options that otherwise would not 

be acceptable, the guide does not make specific suggestions for 

addressing these potential problems—such as studying potential sites 

for future use—or practices that state agencies should consider when 

making special debris disposal accommodations following disasters.3

Along these lines, in its emergency orders following Hurricane Katrina, 

the state of Louisiana made decisions about landfill sites and the 

disposal of debris that some studies indicate could have long-term, 

negative environmental impacts.

• Finally, because of a lack of clarity in the National Response Plan and 

the absence of interagency protocols about federal roles in debris 

management, EPA, in the immediate aftermath of the storms, could not 

ensure that debris such as white goods and electronic waste was 

handled in a timely and appropriate manner that mitigated the potential 

for environmental contamination. Local officials in both Louisiana and 

Mississippi told us that confusion about responsibility for this work 

resulted in delays in removing and disposing of the debris, creating the 

potential in the weeks following Katrina that it was improperly disposed 

of in landfills. 

3

EPA Office of Solid Waste and Emergency Response, Planning for Disaster Debris

(December 1995).
Page 8 GAO-07-651 Hurricane Katrina

We are making recommendations to EPA to implement an asbestos 

monitoring plan that addresses the potential health impacts in New Orleans 

from ongoing extensive demolition and renovation activities, improve its 

future communications to the public on environmental risks resulting from 

disasters, and take several actions to better enable the agency to minimize 

environmental risks following disasters. In commenting on a draft of this 

report, EPA’s Associate Administrator for Homeland Security agreed with 

all but one of the recommendations. Specifically, EPA agreed with the 

recommendations to provide additional asbestos air monitoring in New 

Orleans, improve environmental health risk communications following 

disasters, provide more guidance to states on managing debris disposal 

following disasters, and clarify debris management roles with the Army 

Corps of Engineers. However, EPA disagreed with our recommendation 

that the agency convene a working group that includes potentially affected 

federal land management agencies and the Coast Guard to develop 

protocols or memorandums of understanding on the steps the agencies 

should take to obtain disaster funding for environmental cleanups on 

federal lands in the future—and thereby address damage to federal lands 

and wildlife in a timely and efficient manner. Rather, EPA asserted that this 

recommendation would be more appropriately addressed to the 

Department of the Interior and FEMA. We continue to believe that EPA 

should be involved in helping resolve these issues because, under the 

National Response Plan, EPA is the chair of the National Response Team, 

whose duties include national planning and response coordination for oil 

and hazardous materials incidents. We do agree that FEMA, which declined 

to provide funding to the Department of the Interior for cleanup after 

Hurricane Katrina, and DHS, which coordinates the federal response to 

such incidents as major disasters under the National Response Plan, should 

also take part in planning efforts to resolve funding issues concerning the 

removal of hazardous materials from federal lands following a disaster. 

Accordingly, we have modified our recommendation to state that EPA 

should also work with DHS and FEMA, as well as with federal land 

management agencies and the Coast Guard, to determine what actions are 

needed to ensure that environmental contamination on federal lands, such 

as national wildlife refuges, can be expeditiously and efficiently addressed 

in future disasters. EPA also provided comments on aspects of the report it 

considered misleading or inaccurate, as well as technical comments, which 

we incorporated as appropriate. EPA’s letter and our detailed response to it 

appear in appendix II. 
Page 9 GAO-07-651 Hurricane Katrina

Background Issued in December 2004, the Department of Homeland Security’s National 

Response Plan establishes a comprehensive framework for the 

management of domestic incidents where federal involvement is necessary. 

Hurricane Katrina marked the first time the National Response Plan was 

implemented in response to an “incident of national significance”—an 

actual or potential high-impact event that requires a coordinated response 

by a combination of federal, state, local, tribal, nongovernmental, or 

private-sector entities in order to save lives, minimize damage, and provide 

the basis for long-term community recovery and mitigation activities.4

 The 

National Response Plan describes the structure and process of this national 

approach, sets forth federal roles and responsibilities, and includes 15 

emergency support function annexes that describe the missions and 

responsibilities of federal agencies for coordinating resource and program 

support in specific disaster response areas.

Under the National Response Plan, EPA serves as the coordinator of the 

federal emergency support function for oil and hazardous materials 

releases. Under this support function, both EPA and the U.S. Coast Guard 

are the primary agencies charged with providing the federal support, 

including assessments and cleanups in response to releases. According to 

the plan, EPA generally leads responses to inland releases, while the Coast 

Guard leads responses to releases in coastal zones. The National Response 

Plan incorporates the structures and response mechanisms of the National 

Oil and Hazardous Substances Pollution Contingency Plan, the federal 

government’s guide to oil and hazardous substances spill response under 

the Clean Water Act and the Superfund law. EPA’s role under the National 

Response Plan and the National Contingency Plan is similar: providing 

response and recovery actions to minimize threats to public health, 

welfare, or the environment caused by the actual or potential release of oil 

and hazardous materials. However, in the context of providing major 

disaster assistance to the states under the Stafford Act, EPA’s response is 

approved and funded by FEMA, while when it responds under the National 

Contingency Plan, EPA uses its own processes and funding, based on its 

4

The National Response Plan applies to all incidents requiring a coordinated federal 

response as part of an appropriate combination of federal, state, local, tribal, private-sector, 

and nongovernmental entities. For incidents requiring a coordinated federal response, but 

of lesser severity than an incident of national significance, the plan includes a 

comprehensive network of incident annexes and supplemental federal contingency plans 

that may be implemented by the departments and agencies with established authorities in 

coordination with the National Response Plan framework.
Page 10 GAO-07-651 Hurricane Katrina

authority under the Clean Water Act or Superfund law. Thus, in its 

Hurricane Katrina response, EPA actions were primarily funded by FEMA; 

however, EPA used Superfund authority and funding to test for 

contamination at Superfund sites in the affected Gulf Coast area.

Under the National Response Plan, other agencies, including the 

Department of Defense (U.S. Army Corps of Engineers) and the 

Department of Health and Human Services, are given supporting roles in 

the federal response to oil and hazardous materials releases. The Army 

Corps of Engineers (Corps) is also the primary federal agency tasked with 

providing technical assistance, engineering, and construction management 

resources and support during response activities related to public works 

and engineering. Among other things, the Corps is responsible for 

providing debris removal and disposal and the repair, replacement, or 

restoration of disaster-damaged public facilities. EPA provides support to 

the Corps for, among other activities, assessing drinking water supplies and 

wastewater and solid waste facilities. The Department of Health and 

Human Services is the primary federal agency tasked with assisting state, 

local, and tribal governments in identifying and meeting public health and 

medical services needs. Health and Human Services’ responsibilities 

include providing medical care personnel, equipment, and supplies and 

coordinating with EPA and the Corps on water and wastewater issues, 

solid waste disposal issues, and other environmental health issues. The 

Department of Health and Human Services also determines the 

appropriateness of requests for public health and medical information.5

EPA can exercise its existing environmental authorities during disaster 

response activities. For example, under the Clean Air Act, EPA regulates 

emissions of volatile organic compounds in gasoline, which contribute to 

the formation of ground-level ozone. Also under the Clean Air Act, EPA 

regulates emissions of air toxics such as asbestos. Under the Superfund 

law, EPA responds to the actual or threatened release of hazardous 

substances that pose a threat to public health or welfare or the 

environment. In this regard, EPA maintains the National Priorities List, its 

5

In addition, the primary Joint Information Center, established in support of the National 

Response Plan, is authorized to release general medical and public health response 

information to the public after consultation with the Department of Health and Human 

Services. The Joint Information Center is a physical location where public affairs 

professionals from organizations involved in incident management activities provide 

emergency information, crisis communications, and public affairs support.
Page 11 GAO-07-651 Hurricane Katrina

list of seriously contaminated Superfund sites.6 Under the Resource 

Conservation and Recovery Act (RCRA), EPA has a role in establishing 

criteria for classifying different types of solid waste disposal facilities 

(generally referred to as landfills) and solid waste disposal practices that 

may result in adverse effects on health or the environment. In order to 

facilitate response and recovery activities following the hurricanes, EPA 

exercised its enforcement discretion by issuing “no action assurance” 

letters stating that EPA would not enforce certain Clean Air Act 

requirements for building demolitions involving asbestos-containing 

material to facilitate debris removal in Louisiana and Mississippi. 

According to EPA, the agency also waived some Clean Air Act fuel 

requirements to prevent fuel supply interruptions in the months following 

Hurricanes Katrina and Rita.

EPA Has Taken 

Numerous Actions to 

Mitigate and Assess the 

Environmental Impacts 

of Katrina

Under challenging circumstances, EPA conducted a wide variety of 

activities to assess and mitigate the environmental impacts of Hurricane 

Katrina. Specifically, EPA and federal and state partners have responded to 

chemical and oil spills at industrial facilities, collected abandoned chemical 

drums and tanks, and coordinated recycling efforts for damaged 

refrigerators and other appliances. EPA has also taken a number of actions 

to assess the environmental contamination caused by the hurricane, 

including conducting air, water, and sediment and soil sampling for 

chemicals of potential concern in Louisiana and Mississippi. 

6

The Hazard Ranking System is the principal mechanism EPA uses to place sites on the 

National Priorities List. The system serves as a screening device to evaluate the potential for 

releases of uncontrolled hazardous substances to cause human health or environmental 

damage. 
Page 12 GAO-07-651 Hurricane Katrina

EPA Has Conducted a 

Variety of Activities to 

Mitigate the Impacts of Oil 

Spills and Hazardous 

Materials Releases

As of December 2006, EPA had spent an estimated $416 million on a wide 

variety of activities to assess and mitigate the environmental impacts of the 

hurricanes.7

 At its peak, EPA had about 1,600 staff and contractors working 

in the Gulf Coast region to assist with response and cleanup activities, as 

well as thousands of additional employees supporting the agency’s 

response from headquarters and regional offices across the country.8

Because EPA’s environmental protection responsibilities require it to be 

among the first federal agencies to arrive after a disaster, before Hurricane 

Katrina made landfall, EPA deployed personnel and resources to FEMA 

and state emergency operations centers in Louisiana, Mississippi, Alabama, 

and Florida to facilitate a quick response in the states threatened by 

Katrina. In this regard, the agency assumed an unanticipated role in New 

Orleans, joining federal, state, and local responders in the massive search 

and rescue efforts in the days following the storm. Using watercraft 

equipped to address oil and hazardous substances releases, EPA staff and 

contractors helped save nearly 800 residents from the New Orleans 

floodwaters. 

As the coordinator for the federal response to actual or potential oil and 

hazardous materials releases under the National Response Plan, EPA led 

efforts to evaluate and clean up such spills on land and in inland waters, 

while the Coast Guard led these efforts for spills into coastal waters.9

 EPA 

conducted “reconnaissance” activities at the many industrial facilities, such 

as oil refineries and chemical plants, in the Gulf Coast area to identify and 

plan any cleanup needed as a result of Katrina’s impact. Specifically, EPA 

conducted aerial and ground assessments of these facilities and used 

7

EPA officials said that, as of December 31, 2006, EPA had received funding from FEMA 

totaling $718.4 million. Of this amount, EPA had obligated $563.7 million and had expended 

$415.5 million, including $80.1 million passed directly to the U.S. Coast Guard. In addition, 

EPA had expended approximately $13 million of appropriated resources in support of the 

responses to Hurricanes Katrina and Rita. 

8

EPA used its existing emergency support contracts during its Katrina response: (1) 

Emergency and Rapid Response Services contracts for personnel, equipment, and materials 

to provide emergency removal and remedial response cleanup services, including 

containing, recovering, and disposing of hazardous substances; and (2) Superfund Technical 

Assessment and Response Team contracts for personnel providing technical support for 

gathering and analyzing site assessment technical data, preparing reports on oil and 

hazardous substance investigations, and providing technical support for cleanup efforts. 

9

The Coast Guard estimated that 8 million gallons of oil were released due to Katrina and 

that the hurricane caused six major spills (at least 100,000 gallons each) and numerous 

minor ones (less than 10,000 gallons each).
Page 13 GAO-07-651 Hurricane Katrina

facility self-assessments to determine the magnitude of potential hazardous 

releases and to prioritize facilities needing additional assessments. EPA 

also conducted cleanups at stores selling chemicals for swimming pools, 

home repair and building supply stores, and other sites. Working with the 

Louisiana Department of Environmental Quality, EPA also evaluated 

potentially hazardous chemicals at over 350 chemistry and biology 

laboratories in schools in southern Louisiana, removing chemicals from 

more than 130 schools.

In addition, EPA worked with the Coast Guard and the Louisiana 

Department of Environmental Quality to oversee sampling and cleanup of a 

large oil spill at the Murphy Oil USA refinery in St. Bernard Parish, 

Louisiana. The floodwaters from Katrina had damaged a large aboveground 

storage tank at the refinery, releasing about 1 million gallons of mixed 

crude oil onto the facility and an adjacent residential neighborhood, 

affecting approximately 1,800 homes. EPA and the Coast Guard divided 

responsibility for overseeing Murphy Oil’s voluntary cleanup of the spill. 

EPA worked with the Louisiana Department of Environmental Quality to 

oversee Murphy Oil’s cleanup in residential areas accessible to the public, 

such as parks, school yards, roads, and sidewalks.10 In addition, EPA is 

continuing to oversee Murphy Oil’s soil sampling at residential and other 

properties—for example, by having 10 percent of the soil samples Murphy 

Oil collects analyzed by both Murphy Oil and a separate laboratory as a 

quality control measure. According to EPA officials, the agency will 

continue to oversee Murphy Oil’s cleanup of affected areas until these 

activities are complete.11

Other EPA efforts to mitigate the environmental impacts of Hurricane 

Katrina have centered on managing the disposition of debris that may 

contain hazardous materials. Specifically, EPA established a plan to 

segregate, collect, and properly dispose of debris such as household 

hazardous waste (household cleaning chemicals, paints, and pesticides); 

electronic waste (computers, televisions, printers, DVD players, and other 

10The Coast Guard oversaw the company’s removal of oil from the canals in the area, an oil 

tank farm containment area, and storm drains.

11Murphy Oil agreed to settle a class action lawsuit brought against the company by 

individuals and entities that were allegedly injured or damaged from the oil spill. In January 

2007, a court approved a $330 million settlement agreement that pays for the acquisition of 

property, damage remediation, and compensation for losses. Turner v. Murphy Oil U.S.A., 

Inc., No. 05-4206 (E.D. LA. filed Aug. 9, 2005).
Page 14 GAO-07-651 Hurricane Katrina

electronics); and white goods (large appliances such as air conditioners, 

dishwashers, refrigerators, stoves, and freezers). These items frequently 

contain contaminants, such as lead, mercury, or chlorofluorocarbons, that 

can enter the ground, water, or air if they are not disposed of properly. In 

both Louisiana and Mississippi, EPA organized neighborhood curbside 

pickups of household hazardous waste and circulated information about 

them; EPA also worked with local officials to establish collection and dropoff sites for debris that may contain hazardous materials. In addition, EPA 

established debris staging areas for sorting and categorizing industrial and 

household hazardous waste that EPA and its contractors had collected, 

draining and recycling hazardous chemicals, and ensuring that hazardous 

containers were disposed of properly. As of September 1, 2006, EPA’s 

efforts to facilitate the appropriate disposal of debris that may contain 

hazardous materials had resulted in the

• collection of more than 5.1 million containers of potentially hazardous 

waste consisting of about 4.9 million small household containers and 

about 200,000 large abandoned containers, such as drums, tanks, and 

cylinders;

• removal of the chlorofluorocarbons and other refrigerants that are 

harmful to the environment and recycling of 380,000 white goods; and

• collection and recycling of over 660,000 units of electronic waste.

EPA Has Sampled the Air, 

Water, and Sediment and 

Soil in Affected Gulf Coast 

Areas to Identify and Assess 

Environmental 

Contamination Caused by 

the Storm

EPA also conducted numerous activities to identify and assess air, water, 

and sediment and soil contamination in Gulf Coast areas affected by 

Katrina. For example, EPA was concerned about the potential 

environmental impact of Katrina on the 24 Superfund sites in the affected 

Gulf Coast areas. These sites are on EPA’s National Priorities List, which 

identifies the agency’s highest-priority cleanup sites. Many of the Gulf 

Coast Superfund sites have been cleaned up and have remedies in place to 

maintain the standard of cleanup achieved.12 To determine whether the 

hurricane had caused additional contamination, from September 29 to 

October 14, 2005, EPA collected sediment, surface water, and groundwater 

samples at or near the 24 Superfund sites in Louisiana, Mississippi, and 

Alabama, comparing the samples obtained after the hurricane with pre12EPA also assessed the potential impact on an additional 30 Superfund National Priorities 

List sites in southwest Louisiana and southeast Texas after Hurricane Rita struck this area.
Page 15 GAO-07-651 Hurricane Katrina

Katrina samples collected during remedial investigations or routine 

monitoring activities.13 EPA found that four sites in Louisiana had elevated 

contaminant levels, one with contaminants that had not been previously 

detected.14 Given the particular situations at these four Superfund sites, 

EPA determined that continued monitoring according to the sites’ routine 

operation and maintenance plans would address these problems. On the 

basis of the sampling results, EPA concluded that the other 20 sites 

reviewed were not impacted by Katrina. Additionally, EPA Region 4 

conducted soil and sediment samples near several industrial facilities in the 

affected areas of Mississippi to determine if flooding from Katrina had 

released hazardous materials. With one exception, the region found that 

there did not appear to be any indication of any potential releases due to 

the hurricane.15

In addition, potential sources of air pollution that could occur as a result of 

a hurricane include spills of volatile chemicals, releases or leaks from 

industrial plants, dust from building demolition and debris transport, 

contaminated sediments that can be resuspended as dust, and smoke from 

open burning of debris. EPA began screening air quality in Louisiana and 

Mississippi in coordination with state departments of environmental 

quality on August 30, 2005, to provide initial air quality assessments. EPA 

employed such equipment as the agency’s (1) Airborne Spectral 

Photometric Environmental Collection Technology flying laboratory, 

13EPA Region 4 also compared the sample results from the Superfund sites reviewed in 

Mississippi and Alabama with the EPA Office of Water 2004 National Recommended Water 

Quality Criteria and EPA Region 9 Preliminary Remediation Goals to determine if those 

sites’ conditions might also represent previously unrecognized risks to human health and 

the environment.

14EPA concluded from the assessment of the Agriculture Street Landfill in New Orleans, 1 of 

the 24 Superfund sites reviewed, that the flooding did not cause any lead (the contaminant 

of concern) to migrate up through the site’s soil cover. However, sediment samples EPA 

collected on the site and in the area contained benzo(a)pyrene levels that exceeded 

Louisiana Department of Environmental Quality risk standards. EPA reported on August 17, 

2006, that it had contacted the Housing Authority of New Orleans (the property owner and 

manager) regarding the sampling results and planned to work with the authority to ensure 

plans for the site addressed this contamination. Additionally, EPA stated it would provide a 

closeout report when the authority announced its specific plans.

15The one exception EPA Region 4 identified involved the Naval Construction Battalion 

Center in Gulfport, Mississippi. Although EPA detected elevated dioxins at some of the 

sampling points near this facility, the agency concluded that none of the concentrations 

detected caused concern about effects on human health and that the site was not adversely 

impacted by Katrina.
Page 16 GAO-07-651 Hurricane Katrina

equipment mounted in a small aircraft that can obtain detailed chemical 

information from a safe distance; and (2) Trace Atmospheric Gas Analyzer 

mobile laboratories, which are self-contained units capable of real-time 

sampling and analysis, to conduct air monitoring immediately following 

Katrina. In addition, EPA worked with state partners to restore damaged or 

lost air quality monitoring stations. EPA has performed air sampling to test 

for contaminants such as lead, arsenic, asbestos fibers, volatile organic 

compounds, particulate matter, and other pollutants using temporary 

ambient air monitoring stations in Louisiana and Mississippi.

