OFFICE OF INSPECTOR GENERAL 
 

Catalyst for Improving the Environment 

Evaluation Report 

EPA Provided Quality and Timely 

Information on Hurricane Katrina 

Hazardous Material Releases and 

Debris Management

 Report No. 2006-P-00023 

 May 2, 2006 
Report Contributors: 	 Carolyn Copper 

Steve Hanna 

 Angela Bennett 

 Martha Chang 

 Anne Emory 

 Jee Kim 

Abbreviations 

ATSDR Agency for Toxic Substances and Disease Registry 

EPA Environmental Protection Agency 

ESF Emergency Support Function 

FEMA Federal Emergency Management Agency 

LDEQ Louisiana Department of Environmental Quality 

MDEQ Mississippi Department of Environmental Quality 

NPL National Priorities List 

OIG Office of Inspector General 

PCIE President’s Council on Integrity and Efficiency 

RCRA Resource Conservation and Recovery Act 

RECAP Risk Evaluation/Corrective Action Program 

UST Underground Storage Tank 

Cover photo: Damage from Hurricane Katrina. (Source: EPA) 
U.S. Environmental Protection Agency 2006-P-00023 
 

Office of Inspector General May 2, 2006
 

At a Glance 


Catalyst for Improving the Environment 

Why We Did This Review 

This review was conducted in 

conjunction with the 

President’s Council on Integrity

and Efficiency as part of its

examination of relief efforts 

provided by the Federal 

Government in the aftermath of 

Hurricanes Katrina and Rita. 

We conducted this review to 

assess the Environmental 

Protection Agency’s (EPA’s) 

response efforts related to oil

spills, hazardous materials,

Superfund sites, and debris and 

waste management. 

Background 

On August 29, 2005, Hurricane 

Katrina made landfall, leaving 

behind a trail of destruction in 

three States. In Louisiana and 

Mississippi, the storm created 

an estimated 86 million cubic 

yards of debris; caused the spill 

of more than 7 million gallons 

of oil; produced floodwaters 

that deposited hazardous 

substances in sediments; and 

passed over 18 Superfund 

National Priority List sites and 

more than 400 industrial 

facilities that store or manage 

hazardous materials. 

For further information, 

contact our Office of 

Congressional and Public 

Liaison at (202) 566-2391. 

To view the full report, 

click on the following link: 

www.epa.gov/oig/reports/2006/ 

20060502-2006-P-00023.pdf 

EPA Provided Quality and Timely Information on Hurricane 

Katrina Hazardous Material Releases and Debris Management 

What We Found 

Following Hurricane Katrina, EPA was the Federal agency with lead 

responsibility to prevent, minimize, or mitigate threats to public health and the 

environment caused by hazardous materials and oil spills in inland zones. EPA 

responsibilities also included providing oversight and assistance in the 

management of hurricane-generated debris and waste. 

EPA established quality and timely approaches for rapidly identifying, 

prioritizing, and assessing the nature, magnitude, and impact of hazardous material 

releases: 

x	 EPA coordinated with State, local, and other Federal government agencies to 

assess potential environmental and human health impacts from Hurricane 

Katrina and provided quality and timely information for determining risks and 

impacts in EPA’s areas of responsibility and oversight. 

x	 On its own, or in partnership with State, local, or other Federal agencies, EPA 

provided information on chemicals present in sediment samples, and assessed 

results of damage or releases at all Superfund National Priority List sites in the 

path of the Hurricane, more than 400 industrial facilities, and approximately 

850 Louisiana underground storage tanks. 

Also, EPA is providing quality and timely oversight, assistance, and direct support 

in managing hurricane hazardous debris and waste throughout the affected areas: 

x	 EPA distinguished between hazardous and non-hazardous debris and is 

ensuring consistency in segregation through its management of hazardous 

wastes and oversight assistance at various landfills and staging areas. 

x	 EPA provided the public with information on how to properly dispose of 

household hazardous waste, and collected over 2.5 million hazardous waste 

containers in Louisiana. 

x	 EPA provided information to the States, and the States and EPA have worked 

together to address challenges in Katrina recovery and cleanup efforts. 

EPA responded to issues and questions we raised about response and cleanup 

progress. We make no recommendations. 
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

WASHINGTON, D.C. 20460 

OFFICE OF 
 

INSPECTOR GENERAL
 

May 2, 2006 

MEMORANDUM 

SUBJECT: EPA Provided Quality and Timely Information on Hurricane Katrina 

Hazardous Material Releases and Debris Management 

 Report No. 2006-P-00023 

TO: Susan Bodine 

 Assistant Administrator, Office of Solid Waste and Emergency Response 

James I. Palmer, Jr. 

 Regional Administrator, EPA Region 4 

 Richard E. Greene 

 Regional Administrator, EPA Region 6 

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

of the U.S. Environmental Protection Agency (EPA). The evaluation did not identify any 

conditions requiring corrective actions and no recommendations are made. This report represents 

the opinion of the OIG and the findings in this report do not necessarily represent the final EPA 

position. 

The Agency agreed with our observations and provided only technical comments to our draft 

report. These comments are included in Appendix F. Since our report made no 

recommendations, no further action is required. We appreciate the cooperative efforts of EPA, 

Mississippi, and Louisiana officials and staff as we carried out our work. If you or your staff 

have any questions regarding this report, please contact me at (202) 566-0847, or Carolyn 

Copper, at 202-566-0829. 

Sincerely, 

Bill A. Roderick 

Acting Inspector General 
Table of Contents 
 

At a Glance 

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

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

Scope and Methodology ..................................................................................................... 2 
 

EPA Provided Quality and Timely Information on the Nature, 
 

Magnitude, and Impact of Hazardous Material Releases ................................................. 3 
 

Sediment Contamination............................................................................................

Superfund Sites..........................................................................................................

Operational Facilities..................................................................................................

Underground Storage Tanks......................................................................................

Oil Spills .....................................................................................................................

 4 

5 

7 

7 

8 


 


 


 


 


 

EPA Provided Quality and Timely Information and Actions Regarding 
 

Management of Hazardous and Non-Hazardous Debris and Waste .............................. 10 
 

Hazardous Debris Management ................................................................................

Non-Hazardous Debris Management.........................................................................