Another key component of EPA’s activities to assess the environmental 

impacts of Katrina focused on helping both Louisiana and Mississippi 

perform drinking water and wastewater infrastructure assessments. Many 

of these facilities along the Gulf Coast were damaged and became 

inoperable. EPA helped perform about 4,000 drinking water and 

wastewater infrastructure assessments to help bring these facilities back 

online as quickly as possible after the hurricane. Among other things, EPA 

provided assistance to help assess the status of both states’ public water 

systems; helped collect and analyze drinking water samples, including 

providing mobile labs to help with this effort; and provided information to 

the public, such as flyers about drinking water quality. EPA’s Office of 

Emergency Management also noted in its September 2006 annual report 

that EPA was working closely with FEMA and Louisiana and Mississippi 

state officials to establish long-term recovery plans, with an emphasis on 

water and wastewater infrastructure.

EPA also coordinated with various federal and state agencies to test 

surface water bodies (such as rivers, lakes, and the Gulf of Mexico) and 

floodwaters in the aftermath of Hurricanes Katrina and Rita. Among other 

efforts, EPA, the National Oceanic and Atmospheric Administration, the 

Food and Drug Administration, and the U.S. Geological Survey coordinated 

an environmental impact assessment of the coastal waters throughout the 

affected region. By integrating response activities aboard two EPA and 

National Oceanic and Atmospheric Administration survey and research 

vessels, small boat teams were able to characterize the magnitude and 

extent of the coastal contamination and ecological effects from these 

hurricanes. These efforts, which were conducted between September 27 

and October 14, 2005, generally found that the water was safe for 

recreational use, including swimming. EPA also coordinated with the 

Mississippi Department of Environmental Quality to conduct a water 

quality study in the rivers and bays along the Mississippi coast in 

September 2005. The objective of this study was to provide sediment and 
Page 17 GAO-07-651 Hurricane Katrina

water quality data on the major bay systems along the Mississippi Sound.16

According to this study, few pollutants were identified.

The severe and sustained flooding of about 80 percent of New Orleans and 

large areas of Plaquemines and St. Bernard Parishes from Hurricanes 

Katrina and Rita prompted EPA and the Louisiana Department of 

Environmental Quality to test the floodwaters and the resulting sediment 

from the hurricanes. Because the flooded portions of the New Orleans area 

were below sea level and had little natural drainage, there were grave 

concerns about the environmental health risks as the floodwaters 

commingled with contaminants such as oil and gas from ruptured lines and 

storage tanks; sewage; and various chemicals leached from abandoned 

drums, containers, and vehicles. The additional storm surge from 

Hurricane Rita, which occurred about 1 month after Katrina, further 

exacerbated the situation when it reflooded much of New Orleans and the 

surrounding parishes. To determine the potential environmental effects of 

the floodwaters, EPA and the Louisiana Department of Environmental 

Quality collected nearly 400 water samples of the flooded areas and also 

periodically collected samples from Lake Pontchartrain as the floodwaters 

were being pumped from the flooded areas around New Orleans into the 

lake. The samples from the floodwaters were tested for bacteria and about 

200 chemicals. While numerous samples revealed elevated bacteria levels, 

EPA and the Louisiana Department of Environmental Quality reported that 

this was expected, given the commingling of floodwaters with sewage 

collection system waters. Although a small number of samples contained 

concentrations of chemicals that exceeded short-term (i.e., 90 days) 

standards for dermal contact and incidental ingestion, the agencies 

concluded that there was realistically no circumstance that would lead to 

continuous exposure to the floodwaters beyond a few days.17 Unlike 

Louisiana, areas in Mississippi and Alabama hit by Katrina did not 

16The Mississippi Sound spans the entire Mississippi Gulf Coast and is separated from the 

Gulf of Mexico by a series of narrow islands and sandbars. Numerous coastal bays are 

contained within the system, including St. Louis Bay, Biloxi Bay, and Pascagoula Bay. EPA 

stated that the study was not designed to identify specific pollutant sources or provide 

definitive information on the potential long-term effects of the hurricanes on human or 

ecological health.

17Additionally, the Louisiana Department of Environmental Quality and the U.S. Geological 

Survey collected over 100 samples from 50 pumping stations in the Lake Pontchartrain area 

during September and October 2005 that showed low bacteria concentrations in the lake 

within recreational standards. 
Page 18 GAO-07-651 Hurricane Katrina

experience any sustained flooding, although they did experience severe 

damage from the hurricane’s storm surge, high winds, and rainfall.

Once the Army Corps of Engineers completed draining the floodwaters 

from the New Orleans area on October 11, 2005, the environmental health 

risk to area residents and emergency responders from the waters was 

eliminated. However, renewed concerns arose over the potentially 

contaminated sediment the floodwaters left behind. As the floodwaters in 

New Orleans and the surrounding parishes receded, sediments ranging in 

depth from less than an inch to several feet remained in some areas.18 As 

would be expected, sediment was more prevalent in those areas where the 

floodwaters flowed over or breached levees, while in other areas, little or 

no sediment was left behind. 

EPA, in coordination with the Louisiana Department of Environmental 

Quality and several other federal and state agencies, carried out sediment 

testing in four phases, collecting up to 1,800 sediment and soil samples. The 

samples were collected from streets and other public access areas, 

including golf courses, in sections of New Orleans that had been flooded. 

On the basis of these samples, EPA and the Louisiana Department of 

Environmental Quality generally concluded, in conjunction with other 

federal and state agencies, that the sediments left behind by the flooding 

were not expected to cause adverse health effects to individuals returning 

to New Orleans. Specifics regarding the four phases of the sediment testing 

follow. Unless otherwise noted, the samples were (1) analyzed for about 

200 metals and organic chemicals, including lead, arsenic, gasoline, diesel 

fuel, and oil, as well as for bacteria; and (2) evaluated using Louisiana 

Department of Environmental Quality Risk Evaluation/Corrective Action 

Program Screening Option Standards and EPA’s risk criteria based on longterm (30 years) residential exposure assumptions.19

18For purposes of its hurricane response sampling effort, EPA defined sediment as “residuals 

deposited by receding floodwaters which may include historical sediment from nearby 

water bodies, soil from yards, road and construction debris, and other materials.”

19The Louisiana Department of Environmental Quality has developed a Risk 

Evaluation/Corrective Action Program to address risks to human health and the 

environment from the release of chemical constituents. The program consists of a screening 

option and three management options. The screening option may be used to manage an area 

of concern expeditiously, or determine if it warrants further investigation, while the threetiered management options allow site evaluation and corrective action efforts to be tailored 

to site conditions and risks.
Page 19 GAO-07-651 Hurricane Katrina

• Phase 1 of the sediment sampling included about 450 samples as 

follows: (1) 430 individual samples EPA collected from September 10 to 

October 14, 2005, in Jefferson, Orleans, Plaquemines, and St. Bernard 

Parishes; (2) 23 samples collected by the Louisiana Department of 

Environmental Quality on November 10, 2005; 20 and (3) 14 samples 

collected on November 19 and 20, 2005, by EPA and the Louisiana 

Department of Environmental Quality at locations tested previously 

where contaminant concentrations exceeded the Louisiana Department 

of Environmental Quality and EPA risk criteria.21

• Phase 2 of the sediment sampling included about 280 individual samples 

collected in the Lower Ninth Ward (part of Orleans Parish) and St. 

Bernard Parish from October 29 to November 27, 2005—areas that were 

severely impacted by the flooding.

• Phase 3 of the sediment sampling focused primarily on 43 locations in 

flood-impacted areas where elevated concentrations of arsenic, lead, or 

benzo(a)pyrene had been found in phases 1 and 2.22 To determine 

whether the elevated levels of these contaminants were limited to the 

specific location originally sampled or reflected more widespread 

contamination, up to 10 composite samples were collected within a 500-

foot radius of each of the 43 locations from February 16 to February 22, 

2006. The composite samples combined four discrete sediment or soil 

samples, and most were analyzed only for the individual contaminant 

that was elevated in the original sediment sample.

• Phase 4 sediment sampling included 586 samples collected in Orleans 

and St. Bernard Parishes from February 6 to June 30, 2006.23 These 

samples were analyzed for polycyclic aromatic hydrocarbons, 

pesticides, herbicides, diesel and oil range organic chemicals, and 

20These 23 samples were analyzed for arsenic, lead, polynuclear aromatic hydrocarbons, and 

total petroleum hydrocarbons.

21The agencies resampled at 14 of the 145 locations at which the initial sampling exceeded 

the risk criteria based on their resampling criteria: the sediment depth had to exceed 1.5 

centimeters (a little more than one-half inch).

22To address public concerns, phase 3 also included samples in public access areas of a 

neighborhood near a former pesticide blending facility that had not been included in phases 

1 and 2. These composite samples were analyzed for a complete spectrum of pesticides.

23Duplicate samples were collected at 126 of the locations, resulting in the analysis of 712 

samples.
Page 20 GAO-07-651 Hurricane Katrina

metals. In this phase, potential sampling sites were selected using a grid 

of the “eastern half of the flooded area.” EPA identified 1,676 potential 

sampling sites on the grid. EPA did not collect samples from a majority 

of these sites (1,090) because (1) the sampling site was in a commercial 

area, (2) the sediment was less than 0.5 centimeters thick (less than onequarter of an inch), or (3) no sediment was present. 

EPA’s response activities have included providing a substantial amount of 

information to the public on the environmental health risks from Katrina, 

including three environmental assessment summaries that focused 

primarily on the results of these sediment samples taken in New Orleans. 

The first summary also conveyed the results of air and water sampling in 

the New Orleans area. Beginning shortly after Hurricane Katrina, in 

September 2005, EPA started to provide other information to the public on 

environmental health risks and actions to mitigate exposures via flyers, 

health advisories, and public service announcements that were distributed 

at various locations throughout the hurricane-damaged areas, made 

available to the media, and posted on EPA’s Web page. For example, EPA 

reported that it distributed over 3.8 million flyers on various topics, such as 

hazardous waste collection, mold problems, and potential environmental 

health hazards. 

Overall, EPA’s response activities varied in Louisiana and Mississippi based, 

in part, on the environmental impacts and needs of the affected parishes 

and counties. While EPA’s response is complete in Mississippi, EPA Region 

6 continues to assist the state of Louisiana with its recovery efforts and 

currently plans to continue to do so until at least September 2007. State and 

local government decisions continue to affect the length of time EPA will 

need to maintain a presence in Louisiana parishes. For example, local 

government decisions about home condemnation and demolition 

processes will affect the length of time EPA needs to continue its debris 

management and air monitoring activities in the New Orleans area. 
Page 21 GAO-07-651 Hurricane Katrina

EPA’s Air Monitoring 

for Releases of 

Asbestos Fibers in New 

Orleans Does Not 

Adequately Address 

Neighborhoods with 

Substantial Building 

Demolition and 

Renovation Activities

EPA’s Clean Air Act asbestos regulation seeks to minimize the significant 

human health risks—including lung disease and cancer—associated with 

inhalation of asbestos fibers from building demolition and other activities. 

To facilitate and expedite demolition and rebuilding following Hurricane 

Katrina, EPA stated that it would not enforce certain requirements under 

the asbestos regulation, at the request of the Louisiana and Mississippi 

Departments of Environmental Quality. In addition, many demolition and 

renovation activities—those by individual homeowners—are generally 

unregulated under EPA’s asbestos regulation. EPA took steps to measure 

asbestos emissions after Hurricane Katrina—for example, initially more 

than doubling from 5 to 12 the ambient (outdoor) air monitors in the area 

prior to the storms.24 However, air monitors generally have not been 

located in areas in which much of the building demolition and renovation is 

occurring. 

EPA’s Clean Air Act 

Asbestos Regulation 

Covering Building 

Demolition Activities Seeks 

to Minimize the Significant 

Human Health Risks 

Associated with Exposure 

to Asbestos Fibers in the Air

The Clean Air Act of 1970, as amended, requires EPA to develop and 

enforce regulations to protect the general public from exposure to 

hazardous air pollutants—also called air toxics—that are known to be 

hazardous to human health. Asbestos is an air toxic consisting of naturally 

occurring fibrous minerals with high tensile strength, the ability to be 

woven, and resistance to heat and most chemicals. Because of these 

properties, asbestos fibers have been used in a wide range of manufactured 

goods, including roofing shingles, ceiling and floor tiles, paper and cement 

products, and textiles. Exposure to asbestos can be harmful to human 

health if asbestos fibers are released into the air, such as when asbestos is 

disturbed or in poor condition and these fibers are inhaled into the lungs. 

Such releases of asbestos fibers can occur during building renovations and 

demolitions. Asbestos was among the first air toxics EPA regulated. EPA 

has promulgated regulations governing the renovation and demolition of 

buildings with asbestos-containing materials to protect the public from the 

risks associated with exposure to asbestos fibers.25

24According to EPA, the monitors can measure ambient concentrations of the following 

potential pollutants and categories of pollutants from local and regional sources: arsenic, 

asbestos, lead, particulate matter, polycyclic aromatic hydrocarbon chemicals, and volatile 

organic compounds.

25See National Emissions Standard for Asbestos, 40 CFR Part 61, Subpart M.
Page 22 GAO-07-651 Hurricane Katrina

Some significant health effects associated with asbestos exposure—such 

as asbestosis and lung cancer—have been recognized for many years. 

Asbestosis is a serious, progressive, long-term disease caused by inhaling 

asbestos fibers that produces scarring and inflammation of the lung tissue, 

thereby making it harder for the lungs to get oxygen into the blood. Lung 

cancer causes the largest number of deaths related to asbestos exposure. 

Individuals working in occupations involving the mining, milling, 

manufacturing, and use of asbestos and its products, including 

construction and demolition workers, are more likely to get lung cancer 

than the general population. 

Diseases linked to asbestos exposure take a long time to develop. 

Specifically, most cases of lung cancer or asbestosis in asbestos workers 

occur 15 years or more after initial exposure to asbestos, and cases of 

mesothelioma (cancer of the lining of the lungs) are commonly diagnosed 

30 years or more after exposure. Cases of mesothelioma have been 

reported in family members of asbestos workers after exposure to these 

workers at home and in individuals without occupational exposure who 

live close to asbestos mines.26

According to EPA, scientists have not been able to identify a safe, or 

threshold, level for exposure to airborne asbestos. Rather than regulating 

this air toxic by setting emission standards for emission sources, as is 

typically done to mitigate health risks, EPA’s national emissions standards 

for asbestos regulate various potential sources of asbestos emissions, 

including renovation and demolition activities, by setting standards for 

work practices.27 EPA has granted some states, including Louisiana and 

Mississippi, approval to implement and enforce the asbestos standards. 

However, EPA retains the authority to enforce its requirements; to oversee 

states’ implementation of the air toxics program in general; and to 

withdraw the delegation of the program if a state does not, for example, 

adequately enforce the program. Under EPA’s regulations of demolitions 

26Related information on the adverse health effects due to asbestos can be found via the 

Department of Health and Human Services, Agency for Toxic Substances and Disease 

Registry Web page at http://www.atsdr.cdc.gov/asbestos/asbestos/health_effects.

27The Clean Air Act provides EPA with the authority to promulgate a work practice standard 

to mitigate health risks if it is not feasible to establish an emission standard. 42 U.S.C. § 

7412(h). In its 1978 rule amending EPA’s asbestos standard, the agency said that it was not 

feasible to prescribe a numerical emission standard for building demolitions or renovations. 

See 40 C.F.R. § 61.145(c), Procedures for asbestos emissions control.
Page 23 GAO-07-651 Hurricane Katrina

involving asbestos, the owner or operator of the demolition activity 

generally must

• inspect buildings for asbestos where demolition or substantial 

renovation activity will occur;

• provide written notice to EPA or the state of intention to renovate or 

demolish buildings that have asbestos-containing material;

• remove all regulated asbestos-containing material before any activity 

begins that would break up, dislodge, or disturb the material;28

• wet all regulated asbestos-containing material exposed during cutting or 

disjoining operations and stripping operations so that no emissions are 

visible during the demolition;

• take steps to contain asbestos-containing material in preparation for 

disposal, such as wetting the material or encasing it in leak-tight 

wrapping; and

• undertake the removal of asbestos-containing material in the presence 

of an on-site representative who has been trained to comply with the 

provisions of the asbestos standard.

However, if a building is to be demolished by government order because it 

is structurally unsound and in danger of imminent collapse, it is not 

required to be inspected for asbestos, and the regulated asbestoscontaining materials are not required to be identified and removed first. 

Nevertheless, specified notification requirements and emission control 

28Regulated asbestos containing material (RACM) means (a) Friable asbestos material, (b) 

Category I nonfriable ACM that has become friable, (c) Category I nonfriable ACM that will 

be or has been subjected to sanding, grinding, cutting, or abrading, or (d) Category II 

nonfriable ACM that has a high probability of becoming or has become crumbled, 

pulverized, or reduced to powder by the forces expected to act on the material in the course 

of demolition or renovation operations regulated by the asbestos work practice standards. 

Category I nonfriable asbestos-containing material (ACM) means asbestos-containing 

packings, gaskets, resilient floor covering, and asphalt roofing products containing more 

than 1 percent asbestos as determined using the method specified in appendix E, subpart E, 

40 C.F.R. part 763, section 1, Polarized Light Microscopy. Category II nonfriable ACM means 

any material, excluding Category I nonfriable ACM, containing more than 1 percent asbestos 

as determined using the methods specified in appendix E, subpart E, 40 C.F.R. part 763, 

section 1, Polarized Light Microscopy that, when dry, cannot be crumbled, pulverized, or 

reduced to powder by hand pressure.
Page 24 GAO-07-651 Hurricane Katrina

requirements—primarily the wetting of asbestos-containing materials to 

limit releases of asbestos fibers—still apply to the demolition operation.29

Importantly, these standards generally do not apply to the demolition or 

renovation of a residential building by or for an individual homeowner. 30

Many of the flooded homes in New Orleans that will be demolished or 

substantially renovated are likely to contain asbestos-containing materials, 

such as roof shingles, siding, flooring, and ceilings. For example, analysis 

by the Louisiana Department of Environmental Quality shows that the 

majority of land tracts in the New Orleans area contain homes built before 

1980, when use of asbestos products was prevalent. As of January 2007, 

about 25,000 homes had been identified as awaiting demolition—98 

percent of which are concentrated in the Orleans and St. Bernard 

Parishes.31 According to the Louisiana Department of Environmental 

Quality, another 80,000 homes that were flooded in the New Orleans area 

are not yet included in the demolition estimates, but many of them will 

likely be demolished. Those that are not demolished will very likely have to 

be substantially renovated. 

EPA Has Issued “No Action 

Assurances” for Certain 

Clean Air Act Asbestos 

Requirements Governing 

the Demolition of Buildings 

to Help Expedite the Gulf 

Coast Cleanup

On rare occasions, EPA issues “no action assurance” letters stating that it 

will not enforce certain legal requirements. EPA recognizes that such 

assurances could erode the credibility of the agency’s enforcement 

program by creating real or perceived inequities in the agency’s treatment 

of the regulated community. Consequently, under EPA policy guidance, 

such assurances are to be used only in extremely unusual cases when 

clearly necessary to serve the public interest—such as to avoid extreme 

risks to public health or safety or to obtain important information for 

research purposes—when no other mechanism can adequately address the 

problem presented. 

2940 C.F.R. § 61.145(a)(3); see EPA Office of Compliance, Managing Your Environmental 

Responsibilities: A Planning Guide for Construction and Development, at VII-15 (April 

2005).

30Demolition or renovation by the individual homeowner of a residential building with four 

or fewer dwelling units is not covered by EPA’s asbestos national emissions standards, 

unless the demolition is part of a larger overall project carried out by one owner or operator.

31Summary of homes remaining for demolition. Information compiled from the January 6, 

2007, weekly status report from the Department of Homeland Security.
Page 25 GAO-07-651 Hurricane Katrina

To facilitate and expedite demolition and rebuilding following Hurricane 

Katrina, Louisiana and Mississippi requested that EPA issue no action 

assurance letters concerning some provisions of the national emissions 

standard for asbestos. In light of the extraordinary demolition, cleanup, 

and debris disposal required on the Gulf Coast, EPA issued several no 

action assurance letters to Louisiana and Mississippi. Under letters issued 

in February 2006, residences that are subject to a government-issued 

demolition order based on the residence being (1) structurally unsound but 

not necessarily in danger of imminent collapse, (2) moved off of its 

foundation, or (3) uninhabitable for other environmental reasons, such as 

flooding, are effectively not subject to otherwise applicable requirements 

for inspection and removal of asbestos prior to demolition. Such structures 

must nonetheless be demolished, transported, and disposed of in 

accordance with specified requirements aimed at ensuring adequate 

protection of any asbestos the buildings may contain. These requirements 

include notification, thorough wetting of the building both prior to and 

during the demolition process, and proper disposal of all of the debris as if 

it contained asbestos.32 EPA’s 2006 no action assurance letters also allowed 

government-issued demolition orders to be expanded to groups of 

residences instead of only individual residences because it may not be 

practical for state or local officials to make an individual determination for 

every residential structure. The no action assurances apply to the Louisiana 

and Mississippi Departments of Environmental Quality, to local 

governments, and to the Army Corps of Engineers, as well as to any 

persons operating at the direction of these government entities.

The Army Corps of Engineers is the prime contractor for many of the 

demolitions covered by the no action assurances, including all of them in 

Orleans Parish. Some parishes—most notably St. Bernard Parish—use 

other contractors or a mix of the Corps and other contractors. According to 

data from FEMA, of the vast majority of the remaining 25,000 demolitions 

estimated as of January 2007, approximately half are in Orleans Parish and 

half in St. Bernard. Regarding demolitions conducted by the Corps and its 

contractors, the Corps said that approximately 85 percent of the 2,600 

demolitions conducted in Orleans Parish, which includes the Ninth Ward, 

were classified as containing regulated asbestos-containing materials, 

32EPA also issued an April 28, 2006, no action assurance letter to the Louisiana Department 

of Environmental Quality allowing a staging process for debris from approximately 70 

residential structures to be used in debris grinding and burning pilot studies in Louisiana 

until July 31, 2006. However, FEMA did not approve funding for these pilot studies for 

several reasons.
Page 26 GAO-07-651 Hurricane Katrina

primarily because inspections could not be performed inside properties.33

The Corps also said that in other parishes, between 10 percent and 40 

percent of the structures it had demolished were classified as containing 

regulated asbestos-containing materials on the basis of inspections. 

Initially, the no action assurance letters were in effect for 1 year—that is, 

until February 2007. Officials from Louisiana told us that while EPA’s no 

action assurances were helpful in allowing demolitions to proceed at a 

faster pace, a number of other issues, such as landfill capacity and the 

building condemnation process, have contributed to demolition delays. As 

a result, on December 21, 2006, the Louisiana Department of 

Environmental Quality requested an extension of the no action assurances 

until February 2008 because many demolitions have yet to be conducted. 

Citing information from the Army Corps of Engineers, the Louisiana 

Department of Environmental Quality told EPA that, as of December 2006, 

10,000 residences had been demolished, but more than 25,000 demolitions 

are likely to be needed.34 In supplemental information supporting the 

extension request, the Louisiana Department of Environmental Quality 

provided EPA with repopulation estimates on the basis of estimates by The 

Brookings Institution’s December 2006 report, Katrina Index: Tracking 

Variables of Post-Katrina Recovery. For the Orleans and St. Bernard 

Parishes, 41 percent and 39 percent, respectively, of the residents were 

estimated to have returned as of August 2006, compared with Census 2000 

population estimates.35 The Louisiana Department of Environmental 

Quality also cited a plan for the recovery of the Ninth Ward that stated 

about 20 percent of the residents of the Ninth Ward had returned.36 This 

plan also stated that homeowners have gutted 30 percent of the houses in 

this ward and that owners have repaired or are in the process of repairing 

another 30 percent of the housing. A March 2007 update to the Katrina 

Index, which did not update the August 2006 repopulation estimates, stated 

33According to the Army Corps of Engineers, residences it had demolished were inspected 

for asbestos prior to demolition except when it was not safe to enter a structure, the 

structure had transite shingles or siding (which the Corps classifies as regulated asbestoscontaining materials), or the structure was completely demolished.

34In February 2007, the Louisiana Department of Environmental Quality stated that 12,000 

residences had been demolished and estimated 30,000 more home demolitions were needed.

35The margin of error for the estimates was plus or minus 9.8 percent for Orleans Parish and 

plus or minus 14.4 percent for St. Bernard Parish.

36A Peoples’ Plan for Overcoming the Hurricane Katrina Blues (draft study prepared by 

ACORN Housing/University Partnership, Feb. 1, 2007).
Page 27 GAO-07-651 Hurricane Katrina

that thousands of college students and families on spring break are coming 

to the Gulf Coast to help with rebuilding; it also reported that the New 

Orleans metropolitan area gained more than 50,000 workers from 

November 2006 to January 2007.

On February 2, 2007, EPA approved an extension of the no action 

assurances through September 30, 2007, for the 11 parishes covered under 

Louisiana Emergency Declarations and Administrative Orders. EPA also 

approved an extension of the no action assurance it provided the 

Mississippi Department of Environmental Quality through September 30, 

2007, for four counties in Mississippi. In its no action assurance letters to 

Louisiana and Mississippi, EPA stated that it reserved the right to revoke or 

modify the assurances if it determined that doing so was necessary to 

protect public health or the environment. Moreover, we believe that the 

potential public health effect of demolition and renovation activities by 

individual homeowners—which are generally not regulated under EPA’s 

asbestos work practice standards—also warrants evaluation.

Current Asbestos 

Monitoring Is Not Sufficient 

to Assess the Potential 

Public Health and 

Environmental Impacts of 

Demolition and Renovation 

Activities

Many homes in the New Orleans area contain hazardous materials such as 

asbestos that could be released during demolition and renovation 

activities, posing health hazards for individuals exposed to asbestos fibers. 

The bulk of these demolition and renovation activities have yet to occur. 

For example, in December 2006, the Army Corps of Engineers said it had 

completed about 2,000 of the 6,000 to 12,000 residential demolitions it 

expected to perform in the Orleans Parish.37 In addition to these 

demolitions covered by the no action assurances, the demolition and 

renovation activities by individual homeowners that are outside the scope 

of EPA’s asbestos national emissions standards will likely be substantial. 

For example, in December 2006, the Corps stated that the demolition effort 

by individual homeowners was approximately equal to the public 

demolition effort. Further, because of mold problems caused by the 

extensive flooding, many residences that do not require demolition must 

nonetheless be gutted—stripping the walls down to the studs—before they 

can be renovated. Numerous volunteer organizations continue to help 

individual owners by gutting the homes. For example, the Corps reported 

that, as of October 2006, 6,500 homes were on a list for gutting services to 

be provided by volunteers from various nonprofit organizations. According 

37According to the Corps, the number of residence demolitions continues to be speculative 

and is dependent on the city of New Orleans finalizing condemnation packages.
Page 28 GAO-07-651 Hurricane Katrina

to EPA, whether demolitions by volunteer groups would be subject to the 

asbestos work practice standards depends upon the number and location 

of sites and who is supervising the demolition. That thousands of 

demolitions and substantial renovations may occur in the same geographic 

area and in the same general time frame without being subject to the 

asbestos work practice standards represents a potential health problem—

especially since the protective requirement to wet any asbestos-containing 

materials does not apply to unregulated demolitions and disposal.

To be responsive to potential public questions and concerns, EPA took 

steps to measure asbestos emissions after Hurricane Katrina—initially 

more than doubling from 5 to 12 the number of the ambient (outdoor) air 

monitors in the New Orleans area prior to the storm. EPA officials said the 

agency’s monitoring network was designed to include measuring the 

effects from both the regulated asbestos-containing material to which no 

action assurance letters might apply and activities not regulated, which 

would include demolition or renovation activities by or for individual 

homeowners.38 In July 2006, the agency scaled back ambient air monitoring 

to its prestorm level of five ambient air quality monitors and also reduced 

the frequency of sampling to several times a month.39 EPA said the decision 

to reduce the monitoring sites was based in part on the fact that no 

measurable amounts of asbestos fibers were found for the period of time 

that a 12-monitor network had been in place.40 However, because the 

demolition activities in the New Orleans area generally did not start until 7 

or more months after Hurricane Katrina, EPA’s cutback in asbestos air 

monitoring occurred before (1) most of the demolitions that are now 

38EPA is using a 1-year screening level of 0.01 fibers of the length greater than 5 μm found 

per cubic centimeter of air. According to EPA, this screening level was developed with 

consideration of the Asbestos Hazard Emergency Response Act regulations and EPA’s 

asbestos risk estimates.

39One monitor is in St. Tammany Parish, north of Lake Ponchartrain and Orleans Parish; one 

is in Metairie, west of Orleans; one is in St. Bernard Parish (Arabi); and two are in Orleans 

Parish—in the north at the University of New Orleans and in the east at a fire training 

academy near some landfill operations. 

40According to air sampling information on EPA’s Web page, measurements of asbestos were 

below the method detection limit, a value below the minimum detectable by the method 

used. According to EPA, the reduction in air monitors was also a response to the delays in 

the demolition activities.
Page 29 GAO-07-651 Hurricane Katrina

completed had taken place and (2) the substantial number of remaining 

demolitions had begun.41

While officials from EPA’s Office of Research and Development said the use 

of air monitors would not be effective in detecting asbestos emissions from 

home demolitions and renovations unless monitors were located 

immediately adjacent to demolition and renovation sites, monitors 

generally have not been located in areas in which much of the building 

demolition and renovation is occurring. For example, since Hurricane 

Katrina, EPA has not located ambient or emissions monitors in the Ninth 

Ward, a residential area subjected to widespread flooding in which 

extensive demolition and renovation are occurring. Specifically, the closest 

monitor is in Arabi, a city south of the Ninth Ward. EPA’s air monitoring 

focus has not included proximity to demolition sites. EPA officials said the 

locations for the monitors, initially selected in October 2005, were chosen 

based on proximity to public access (e.g., near populated areas), wind and 

geographical factors, and locations of waste-moving activities.

In January 2007, EPA said that its air monitoring currently focuses on more 

limited geographic areas where “grinding and other remediation activities 

are ongoing”—for example, at debris volume reduction sites, which are 

often landfills. This monitoring does not rely solely on the five ambient air 

monitors around New Orleans but instead includes some monitoring at 

sites involving waste handling, burning, or grinding activities. According to 

EPA, conducting air monitoring at debris reduction sites is more 

conservative than at demolition sites since volume reduction activities 

such as grinding or burning have the potential to release more asbestos 

fibers as the material is destroyed. While this focus on debris and landfills 

is important, so, too, is monitoring data from areas undergoing 

concentrated levels of demolition and renovation.

Along these lines, according to EPA, the Army Corps of Engineers and its 

contractors who are conducting demolitions under government orders 

have monitored the air at demolition sites for asbestos emissions, and the 

Louisiana Department of Environmental Quality has told EPA that this 

monitoring has found “little or no asbestos emissions.” For example, in 

41The Army Corps of Engineers demolished the first storm-damaged homes in Orleans 

Parish in March 2006, and demolition activities started in St. Bernard Parish in April 2006. 

According to Corps data reported in the December 2006 Brookings Institution Katrina 

Index cited above, the Corps had completed 195 demolitions in Orleans Parish as of July 

2006 and 2,289 as of December 2006.
Page 30 GAO-07-651 Hurricane Katrina

November 2006, one Corps contractor reported on air sampling conducted 

at demolition sites where samples were primarily taken from the site 

perimeters (using personal sampling pumps) and from employees wearing 

personal monitoring equipment required by the Occupational Safety and 

Health Administration (OSHA).42 Most of the sampling was conducted at 

sites that the Corps classified as containing regulated asbestos materials, 

and the contractor concluded that exposures to asbestos were minimal and 

respiratory protection was needed only as a precautionary measure.

Such air monitoring data from the Corps and its contractors do not, 

however, address potential asbestos emissions from the privately 

sponsored demolitions and renovations by individual homeowners. Since 

these activities are not regulated—and emissions control actions such as 

wetting the material from before the demolition process through disposal 

are not required—the potential for asbestos emissions at these sites is 

greater than at the regulated sites. Because EPA’s air monitors have not 

been deployed in and around neighborhoods where demolition and 

renovation activities—both publicly and privately sponsored—are 

concentrated, the agency’s finding of no measurable amounts of asbestos at 

its ambient monitoring sites does not necessarily address the asbestos to 

which residents, workers, and volunteers may be exposed in some 

neighborhoods.

This monitoring gap exists even though immediately after Hurricane 

Katrina, EPA recognized the potential health and environmental issues that 

could arise in New Orleans from asbestos emissions at both demolition and 

disposal sites. Specifically, EPA’s September 2005 Overview Plan for 

Ambient Air Monitoring After Hurricane Katrina—which addresses air 

monitoring in Louisiana, Mississippi, and Alabama—discusses asbestos 

monitoring tentatively planned at a number of fixed sites and states that 

additional monitoring requirements to more specifically address both 

asbestos demolition and disposal operations may be established. The 

October 2005 Regional Air Monitoring Plan for Hurricane Katrina in 

Louisiana, developed by EPA Region 6, mentions air monitoring for 

potential emissions during decontamination, demolition, removal, and 

remedial action in impacted areas, but it does not establish additional 

monitoring requirements for asbestos demolition or disposal operations. 

42While the report includes some samples covering other activities, such as canal cleaning 

and debris removal, 93 percent of the samples identified in the report were collected at 

demolition sites.
Page 31 GAO-07-651 Hurricane Katrina

This plan also notes that a site-specific air sampling plan will be established 

to assess air pollutants resulting from debris burns and building 

demolition. In this regard, EPA Region 6 issued its Air Monitoring and 

Sampling Plan for Construction and Demolition Debris Burning or Grinding 

Sites in February 2006.43 This plan addresses the asbestos sampling 

methodology to be used around activity areas such as debris piles or 

landfills. While this plan notes that numerous properties are expected to 

contain hazardous materials such as asbestos that could result in inhalation 

exposure, posing health hazards for individuals in the vicinity, it does not 

include any requirements for monitoring asbestos emissions at building 

renovation or demolition sites. 

In contrast, EPA’s conditions for granting the first Hurricane Katrinarelated asbestos no action assurance to Louisiana in October 2005—which 

Louisiana chose not to use and which expired in April 2006—included a 

requirement that the Louisiana Department of Environmental Quality 

ensure that adequate monitoring was conducted prior to and during 

demolition of residences.44 EPA’s conditions, which were reviewed by EPA’s 

Science Advisory Board, specifically directed Louisiana to develop a plan 

for monitoring that provides information sufficient to ensure adequate 

protection of public health and the environment and to have the plan 

approved by EPA Region 6. EPA further directed that the plan must, at a 

minimum, include representative asbestos monitoring at demolition sites.

Along these lines, an EPA pilot study conducted in 2006 in Fort Smith, 

Arkansas, demonstrates that air monitoring close to the source of asbestos 

emissions is important to detect releases of asbestos fibers. The pilot was 

designed to test the effectiveness of an alternative asbestos control method 

for building demolitions using monitoring information from the demolition 

43Region 4 officials told us they did not develop additional air monitoring plans for 

Mississippi because they determined that the overview plan developed for both states was 

adequate.

44The initial no action assurance letter largely focused on disposition of the construction and 

demolition debris using an open burning technology. Louisiana Department of 

Environmental Quality officials said the state chose to not conduct the test burn required 

under the terms of the letter or exercise the flexibility EPA authorized in the letter because 

of the conditions for the test burn and the time it would take to reach agreement with EPA 

on a test protocol.
Page 32 GAO-07-651 Hurricane Katrina

site and the landfill.45 Specifically, the quality assurance project plan for the 

pilot—which had been subject to independent peer review—called for, 

among other things, perimeter asbestos monitoring during demolition as 

well as at landfill sites.46 The quality assurance project plan also specified 

that an air monitoring network consisting of two concentric rings of 

monitors would be placed at intervals around each of the two buildings 

being demolished. According to EPA officials, it is preferable to have 

emissions monitors stationed as close to a potential source of asbestos 

emissions as possible because the risk of exposure decreases by orders of 

magnitude the farther away one is from the emissions source. For this 

reason, EPA’s pilot was intentionally located in Arkansas in a “remote, 

secure location to ensure no public exposure,” with the nearest residence 

approximately 2 miles from the demolition site. The plan also called for 

asbestos monitoring in the soil at the demolition site, in dust that settled on 

surfaces near the demolition site, and in collected runoff water from 

wetting the building and debris during demolition and debris loading. EPA 

officials said that any monitoring of asbestos emissions at demolition sites 

in New Orleans would not need to be as elaborate as that done for the pilot, 

which was conducted to develop data for potential use in a revision to 

EPA’s asbestos regulation. However, they noted that using the second 

concentric ring of monitors in the pilot allowed EPA’s Office of Research 

and Development to compare air monitor results between the outer 

perimeter ring and the inner ring and project emissions levels outward with 

increased accuracy. 

45The methods used in the pilot had more stringent requirements before and during 

demolition than EPA is requiring under the current asbestos no action assurances in 

Louisiana and Mississippi.

46Environmental Quality Management and EPA, Quality Assurance Project Plan: 

Evaluation of an Alternative Asbestos Control Method for Building Demolition (Mar. 31, 

2006).
Page 33 GAO-07-651 Hurricane Katrina

Some Shortcomings in 

EPA’s Communications 

on Environmental 

Health Risks Have 

Limited the 

Communications’ 

Usefulness to the 

Public

EPA’s key communications about the potential health risks from exposure 

to environmental contamination in New Orleans—three environmental 

assessment summaries prepared with, among others, the Louisiana 

Department of Environmental Quality—did not sufficiently disclose some 

information that would have helped residents better understand the 

potential health risks of returning home and how to mitigate them. In 

addition, some of EPA’s other communications, including flyers and public 

service announcements, provided unclear and inconsistent information on 

mitigating exposure to some contaminants many returning residents would 

likely be exposed to in their homes.

EPA’s Insufficient 

Disclosure about Its 

Decisions Regarding 

Sampling of Contaminants 

Limited Residents’ 

Understanding of the 

Potential Health Risks of 

Returning Home

Following disasters such as Hurricane Katrina, an immediate and primary 

concern of evacuees is whether and when it is safe to return to their homes. 

Accurate and timely information on many factors is important for residents 

to make this assessment—and to determine what they should bring with 

them when they do return, including items to mitigate potential health 

risks. One important factor residents need information on is the 

environmental contamination to which they may be exposed when they 

return home. Such contamination was a particular concern in New Orleans, 

a densely populated, older urban area in proximity to petroleum and 

chemical industry sites, as well as a number of Superfund sites, from which 

contaminants may have migrated into residential areas. 