 11 

13 


 


 

Appendices 

A National Response Plan Emergency Functions Supported by EPA ............. 15 
 

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

C Sediment Sampling Sites in Flooded Areas of New Orleans ......................... 18 
 

D Mississippi Household Waste Collection Flyer............................................... 19 
 

E Curbside Waste Segregation Instructions....................................................... 20 
 

F EPA Comments .................................................................................................. 21 
 

G Distribution ......................................................................................................... 23 
 
Purpose 

The President’s Council on Integrity and Efficiency (PCIE), a group of Federal audit and 

investigative organizations, is conducting multiple audits, evaluations, and investigations of the 

Federal Government’s response to Hurricanes Katrina and Rita. This review was conducted in 

conjunction with the PCIE as part of its examination of relief efforts provided by the Federal 

Government in the aftermath of Hurricanes Katrina and Rita. As such, a copy of the report has 

been forwarded to the PCIE Homeland Security Working Group, which is coordinating 

Inspectors General reviews of this important subject. 

As a member of the PCIE, the Environmental Protection Agency (EPA) Office of Inspector 

General (OIG) was tasked with evaluating several issues related to EPA’s response. One of 

these evaluations was to assess EPA’s Hurricane Katrina response efforts related to oil spills, 

hazardous materials, Superfund sites, and debris and waste management. Overall, we sought to 

determine whether EPA is providing quality and timely information relative to the safety of 

individuals and the environment, and whether the information is being used by the States and 

other regulatory agencies in their response efforts. To address this overall objective, we sought 

to answer the following questions: 

x	 How is EPA determining the nature, magnitude, and impact of oil spills, fuel releases, 

sediment contamination, and other hazardous material or substance releases (including new 

releases and/or those from existing Superfund sites) on human health and the environment? 

x	 How is EPA making distinctions between hazardous and non-hazardous hurricane debris 

and waste, and are these distinctions being made consistently across the Gulf Coast region? 

Background 

On August 29, 2005, Hurricane Katrina made landfall on the Gulf Coast, leaving behind a trail of 

mass destruction in parts of Louisiana, Mississippi, and Alabama. In Louisiana and Mississippi, 

the storm created an estimated 86 million cubic yards of debris; caused the spill of more than 

7 million gallons of oil; produced floodwaters that deposited fuel oils, gasoline, bacteria, and 

metals in sediments; and passed over 18 Superfund National Priorities List (NPL) hazardous 

waste sites and more than 400 industrial facilities that store or manage hazardous materials. Due 

to flooding and hurricane storm surges, millions of hazardous products – such as bleach, 

cleaners, oil, fuels, pesticides, herbicides, paint, and batteries – were scattered into the 

environment. In Louisiana alone, the hurricane potentially impacted approximately 850 

underground storage tank facilities and over 300,000 “white goods” (appliances, such as 

refrigerators and air conditioners, which may contain harmful substances such as Freon). 

After EPA’s initial focus and assistance with urgent rescue needs, EPA shifted its efforts to its 

responsibilities under the National Response Plan. The plan establishes a single, comprehensive 

framework for the management of domestic incidents, including hurricanes. It provides the 

structure and mechanisms for the coordination of Federal support to State, local, and tribal 

incident managers and for exercising direct Federal authorities and responsibilities. Based on the 

authorities and responsibilities under the National Response Plan, the Federal Emergency 

1
 
Management Agency (FEMA) assigns specific missions to various Federal agencies through 

Emergency Support Functions (ESFs). Agencies may participate in a variety of ESFs, either as 

the lead or support agency. EPA is the lead Federal agency for ESF #10 – Oil and Hazardous 

Materials. ESF #10 responsibilities may include: 

x Addressing threats from actual or potential releases including oil spills, sediment 

contamination, and hazardous substances. 

x Managing household hazardous waste, and other material releases which may pose a 

threat to public health or the environment, such as electronics and white goods. 

x Managing, overseeing, and assisting in the segregation of hazardous debris and waste. 

In addition to ESF #10, EPA also serves as a support agency under a variety of other ESFs, 

including ESF #3 – Public Works and Engineering – which addresses managing contaminated 

debris and waste. ESF functions supported by EPA are listed in Appendix A. 

Various principal authorities guide the structure, development, and implementation of the 

National Response Plan that pertain to ESF functions supported by EPA: 

x	 Federal disaster legislation: The Robert T. Stafford Disaster Relief and Emergency 

Assistance Act, Public Law 93-288, as amended (the Stafford Act) supports State and 

local governments and their citizens overwhelmed by disasters. This law establishes a 

process for requesting and obtaining a Presidential disaster declaration, defines the type 

and scope of assistance available, and sets conditions for obtaining assistance. 

x	 Other regulatory authorities: EPA’s other authorities to respond to environmental 

events remain in effect, such as those provided in the National Contingency Plan; 

Comprehensive Environmental Response, Compensation, and Liability Act; Resource 

Conservation and Recovery Act (RCRA); and Oil Pollution Act of 1990. 

Scope and Methodology 

This evaluation focused on the States impacted most by Hurricane Katrina – Mississippi and 

Louisiana – and did not include Alabama. To gain first-hand knowledge on Hurricane Katrina’s 

impact in these two States, we visited portions of the affected areas in Louisiana and Mississippi. 

In Louisiana we visited the Metairie Incident Command Center, Old Gentilly Landfill, debris 

staging areas, and a household hazardous waste collection site. We also visited impacted areas 

in and around the New Orleans area, including the Lower Ninth Ward, St. Bernard Parish 

(Murphy Oil spill site), Agriculture Street Landfill Superfund site, and the area surrounding the 

17th Street Canal levee break. In Mississippi we visited the Biloxi Incident Command Center, a 

Division A landfill and staging area, and other impacted areas along the Gulf Coast including the 

cities of Waveland and Biloxi. 