EPA worked with other federal and state agencies to support local officials 

evaluating home and neighborhood safety. In addition, as discussed earlier, 

EPA provided a substantial amount of information to the public on 

environmental health risks using reports (environmental assessment 

summaries), flyers, public service announcements made available to the 

media, and EPA’s Web page. However, EPA’s communications about the 

potential health risks from environmental contamination in New Orleans—

three environmental assessment summaries prepared with, among others, 

the Louisiana Department of Environmental Quality47—were released 

about 3, 6, and 11 months after Hurricane Katrina, limiting their usefulness 

to residents who would have benefited from more timely information about 

47In addition, EPA worked with the Centers for Disease Control and Prevention, the Agency 

for Toxic Substances and Disease Registry, the Louisiana Department of Health and 

Hospitals, and FEMA.
Page 34 GAO-07-651 Hurricane Katrina

the environmental health risks they could face when returning home. These 

environmental assessment summaries convey some helpful information 

about the floodwaters, sediments, and air quality in the New Orleans area 

after the hurricanes—that is, about the potential health risks of being 

outdoors in the New Orleans area. 

However, because some sampling decisions that EPA made were not 

sufficiently disclosed, residents could have been given the wrong 

impression about the potential health risks they could face in returning to 

their homes. For example, the first environmental assessment summary, 

released in December 2005, states that “the great majority of the data 

available show that adverse health effects would not be expected from 

exposure to the sediments from previously flooded areas provided people 

used common sense and good personal hygiene and safety practices.” 

However, 8 months later in its third and final assessment summary, 

released in August 2006, EPA said that the December 2005 summary 

indicated no immediate health risk to residents returning for a quick 

assessment of damage to their homes. The August 2006 summary said that 

the focus of the analyses of sediments reported on in December 2005 was 

to assess “(1) whether hazardous substances were present in the sediment 

in residential areas and (2) the potential health effects to emergency 

workers and residents from short-term exposure to any hazardous 

substances found in the sediment.” Because the December 2005 summary 

did not include this qualification, residents could have misinterpreted it 

and assumed it was generally safe to return to their homes.

EPA also insufficiently disclosed an important decision it had made about 

sampling in New Orleans. That is, all sediment samples analyzed were 

taken outdoors, from streets and other areas of public access in previously 

flooded residential areas, and samples were not collected from private 

property, such as residents’ yards or inside residences. Regarding 

disclosure of this sampling decision, EPA states in its first assessment 

summary that all of its sampling was conducted “outdoors.” While the 

subsequent assessment summaries issued in March 2006 and August 2006 

provide overviews of the previous assessment summaries, they do not 

disclose that the assessments did not include sediment samples taken 

inside buildings or on private property. For example, the March 2006 

summary states only that the December 2005 assessment summary was 

based on the results of “samples from floodwaters and sediments analyzed 

throughout the flood-impacted areas.” 
Page 35 GAO-07-651 Hurricane Katrina

However, according to EPA officials, in its assessments, the agency 

assumes that results from sediment samples collected from streets or other 

public access areas in residential neighborhoods can be used to 

characterize the degree and nature of contamination in New Orleans, 

including inside homes and in yards. We believe this assumption is 

important and warrants highlighting in the EPA environmental assessment 

summaries for two main reasons. First, environmental contamination 

levels inside buildings can potentially be significantly higher than and 

different from the contamination levels outside for a variety of reasons, 

potentially causing more adverse health effects. For example, 

contaminants that could have been washed into a building during the 

flooding—such as petroleum-based products and arsenic—are not 

dispersed into the atmosphere over time if confined indoors. Moreover, any 

toxic chemicals or other contaminants already in a building at the time of 

the flooding—such as pesticides, asbestos, and lead-based paint—may be 

released inside the building. Finally, after flooding, mold frequently forms 

and spreads. For example, in the case of the Gulf Coast 2005 hurricanes, 

the Centers for Disease Control and Prevention (CDC) concluded that the 

duration and extent of the flooding and the number of structures flooded 

made massive mold contamination a certainty.48 Along these lines, the 

Natural Resources Defense Council conducted tests in several moldcontaminated homes in New Orleans and found that mold in one home was 

at concentrations that would render the building “dangerously 

uninhabitable”; in three other homes, mold spore concentrations were 

“dangerously high.” In addition to causing respiratory discomfort, mold 

also can cause major allergic reactions, asthma attacks, and a pneumonialike illness (pneumonitis) that causes breathing difficulty and fever. 

Second, to understand the level of assurance that EPA can provide about 

the extent to which localized areas of contamination may exist throughout 

the city, it is important to understand that limiting sediment and soil 

sampling to outdoor, public access areas can be problematic in that, for 

example, sediments in streets may be subject to more dispersion than 

those that settled in more protected areas, such as close to residences. 

Further, regarding indoor sampling, in September 2005, EPA’s Science 

Advisory Board had suggested that EPA consider some indoor sampling in 

New Orleans, including sampling of surface films on walls and structures, 

48Generally, CDC has said that any structure flooded after hurricanes or major floods should 

be presumed to contain materials contaminated with mold if those materials were not 

thoroughly dried within 48 hours.
Page 36 GAO-07-651 Hurricane Katrina

because material deposited outdoors may have been different from 

material indoors, where the potential for human exposure is likely to be 

greater. At that time, EPA said that indoor testing of private homes could 

not be conducted in the initial sampling effort because of worker safety 

issues and difficult logistical issues—such as obtaining owners’ consent—

that could not be quickly resolved. EPA stated the agency would revisit this 

recommendation as these issues were addressed. To date, while CDC has 

tested some New Orleans homes for mold contamination, EPA has not 

tested for contamination inside homes that were flooded as a result of the 

hurricanes. EPA officials told us the agency has not tested indoors because 

state and local governments did not request this assistance and because 

EPA determined that indoor testing was not necessary to characterize the 

environmental contamination resulting from the storm. 

During the time EPA was conducting the sediment sampling program, the 

agency posted test results on its Web page as the results became available, 

identifying the general area of the sampling sites on a map of the New 

Orleans area. Thus, any residents with access to the Internet and with 

experience in searching and reviewing government Web sites could obtain 

some information about the environmental contamination in New Orleans 

prior to the release of the assessment summaries. However, the 

information about the individual samples on EPA’s Web page is highly 

technical and would be of limited value to individuals who are not experts 

in health risk assessment. For example, the Web page provides information 

on the micrograms per kilogram (μg/kg) of arsenic and benzo(a)pyrene in 

the sediment at one sampling site. Accompanying text indicates whether 

the detected levels were above or below the “LDEQ RECAP value” and 

states that in cases where they exceeded the RECAP value, “the levels fall 

within EPA’s risk range of 1 in 1,000,000 to 1 in 10,000 risk of an individual 

developing cancer over a lifetime from exposure to those concentrations in 

residential soils.” Although we believe that posting data on the individual 

samples on EPA’s Web site was not a particularly effective tool for 

communicating information to residents about potential health risks and 

mitigation strategies, we agree with EPA’s Inspector General that EPA’s 

posting of information on sediment contamination on its Web page 

provided timely information to the states and other federal decision makers 

for use in determining associated risk and impact assessment.49

49EPA Office of Inspector General, EPA Provided Quality and Timely Information on 

Hurricane Katrina Hazardous Material Releases and Debris Management, Report No. 

2006-P-00023 (Washington, D.C., May 2, 2006).
Page 37 GAO-07-651 Hurricane Katrina

Some Information EPA 

Provided to Residents in Its 

Public Service 

Communications Was 

Unclear and Inconsistent

Although EPA did not perform environmental assessments of any flooded 

homes in New Orleans, it did provide information to residents based on 

general knowledge and assumptions about potential environmental health 

risks inside buildings following disasters. Specifically, EPA relied on flyers, 

public service announcements, and EPA’s Web site to provide information 

on the potential health risks in buildings stemming from exposure to, for 

example, asbestos, lead, and mold—three contaminants that were of 

concern to EPA and other officials immediately after the hurricanes. While 

the flyers, public service announcements, and documents on EPA’s 

hurricane Web page provide information on mitigating exposure to these 

contaminants, some information lacks clarity and consistency on certain 

key points.50 For example, EPA’s most widely distributed flyer on 

environmental health risks—EPA and Louisiana Department of 

Environmental Quality Warn of Potential Environmental Health 

Hazards When Returning to Homes and Businesses51—states that 

buildings constructed before 1970 are likely to contain asbestos, including 

pipe and other insulation, ceiling tiles, exterior siding, and roof shingles. In 

contrast, another document available on EPA’s hurricane Web page, 

Dealing with Debris and Damaged Buildings, states that all structures 

built before 1975 may contain significant amounts of asbestos, and 

structures built after 1975 may also contain asbestos. Further, in 

developing estimates of the number of homes that may contain asbestos, 

the Louisiana Department of Environmental Quality included homes built 

before 1980 as those likely to contain asbestos.52 Accurate and consistent 

information about the age of buildings that are most likely to contain 

asbestos is important in helping residents understand what protections 

they may need when entering and working in their homes. 

In addition, EPA’s flyer on potential environmental health hazards 

recommends seeking assistance from public health authorities and 

specially trained contractors, if possible, when a resident knows or 

50EPA’s hurricane Web page, “Response to 2005 Hurricanes,” is still accessible on EPA’s Web 

site using a search function, but it is no longer highlighted on EPA’s home page.

51In August 2006, EPA reported that more than 1.3 million of these flyers had been 

distributed, as had about 900,000 flyers on mold problems.

52This date is consistent with other sources we reviewed that indicate that any building 

constructed before 1980 can be presumed to contain asbestos. See “Asbestos: A Legal 

Primer for Air Force Installation Attorneys,” Air Force Law Review (2004); and “Asbestos in 

Construction Hazard Alert,” The Center to Protect Workers’ Rights (2004).
Page 38 GAO-07-651 Hurricane Katrina

suspects that asbestos or lead-based paint may be in the home and these 

materials have been damaged or will be disturbed during cleanup. 

However, the flyer does not contain the following more strongly worded 

guidance from the Frequent Questions document on EPA’s hurricane Web 

page: “Before you begin your cleanup, seek help from public health 

authorities and specially trained contractors. Although conditions 

following a hurricane may make it difficult to obtain such assistance, EPA 

strongly advises against individuals attempting to handle such materials 

themselves.” 

Both the flyer and the Frequent Questions document then list a number of 

steps individuals should take when handling this debris. However, the 

information provided on the hurricane Web page regarding respiratory 

protection that individuals should wear is more clear and useful than the 

information in the widely distributed flyer on potential environmental 

health hazards and in the relevant EPA public service announcement. 

Specifically, the flyer states, “In handling materials that are believed to be 

contaminated with asbestos or lead, EPA recommends that, at a minimum, 

you wear gloves, goggles, and most importantly, OSHA-approved 

respiratory protection, if available.” The public service announcement 

recommends wearing “gloves, goggles, and a face mask.” The information 

on EPA’s hurricane Web page, however, is more specific about what 

respiratory protection is required, where it can be purchased, and the 

importance of wearing it: “Wear gloves, goggles, pants, shirts, socks, and 

most importantly, a tightly-fitted N-95 OSHA-approved respiratory mask. A 

regular ‘dust mask’ is not enough to protect against lead or asbestos. N-95 

masks are available at minimal cost at the hardware store. Carefully follow 

instructions when using a respiratory mask to make sure it fits correctly. A 

tight fit is important, and despite the heat, it is the best way to protect 

yourself.”

However, a safety step EPA recommended on its hurricane Web page that 

many individuals were not likely to have been able to perform was to 

determine if asbestos-containing products—specifically, asbestos-cement 

corrugated sheet, asbestos-cement flat sheet, asbestos pipeline wrap, 

roofing felt, vinyl-asbestos floor tile, asbestos-cement shingle, millboard, 

asbestos-cement pipe, and vermiculate-attic insulation—were present in 

their damaged homes. How individuals would determine if these asbestoscontaining products were present is not clear, as another EPA document 

(available on the general EPA Web site but not cited in either the flyer for 

residents or the Frequent Questions document) states that unless they are 

labeled, materials containing asbestos cannot be identified by visual 
Page 39 GAO-07-651 Hurricane Katrina

inspection. This document further cautions readers to treat the material as 

if it contained asbestos when in doubt or have it sampled and analyzed by a 

qualified professional. 

Some communications about exposures to mold also were not sufficiently 

clear or consistent to be helpful to residents whose homes had been 

flooded. For example, a flyer distributed to many residents specifically 

addressing mold is more focused on urging people to clean up than on 

providing information on how to protect themselves while doing so. The 

flyer, Cleaning Up After a Flood: Addressing Mold Problems, gives this 

general safety advice: “Take precautions to limit your exposure to mold and 

mold spores when attempting to clean up mold. If you have health 

concerns, you may want to have someone else clean up the mold.” Yet this 

flyer does not explain what precautions to take. Moreover, the flyer urges 

residents to act quickly to remove materials contaminated with mold and 

bacteria, explaining that these contaminants can trigger allergic reactions 

and induce respiratory infections. For “more specific information on mold,” 

the flyer refers readers to EPA’s Indoor Air Quality Hotline, EPA and CDC 

Web sites, and two documents available on EPA’s Web page (one 

addressing mold in schools and commercial buildings and the other 

addressing mold in homes). The document that addresses mold in homes 

includes the following somewhat tentative guidance: “In order to limit your 

exposure to airborne mold, you may want to wear an N-95 respirator, 

available at many hardware stores and from companies that advertise on 

the Internet....” However, other information on EPA’s general Web site that 

is not specifically cited in the flyer less ambiguously recommends wearing 

an N-95 respirator. Specifically, Flood Cleanup and the Air in Your Home

says to wear an “N-95 respirator” over the mouth and nose to avoid 

breathing in mold. This publication further explains that a dust mask or 

handkerchief does not provide protection from mold because it can pass 

through them. In contrast, EPA’s flyer on potential environmental health 

hazards advises readers to wear “an N-95 respirator, if available, or a dust 

mask” when, for example, cleaning significant areas of mold 

contamination.

Importantly, as of March 2007, none of EPA’s communications, including its 

hurricane Web page, were updated to highlight comprehensive information 

on mold exposure released by CDC on June 9, 2006. Specifically, CDC’s 

report Mold Prevention Strategies and Possible Health Effects in the 

Aftermath of Hurricanes and Major Floods includes population-specific 

recommendations for protection from exposure to mold in buildings after 
Page 40 GAO-07-651 Hurricane Katrina

hurricanes and major floods.53 For example, CDC states that healthy 

individuals do not need to take special precautions for exposure to mold in 

buildings after hurricanes when they are observing from outside or simply 

inspecting or assessing damage. However, if healthy individuals are 

recovering moldy personal belongings (thereby disturbing some dust or 

mold), CDC recommends that they wear respiratory protection (N-95 

filtering face pieces), gloves, and dermal protection. This report also 

identifies individuals who should avoid specific activities (inspecting, 

recovering belongings, sweeping, etc.) and specifies the protection they 

should have to conduct the activities. For example, pregnant women and 

those over the age of 65 may recover personal belongings wearing 

respiratory protection, dermal protection, and eye protection but are to 

avoid any sweeping or cleaning activities. Individuals with “profound 

immunosuppression”—such as those with HIV infection—are to avoid all 

exposures, while those with “immunosuppression”—such as those in 

cancer treatment—or those with lung disease can conduct some specified 

activities with recommended protective gear.

In addition, some information in EPA’s December 2005 environmental 

assessment summary was inconsistent. For example, according to the 

summary, it does not address indoor environmental issues associated with 

re-entry into flooded homes and structures. However, the following excerpt 

from the conclusions section of the summary appears to contradict this 

statement:

Good personal hygiene should be practiced with frequent hand washing, laundering of 

clothing, and cleaning of the homes (i.e. vacuuming, dusting, etc.). Efforts should be made 

to avoid tracking sediments into homes from un-vegetated or uncovered areas as well as 

stirring up dust from those same areas. Obvious signs of hazardous material or oil spillage 

should be avoided and reported, as well.

This guidance does not acknowledge that sediments and contaminants may 

have been washed into or spilled inside structures as a result of flooding. 

Thus, the detailed guidance the summary provides for working outdoors, 

which may also be applicable for working inside homes, is not 

recommended for working indoors. Specifically, the December assessment 

summary provides the following “good personal hygiene” guidance for 

those working with or near exposed sediments outdoors:

• “Wear gloves, boots, and safety glasses.

53CDC, Morbidity and Mortality Weekly Report, 55(RR08); 1-27 (June 9, 2006).
Page 41 GAO-07-651 Hurricane Katrina

• Wear a dust mask (an N-95 dust mask is recommended and can be 

purchased at your local pharmacy or building supply stores).

• Keep arms and legs covered. Wear long sleeves and long pants.

• Wash hands frequently with soap and water.

• Wash work clothes separate from other laundry.”

In general, EPA’s communications recommend wearing some sort of 

respiratory protection as a key step in mitigating potential health effects of 

exposure to sediments and three contaminants—asbestos, lead, and 

mold—likely to be present in many homes damaged by the 2005 Gulf Coast 

hurricanes. However, EPA refers to this protection inconsistently and with 

varying levels of specificity:

• “a face mask”; 

• “N-95 masks”;

• “OSHA-approved respiratory protection”;

• “a dust mask (an N-95 dust mask is recommended...)”;

• “an N-95 respirator, if available, or a dust mask”; and

• “a tightly fitted N-95 OSHA-approved respiratory mask—a regular ‘dust 

mask’ is not enough to protect against lead or asbestos.” 

These varying terms are confusing and could result in an insufficiently 

protective choice. For example, “OHSA-approved respiratory protection” is 

not a common term or household item, and people might not understand 

what to look for and where to find it. Moreover, the federal agency that 

approves respirators to protect against a variety of hazards is the National 

Institute for Occupational Safety and Health (NIOSH). Thus, respirators 

approved by NIOSH that are available for purchase will be labeled as in 
Page 42 GAO-07-651 Hurricane Katrina

compliance with specified NIOSH requirements.54 Further, it is not clear 

what a “face mask” is, and “dust masks” and “dust respirators” vary widely 

in terms of the respiratory protection they provide. That is, dust masks can 

provide some protection to the lungs from the irritating effects of nontoxic 

dust and airborne particles such as pollen, common household dust, and 

cut grass, but they are not protective against mold spores or toxic dusts. 

Given the number and variety of dust masks and respirators that are 

available and that provide varying levels of protection, EPA’s 

communications would be more useful if they clearly and consistently 

named and described the type of respiratory protection the agency is 

recommending for the specific exposures being addressed. 

EPA Faced Challenges 

in Assessing and 

Mitigating Some 

Environmental Impacts 

of the Gulf Coast 

Hurricanes

EPA did not remove clearly visible abandoned chemical drums and tanks 

from several national wildlife refuges in Louisiana as part of its Katrina 

response activities, in part because FEMA disaster assistance funding 

generally is not used for debris cleanups on federal land. As a result, more 

than a year later, debris containing hazardous materials continued to pose 

an environmental threat to natural resources at several refuges. In addition, 

EPA’s guidance to states on making some emergency debris disposal 

decisions is limited, and the agency has a limited debris management role 

under the National Response Plan and federal law. Finally, because of a 

lack of clarity in the National Response Plan and the absence of 

interagency protocols about federal roles in debris management, EPA, in 

the immediate aftermath of the storms, could not ensure that debris such 

as white goods and electronic waste was handled in a timely and 

appropriate manner that mitigated the potential for environmental 

contamination. 