To answer the first question, we identified sites or facilities that can be, or have been, associated 

with hazardous material substance releases, and collected and analyzed specific operational, 

management, and response-related information about them. The categories of sites or facilities 

we looked at for this question included: 

2
 
x	 Operational Facilities: Operational facilities regulated by existing Federal, State, and 

local environmental programs. Operational facilities utilize, produce, and/or store 

chemicals and other hazardous substances, and thus have the potential to release 

hazardous substances into the environment. They include RCRA generators; RCRA 

transport, storage, and disposal facilities; Toxic Release Inventory filers; and Risk 

Management Plan filers. 

x	 Contaminated Hazardous Waste Sites: Superfund NPL sites as identified by the 

Federal Superfund Program. Established pursuant to the Comprehensive Environmental 

Response, Compensation, and Liability Act, the NPL is a list of abandoned or 

uncontrolled hazardous substance sites that are prioritized for long-term remediation. 

x Underground Storage Tanks (USTs): USTs as identified by State and local programs. 

x Oil Spills: Spills in navigable waters and land releases. 

x Sediments: Non-point source contamination of New Orleans by flood water sediments. 

EPA conducted air, flood water, sediment, and soil sampling; this evaluation addresses 

only the sediment sampling activities. 

To determine the quality and timeliness of EPA’s efforts, we evaluated how EPA was 

determining the nature, magnitude, and impact of oil spills, sediment contamination, and other 

hazardous material or substance releases on human health and the environment. We evaluated 

whether the information associated with this was timely and presented to the public. In carrying 

this out, we interviewed officials from various EPA headquarters program offices, including the 

Office of Solid Waste and Emergency Response and its constituent offices: Office of 

Emergency Management, Office of Solid Waste, and Office of Underground Storage Tanks. We 

also interviewed program officials in EPA Region 4 (which covers Mississippi) and Region 6 

(which covers Louisiana), as well as State officials from the Louisiana Department of 

Environmental Quality (LDEQ) and the Mississippi Department of Environmental Quality 

(MDEQ). 

We performed field work from October 2005 through February 2006. We conducted our review 

in accordance with Government Auditing Standards, issued by the Comptroller General of the 

United States. Additional details on scope and methodology are in Appendix B. 

EPA Provided Quality and Timely Information on the Nature, 

Magnitude, and Impact of Hazardous Material Releases 

EPA Regions 4 and 6 established quality and timely approaches for rapidly identifying, 

prioritizing, and assessing the nature, magnitude, and impact of hazardous material releases. 

EPA coordinated with State, local, and other Federal Government agencies to assess potential 

environmental and human health impacts from Hurricane Katrina. Further, EPA provided the 

public, State and local officials, and other Federal decision makers with quality and timely 

information in EPA’s areas of responsibility and oversight. This included conducting and 

distributing sampling results of floodwater sediments in New Orleans, and identifying and 

assessing Superfund NPL sites and major operational facilities. Details follow. 

3
 
Sediment Contamination 

EPA provided quality and timely information on sediment contamination to the States and other 

Federal decision makers for use in determining associated risk and impact assessment. As of 

February 2006, EPA, in coordination with LDEQ, took more than 800 sediment samples in the 

New Orleans area to determine the nature and type of contamination that may have impacted 

residential areas due to the migration of chemicals and other hazardous materials by floodwaters. 

While some samples exceeded LDEQ and EPA criteria, the majority of the chemicals detected 

were below levels of health concern. Sampling results were provided to FEMA and to State and 

Federal health agencies – including the Centers for Disease Control and Prevention, Agency for 

Toxic Substances and Disease Registry (ATSDR), and Louisiana Department of Health and 

Hospitals – for risk and impact assessment and public notification. EPA promptly posted 

summaries of sediment sampling activities, test results, and safety precautions recommended by 

public health agencies on public Web sites as they became available. Public service 

announcements were promptly issued regarding precautions related to the now receded 

floodwaters and the cleanup of sediments. EPA continues to post results to its Web site as they 

become available. 

Region 6 is tasked under ESF #10 to conduct sampling and assessment of sediments in 

residential areas where floodwaters from Hurricane Katrina receded. EPA defines sediment as 

residuals deposited by receding flood waters that may include historical sediment from nearby 

water bodies, soil from yards, road and construction debris, and other material. The objective of 

the sampling is to determine the nature and type of contaminants that may have impacted 

residential areas due to migration of hazardous materials. Region 6 geared initial sampling 

toward characterizing the sediment to determine potential risks to first responders. On-going 

sampling and analysis is being conducted to address risk associated with long-term exposure. To 

help ensure reliable and quality sampling data, Region 6 developed an emergency response 

quality assurance sampling plan1 that includes screening levels, quality assurance measures, and 

data validation requirements. 

Within days of the floodwaters receding, EPA, in coordination with LDEQ, had drafted a quality 

assurance sampling plan and began collecting sediment samples. During the initial sampling 

period of September 10 – October 14, 2005, EPA and LDEQ collected sediment samples at more 

than 430 sites in the streets and public areas of Jefferson, Orleans, Plaquemines, and St. Bernard 

Parishes (all sampling sites as of December 11, 2005, are displayed in the map in Appendix C). 

EPA tested each of the samples for about 200 different pollutants, including volatile organic 

compounds, semi-volatile organic compounds, total metals, pesticides, and total petroleum 

hydrocarbons. EPA and LDEQ compared levels of chemicals with ATSDR Minimum Risk 

Levels to the appropriate Minimum Risk Levels to determine risk. For those chemicals with no 

Minimum Risk Level, ATSDR developed exposure models based on current available toxicity 

information to determine associated risk. 

Based on sample results released during the period September 17-26, 2005, some samples 

contained a variety of chemicals, as expected in a highly populated urban area. However, the 

1 Emergency Response Quality Assurance Sampling Plan for Hurricane Katrina Response Screening Level 

Sampling for Sediment in Areas Where Flood Water Receded, Southeast Louisiana, September 2005. 

4
 
majority of the chemicals were below levels of health concern. The most frequently detected 

chemicals included some metals; petroleum hydrocarbons; polycyclic aromatic hydrocarbons 

(PAHs); and, to a lesser degree, pesticides (e.g., chlordane, dieldrin, aldrin). Many of these 

chemicals are or were commonly used, and therefore are routinely present in the environment. 

To determine short-term risk associated with the detected chemicals, EPA worked closely with 

ATSDR to determine appropriate exposure scenarios. EPA and ATSDR concluded that 

exposure during response activities to the low levels detected should not cause adverse health 

impacts as long as proper protective equipment is worn (e.g., gloves and safety glasses). 

Following the initial sampling period, EPA began addressing risks associated with long-term 

exposure. EPA and LDEQ compared results of samples collected after September 25, 2005, to 

LDEQ’s Risk Evaluation/Corrective Action Program (RECAP) Management Option 1 Soil 

Standards. LDEQ’s non-industrial RECAP Soil Standards are intended to be protective of longterm (i.e., 30-year) exposures to children and adults in a residential setting. Although the levels 

in some samples exceed RECAP standards, they fall within a 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, which EPA has found acceptable in other contexts. 

Subsequent sampling conducted through February 2006 continues to detect many of the same 

chemicals as noted in the previous sampling events, but the majority of chemicals detected are 

below levels of concern. Approximately 40 locations, found within 17 of 26 New Orleans area 

zip codes, continue to detect some values at levels exceeding RECAP standards. These locations 

have been identified for further sediment/soil evaluation and possible re-sampling. EPA officials 

said that should an area be found to pose an unacceptable risk after confirmatory sampling, they 

will work with the State of Louisiana to determine appropriate next steps. 

Superfund Sites 

EPA promptly identified, prioritized, and 

assessed all Superfund NPL sites in the affected 

areas of Louisiana and Mississippi (see Figure 

1). EPA generally provided quality and timely Louisiana Mississippi

information on the assessment process to the 

States, local agencies, and general public. EPA 

promptly posted assessment results, along with 

supporting validated analytical data, on the 

Agency’s public Web site. Overall, EPA 

concluded that there were no impacts from 

Hurricane Katrina for 15 of the 18 sites in the 

affected areas. 

Gulf of Mexico 

Under ESF #10, EPA is the lead Federal agency 

responsible for addressing actual or potential 

releases of hazardous materials, including those 

from NPL sites. EPA identified 18 NPL sites in 

the affected areas through its Superfund 

5
 

Figure 1- NPL sites in Louisiana and Mississippi. 

(Source: Congressional Research Service Report 

Cleanup After Hurricane Katrina: Environmental 

Considerations, October 13, 2005. Text added by 

EPA OIG) 
database (15 in Louisiana and 3 in Mississippi). EPA prioritized these sites based on proximity to 

the hurricane’s path, and assessed them with assistance from the States. The assessment process 

generally included an initial damage assessment (e.g., contact with State and/or responsible 

parties, and/or visual inspections), followed by further evaluation, including site inspection and 

sampling. Although the approaches varied somewhat, both Regions utilized approved sampling 

plans and performed data validation to ensure data quality. 

In Louisiana, Region 6, with assistance from the State, conducted initial NPL site assessments 

during September 2-9, 2005. EPA and LDEQ conducted further evaluation and sample activities 

(sediments, surface water, and groundwater) from September 13 through October 14, 2005, in 

accordance with site-specific operations and maintenance monitoring plans.2 EPA’s conclusions 

regarding the potential impact of the hurricane on the sites were based on comparisons of posthurricane data to past sample data collected during routine monitoring activities. Region 6 

received, evaluated, and promptly posted validated analytical data results on the Agency’s public 

Web site. 

In Mississippi, MDEQ conducted initial NPL site assessments during September 7-8, 2005. 

EPA Region 4 conducted further evaluation and sampling activities from September 15 through 

October 14, 2005. Sampling activities were conducted in accordance with Region 4’s Quality 

Assurance Project Plan, Post-Katrina Site Evaluations, Southern and Coastal Alabama and 

Mississippi, October 2005, which was developed according to EPA guidance for Quality 

Assurance Project Plans. EPA’s conclusions regarding potential impact of the hurricane on the 

sites were based on comparison of post-hurricane data to existing soils and sediment cleanup 

values defined for the site, or past sample data. In addition, the results were compared to EPA 

Region 9 Preliminary Remediation Goals3 and the Office of Water’s 2004 National 

Recommended Water Quality Criteria4 to determine whether site conditions might represent 

previously unrecognized risks to human health and the environment. Region 4 received, 

evaluated, and promptly posted validated analytical data results to the Agency’s public Web site. 

Based on the post-hurricane evaluations of Superfund sites, EPA concluded that the hurricane 

did not impact 15 of the 18 sites. The remaining three sites are in Louisiana. Two of these sites 

– Delatte Metals and PAB Oil – showed higher concentrations of metals in groundwater samples 

than from pre-hurricane samples. EPA said it will continue to monitor groundwater at these sites 

as part of the routine operations and maintenance. Initial results for the third site – Agriculture 

Street Landfill in Orleans Parish – confirmed that the remedy implemented at the site was not 

impacted by the hurricane, but completion of the final evaluation is pending further sampling of 

sediments deposited by flooding in the area that exceeded LDEQ RECAP criteria. 

2

 Seven of the 15 NPL sites are Final NPL sites and are in the construction completion–operations and maintenance
 

phase with monitoring plans. The remaining sites are deleted NPL sites, which had been removed from the NPL
 

after EPA determined no further response is required to protect human health and the environment.
 3 EPA Region 9 Preliminary Remediation Goals are risk-based concentrations based on long-term (i.e., 30-year) 
 

exposures to children and adults in a residential setting. The goals are intended to assist risk assessors and others in 
 

initial screening-level evaluations of environmental measurements. 
 4

 This is a compilation of surface water quality criteria for the protection of aquatic life and human health for 
 

approximately 150 pollutants.
 

6
 
Figure 2- A chemical manufacturing facility in Mississippi after 

the hurricane. (Source: EPA) 

Operational Facilities 

EPA, in coordination with the States, quickly identified, prioritized, and assessed the major 

operational facilities in the path of Hurricane Katrina. Examples of major operational facilities 

in the Gulf Coast area include chemical manufacturing facilities and oil refineries. 

Operational facilities utilize, produce, and/or store chemicals, pesticides, and other hazardous 

material or substances, and thus have the increased potential to release hazardous materials or 

substances into the environment. The identification and assessment of such facilities after a 

natural disaster is important to ensure no significant releases of these materials occurred, and to 

contain or remediate any such releases. Both Louisiana and Mississippi used data from the Risk 

Management Plan program and the Toxic Release Inventory as major sources for identifying 

operational facilities to be assessed 

after Hurricane Katrina. EPA 

identified 224 Toxic Release 

Inventory and 233 Risk Management 

Plan facilities in affected areas of 

Louisiana, and 26 Toxic Release 

Inventory and 50 Risk Management 

Plan facilities in affected areas of 

Mississippi. In addition to these 

facilities, EPA and the States used 

other information sources, such as 

regulated hazardous waste handlers, 

to ensure major potential sources of 

chemical releases were rapidly 

assessed. 