Funding Issues Delayed 

Cleanups at National 

Wildlife Refuges for More 

Than a Year

In 2005, Hurricanes Katrina and Rita caused debris containing hazardous 

materials to be released into several national wildlife refuges in Louisiana, 

posing an environmental threat to natural resources and requiring that 

some refuges be closed to the public because of safety issues. Under the 

National Response Plan, EPA is to take appropriate actions to prevent, 

minimize, or mitigate a threat to public health, welfare, or the 

54Respirator labels may cite compliance with both NIOSH and OSHA requirements. OSHA 

regulations require certain employers to have respiratory protection programs to protect 

employees against workplace hazards. A requirement of the programs is the selection of 

appropriate respirators approved by NIOSH.
Page 43 GAO-07-651 Hurricane Katrina

environment—including the protection of natural resources—caused by 

actual or potential oil and hazardous materials incidents.55 As EPA and 

contractor responders worked to clean up releases of oil and hazardous 

materials in areas adjacent to several national wildlife refuges using 

disaster assistance funding authorized by FEMA, they identified clearly 

visible abandoned drums and tanks on the federal lands, and they could 

have efficiently removed them. However, FEMA did not approve the 

Department of the Interior’s request for funding to clean up this debris in 

part because it was on federal lands. Consequently, EPA did not remove 

clearly visible abandoned chemical drums and tanks from national wildlife 

refutes in Louisiana as part of its hurricane response activities because 

disaster assistance funding was unavailable for debris cleanup actions on 

these federal lands. According to FEMA officials relying on the agency’s 

regulations and debris management guidance, federal agencies are 

responsible for their own property, and FEMA does not have authority to 

provide assistance to federal agencies for debris removal following 

disasters unless the debris constitutes an immediate threat to life, public 

health, and safety. 

According to Fish and Wildlife Service officials, in the fall of 2006—a year 

after the hurricanes—chemical drums and tanks remained in the Sabine 

and Cameron Prairie refuges in western Louisiana and may also have 

remained at the Bayou Sauvage and Big Branch Marsh refuges in the New 

Orleans area in eastern Louisiana. For example, a January 2006 study 

conducted for the Fish and Wildlife Service estimated that about 1,400 

containers—potentially holding a total of between 115,000 and 350,000 

gallons of hazardous liquids and gases—were at the Sabine National 

Wildlife refuge, a 125,000-acre refuge that consists almost entirely of 

marshland and open water. The study identified hazardous materials in 

containers ranging in size from 35-gallon drums to 10,000-gallon liquid 

storage tanks. 

According to Fish and Wildlife officials, leaving this debris in place for 

about a year caused containers holding hazardous materials to settle into 

marshlands and begin to corrode and leak. For example, officials said that 

after a chemical sheen was observed on the water during a flight over a 

55The National Response Plan directs the Departments of Agriculture and the Interior, which 

are responsible for incidents affecting agriculture and natural resources, to coordinate with 

EPA and other oil and hazardous materials response partners on the removal of debris 

affecting natural and cultural resources.
Page 44 GAO-07-651 Hurricane Katrina

refuge in August 2006, a hazardous materials team found a leaking 55-

gallon drum containing hydraulic fluid. Also in August 2006, a fire in the Big 

Branch Marsh refuge spread over 120 acres, reaching a debris field with 

propane and other hazardous material containers. When containers began 

exploding, firefighters had to let the fire burn through the field because it 

was too dangerous for them to attempt to put the fire out. 

In addition to presenting safety concerns to responders cleaning up the 

debris, the delay in removing the debris complicated the required cleanup 

efforts and increased the cost of removal. Fish and Wildlife officials said 

that many containers were 2 or 3 feet under water, requiring excavation 

using heavy equipment. While smaller materials can be removed by hand, 

specialized equipment such as airboats, sleds or skids, and amphibious 

marsh vehicles are required to remove larger containers to minimize 

adverse effects to the marsh. Such excavations are costly and could 

damage sensitive marshy areas, which could have been avoided if drums 

and tanks had been removed expeditiously. In addition, Fish and Wildlife 

officials said that cleanup crews may not be able to locate all of the 

containers that have sunk into marshlands until the containers begin 

leaking, which could take several years.

According to the Fish and Wildlife Service, Sabine and other national 

wildlife refuges are important to the long-term recovery of Louisiana 

coastal communities because of the tourism they generate. For example, 

prior to being closed in 2005 because of safety concerns related to the 

debris from Hurricane Rita, the Sabine refuge, a principal component of the 

Creole Nature Trail All-American Road, a National Scenic Byway, and an 

All-American Road designated by the Federal Highway Administration, 

helped attract about 300,000 visitors each year. The Sabine refuge’s 125,000 

acres are home to concentrations of ducks, geese, alligators, muskrats, 

nutria, raptors, and other wildlife. Visitors to the refuge have opportunities 

to observe wildlife and have access to a wetland walkway and a visitors 

center; recreational options include boating, fishing, and hunting. 

According to a Fish and Wildlife official, previous hurricanes in other Gulf 

states have not affected national wildlife refuges as severely as the 

hazardous material debris impacts of Hurricanes Katrina and Rita on 

Louisiana’s refuges. Consequently, he said that Fish and Wildlife has not 

sought funding for hazardous material debris removal under the Stafford 

Act following other hurricanes in recent years. Because disaster assistance 

funding from FEMA was not available for cleaning up hazardous materials 

on these federal lands following Hurricanes Katrina and Rita, Interior’s Fish 
Page 45 GAO-07-651 Hurricane Katrina

and Wildlife Service sought appropriations for this activity, which the 

agency received as part of a June 2006 supplemental appropriation for 

disaster response activities.56 The Fish and Wildlife Service allocated $12 

million for the cleanup of the Sabine refuge and $8 million for the other 

refuges. The agency received this appropriation 8 months after EPA’s 

cleanup of the adjacent area under the National Response Plan. In addition, 

EPA and the Fish and Wildlife Service do not have a protocol for 

expeditiously handling circumstances such as cleanup of national wildlife 

refuges following disasters, and developing interagency agreements with 

EPA and the Coast Guard for the cleanups required time and resulted in 

further delays.

In September 2006, Fish and Wildlife signed agreements with EPA and the 

Coast Guard to obtain these agencies’ assistance in cleaning up the Sabine 

refuge. Subsequently, EPA provided the incident commander for the team 

that oversaw the hazardous materials recovery and debris cleanup in the 

Sabine and Cameron Prairie refuges in Cameron Parish, Louisiana, while 

the Coast Guard provided the deputy incident commander and other 

support. The project was completed in January 2007. While the Fish and 

Wildlife Service had estimated that about 1,400 containers potentially filled 

with hazardous liquids and gases had been deposited into the refuge, about 

2,200 such containers were found and removed, along with several 

thousand household hazardous waste items, tires, batteries, munitions, and 

white goods. Fish and Wildlife estimated that cleanup at Bayou Sauvage 

and Big Branch Marsh would be completed by May 2007.

56The Fish and Wildlife Service also considered requesting EPA cleanup assistance under the 

Superfund law, the Clean Water Act, and the Oil Pollution Act. In a draft 2006 letter to EPA, 

the Fish and Wildlife regional director stated that these authorities extended to the cleanup 

needed on the refuges because the debris was deposited on these lands by the hurricanes, 

not because of any action on the part of Fish and Wildlife. While Fish and Wildlife worked 

with EPA to draft a letter requesting EPA assistance under the Superfund law, the request 

was never sent to EPA. Under this law, the Superfund is generally unavailable at federal 

facilities. Funds from the Superfund may be used to pay for removal actions on federal lands 

at EPA’s discretion but must be reimbursed by the relevant federal agency.
Page 46 GAO-07-651 Hurricane Katrina

EPA Has a Limited Debris 

Management Role under 

Federal Law and the 

National Response Plan, and 

Its Guidance to States on 

Making Certain Emergency 

Debris Disposal Decisions Is 

Limited

EPA’s 1995 guide on planning for disposal of disaster debris acknowledges 

that disaster debris can overwhelm existing landfills—solid waste 

management facilities—or force communities to use disposal options that 

otherwise would not be acceptable.57 The guide also notes that state waste 

management agencies can make special accommodations for the unusual 

waste management needs resulting from a disaster, such as temporarily 

lifting permit requirements for landfills. However, the guide does not 

provide specific guidance on the selection of emergency landfill sites or 

practices that state agencies should consider when making special debris 

disposal accommodations following disasters.

In addition, as set forth in the Stafford Act and other executive policy, EPA 

and other federal agencies generally provide disaster assistance at the 

request of state or local governments.58 Along these lines, when the 

National Response Plan is activated in response to a Stafford Act major 

disaster such as Hurricane Katrina, EPA’s role regarding waste disposal is 

to provide assistance requested by a state. For example, EPA may supply 

environmental scientists and engineers to assess landfills, help locate 

disposal sites for debris clearance activities, and assist with contaminated 

debris management activities.59 EPA’s support may also include providing 

technical assistance and consultation to the Department of Health and 

Human Services on solid waste disposal issues related to public health 

effects.60

Further, the Resource Conservation and Recovery Act (RCRA), the federal 

law addressing the management of hazardous and other solid wastes, 

addresses nonhazardous solid wastes under subtitle D. According to 

subtitle D, states have primary responsibility for permitting and monitoring 

solid waste disposal facilities (generally referred to as landfills) and 

57EPA Office of Solid Waste and Emergency Response, Planning for Disaster Debris

(December 1995).

58See 42 U.S.C. § 5170 et seq.; Homeland Security Presidential Directive 5 (Feb. 28, 2003).

59EPA provides this support to the U.S. Army Corps of Engineers, the federal coordinator for 

the public works and engineering emergency support function, which addresses debris 

removal and disposal, among other things.

60EPA provides this support under the public health and medical services emergency 

support function, which is coordinated by the Department of Health and Human Services. 

The department, in coordination with EPA’s oil and hazardous materials response, may 

request this support from agencies such as EPA.
Page 47 GAO-07-651 Hurricane Katrina

developing solid waste management plans in accordance with minimum 

federal requirements.61 EPA regulations establish criteria for classifying 

different types of landfills and practices that may result in adverse effects 

on health or the environment, among other things. The act prohibits “open 

dumping”—the disposal of solid waste in landfills failing to meet the 

relevant criteria—and requires state plans to prohibit the establishment of 

open dumps. RCRA provides EPA with limited authority to address 

environmental problems at solid waste landfills. 

Solid waste landfills may generally receive household waste (garbage), 

industrial waste (solid waste generated by manufacturing, industrial, or 

mining processes), commercial nonhazardous waste (solid waste 

generated by stores, offices, restaurants, and other nonmanufacturing 

entities), and construction and demolition (C&D) waste (nonhazardous 

waste that is not water soluble, such as metal, concrete, and asphalt). 

Under Louisiana solid waste regulations, landfills that receive household 

waste, industrial waste, or commercial nonhazardous waste must have 

safeguards that include a liner designed to control groundwater 

contamination.62 The regulations do not require C&D landfills to have liners 

in place.63 Louisiana regulations exclude asbestos-contaminated waste, 

white goods, furniture, trash, and treated lumber from the categories of 

debris that may be disposed of at C&D landfills. 

Because EPA’s debris management role is limited under federal law and the 

National Response Plan, its guidance to states and localities on planning 

for disposal of disaster debris could be especially important in helping 

ensure that hazardous materials are disposed of in landfills with 

appropriate safeguards when disposal options that would not otherwise be 

acceptable are used for disaster debris, thereby preventing contaminants 

from migrating and causing air, water, and soil contamination. Such 

guidance could help states and localities consider the potential 

61While EPA may review approved state subtitle D permit programs and withdraw approval 

of state programs it determines do not meet the national minimum requirements, EPA 

officials told us the agency has never withdrawn approval of a state subtitle D permit 

program.

62These landfills are designated as Type I or II facilities under Louisiana solid waste 

regulations. These facilities must have a composite liner that consists of a geomembrane 

liner at least 30-mil thick installed directly above and in uniform contact with a 3-foot 

recompacted clay liner.

63These landfills are designated as Type III facilities under Louisiana solid waste regulations.
Page 48 GAO-07-651 Hurricane Katrina

environmental impacts of debris management accommodations that may 

be made in emergency situations if affected areas are to be cleared of 

debris without causing adverse public health effects in the future. One 

potential example of a prior problem with hurricane debris is the 

Agriculture Street Superfund site in New Orleans, which was a municipal 

landfill from about 1909 until the late 1950s. During this period, oil was 

used to burn the refuse at the dump, and during the 1940s and 1950s the 

area was routinely sprayed with DDT. The landfill was reopened after 

Hurricane Betsy occurred in 1965 to receive debris from destroyed 

buildings and ash from municipal incinerators. In the 1970s and continuing 

into the late 1980s, portions of the site were developed with private and 

public housing units, an elementary school, and a community center. 

Following health concerns among residents in the area, EPA initiated 

investigations at the site in 1986, ultimately identifying elevated levels of 

lead, arsenic, and carcinogenic polycyclic aromatic hydrocarbons—the 

primary contaminants of concern identified in sediment tests following 

Hurricane Katrina. Analyses of the health effects of these contaminants 

found at the Agriculture Street Landfill led EPA to place the site on the 

Superfund National Priorities List in 1994. Cleanup of the site, which 

primarily entailed soil excavation, placement of clean cover and soil, and 

resodding, was completed in 2001.64 As part of litigation involving EPA 

efforts to recover its cleanup costs at the site, some private parties have 

argued that the debris disposed of at the Agriculture Street Landfill in the 

wake of Hurricane Betsy contained hazardous substances that contributed 

to the contamination at the site.65 EPA officials told us that after years of 

case development research and discovery the agency has no evidence that 

hazardous substances were disposed of at the Agriculture Street Landfill 

during the Hurricane Betsy response. The case is pending, and settlement 

negotiations are under way. 

As the entity with primary responsibility for solid waste disposal under 

RCRA subtitle D, the Louisiana Department of Environmental Quality has 

made decisions about landfills and the disposal of debris that some studies 

suggest could have long-term, negative environmental impacts. For 

example, under a November 2005 Louisiana Department of Environmental 

64Soil samples collected at the Agriculture Street Landfill site following Hurricane Katrina 

revealed elevated levels of benzo(a)pyrene, a polycyclic aromatic hydrocarbon. EPA and 

local authorities are developing a plan to address this contamination.

65United States v. City of New Orleans, et al, Civil Action No. 02-3618, Section E, Magistrate 

3 (E.D. La.).
Page 49 GAO-07-651 Hurricane Katrina

Quality amendment to an emergency order addressing Hurricane Katrina 

and its aftermath, the types of debris that C&D landfills could receive were 

broadened to include some potentially hazardous wastes, including 

furniture, painted or stained lumber from demolished buildings, and 

asbestos-contaminated waste that cannot be extracted from demolition 

debris.66 The order states that this and other actions were taken because 

Hurricane Katrina created conditions that require immediate action to 

prevent irreparable damage to the environment and serious threats to life 

or safety. A Louisiana Department of Environmental Quality official told us 

that the department elected to include these categories of waste because 

separating this waste from other debris took considerable effort, and the 

department determined the environmental risks resulting from the 

expanded definition were minimal. The official also noted that the 

expanded definition allowed this waste to be cleaned up more quickly, 

enabling residents to return home. 

However, a draft 1995 study prepared for EPA identifies a number of the 

debris components being allowed at C&D landfills under the emergency 

order—including asbestos insulation and shingles, furniture, and wood 

paints and stains—as “problematic,” even though these materials are not 

necessarily classified as hazardous wastes under RCRA.67 Moreover, 

studies by a Louisiana State University research institute and an 

environmental engineering firm state that these categories of waste can 

introduce hazardous materials into landfills, increasing the likelihood of 

pollution.68 For example, wood treated with chromated copper arsenate as 

a preservative can leach arsenic, which can cause problems with 

circulatory systems and may increase cancer risk if ingested. Chromated 

copper arsenate is often used to prevent termite infestation in areas where 

termites are prevalent, such as New Orleans. Lumber with lead paint also 

poses health hazards. Lead poisoning in children can cause learning 

66State of Louisiana Department of Environmental Quality, Second Amended Declaration of 

Emergency and Administrative Order regarding Hurricane Katrina and Its Aftermath (Nov. 

2, 2005). The Louisiana Department of Environmental Quality extended the emergency 

order several times, most recently extending the broadened definition through May 18, 2007.

67ICF Inc., Construction and Demolition Waste Landfills (draft document prepared for the 

EPA Office of Solid Waste, 1995). 

68G.F. Lee, Summary of Findings on the Environmental Impacts of the Proposed C&D 

Landfill on Top of the Closed Gentilly Landfill (February 2006); and John H. Pardue, 

Director, Louisiana Water Resources Research Institute, Louisiana State University, 

Anticipating environmental problems facing hurricane debris landfills in New Orleans 

East (undated).
Page 50 GAO-07-651 Hurricane Katrina

disabilities, impaired hearing, and behavioral problems, and in pregnant 

women, it can result in adverse developmental effects to fetuses. Even 

before Hurricane Katrina struck, concentrations of lead as much as 10 

times EPA’s screening level were detected in soil samples taken in New 

Orleans. In addition, some household furniture is treated with fire 

retardants containing polybrominated diphenyl ethers, carcinogens that 

have been found as environmental pollutants accumulating in human 

breast milk and wildlife. 

The inclusion of asbestos-contaminated waste mixed with other debris in 

the state’s expanded definition of C&D debris may also present a potential 

health hazard. As we previously noted, asbestos exposure has been 

recognized for many years as causing serious human health problems. 

Moreover, the requirements of the Clean Air Act’s asbestos work practice 

standard generally do not apply to residential buildings with four or fewer 

units, and unregulated asbestos-containing material may be disposed of in 

C&D landfills.69 The extensive renovation and demolition activities in New 

Orleans create the potential for large quantities of asbestos-contaminated 

waste to enter C&D landfills.

Furthermore, while white goods and household hazardous waste may 

generally not be disposed of at C&D landfills, until recently the emergency 

order stated that such wastes should be segregated from other solid waste 

prior to disposal in C&D landfills except in cases where segregation is not 

practicable. The order did not specifically state what must happen in cases 

where segregation is not practicable. Environmental groups filed a lawsuit 

against Louisiana in August 2006 alleging that the state’s order authorizes 

the disposal of white goods and household hazardous waste in landfills that 

do not meet RCRA criteria for these types of debris and, therefore, that the 

state has authorized “open dumping” of potentially dangerous solid wastes 

in violation of RCRA’s prohibition on such dumping.70 The state contends 

that the order does not authorize any practices that violate RCRA and, 

69Louisiana also authorized some landfills in the New Orleans area to operate as “enhanced” 

C&D landfills that may receive regulated asbestos-containing material as well as 

unregulated material. These facilities are required to have additional controls in place, such 

as air monitoring for asbestos emissions. According to the Louisiana Department of 

Environmental Quality, these landfills meet the landfill requirements under the federal 

asbestos standard (40 C.F.R. § 61.154).

70The lawsuit further alleges that because the emergency orders conflict with RCRA’s open 

dumping prohibition, the state’s issuance and implementation of the orders violates the 

Supremacy Clause in Article VI of the U.S. Constitution.
Page 51 GAO-07-651 Hurricane Katrina

accordingly, that the groups’ suit is without merit. EPA is currently 

mediating settlement negotiations between the parties. On January 19, 

2007, the Louisiana Department of Environmental Quality issued an 

amended emergency order that, among other things, deleted the phrase 

“where segregation is not practicable.”

In addition, the Louisiana Department of Environmental Quality authorized 

the controversial use of two landfills to receive C&D waste in locations of 

concern to nearby communities and environmental organizations. 

Specifically, pursuant to its Katrina emergency authorities, the Louisiana 

Department of Environmental Quality authorized (1) the utilization of an 

existing C&D landfill in proximity to hurricane-devastated areas in New 

Orleans called the Gentilly Landfill and (2) the construction and operation 

of the Chef Menteur landfill, located near a minority residential community 

and a national wildlife refuge.71 Studies conducted by an environmental 

engineering firm and Louisiana State University raised concerns about 

debris disposal at the Gentilly and Chef Menteur landfills, citing possible 

surface water and groundwater implications from potentially hazardous 

storm debris. These studies suggest that debris disposal in landfills without 

appropriate safeguards could result in the migration of contaminants, 

potentially causing pollution and affecting public health and the 

environment.72 For example, the studies identified concerns about the 

potential discharge of leachate (water that has come into contact with 

waste) into water—in the case of Gentilly, into groundwater and surface 

water, and in the case of Chef Menteur, into surrounding wetlands. In both 

cases, concerned groups filed lawsuits. The Gentilly suit was settled, with 

the Louisiana Department of Environmental Quality agreeing to limit the 

amount of debris entering the landfill daily. In the case of Chef Menteur, an 

environmental group alleged that proper procedures had not been followed 

in issuing an emergency authorization for the landfill under the Clean Water 

71The Louisiana Department of Environmental Quality issued a permit to conduct 

construction and demolition waste disposal to the Gentilly Landfill in 2004 and an Order to 

Authorize Commencement of Operations on August 29, 2005. However, according to the 

Louisiana Department of Environmental Quality, following the litigation related to a lawsuit 

against the Louisiana Department of Environmental Quality, “It became apparent that 

although the decision to use the Gentilly landfill was properly based upon the Louisiana 

Department of Environmental Quality’s emergency authority under the Louisiana 

Environmental Quality Act, this authority and the underlying reasoning for arriving at that 

decision was not clearly reflected in the Order.” Therefore, the order was revoked and an 

administrative order and decision were issued authorizing use of the landfill pursuant to 

state law and the Hurricane Katrina emergency order. 

72See footnote 68.
Page 52 GAO-07-651 Hurricane Katrina

Act—in particular, that the public had not been provided notice and the 

opportunity to comment on the action.73

In authorizing the use of the Gentilly landfill under the Hurricane Katrina 

emergency order, the Louisiana Department of Environmental Quality 

stated that it had considered alternative sites and determined that the 

Gentilly site met state solid waste requirements and was located in 

proximity to the bulk of the hurricane-generated C&D debris. The 

department further noted that allowing debris disposal at Gentilly would 

decrease waste-hauling time and expense and alleviate traffic problems, 

thereby aiding New Orleans’ recovery. In addition, although the Chef 

Menteur site faced opposition, the Louisiana Department of Environmental 

Quality maintained that it was environmentally suitable, citing independent 

sampling of air and water quality in May and June of 2006. The air results 

found no contaminants at or above health risk levels, while the water 

quality results showed that the contaminants tested for fell within the daily 

maximum limits of the site’s discharge permit, though ammonia was 

detected above the monthly average discharge limit. Furthermore, the 

Louisiana Department of Environmental Quality underscored the 

importance of the centrally located landfill to disaster cleanup in Orleans 

Parish.

EPA’s review of the Gentilly site following its authorization to receive 

Hurricane Katrina debris found that current use of the landfill appeared to 

be consistent with the types and volumes of wastes for which it was 

designed and permitted by the state, but noted that there is no way to 

insulate the federal government against future Superfund liability 

absolutely. EPA recommended steps that Gentilly operators should take to 

minimize risks, including posting signs, developing debris inspection and 

segregation procedures, and working with the Louisiana Department of 

Environmental Quality on groundwater monitoring. EPA officials told us 

the agency worked with the Department of Environmental Quality to 

develop a process for reviewing key technical areas of concern at the 

Gentilly site, and EPA officials said that the Louisiana Department of 

Environmental Quality has put effective measures in place to address these 

areas of concern. In May 2007, EPA said that the Gentilly landfill operator 

installed groundwater monitoring wells and inclinometers at the Gentilly 

73This lawsuit was dismissed by the court 2 days after the landfill was closed on August 14, 

2006, when, as is discussed later in this report, the local order authorizing the zoning of the 

landfill expired and was not renewed.
Page 53 GAO-07-651 Hurricane Katrina

site and reported that the environmental samples “do not indicate any 

problem.” The newly constructed Chef Menteur landfill continued to 

generate considerable controversy, and the Mayor of New Orleans allowed 

the local order authorizing the zoning of the landfill to expire on August 14, 

2006—closing it 4 months after it opened.

While EPA provided consultations to the Louisiana Department of 

Environmental Quality on some landfill decisions, under the National 

Response Plan and RCRA, the agency does not have a formal role in this 

decision making. Further, EPA did not review or approve state decisions 

regarding the use of the Gentilly or Chef Menteur landfills. However, at the 

request of the state, EPA did provide technical support and conducted 

some oversight activities at New Orleans area landfills to supplement 

existing controls at landfills.74 Specifically, EPA took steps to promote the 

segregation of debris before it entered landfills, such as organizing 

hazardous waste collection events. At the request of the Louisiana 

Department of Environmental Quality, EPA also began sending landfill 

observers to about 12 landfills in the New Orleans area in February 2006.75

EPA’s landfill observers usually visited landfills unannounced and 

documented that they were generally operating appropriately—with 

entrance tower monitors and dump-site spotters in place, record keeping 

on violations, and financial and other documentation in order—and 

prepared and transmitted a report to the Louisiana Department of 

Environmental Quality citing any problems.76 EPA officials told us the 

problems observers identified were minor, such as excessive dust on roads 

or instances of debris segregation not taking place. Moreover, EPA officials 

believe that work practices at the landfills, such as periodic covering, 

mitigate the potential migration of specific materials from the landfills. 

However, the officials also noted that while EPA’s limited oversight 

74According to the Louisiana Department of Environmental Quality, landfills were subject to 

several controls intended to minimize hazardous waste disposal, including monitoring at 

entrance towers and debris dump sites. In addition, daily inspections by department 

officials at five construction and demolition landfills in the New Orleans area, an increase 

from twice-weekly inspections, were conducted in May and June 2006.

75According to EPA, as of December 2006, EPA landfill observers were observing at seven 

landfills, the reduced number reflecting the fact that some landfills are no longer receiving 

hurricane-related debris.

76EPA landfill observers also visited landfill sites in Mississippi from October 2005 to June 

2006.
Page 54 GAO-07-651 Hurricane Katrina

provided assistance to the state, it did not allow the agency to ensure that 

debris containing hazardous materials would not enter landfills.

Finally, detailed guidance from EPA to the states on advance planning for 

potential emergency landfill sites and practices to consider when making 

special debris disposal accommodations following disasters might have 

helped Louisiana avoid some of the controversies and lawsuits it faced as a 

result of its emergency debris management decisions in New Orleans. 

Along these lines, after reviewing its Hurricane Katrina response actions in 

Mississippi, EPA’s Region 4 identified helping states with hurricane-prone 

coastal areas with such advance planning as one of several steps EPA could 

take to improve its emergency responses in the future. Specifically, Region 

4’s September 2006 summary report on its response actions in Mississippi 

stated that advance planning for landfill sites would allow geologic and 

other crucial data to be known before an incident, including data for 

staging areas or temporary landfills for vegetative and C&D debris. The 

report said that EPA Region 4 could provide assistance to states so that 

debris-clearing operations have preapproved disposal sites that would not 

pose long-term environmental issues after they were used during an 

emergency. 

Lack of Clarity on Federal 

Debris Management Roles 

Delayed Actions to Ensure 

That White Goods and 

Electronic Waste Were 

Handled in a Timely and 

Appropriate Manner

The recycling and disposal of debris such as white goods and electronic 

waste also presented the agency with a challenge in mitigating the potential 

for environmental contamination following the storms. Because of a lack of 

clarity in the National Response Plan and the absence of interagency 

protocols about federal roles in debris management, EPA could not ensure 

that debris such as white goods and electronic waste was handled in a 

timely and appropriate manner. Specifically, the plan does not state 

whether EPA or the Army Corps of Engineers should manage the 

collection, processing, recycling, and disposal of white goods, such as 

refrigerators and freezers, and electronic waste, such as televisions, 

computers, and printers. Recycling of white goods entails the removal of 

chemicals, such as chlorofluorocarbons and other refrigerants that are 

harmful to the environment. Recycling of electronic waste entails removing 

toxic components, such as lead and mercury. Computers contain toxic 

chemicals such as mercury, while the average television contains more 

than 4 pounds of lead.

The National Response Plan assigns the Corps primary responsibility for 

the public works and engineering emergency support function, which 

includes debris removal and disposal. In addition to EPA’s role as the 
Page 55 GAO-07-651 Hurricane Katrina

coordinator for the federal response to actual or potential discharges of oil 

and hazardous materials, the plan states that EPA can, among other things, 

assist the Corps with contaminated debris management activities by 

coordinating and providing resources, assessments, data, expertise, 

technical assistance, monitoring, and other appropriate support. In this 

regard, EPA’s Hurricane Katrina response activities included the collection 

and disposal of household hazardous waste such as paints, pesticides, and 

propane tanks. While debris such as white goods and electronic waste 

contain hazardous materials, neither the plan nor interagency protocols 

address whether EPA or the Corps should manage the collection, 

processing, recycling, and disposal of these types of waste.

After initial delays in determining whether EPA or the Corps would be 

responsible for white goods and electronic waste disposal, the agencies 

agreed that they would fulfill this role jointly in Louisiana, while the Corps 

or local agencies would handle white goods and electronic waste disposal 

in Mississippi. Local officials in Louisiana and Mississippi told us that 

confusion about EPA’s role in white goods and electronics waste disposal 

resulted in delays in removing and disposing of this debris. A parish official 

in Louisiana also said that the delays may have resulted in the 

inappropriate disposal of some electronic waste in landfills without proper 

safeguards.

In Mississippi, county officials from the three coastal counties hit by 

Katrina expressed frustration that EPA did not assist with either white 

goods or electronic waste disposal. Officials in one county told us that the 

collection of white goods was delayed for 7 weeks because of confusion 

among EPA, the Corps, and the county about responsibility for this task. 

Officials from another county said that while they appreciated EPA’s 

assistance with household hazardous waste collection, the county would 

have also appreciated EPA’s help with other activities that they believed 

involved environmental issues, such as white goods and electronic waste 

disposal and removing and cleaning up fuel that leached into waterways 

and bayous from abandoned automobiles. Although EPA did help 

coordinate some electronic waste recycling in one Mississippi county, an 

official from this county said that the effort was limited and only came 

about at the county’s insistence. According to officials from all three 

counties, EPA generally informed them that white goods and electronic 

waste disposal were beyond the purview of the agency’s disaster response 

activities in Mississippi. One of these officials suggested that EPA and the 

Corps should develop a better plan to address the collection of white goods 

following future disasters. According to EPA, the agency has been having a 
Page 56 GAO-07-651 Hurricane Katrina

series of discussions with the Corps and FEMA to clarify roles and 

responsibilities and enhance coordination, based on Katrina experience 

related to debris, among other things. EPA said it has not yet been 

determined how the discussions will be documented, but possibilities 

include a memorandum of understanding or supporting documents to the 

National Response Plan. 

Conclusions Working under extraordinary conditions, EPA undertook a broad range of 

activities to support state and local entities in Louisiana and Mississippi in 

assessing and minimizing the environmental risks resulting from Hurricane 

Katrina, including search and rescue efforts that brought 800 New Orleans 

residents to safety. Because of the breadth and scope of this disaster, 

cleanup and recovery efforts are still under way in the New Orleans area. 

For example, many homes have yet to be demolished or substantially 

renovated. A significant number of them will be demolished or renovated 

during the next year, and likely these activities will continue for a longer 

period of time. Given the age of many New Orleans residences, 

environmental hazards such as asbestos are likely to be present. For the 

demolitions covered by the no action assurances, in lieu of the requirement 

for prior identification and removal of regulated asbestos-containing 

materials, homes that are not inspected before demolition are required to 

be wetted during the demolition and disposition processes to reduce 

potential asbestos emissions. However, much of the demolition and 

renovation activities, including house gutting, will be undertaken by 

individual homeowners; these activities are not regulated and therefore 

none of the asbestos control requirements apply. While EPA has taken 

steps to monitor asbestos concentrations in the air in New Orleans, it is not 

clear how its approach can accomplish the agency’s stated goal of 

measuring the effects from both the regulated asbestos-containing 

material, to which the no action assurances might apply, and the 

unregulated activities, which would include demolitions and renovations 

by individual homeowners. To date, according to EPA, the asbestos air data 

it has collected have not identified potential problems regarding public 

exposure to asbestos fibers. However, these results may not be 

representative of asbestos releases to which residents, workers, and 

volunteers may be exposed in some neighborhoods because of monitoring 

gaps stemming from monitor locations and the scaling back of monitoring 

sites a few months after demolitions began. Specifically, without sufficient 

and targeted asbestos air monitoring data from neighborhoods where 

demolitions and renovations are concentrated, EPA has limited assurance 

that the public health is protected from risks associated with inhalation of 
Page 57 GAO-07-651 Hurricane Katrina

asbestos fibers potentially stemming from the substantial levels of both 

regulated and unregulated demolition and renovation activities occurring 

in concentrated geographic areas. 

In addition, EPA could improve the effectiveness of its communications 

about the potential health risks from exposure to environmental 

contamination when responding to future disasters. Following a disaster 

that has involved evacuation, residents are typically anxious to return to 

their homes, and public leaders are eager to take steps to return to 

normalcy, including having residents return as soon as it is safe for them to 

do so. Among the important information residents need in order to 

minimize their environmental health risks when they do return is timely, 

complete, clear, and consistent guidance about the environmental 

contamination they may be exposed to, both indoors and outdoors, and 

how to best protect themselves from it. Without such information, people 

may return too soon or without the proper protective gear and supplies, 

which might expose them to both short-term and long-term negative health 

effects. This could well have been the case in New Orleans since, for 

example, EPA did not state until August 2006 that its December 2005 

assessment summary applied to short-term visits, such as to view the 

external damage to their homes. This situation was exacerbated by some 

confusing information EPA provided in public service communications—

for example, about the respiratory protection residents should use to 

mitigate potential exposure to asbestos, lead, and mold in their homes. 

Mitigating some challenges EPA faced addressing Hurricane Katrina could 

better protect the environment in the future. For example, while under the 

National Response Plan, EPA’s responsibilities include mitigating threats to 

the environment—including the protection of natural resources—funding 

may not always be available to carry out these essential actions. It is 

shortsighted, inefficient, and potentially dangerous to limit the removal of 

debris containing hazardous materials to state lands and waterways, 

halting such cleanups arbitrarily at federal land or water boundaries. Thus, 

while the Department of the Interior’s Fish and Wildlife Service ultimately 

requested and received funding through supplemental appropriations that 

it then provided to EPA to conduct the cleanups, this is not an effective or 

efficient solution in disaster situations. In such situations, timely cleanup 

can lessen the damage to the environment, better protect the public from 

exposure to contaminants, prevent further migration of hazardous 

materials, and likely be more cost-effective. Without a framework in place 

to enable EPA, the Coast Guard, and federal land management agencies 

such as the Department of the Interior and the Department of Agriculture 
Page 58 GAO-07-651 Hurricane Katrina

to quickly obtain funding to respond to environmental impacts of disasters 

on federal lands and waterways, these natural resources—and state areas 

that can be harmed by the migration of chemical releases from federal 

lands—are at risk. 

In addition, given EPA’s limited role in ensuring that states dispose of storm 

debris appropriately, EPA’s lack of sufficient guidance to state and local 

entities on selecting additional landfill sites and on practices that state 

agencies should consider when making special accommodations for debris 

disposal following disasters becomes increasingly important. Such 

guidance could help avoid controversies over landfill sites selected under 

emergency conditions, assist state and local agencies in planning for 

accommodations that may be needed to handle large volumes of hazardous 

materials after disasters, and identify strategies needed to mitigate the 

potential environmental impacts of such accommodations. Finally, greater 

clarity in the roles of EPA and the Army Corps of Engineers in recycling 

and disposing of white goods and electronic waste could help minimize the 

inappropriate disposal of these wastes in the immediate aftermath of 

disasters.

Recommendations for 

Executive Action

To enhance EPA’s ability to monitor and assess information on asbestos 

emissions resulting from the extensive demolition and renovation activities 

in New Orleans, we recommend that the EPA Administrator develop and 

implement an asbestos monitoring plan that addresses the potential health 

effects of both (1) the nonenforcement of certain asbestos requirements 

covering government-ordered demolitions of residences and (2) the general 

exemption from EPA’s asbestos work practice standards for demolition and 

renovation activities of residential buildings with four or fewer dwelling 

units when done at the initiative of individual homeowners. 

To provide environmental health risk information to the public that is 

timely, complete, clear, and consistent about (1) the environmental 

contamination to which individuals may be exposed subsequent to 

disasters and (2) how individuals can best protect themselves, we 

recommend that the EPA Administrator take the following two actions:

• Develop protocols to ensure that the agency’s communications 

following disasters are timely and sufficiently disclose all of the 

information that affected residents would need to understand the 

potential health risks they may face upon returning, including 
Page 59 GAO-07-651 Hurricane Katrina

information on the scope and methodology for EPA’s assessments of 

environmental health risks.

• Develop clear and consistent generic information for the public 

regarding mitigating exposure to contaminants—such as asbestos, lead, 

and mold—likely to be present in many disaster situations and ensure 

that this information can be expeditiously communicated via all 

appropriate media, thereby providing the public with basic protective 

information at the same time that EPA is developing any additional 

event-specific health risk information that is needed.

To better enable EPA and its partner agencies to minimize the 

environmental risks resulting from future disasters, we recommend that 

the EPA Administrator take the following three actions:

• Work with potentially affected federal land management agencies, the 

Coast Guard, DHS, and FEMA to determine what actions are needed to 

ensure that environmental contamination on federal lands, such as 

national wildlife refuges, can be expeditiously and efficiently addressed 

in future disasters. Potential actions include the development of 

protocols or memorandums of understanding or amendments to the 

Stafford Act if the agencies determine that amendments are needed to 

achieve the timely availability of such funding when responding to 

disasters involving federal lands.

• 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.

• Work with the Army Corps of Engineers to clarify each agency’s role in 

debris disposal and develop a memorandum of understanding or other 

agency protocol to allow the agencies to quickly manage and recycle 

white goods and electronic waste following future disasters. 

Agency Comments and 

Our Evaluation

In commenting on a draft of this report, EPA’s Associate Administrator for 

Homeland Security agreed with all but one of the recommendations. 