Initial assessments began shortly after the hurricane made landfall, starting with telephone calls 

and e-mails to operational facilities that had been identified prior to impact. Within a few weeks, 

EPA had conducted aerial and ground assessments and had utilized facility self assessments to 

determine the magnitude of potential hazardous material and substance releases, and to prioritize 

those operational facilities needing additional assessment. Prioritization of facilities was based 

on a combination of facility size, hardest hit areas, proximity to people and sensitive 

environmental areas, facility contact non-response, local regulatory expertise, and calls into the 

National Response Center. 

Underground Storage Tanks 

Louisiana and Mississippi, under applicable program delegations (RCRA Subtitle I), identified, 

prioritized, and performed initial damage assessments to USTs in affected areas. EPA provided 

assistance requested by the States. The States identified hurricane-affected USTs and prioritized 

them for initial assessment primarily based on accessibility. The States generally limited initial 

assessments to visual site inspections, which looked for signs of damage. 

7
 
An UST consists of a tank and any underground 

piping connected to the tank that has at least 

10 percent of its combined volume underground. 

USTs are used to store petroleum products or other 

hazardous substances and are operated for gasoline 

sales to the public or individuals. The greatest 

potential hazard from a leaking UST is that the 

contents can seep into the soil and contaminate 

groundwater. A leaking UST also has the potential 

for fire and explosion. 

In Louisiana, EPA assisted LDEQ in conducting 

initial damage assessments at 848 facilities within the 

affected New Orleans area, including the parishes that 

sustained the greatest storm-related damage: 

Jefferson, Orleans, Plaquemines, St. Bernard, St. 

Tammany, and Washington. By November 15, 2005, 

initial assessments were completed in Louisiana. 

In Mississippi, MDEQ performed its assessments 

without EPA assistance, and identified 355 facilities 

in Hancock, Harrison, and Jackson counties. Initial 

assessments are on-going, with 110 completed to 

date. Mississippi assessment activities have been 

complicated by massive debris piles that must be 

cleared to access affected UST facilities. 

Oil Spills 

In the aftermath of Hurricane Katrina, EPA, the U.S. Coast Guard, and LDEQ worked together 

with local industries to assess, manage, and mitigate environmental damage resulting from oil 

spills in affected areas of Louisiana. There have been at least five major oil spills reported, each 

involving over 100,000 gallons, and one spill impacted a residential neighborhood. EPA is 

providing oversight of the residential cleanup as well as conducting independent sampling 

analysis. Sampling results from the residential cleanup indicate that short- and long-term 

exposures to sediments in the oil spill areas do not pose a public health hazard. Sampling results, 

activities performed, and recommendations for short-term protectiveness in the residential area 

are posted on EPA’s public Web site as the information becomes available. 

Under the National Response Plan, the U.S. Coast Guard is the lead agency for ESF #10 

responses in coastal zones, while EPA is the lead agency for inland zones. For incidents 

affecting both zones, EPA serves as the lead agency. ESF #10 responsibilities include 

appropriate response and recovery actions to prepare for, prevent, minimize, or mitigate a threat 

to public health, welfare, or the environment caused by actual or potential oil and hazardous 

8
 

Figure 3 - Storm-damaged UST in Mississippi. 

(Source: MDEQ) 

Figure 4 - Twisted UST vent lines in a debris pile. 

(Source: MDEQ) 
Figure 5 - Murphy Oil and adjacent residential area. (Source: EPA) 

materials incidents. Response and recovery actions include efforts to detect, identify, contain, 

clean up, or dispose of released oil and hazardous materials. 

Since most of the hurricane-related oil spills occurred at facilities in the coastal zones near the 

Mississippi River south of the New Orleans area, the U.S. Coast Guard served as the primary 

agency for response and recovery actions. As shown in Table 1, EPA identified at least five 

major oil spills, with the total spill volume approaching 7.5 million gallons (about two-thirds as 

much oil spilled from the Exxon Valdez tanker in 1989). 

Table 1 - Louisiana Oil Spills 

Facility Name Location Gallons 

Bass Enterprises Cox Bay, Plaquemines Parish 3,780,000 

Chevron Empire Terminal Buras, Plaquemines Parish 1,428,000 

Shell Oil Pilottown, Plaquemines Parish 1,066,800 

Murphy Oil Meraux, St. Bernard Parish 1,050,000 

Shell Pipeline Oil LP Nairn, Plaquemines Parish 138,600 

TOTAL 7,463,400 

Additionally, the U.S. Coast Guard estimated that approximately 134 spills of less than 100,000 

gallons also occurred. 

Murphy Oil, ranking fourth in spill volume, could be considered the most significant of the 

spills, due to it being adjacent to a residential neighborhood. Over 1 million gallons of oil were 

released when an above ground storage tank was dislodged, lifted, and damaged by floodwaters 

(see Figure 5). The release impacted over 1,800 homes in more than a 1-mile radius, as well as 

in surrounding canals and Murphy’s tank farm containment area. 

The U.S. Coast Guard, with 

support from EPA, conducted 

initial response and assessment 

efforts at the Murphy Oil spill 

site. Subsequently, the Coast 

Guard and EPA split lead 

responsibilities for oversight 

of Murphy’s cleanup activities at 

the site. The Coast Guard agreed 

to provide oversight of the 

removal of free oil in the canals, 

tank farm containment area, 

neighborhood streets, and storm 

drains. EPA agreed to provide 

oversight of cleanup in 

residential areas accessible to the 

public (e.g., parks, school yards, 

roads, highway median strips, 

and sidewalks). 

9
 
EPA, working closely with LDEQ, is also overseeing ongoing sampling activities of residential 

and other properties, and is performing independent analysis of samples taken by Murphy Oil 

under EPA oversight. As of March 13, 2006, EPA had collected 745 quality assurance/quality 

control split samples from 7,200 interior and exterior sediment samples gathered at 4,252 

addresses by Murphy Oil. The results of EPA’s sampling activities show that the primary 

contaminants detected include arsenic, PAHs, and diesel and oil range organic chemicals. 