Specifically, EPA agreed with the recommendations to provide additional 
Page 60 GAO-07-651 Hurricane Katrina

asbestos air monitoring in New Orleans, improve environmental health risk 

communications following disasters, provide more guidance to states on 

managing debris disposal following disasters, and clarify debris 

management roles with the Army Corps of Engineers. However, EPA 

disagreed with our recommendation that the agency convene a working 

group that includes potentially affected federal land management agencies 

and the Coast Guard to develop protocols or memorandums of 

understanding on the steps the agencies should take to obtain disaster 

funding for environmental cleanups on federal lands in the future—and 

thereby address damage to federal lands and wildlife in a timely and 

efficient manner. EPA asserted that this recommendation would be more 

appropriately addressed to the Department of the Interior and FEMA. We 

continue to believe that EPA should be involved in helping to resolve these 

issues because, under the National Response Plan, EPA is the chair of the 

National Response Team, whose duties include national planning and 

response coordination for oil and hazardous materials incidents. We do 

agree that FEMA, which declined to provide funding to the Department of 

the Interior for cleanup after Hurricane Katrina, and DHS, which 

coordinates the federal response to disasters under the National Response 

Plan, should also take part in planning efforts to resolve funding issues 

concerning the removal of hazardous materials from federal lands 

following a disaster. Accordingly, we have modified our recommendation 

to state that EPA should also work with DHS and FEMA, as well as with 

federal land management agencies and the Coast Guard, to determine what 

actions are needed to ensure that environmental contamination on federal 

lands, such as national wildlife refuges, can be expeditiously and efficiently 

addressed in future disasters. This recommendation is aimed at supporting 

EPA’s efforts in conducting its environmental protection and coordination 

missions expeditiously in future disasters, thereby avoiding situations in 

which the removal of hazardous materials is halted at federal land or water 

boundaries and individual federal land management agencies waste 

valuable time seeking appropriations to pay EPA to conduct cleanup, as 

was the case during the year following the Gulf Coast hurricanes. Further, 

as was the case following Hurricane Katrina, EPA will often have the 

necessary cleanup infrastructure in place (such as contractors, equipment, 

and personnel with cleanup oversight expertise) to respond rapidly and 

effectively to contamination. EPA also provided comments on aspects of 

the report it considered misleading or inaccurate, as well as technical 

comments, which we incorporated as appropriate. EPA’s letter and our 

detailed response to it appear in appendix II. 
Page 61 GAO-07-651 Hurricane Katrina

We are sending copies of this report to the Adminstrator, EPA; appropriate 

congressional committees; and other interested parties. We will also make 

copies available to others on request. In addition, this report will be 

available at no charge on the GAO Web site at http://www.gao.gov. 

If you or your staffs have any questions about this report, please contact 

me at (202) 512-3841 or stephensonj@gao.gov. Contact points for our 

Offices of Congressional Relations and Public Affairs may be found on the 

last page of this report. Other GAO staff who made major contributors to 

this report are listed in appendix III.

John B. Stephenson

Director, Natural Resources

and Environment
Page 62 GAO-07-651 Hurricane Katrina

List of Committees

The Honorable Barbara Boxer

Chairman

The Honorable James M. Inhofe

Ranking Member

Committee on Environment and Public Works

United States Senate

The Honorable John D. Dingell

Chairman

The Honorable Joe Barton

Ranking Member

Committee on Energy and Commerce

House of Representatives
Page 63 GAO-07-651 Hurricane Katrina

Appendix I

Objectives, Scope, and Methodology AAppenednxidexiIs

The objectives of our work on environmental issues stemming from 

Hurricane Katrina were to (1) review the Environmental Protection 

Agency’s (EPA) actions under the Department of Homeland Security’s 

National Response Plan to assess and mitigate the environmental impacts 

of Hurricane Katrina; (2) determine the extent to which EPA has assurance 

that public health in New Orleans is being protected from asbestos 

inhalation health risks posed by extensive demolition activities; (3) 

determine the extent to which EPA’s communications on environmental 

health risks posed by Hurricane Katrina have provided useful information 

to the public; and (4) identify challenges EPA has faced in addressing the 

environmental impacts of Hurricane Katrina that, if mitigated, could enable 

EPA to better protect the environment in future disasters.

In reviewing EPA’s actions under the National Response Plan to assess and 

mitigate the environmental impacts of Hurricane Katrina, we analyzed the 

National Response Plan and its accompanying annexes—particularly the 

Emergency Support Function Annexes, which specify the various 

responsibilities EPA and other agencies have with regard to providing 

emergency assistance. We discussed EPA’s hurricane response actions with 

EPA’s Offices of Emergency Management, Enforcement and Compliance 

Assurance, Water, Air, and Solid Waste and reviewed documentation 

related to these actions. We visited the EPA Incident Command Centers in 

both Metairie, Louisiana, and Biloxi, Mississippi, and discussed with 

various EPA officials from Region 6 (covering Louisiana) and Region 4 

(covering Mississippi) their overall Hurricane Katrina response actions. We 

visited affected areas to survey the massive damage and cleanup 

operations, including the Lower Ninth Ward and the Murphy Oil Spill in 

Louisiana and some of the Mississippi’s most severely damaged areas, such 

as Waveland, Bay St. Louis, Biloxi, and Gulfport. We interviewed other 

federal, state, and local officials who were either directly or indirectly 

involved with EPA’s response efforts, such as officials with the Federal 

Emergency Management Agency, the Department of Health and Human 

Services’ Agency for Toxic Substances and Disease Registry and Centers 

for Disease Control and Prevention, the Army Corps of Engineers, and the 

Department of the Interior’s U.S. Fish and Wildlife Service. State and local 

officials interviewed included representatives with the Louisiana and 

Mississippi Departments of Environmental Quality and local officials from 

Jefferson, Plaquemines, Orleans, and St. Bernard Parishes in Louisiana and 

from Jackson, Hancock, and Harrison Counties in Mississippi. In addition, 

we spoke with national and regional stakeholder groups, including the 

Natural Resources Defense Council, the Lake Pontchartrain Basin 

Foundation, the Louisiana Environmental Action Network, the Louisiana 
Appendix I

Objectives, Scope, and Methodology

Page 64 GAO-07-651 Hurricane Katrina

Mid-Continent Oil and Gas Association, the Mississippi Environmental 

Recovery Alliance, the Mississippi Power Company, and Sierra Club 

chapters in both Louisiana and Mississippi. We also reviewed various 

Congressional Research Service reports that provided an overall context 

for various environmental issues emerging from Hurricane Katrina, as well 

as reports from the EPA Inspector General on the hurricane response.

To analyze the extent to which EPA has assurance that public health in 

New Orleans is being protected from asbestos inhalation health risks posed 

by extensive demolition activities, we reviewed key documents, such as 

relevant Clean Air Act provisions; EPA’s national emissions standards for 

asbestos, which set work practice standards for building demolition and 

renovation activities; and EPA’s no action assurance letters to Louisiana 

and Mississippi. Other key documents reviewed include EPA’s September 

2005 Overview Plan for Ambient Air Monitoring After Hurricane 

Katrina, EPA’s October 2005 Regional Air Monitoring Plan for Hurricane 

Katrina in Louisiana, and EPA’s February 2006 Contingency Air 

Monitoring and Sampling Plan for C&D Burning or Grinding Sites, all of 

which cover areas of southern Louisiana impacted by Hurricanes Katrina 

and Rita. We also reviewed EPA’s March 2006 Quality Assurance Project 

Plan for a building demolition project in Fort Smith, Arkansas, testing an 

alternative asbestos control method for building demolition. Additionally, 

we examined the air monitoring data EPA posted on its “Response to 2005 

Hurricanes” Web page, which identified the location of the various air 

monitors the agency used to measure air quality after Hurricanes Katrina 

and Rita in Louisiana and Mississippi and the pollutants each monitor 

measured. We spoke with officials from EPA’s Office of Enforcement and 

Compliance Assurance regarding EPA’s asbestos no action assurance 

letters and its approach to addressing asbestos issues resulting from the 

hurricanes. We also spoke with EPA officials in the Office of Emergency 

Management, Office of Research and Development, and Regions 4 and 6 

regarding asbestos and demolition issues, as well as with officials from the 

Army Corps of Engineers and the Louisiana and Mississippi Departments of 

Environmental Quality.

To determine the extent to which EPA’s communications on environmental 

health risks posed by Hurricane Katrina have provided useful information 

to the public, we reviewed the agency’s key communications about the 

potential health risks from environmental contamination in New Orleans—

three environmental assessment summaries that were released in 

December 2005, March 2006, and August 2006. We also reviewed EPA’s 

various flyers, public service announcements, advisories, and other 
Appendix I

Objectives, Scope, and Methodology

Page 65 GAO-07-651 Hurricane Katrina

documents on EPA’s “Response to 2005 Hurricanes” Web page that provide 

information to the public about environmental health risks and how to 

mitigate them. We spoke with EPA officials from the Office of Emergency 

Management and Regions 4 and 6 about the agency’s efforts to 

communicate information regarding the environmental health risks from 

the hurricanes and reviewed comments provided by EPA’s Science 

Advisory Board related to EPA’s sediment sampling plan. Additionally, we 

reviewed various reports from the Department of Health and Human 

Services’ Centers for Disease Control and Prevention, including the 

agency’s June 2006 report Mold Prevention Strategies and Possible Health 

Effects in the Aftermath of Hurricanes and Major Floods. We also 

reviewed EPA Inspector General reports on EPA’s response activities. The 

focus of our review of EPA’s communications of environmental health risks 

following Hurricane Katrina was on their content and the extent to which 

they provided clear and consistent information; we did not evaluate the 

scientific merits of EPA’s environmental risk assessment methodology.

In conducting this work, we identified several challenges EPA faced in 

addressing the environmental impacts of Hurricane Katrina, based on our 

interviews with the federal, state, local, and private-sector officials 

identified above; our site visits in Louisiana and Mississippi; and a review of 

federal and private-sector reports and articles about environmental 

cleanup activities in the Gulf Coast after the hurricanes. Regarding the 

landfill issues, we reviewed related laws and guidance such as the Stafford 

act, the Resource Conservation and Recovery Act, the National Response 

Plan, Federal Emergency Management Agency debris management 

guidance, state regulations and emergency orders, and independent reports 

that addressed potential debris issues at landfill sites in Louisiana that 

received debris from Katrina. Finally, we visited the Chef Menteur and Old 

Gentilly landfill sites to observe debris management activities. Officials of 

the Federal Emergency Management Agency, the Department of the 

Interior’s Fish and Wildlife Service, and the Army Corps of Engineers 

reviewed sections of the draft report that applied directly to their agencies. 

We conducted our work from November 2005 through June 2007 in 

accordance with generally accepted government auditing standards.
Page 66 GAO-07-651 Hurricane Katrina

Appendix II

Comments from the Environmental 

Protection Agency ApendxiI

Note: GAO comments 

supplementing those in 

the report text appear 

at the end of this 

appendix.

See comment 1.

See comment 2.
Appendix II

Comments from the Environmental 

Protection Agency

Page 67 GAO-07-651 Hurricane Katrina

See comment 3.

See comment 4.

See comment 5.

See comment 6.

See comment 7.

See comment 8.

See comment 9.
Appendix II

Comments from the Environmental 

Protection Agency

Page 68 GAO-07-651 Hurricane Katrina

See comment 10.

See comment 11.

See comment 12.

Note: Pages in draft 

report may differ from 

those in this report.
Appendix II

Comments from the Environmental 

Protection Agency

Page 69 GAO-07-651 Hurricane Katrina

See comment 13.

See comment 14.

See comment 15.

See comment 16.
Appendix II

Comments from the Environmental 

Protection Agency

Page 70 GAO-07-651 Hurricane Katrina

See comment 17.

See comment 18.

See comment 9.

See comment 8.
Appendix II

Comments from the Environmental 

Protection Agency

Page 71 GAO-07-651 Hurricane Katrina

See comment 19.

See comment 20.

See comment 21.
Appendix II

Comments from the Environmental 

Protection Agency

Page 72 GAO-07-651 Hurricane Katrina

See comment 22.

See comments 1, 3, 

and 6.

See comments 2 

and 24.

See comment 23.
Appendix II

Comments from the Environmental 

Protection Agency

Page 73 GAO-07-651 Hurricane Katrina

See comments 1 and 2.

See comment 6.

See comment 7.

Note: Strike-throughs 

indicate deletions suggested 

by EPA.
Appendix II

Comments from the Environmental 

Protection Agency

Page 74 GAO-07-651 Hurricane Katrina

See comments 6 and 24.

See comments 8 and 9.

See comment 5.

Note: Strike-throughs 

indicate deletions suggested 

by EPA.

Note: Strike-throughs 

indicate deletions 

suggested by EPA.

See comment 25.
Appendix II

Comments from the Environmental 

Protection Agency

Page 75 GAO-07-651 Hurricane Katrina

See comment 26.

See comment 4.
Appendix II

Comments from the Environmental 

Protection Agency

Page 76 GAO-07-651 Hurricane Katrina

See comment 4.

See comment 27.

See comment 28.

See comment 29.

See comment 30.
Appendix II

Comments from the Environmental 

Protection Agency

Page 77 GAO-07-651 Hurricane Katrina

See comment 31.

See comment 32.

See comment 33.

See comment 34.

See comment 35.

See comment 36.
Appendix II

Comments from the Environmental 

Protection Agency

Page 78 GAO-07-651 Hurricane Katrina

See comment 37.

See comment 38.

See comment 39.

See comment 40.

See comment 41.
Appendix II

Comments from the Environmental 

Protection Agency

Page 79 GAO-07-651 Hurricane Katrina

See comment 42.

See comment 43.
Appendix II

Comments from the Environmental 

Protection Agency

Page 80 GAO-07-651 Hurricane Katrina

See comment 42.

See comment 44.

See comment 45.

See comment 46.

See comment 47.
Appendix II

Comments from the Environmental 

Protection Agency

Page 81 GAO-07-651 Hurricane Katrina

See comment 48.

See comment 49.

See comment 50.

See comments 9 and 50.

Note: Strike-throughs 

indicate deletions suggested 

by EPA.
Appendix II

Comments from the Environmental 

Protection Agency

Page 82 GAO-07-651 Hurricane Katrina

See comment 51.

See comment 52.
Appendix II

Comments from the Environmental 

Protection Agency

Page 83 GAO-07-651 Hurricane Katrina

See comment 53.
Page 84 GAO-07-651 Hurricane Katrina

The following are GAO’s comments on the Environmental Protection 

Agency’s letter dated May 9, 2007.

GAO Comments 1. As stated in the draft report, we reviewed the extent to which EPA’s 

communications on environmental health risks posed by Hurricane 

Katrina have provided useful information to the public. In this regard, 

the issue with timeliness that we raise focused on EPA’s three key 

environmental assessment summaries covering its environmental 

sampling in New Orleans after the floodwaters had receded. The draft 

report also addressed the many other communications on 

environmental health risks EPA provided to the public via flyers and 

health advisories distributed at various locations throughout the 

hurricane-damaged areas, public service announcements made 

available to the media, and information posted on EPA’s Web page. We 

recognize that many of these communications preceded the release of 

the environmental assessment summaries. Therefore, to address EPA’s 

concern that the report may be construed as indicating that EPA did not 

release information about environmental conditions following 

Hurricane Katrina until December 2005, when it released the first 

assessment summary, we have added a statement on the Highlights 

page that “EPA issued timely information to the public on a variety of 

environmental health risks.” Also, in the body of the report, we now 

state that EPA started its communications efforts shortly after the 

storm, beginning in September 2005. In addition, EPA suggested we 

include some information it provided to FEMA, but we did not because 

it was not relevant to this report, which addresses EPA’s 

communications to the public.

2. We do not agree that the draft report created an impression that it was 

EPA’s role to determine if it was safe for residents to return to their 

homes. The draft report stated that “EPA worked with other federal and 

state agencies to support local officials evaluating home and 

neighborhood safety.”

3. We disagree with EPA’s statement that the draft report did not 

recognize that EPA worked with the Louisiana Department of 

Environmental Quality and other federal and state agencies in the 

development of the environmental assessment summaries. The draft 

report explicitly stated in several places, starting with the Results in 

Brief section and again in the body of the report, that EPA worked with 

the Louisiana Department of Environmental Quality and others in 
Appendix II

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Page 85 GAO-07-651 Hurricane Katrina

developing the summaries. All of the other federal and state entities are 

identified in the body of the draft. We have, however, added the 

language used in the Results in Brief section of the report to the 

Highlights page.

4. We disagree with EPA’s assertion that the draft report suggested that 

EPA’s sampling program was incomplete. The draft report explicitly 

stated that we (1) determined the extent to which EPA’s 

communications on environmental health risks posed by Hurricane 

Katrina have provided useful information to the public and (2) did not 

evaluate the agency’s environmental risk assessment methodology. In 

the context of the usefulness of the communications to the public, the 

draft report stated that we believe EPA’s assumption (that the results 

from sediment samples from streets or other public access areas can be 

used to accurately characterize the degree and nature of contamination 

in New Orleans, including inside homes and in yards) is important and 

warrants highlighting in the environmental assessment summaries 

for two main reasons. First, as the draft report stated, environmental 

contamination levels inside buildings can potentially be higher than and 

different from the contamination levels outside for a variety of reasons, 

potentially causing more adverse health effects. Further, as the draft 

report also stated, EPA’s Science Advisory Board had suggested that 

EPA conduct some indoor sampling in New Orleans for this reason. 

Second, the draft report stated that to understand the level of assurance 

that EPA can provide about the extent to which localized areas of 

contamination may exist throughout the city, it is important to know 

that limiting sediment and soil sampling to outdoor, public access areas 

can be problematic. For example, sediments in streets may be subject 

to more dispersion than those that settled in more protected areas, 

such as on private property close to residences. Our point is that EPA 

should have disclosed, and provided its rationale for, important 

assumptions such as this in the assessment summaries themselves.

5. EPA said that the data the agency has collected to date do not support 

the statement in the draft report that the environmental contamination 

caused by this natural disaster could have both short- and long-term 

effects on the health of residents in impacted areas, as well as workers, 

volunteers, and wildlife. We believe that it would be premature to 

conclude that the environmental contamination caused by Hurricane 

Katrina has not and will not cause any short- and long-term public 

health effects. Further, EPA has not demonstrated that it has assurance 
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Comments from the Environmental 

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Page 86 GAO-07-651 Hurricane Katrina

that the environmental contamination both has not and will not cause 

any short- and long-term public health effects.

6. EPA takes issue with the draft’s assertion that EPA’s August 2006 

summary indicates that the data presented in the December 2005 

summary applied to only short-term visits. In fact, the statement that 

EPA is questioning is taken directly from its August 2006 summary, 

which describes the results of EPA’s analysis of 450 samples (termed 

phase I by EPA) addressed in its December 2005 summary. The 

complete statement in EPA’s summary is as follows: “The results of the 

phase I sampling indicated that hazardous substances were not 

detected in the sediments at levels that would pose an immediate 

health risk to workers involved in response activities or to residents 

returning for a quick assessment of damage to their homes.” Further, 

the August 2006 summary also states that the data from the phase I 

analysis were used to assess “(1) whether hazardous substances were 

present in the sediment in residential areas; and (2) the potential health 

effects to emergency workers and residents from short-term exposure

[emphasis ours] to any hazardous substances found in the sediment.” 

EPA’s summary of the results of the testing, combined with its 

explanation of the goal of this testing, indicates that the data presented 

in the December 2005 summary apply to short-term visits. 

Moreover, in its comments, EPA appears to question the assessment 

results it reported by stating that “both summaries discuss how 

samples were compared to both short and long term health criteria.” 

While the summaries do not “discuss” the health criteria, they do state 

that the samples were compared to both “LDEQ Risk 

Evaluation/Correction Action Program (RECAP) and EPA’s risk criteria 

based on long-term (30 years) residential exposure assumptions.” EPA 

appears to be suggesting in its comments that a reader of the August 

2006 summary should independently infer—on the basis of its 

reference to technical (and to the general public, arcane) risk criteria—

that the December 2005 analysis also provided assurance that longerterm exposures would not pose any health risks. However, EPA’s 

assessment of the initial 450 sediment samples addressed only shortterm visits, according to the agency’s August 2006 summary as quoted 

above. We believe this example, and EPA’s response to it, illustrates the 

need for EPA to improve its environmental risk communications, as we 

are recommending.
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Comments from the Environmental 

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Page 87 GAO-07-651 Hurricane Katrina

7. We disagree with EPA’s statement that the draft report underestimated 

the extent of asbestos monitoring. We believe the draft report 

accurately presented information about the monitoring conducted by 

the federal and state network—the ambient air monitors; some 

monitoring conducted at some debris reduction sites; and the 

monitoring conducted by the Army Corps of Engineers and its 

contractors, who are conducting demolitions under government orders. 