EPA provided its sample results to ATSDR for evaluation and notification to the public. 

ATSDR concluded that short- and long-term exposures to sediments in the oil spill area below 

LDEQ RECAP standards do not pose a public health hazard. However, ATSDR recommended 

that returning residents should avoid direct contact with the oil contaminated sediments, as they 

may cause skin irritation. Sample results, activities performed, and recommendations for shortterm protectiveness are posted on EPA’s public Web site5

 as the information becomes available. 

EPA Provided Quality and Timely Information and Actions Regarding 

Management of Hazardous and Non-Hazardous Debris and Waste 

EPA established an effective hazardous 

and non-hazardous debris and waste 

management approach which facilitated 

quality and timely information 

dissemination and hazardous debris 

management activity. EPA distinguished 

between hazardous and non-hazardous 

debris and waste and is ensuring 

consistency in segregation through its 

management of hazardous wastes and 

oversight assistance at non-hazardous 

landfills and staging areas. EPA’s 

partnership with States and other 

regulatory agencies contributed to the 

effective management of hazardous debris 

and the safeguarding of individuals and 

the environment from risks arising from 

the improper removal and disposal of hazardous debris and waste. Specifically, EPA’s debris 

management activities include: 

x Direct oversight of hazardous waste management. 
 

x Management of household hazardous waste collection. 
 

x Management of electronics collection. 
 

x Management of white goods, including removal and recycling of Freon. 
 

x Oversight of the segregation of hazardous and non-hazardous waste and debris. 
 

x Guidance to State and local governments in managing non-hazardous solid waste. 
 

5

 EPA’s Public Web site for Murphy Oil Spill - http://www.epa.gov/katrina/testresults/murphy/index.html 

Figure 6 - Debris field resulting from storm surge through a 

residential neighborhood in Waveland, Mississippi. 

(Source: EPA OIG) 

10
 
Hazardous Debris Management 

EPA has provided quality and timely oversight, assistance, and guidance to ensure consistency in 

the management of hazardous hurricane debris and waste throughout the affected areas in 

Louisiana and Mississippi. EPA has directly managed hazardous waste, including household 

hazardous waste; electronics; and white goods. EPA quickly established a plan to address the 

segregation, collection, and disposal of hazardous waste. EPA’s hazardous waste and debris 

collections used established collection and drop-off sites as well as neighborhood sweeps. EPA 

collaborated to organize household hazardous waste and electronic waste collection campaigns 

in individual parishes in Louisiana and counties in Mississippi, distributing over 2 million flyers 

in Louisiana alone, and using other media to advertise these events. An example of a household 

hazardous waste collection flyer is in Appendix D. EPA also promptly provided advisories, and 

public service announcements and public outreach materials in multiple languages, to inform the 

community of potential hazards and debris disposal options. In addition to general public 

collections, EPA is collecting segregated hazardous debris and waste directly from nonhazardous debris landfills and staging areas. EPA is also conducting marsh and wetland 

reconnaissance to retrieve hazardous debris and alleviate potential environmental threats. 

Hazardous debris management varies slightly across the affected States due to the differing 

nature of the hurricane’s impact. For example, the storm surge in Mississippi complicates the 

segregation of hazardous from non-hazardous debris because the surge caused explosive-like 

destruction and debris became 

intermingled. On the other hand, because 

Louisiana was mostly impacted by 

floodwaters that have receded, debris is 

generally recognizable for proper 

segregation purposes. EPA’s collection 

efforts in Louisiana have included an 

emphasis on segregation at pickup, which 

includes segregating at the residential 

level. Instructions to Louisiana residents 

(where they have returned) on how to 

segregate their waste are illustrated in 

Appendix E. 

Examples of EPA’s management of 

hazardous debris, segregated into the 

categories of hazardous waste, electronics, 

and white goods, are: 

Hazardous Waste: EPA managed hazardous waste in Louisiana and Mississippi by 

establishing multiple collection sites in each State. These sites receive hazardous waste and 

segregate the waste for disposal as hazardous waste or recycling, according to the type of 

waste. In addition, both Louisiana and Mississippi, in collaboration with EPA, advertised 

and held household hazardous waste collection events. Waste that includes leftover 

household products that contain corrosive, toxic, ignitable, or reactive ingredients is 

11
 

Figure 7 - Segregation of household hazardous waste at an 

EPA collection site. (Source: EPA OIG) 

x
Figure 8 - EPA hazardous waste collection volume. 

(Source: EPA OIG analysis of data from EPA Situation Reports) 

Hazardous Waste 

(cumulative number of drums, propane tanks, cylinders, small containers, batteries, etc.) 

3,000,000 

2,500,000 


 2,000,000
 

1,500,000
 Mississippi 

Louisiana 

1,000,000
 

500,000
 

0
 

Sept 05 Oct 05 Nov 05 Dec 05 Jan 06 Feb 06 

considered to be household hazardous waste. Examples are batteries, paint, pool supplies, 

lawn and automotive products, and other household chemicals such as bleach and carpet 

cleaners. Improper 

disposal of these wastes ca

pose risks to human health 

and the environment. 

As shown in Figure 8, EPA

collected over 2.5 million 

hazardous waste units since

September 2005. These 

units include household 

hazardous waste from
 

collections and segregation 

efforts, and also include 

other types of hazardous 

waste such as drums, 
 

cylinders, and larger 
 

containers.
 

n

x	 Electronic Waste: Electronic devices contain varying amounts of lead and other heavy 

metals considered hazardous to human health, and proper disposal (including recycling) 

needs to be considered. Common 

examples of electronic waste are 

televisions, radios, stereos, cameras, 

VCRs, computers, and microwave 

ovens. Over 300,000 electronics devices 

have been collected in Louisiana through 

electronics recycling contracts. During 

the course of our review, we suggested 

that EPA provide consistent information 

to the impacted public on potential 

hazards in electronic goods, particularly 

for those that cannot be recycled or 

collected and those that may remain in 

damaged homes. We also suggested that 

EPA better inform the public about the 

means of disposal throughout the 

affected parishes. EPA implemented 

these suggestions and they have been 

reflected in subsequent collection 

campaigns. 

x	 White Goods: White goods are appliances, such as refrigerators and air conditioners, that 

may contain hazardous substances such as Freon, compressor oil, and mercury switches. Up 

to 1 million white goods may require processing in Louisiana. EPA has been collecting 

12
 

Figure 9 - Electronic waste at curbside. 