Further, although the draft report stated that the Louisiana Department 

of Environmental Quality has told EPA that monitoring by the Army 

Corps of Engineers and its contractors has found “little or no asbestos 

emissions,” it also stated that such air monitoring data from the Army 

Corps of Engineers and its contractors do not address potential 

asbestos emissions from the privately sponsored demolitions and 

renovations by individual homeowners. Since these activities are not 

regulated—and emissions control actions such as wetting the material 

from before the demolition process through disposal are not required—

the potential for asbestos emissions at these sites is greater than at 

regulated sites. Because EPA’s air monitors have not been deployed in 

and around neighborhoods both where publicly and privately 

sponsored demolition and renovation activities are concentrated, the 

agency’s finding of no measurable amounts of asbestos at its ambient 

monitoring sites does not necessarily address the asbestos to which 

residents, workers, and volunteers may be exposed in some 

neighborhoods. 

8. EPA said that the draft report was misleading regarding responsibility 

for mitigating environmental impacts on national wildlife refuges 

following disasters, stating that the decision to remove hazardous 

materials from the national wildlife refuges was the responsibility of 

FEMA and the Department of the Interior and did not involve EPA. We 

have revised the language in the report to clarify the discussion of 

responsibilities. In presenting this issue—which we cite as a challenge 

EPA faced in addressing the environmental impacts of Hurricane 

Katrina—the draft report explained that EPA did not remove hazardous 

materials from national wildlife refuges in a timely manner as part of its 

response in part because disaster assistance funding generally is not 

used for debris cleanups on federal lands. The draft report also 

explained that FEMA did not approve the Department of the Interior’s 

request for funding to clean up this debris because it was on federal 

lands. The draft report showed the impact on national wildlife refuges 

from the 2005 Gulf Coast hurricanes: Debris that could have been 

removed in conjunction with EPA cleanup activities in areas 
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Comments from the Environmental 

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Page 88 GAO-07-651 Hurricane Katrina

immediately adjacent to refuges was instead left in place for a year or 

more, allowing containers holding hazardous materials to settle into 

marshlands and begin to corrode and leak. In one refuge, a fire spread 

to a 120-acre debris field with propane and other hazardous material 

containers, causing explosions that endangered firefighters. We 

continue to believe that EPA should be involved in helping resolve 

these issues because, under the National Response Plan, EPA is the 

chair of the National Response Team, whose duties include national 

planning and response coordination for oil and hazardous materials 

incidents. We do agree that FEMA, which declined to provide funding 

to the Department of the Interior for cleanup after Hurricane Katrina, 

and DHS, which coordinates the federal response to disasters under the 

National Response Plan, should also take part in planning efforts to 

resolve funding issues concerning the removal of hazardous materials 

from federal lands following a disaster. Accordingly, we have modified 

our recommendation to state that EPA should also work with DHS and 

FEMA, as well as with federal land management agencies and the Coast 

Guard, to determine what actions are needed to ensure that 

environmental contamination on federal lands, such as national wildlife 

refuges, can be expeditiously and efficiently addressed in future 

disasters. Timely cleanup can lessen the damage to the environment, 

better protect the public from exposure to contaminants, and prevent 

further migration of hazardous materials to state and local waters and 

land—and would likely be more cost-effective. 

9. We disagree with EPA’s statement that the draft report asserted that 

EPA had a limited role in ensuring that states dispose of storm debris 

appropriately. Specifically, we stated in the draft that EPA’s debris 

management role is limited; however, we did not say that EPA had a 

limited role in helping states dispose of storm debris appropriately. In 

fact, our draft report specifically highlighted EPA’s efforts with its 

partners in addressing waste segregation, recycling, and landfill 

operations—the areas EPA’s comments cited as not being recognized in 

the draft report. Our finding and recommendation in this area relate to 

current limitations in EPA guidance to states on making certain 

emergency debris disposal decisions—such as where to locate 

emergency landfills and the implications of selecting disposal options 

that otherwise would not be acceptable. We note that EPA has agreed 

to implement our recommendation as it makes revisions to its disaster 

debris manual in calendar year 2007.
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Comments from the Environmental 

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Page 89 GAO-07-651 Hurricane Katrina

10. The information EPA provides on its asbestos monitoring activities in 

this paragraph was presented and analyzed in the draft report. 

Specifically, the draft cited the asbestos monitoring conducted by 

demolition contractors using personal sampling pumps and employees 

wearing personal monitoring equipment required by the Occupational 

Safety and Health Administration. In addition, the draft report cited the 

Louisiana Department of Environmental Quality’s report to EPA that 

this monitoring has found “little or no asbestos emissions.” Further, the 

draft report discussed reasons we believe additional monitoring is 

warranted: (1) Neither ambient nor demolition site monitors have been 

located in neighborhoods with substantial demolition and renovation 

activities, such as the Ninth Ward; (2) EPA scaled back its ambient 

monitoring to the prestorm level and reduced the frequency of 

sampling—thus EPA’s expanded monitoring covered only the first few 

months of demolition activities, when few demolitions were conducted; 

and (3) many thousands of demolitions and renovations may occur in 

the same geographic area and in the same general time frame—some of 

which are not subject to the enforcement of certain asbestos work 

practice standards, while others are not subject to the standards at all. 

The draft report also stated that as of January 2007, about 25,000 homes 

concentrated in the Orleans and St. Bernard Parishes were awaiting 

demolition, and another 80,000 homes that were flooded in the New 

Orleans area were not yet included in the demolition estimates, but 

many of these homes will likely be demolished. Those not demolished 

will likely have to be substantially renovated.

11. This information cited by EPA is background information about 

asbestos and EPA’s asbestos regulation, which was provided in the draft 

report.

12. Contrary to EPA’s assertion, the draft report did identify the emission 

controls required by EPA’s no action assurances (in its comments, EPA 

refers to these controls as engineering controls). The draft also 

discussed the monitoring of air at grinding sites and EPA’s rationale for 

focusing on these sites rather than demolition sites. We continue to 

believe it is appropriate for EPA or the state to conduct monitoring at 

both demolition and volume reduction sites. Further, while some 

emission controls may be in place at demolitions covered by the no 

action assurances, the many demolitions and substantial renovations 

by individual homeowners generally are not subject to any of these 

controls; further, the debris from these unregulated activities may be 
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Comments from the Environmental 

Protection Agency

Page 90 GAO-07-651 Hurricane Katrina

transported without emission controls to construction and demolition 

landfills.

13. We encourage EPA to expeditiously implement the plan the agency 

discusses in its comments to work with state and local officials to 

develop further demolition/renovation advisories that can be used 

throughout the area to advise individuals to take appropriate 

precautions. We note that numerous volunteers of all ages travel to the 

Gulf Coast to help with demolitions and renovations, particularly 

during the summer months and holiday periods, and they should have 

clear guidance on protective measures to take when they are in areas 

undergoing demolition or renovation. 

14. We urge EPA, in developing a plan for additional air monitoring, to 

evaluate the number and location of the air monitors to ensure 

sufficient coverage of areas with substantial demolition and renovation 

activities, both regulated and unregulated. If air monitors are not 

appropriately located in neighborhoods undergoing demolition and 

renovation, the monitoring network will not be adequate to ensure that 

public health is being protected.

15. Our draft report highlighted EPA’s communications activities, which 

EPA reiterates in its comments.

16. Our draft report illustrated the need for EPA to revise and organize 

existing crisis communication fact sheets and other information to 

ensure that accurate and consistent information can be accessed 

quickly at the time of response. In its comments, EPA states its 

intention to do so by developing and using a resource guide to be 

completed in early 2008.

17. EPA’s comments describe as misleading a statement in the draft report 

explaining that EPA did not remove hazardous materials from national 

wildlife refuges because disaster assistance funding generally is not 

used for debris cleanups on federal lands. We believe this statement is 

factual as written and does not imply that EPA was involved in the 

decision to remove or not to remove hazardous materials from national 

wildlife refuges. Further, the draft report also explained that FEMA did 

not approve the Department of the Interior’s request for funding to 

clean up this debris because it was on federal lands. See comment 8.
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Comments from the Environmental 

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Page 91 GAO-07-651 Hurricane Katrina

18. EPA’s comment that EPA and the Coast Guard completed their cleanup 

work at the national wildlife refuges “under budget and ahead of 

schedule” does not acknowledge the fact that the hazardous materials 

were left in place in national wildlife refuges for a year or more before 

the cleanup was initiated. During that time, containers holding 

hazardous materials settled into marshlands and began to corrode and 

leak. When the cleanup of the Sabine National Wildlife Refuge was 

completed—16 months after Hurricane Rita—about 2,200 containers 

potentially filled with hazardous liquids and gases had been found and 

removed, along with several thousand other hazardous waste items, 

tires, batteries, munitions, and white goods. At another refuge, a fire 

spread to a 120-acre debris field with propane and other hazardous 

material containers, causing them to explode and endanger the 

firefighters. EPA’s comments also do not acknowledge that the delays in 

removing the debris complicated the cleanup efforts and increased the 

cost of removal—or that hurricane response actions to collect 

hazardous materials in adjacent areas were halted at federal 

boundaries.

19. EPA commented that it consulted with the Louisiana Department of 

Environmental Quality regarding landfills. The draft report so 

indicated. Further, EPA stated that its staff assisting the state at 

landfills did not provide oversight as the draft report indicated but 

“provided assistance in a variety of ways.” Some of the assistance EPA 

provided, such as sending observers to landfills to monitor and report 

on activities, constitutes oversight. EPA also said that the operator of 

the Gentilly landfill has conducted monitoring of groundwater at the 

landfill. We have added this information to the report.

20. EPA said in its comments that it is revising the agency’s disaster debris 

manual. If the revisions include detailed guidance to states and local 

entities on selecting additional landfill sites under emergency 

situations, and practices that agencies can adopt to mitigate the 

potential environmental impacts of special accommodations to address 

storm debris, EPA could help states avoid controversies over landfill 

sites selected under emergency conditions and help state and local 

agencies plan for accommodations that may be needed to handle 

hazardous storm debris after disasters.

21. Our report discusses delays in determining whether EPA or the Army 

Corps of Engineers would be responsible for white goods and 

electronic waste disposal in Louisiana and Mississippi. Local officials in 
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Comments from the Environmental 

Protection Agency

Page 92 GAO-07-651 Hurricane Katrina

both states told us that confusion about EPA’s role in disposing of white 

goods and electronics waste caused delays in removing and disposing 

of this debris. We note that EPA has agreed to clarify the roles of EPA 

and the Corps regarding debris disposal activities.

22. Among other things, our report addresses the extent to which EPA has 

assurance that public health is protected from asbestos inhalation risks 

in New Orleans, and the Highlights page appropriately discusses key 

actions by EPA to monitor asbestos after Hurricane Katrina. The body 

of the draft report provides more contextual information—that the 

ambient air monitors in and around New Orleans used to measure 

asbestos are also used to measure other contaminants. The report 

states that monitors measure ambient concentrations of the following 

pollutants: arsenic, lead, particulate matter, polycyclic aromatic 

hydrocarbon chemicals, and volatile organic compounds.

23. The introduction and background sections of the draft report provided 

information on the roles of EPA, the Coast Guard, the Army Corps of 

Engineers, and the Department of Health and Human Services as they 

relate to the topic of our review, EPA’s hurricane response activities. 

24. See comment 6. In addition, rather than stating that EPA’s December 

2005 risk assessment summary indicated it was generally safe for 

residents to return to New Orleans, we revised the report to cite EPA’s 

exact language in that summary: “the great majority of the data showed 

that adverse health effects would not be expected from exposure to 

sediments from previously flooded areas.” 

25. Although EPA questions our statement that the asbestos work practice 

standards generally do not apply to individual homeowners, this 

statement is accurate as stands. We added wording to the final report 

regarding the possible applicability of the work practice standards to 

volunteer groups.

26. We disagree with EPA’s statement that it is inaccurate to say that the 

agency is not enforcing some of the work practice standards for certain 

residences. Under most circumstances, EPA’s asbestos work practices 

require the demolition operator to inspect buildings for asbestos and to 

remove the asbestos prior to demolition. In letters to the Louisiana and 

Mississippi Departments of Environmental Quality, EPA explicitly 

stated that its no action assurance letters would “allow [specified] 

houses to be demolished without inspection and removal of asbestos 
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Comments from the Environmental 

Protection Agency

Page 93 GAO-07-651 Hurricane Katrina

prior to demolition.” Our draft report stated that EPA’s no action 

assurance letters did not extend to some other elements of the asbestos 

work practice standards. Finally, we note the purpose of EPA’s no 

action assurance letters is to provide assurance that it will not enforce 

certain legal requirements—as it has done for certain asbestos 

requirements. 

27. EPA’s public service announcements and communications, which we 

highlighted in the draft report, addressed generic environmental health 

risks and guidance. The actions by the public that EPA cites in its 

comments (voluntary curbside sorting of household chemicals) may be 

related to those communications efforts. However, EPA appears to be 

making a link between these communications and actions and the 

comprehensiveness of EPA’s sampling program—a connection we do 

not find supportable.

28. EPA questioned the “intended meaning” of the draft report’s statement 

that “after flooding, mold frequently forms and spreads.” This 

statement was provided to identify mold as a likely indoor air 

contaminant in the discussion of contamination inside New Orleans 

residences that had been flooded. The draft then highlighted the 

Centers for Disease Control and Prevention’s conclusion that “the 

duration and extent of the flooding and the number of structures 

flooded made massive mold contamination a certainty.”

29. Key information about EPA’s no action assurances was included in our 

draft report.

30. We edited the sentence on household hazardous wastes as suggested.

31. In its comments, EPA incorrectly states that we characterized 

chlorofluorocarbons as “hazardous.” Actually, the draft report said that 

electronic waste and white goods frequently contain “potentially 

hazardous contaminants, such as lead, mercury, or 

chlorofluorocarbons....” The final report refers to these substances 

simply as “contaminants.”

32. The draft report reflected that EPA approved an extension of the no 

action assurance through September 30, 2007, for four counties in 

Mississippi.
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Comments from the Environmental 

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Page 94 GAO-07-651 Hurricane Katrina

33. Rather than stating that monitors measure ambient concentrations of 

up to six contaminants, we have revised the report in response to EPA’s 

comment to state that the monitors can measure ambient 

concentrations of the following potential pollutants and categories of 

pollutants from local and regional sources: arsenic, asbestos, lead, 

particulate matter, polycyclic aromatic hydrocarbon chemicals, and 

volatile organic compounds. 

34. EPA disagreed with the statement that EPA “delegated the authority” to 

states to implement and enforce the asbestos standard, asserting 

instead that EPA “authorizes” the programs. According to 40 C.F.R. § 

61.04(c), EPA “delegates” the relevant authority to states. Nevertheless, 

the Clean Air Act uses the term “approve,” and we revised the report as 

EPA suggested. We express no view concerning the apparent conflict 

between EPA’s comments and the agency’s decision to employ the term 

“delegate” in its regulations.

35. We revised our footnote defining regulated asbestos-containing 

materials to quote the regulations verbatim as EPA recommended.

36. We added the regulatory citation to the footnote as EPA suggested.

37. We state that the demolition owner or operator “generally” must notify 

EPA, which encompasses the contingency EPA notes here.

38. Our draft report stated that specified wetting and notification 

requirements still apply to demolition operations in which the building 

is structurally unsound and in danger of imminent collapse.

39. We made the editorial change EPA suggested for clarity.

40. We made the recommended revision to the footnote that specifies EPA’s 

asbestos screening level.

41. The draft report stated that Louisiana chose not to use the October 

2005 no action assurance, which authorized, among other things, a test 

of an open burn technology for disposing of construction and 

demolition debris.

42. EPA said that the agency wanted to clarify the purpose of the Fort 

Smith research project. We believe the draft report clearly stated the 

purpose of this pilot. For example, the second sentence of the short 
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Comments from the Environmental 

Protection Agency

Page 95 GAO-07-651 Hurricane Katrina

paragraph describing the Fort Smith project identified the purpose of 

this research project. Further, the draft report stated that “EPA officials 

said that any monitoring of asbestos emissions at demolition sites in 

New Orleans would not need to be as elaborate as that done for the 

pilot which was conducted to develop data for potential use in a 

revision to EPA’s asbestos regulation.”

43. The draft report provided information on EPA’s asbestos monitoring 

efforts and on monitoring data from the Army Corps of Engineers.

44. The draft report referred to EPA’s environmental assessment 

summaries as “EPA’s primary communications about the health risks 

from exposure to contamination in New Orleans.” EPA disagreed that 

these summaries represented its primary communications, referring to 

the other health risk communications—which the draft report also 

discussed. To address EPA’s concern, we have revised the draft, 

describing the assessment summaries as key health risk 

communications because they are significant in that they provide EPA’s 

analyses of its sediment sampling efforts in New Orleans.

45. As suggested, we replaced the term “sanitary engineers” with 

“environmental scientists and engineers.”

46. The draft report identified the primary subtitle D responsibilities of 

states that EPA cited in its comments. As suggested, we clarified that 

EPA’s enforcement authority is limited.

47. EPA proposed several deletions from the paragraph on the Agriculture 

Street Landfill. In response, we have replaced “concerns about cancer” 

with “health concerns.” However, we did not delete “debris from 

destroyed buildings and ash from municipal incinerators” because 

EPA’s comments conflict with EPA documentation that we obtained 

during our review.

48. We made the suggested deletion.

49. We made the suggested clarification in the footnote.

50. We revised the draft to reflect that EPA provided technical support and 

undertook some oversight activities at New Orleans landfills because 

some of the activities involved overseeing and reporting on landfill 

operations.
Appendix II

Comments from the Environmental 

Protection Agency

Page 96 GAO-07-651 Hurricane Katrina

51. EPA provided information on guidance the agency issued in Mississippi 

on management practices for white goods. However, the 

implementation of the procedures was problematic, as indicated by the 

comments of Mississippi county officials cited in the draft report. 

52. Our finding and recommendation regarding problems with the 

disposition of electronic waste focused on the issues Louisiana and 

Mississippi officials described to us—these problems occurred in the 

weeks immediately after the storm because of confusion regarding the 

roles of EPA and the Corps. We did not identify problems after EPA and 

the Corps defined their responsibilities. Therefore, we did not report on 

all electronics recycling activities, such as the activities EPA says were 

omitted from the report. 

53. We revised the sentence to more clearly separate the land management 

agencies referred to from the other agencies cited (EPA and the Coast 

Guard).
Page 97 GAO-07-651 Hurricane Katrina

Appendix III

GAO Contact and Staff Acknowledgments ApendxiI

GAO Contact John B. Stephenson, (202) 512-3841 or stephensonj@gao.gov

Staff 

Acknowledgments

In addition to the contact named above, Christine Fishkin, Assistant 

Director; Joanna Owusu; Kirk Menard; Nancy Crothers; Richard Johnson; 

Karen Keegan; and Omari Norman made key contributions to this report. 

Jessica Lemke and Hilary Sloan also made important contributions to this 

report.

(360648)
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