(Source: EPA OIG) 
white goods to minimize the 

amount of hazardous substances 

that may accompany debris into 

landfills. As indicated in Figure 

11, in Louisiana EPA has 

processed over 300,000 white 

goods and removed Freon from 

over 280,000. In contrast to 

Louisiana, where white goods 

remain largely intact, white goods 

in Mississippi are more difficult to 

segregate and manage due to the 

destructive nature of the storm 

surge, which typically damaged 

and intermingled white goods with other debris. 

Figure 10 – EPA contractors removing contents and 

recycling Freon from refrigerators at Old Gentilly landfill in 

Louisiana. (Source: EPA OIG) 

0 

50,000 

100,000 

150,000 

200,000 

250,000 

300,000 

350,000 

Nov 05 Dec 05 Jan 06 Feb 06 

Louisiana White Goods Collection 

No Freon 

Freon 

Figure 11 –White goods collection volume. 
 

(Source: OIG analysis of EPA Situation Reports) 
 

Non-Hazardous Debris Management 

EPA has provided quality and timely oversight, assistance, and guidance to ensure consistency in 

the management of non-hazardous hurricane debris and waste throughout the affected areas in 

Louisiana and Mississippi. EPA is ensuring consistency in the distinction of debris and waste 

provided to States and local agencies. This is being accomplished through EPA’s oversight in 

the segregation of hazardous debris from non-hazardous debris at landfill and staging areas. 

13
 
Under ESF #3-Public Works and Engineering, the U.S. Army Corps of Engineers is the lead 

Federal agency6

 for the management of non-hazardous debris, with support from EPA and other 

agencies. Debris management activities under ESF #3 include managing, monitoring, and/or 

providing technical advice in the clearance, removal, and disposal of contaminated and 

uncontaminated debris from public property. 

Uncontaminated debris includes: 

x Vegetative debris (trees, bushes, and shrubs, etc.) 

x Municipal Solid Waste (typical household and commercial garbage) 

x Construction and demolition debris (resulting from damaged buildings and structures) 

In November 2005, a fire occurred at a staging area for non-hazardous debris at a construction 

and demolition debris landfill operated by St. Bernard Parish. The fire resulted from the 

commingling of a hazardous substance with other non-hazardous debris and waste. EPA’s 

Region 6 Response Group provided oversight, equipment operators, and fire suppression 

operations at the site until the ignition source was located, removed from the debris, and 

prepared for appropriate disposal. Simultaneously, EPA took action to prevent a similar-type 

fire from occurring at the household hazardous waste collection site in another section of the 

landfill. These actions included: spot checking all loads coming into the landfill, additional 

monitoring of contractor technicians, and installing large signs at entrances to the parish 

notifying residents to separate household hazardous waste at the curb. To ensure that appropriate 

controls and oversight are in place at the St. Bernard Parish landfill staging areas, we suggested 

that EPA work closely with FEMA, LDEQ, and the parish to ensure that the landfill has 

implemented controls, and to verify that appropriate controls are in place at all landfills in 

Louisiana accepting hurricane debris and waste. EPA placed representatives at the St. Bernard 

landfill to monitor incoming waste streams and perform random inspections on trucks entering 

the site. For other Louisiana parishes, EPA and LDEQ agreed to institute more frequent 

unannounced observation of operations and to document the results on a regular basis. 

6 While U.S. Army Corps of Engineers is the lead for debris management, some local agencies (e.g., parishes, 

counties) have elected to perform their own debris management activities with FEMA oversight and reimbursement 

assistance. 

14
 
 Appendix A 

National Response Plan 
 

Emergency Support Functions Supported by EPA 
 

EPA and other Federal agencies work within the National Response Plan framework to ensure that work 

needed to help recover from disasters, such as hurricanes, is carried out. Specific missions are assigned 

through Emergency Support Functions (ESFs). EPA supports ESFs as shown below. 

ESF EPA’s role may include: 

ESF #3 – Public Works and 

Engineering 

Infrastructure protection activities for drinking water and 

wastewater facilities; assistance in determining suitability of 

drinking water sources; location of disposal sites for debris 

clearance activities; and assessments, technical assistance, and 

monitoring for contaminated debris management 

ESF #4 – Firefighting Technical assistance for fires involving hazardous materials and 

also assistance in identifying uncontaminated water sources for 

firefighting. 

ESF #5 – Emergency 

Management 

Support to the Joint Field Office and provision of staff liaisons 

and technical experts. Joint Field Office is a temporary Federal 

facility established locally to provide a central point to coordinate 

resources in support of State, local, and tribal authority. 

ESF #8 – Public Health and 

Medical 

Technical assistance and environmental information for 

health/medical aspects of hazardous materials situations, 

technical assistance regarding drinking water supplies, and 

assistance identifying water supplies for critical care facilities. 

ESF #10 – Oil and Hazardous 

Materials Response 

Detection, identification, containment, cleanup, or disposal of 

released oil or hazardous materials; removal of drums, barrels, 

tanks, or other bulk containers that contain oil or hazardous 

materials; collection of household hazardous waste; permitting 

and monitoring of debris disposal; monitoring and protection of 

water quality; sampling and monitoring of air quality; and 

protection of natural resources. 

ESF #11 – Agriculture and 

Natural Resources 

Technical assistance for biological and chemical agents 

regarding environmental monitoring, contaminated 

crops/animals, and food/product decontamination. 

ESF #12 – Energy Response to State/local requests for fuel waivers to address fuel 

shortages. 

ESF #13 – Public Safety 

and Security 

Assistance through specialized evidence response teams who 

can work in a contaminated environment, investigation of 

criminal violations of environmental statutes, and forensic 

analysis of industrial chemicals. 

ESF #14 – Long-Term 

Community Recovery 

Technical assistance for planning for contaminated debris 

management and environmental remediation. 

ESF #15 – External Affairs Appropriate support as required. 

15
 
Appendix B 

Details on Scope and Methodology 

To determine the quality of EPA’s information on the identification of operational facilities, we 

identified facilities from various EPA data systems and compared them to the facilities identified 

and assessed by Regions 4 and 6. The data systems are provided in Table 2. 

Table 2- Federal databases used to analyze the identification of operational facilities 

System Contains information on: 

Toxic Release Inventory Businesses that manufacture, process, or otherwise use above the 

threshold level of a listed chemical. Includes pounds of chemicals 

released to air, water, and land. 

Risk Management Plans Businesses that use specified flammable and toxic substances. 

Includes hazard assessments with a worst-case scenario, prevention 

programs, and emergency response programs. 

Biennial Reports on 

hazardous waste 

Quantitative hazardous waste generation and disposal volumes from 

large generators and treatment, storage, and disposal facilities. 

Inventory Update Rule Manufacturing volumes from large chemical manufacturers. 

Section Seven Tracking 

System 

Production volumes of pesticides reported by pesticide 

manufacturers. 

National Response Center 

discharges reported 

Oil spills or chemical releases. 

To determine the quality and timeliness of EPA’s information on Superfund NPL sites, we 

examined EPA’s Superfund database (Comprehensive Environmental Response, Compensation, 

and Liability Information System, or CERCLIS) to identify sites in the affected areas of 

Mississippi and Louisiana. We then compared the OIG listing of sites to those sites identified 

for assessment by Regions 4 and 6. We reviewed Region 4’s quality assurance plan7 and sample 

results, as well as information provided to the public on the EPA’s Web site. We reviewed the 

associated timeframes for these items in relationship to the Hurricane to determine the timeliness 

of EPA’s efforts. 

Our evaluation of EPA’s information on oil spills was limited to the residential cleanup for the 

Murphy Oil spill. We identified major and medium oil spills, and the identification of the lead 

Federal agency (Coast Guard or EPA) through EPA Region 6 Situation Reports8 and the Coast 

Guard’s Web site. In addition, we identified and reviewed EPA’s lead oversight activities at the 

Murphy Oil spill, including information on EPA’s Web site. We also reviewed the ATSDR 

health consultant reports on the Murphy Oil spill to identify impacts or potential impacts on 

human health and the environment. We did not evaluate how the Coast Guard determined the 

7

 Region 4’s Quality Assurance Project Plan, Post-Katrina Site Evaluations, Southern and Coastal Alabama and 
 

Mississippi, October 2005-sampling plan that includes sampling/data quality objectives, investigation management 
 

plan, sampling design and rationale, quality assurance requirements, and investigation results. 
 8

 Situation Reports are internal briefing documents used by the Regions to document and track operational activities. 
 

16
 
nature, magnitude, and impact from oil spills on human health and the environment as presented 

in our first question. 

The States, and not EPA, are responsible under their delegated programs for the identification 

and assessment of USTs. We therefore did not evaluate the quality and timeliness of information 

provided. Our work in this area was limited to the review of UST guidance and regulations for 

the purpose of gaining an understanding of USTs and EPA’s and the States’ authorities under the 

program. In addition, we obtained information on the number of USTs in the affected areas and 

the status of the States’ initial damage assessments. This information was obtained directly from 

the Regions, the States, and/or Situation Reports. 

To determine the quality and timeliness of EPA’s information on sediment contamination in 

New Orleans, we reviewed Region 6’s emergency response quality assurance sampling plan for 

sediments, as well as EPA’s Science Advisory Board9 comments on the proposed plan. In 

addition, we reviewed sediment sampling information provided in the Region 6 Situation 

Reports and information provided for the public via EPA and LDEQ Web sites. We reviewed 

the associated timeframes for these items in relationship to the Hurricane to determine the 

timeliness of EPA’s efforts. 

Our general approach for answering our second question, regarding management of hazardous 

and non-hazardous debris and waste, was to identify relevant activities in the affected States and 

the underlying information needed to manage this debris and waste. We collected and analyzed 

operational and response-related information about how these activities were performed or how 

information was obtained. The activities and information reviewed pertained to waste 

characterization and segregation, landfill capacity, staging and burning facilities, tracking of 

debris and waste, waivers, and FEMA and U.S. Army Corp of Engineers debris management. 

To determine whether EPA was providing timely and quality information and actions regarding 

distinctions between hazardous and non-hazardous hurricane debris and waste and whether the 

distinctions were being made consistently, we conducted interviews with various EPA 

headquarters program officials, Region 4 and 6 program officials, and State officials. We 

researched EPA and State Web sites to obtain information, guidance, and authorities that 

generally pertained to debris management. This information included the National Response 

Plan, Situation Reports, State and Federal regulations, FEMA Mission Assignments, emergency 

orders and State guidance documents, Recycling Electronics and Asset Disposition documents, 

public notices/flyers, State landfill lists, maps, and news articles. We reviewed the associated 

timeframes for these items in relationship to the Hurricane to determine the timeliness of EPA’s 

efforts. To enhance our understanding of the complexity of the segregation of debris and waste 

in the affected areas, we visited selected landfills and staging areas in Mississippi and Louisiana 

to see if these distinctions were being implemented and how the various types of hazardous and 

non-hazardous waste were segregated and managed. We did not conduct interviews with FEMA 

or the U.S. Army Corps of Engineers regarding their activities related to the management of 

hazardous and/or non-hazardous debris. 

9 Congress established the EPA Science Advisory Board in 1978 and gave it a broad mandate to advise the Agency 

on technical matters, advising the Agency on emergency and other short-notice programs. 

17
 
 Appendix C 

Sediment Sampling Sites 

in Flooded Areas of New Orleans 

18
 
 Appendix D 

Mississippi Household Waste Collection Flyer 

19
 
Appendix E 

Curbside Waste Segregation Instructions 

20
 
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

WASHINGTON, D.C. 20460 

Appendix F 

OFFICE OF 

SOLID WASTE AND 

EMERGENCYRESPONSE 

MEMORANDUM 

SUBJECT: Draft Evaluation Report: 

EPA Provided Quality and Timely Information on Hurricane Katrina 

Hazardous Releases and Debris Management 

Assignment No. 2005-00175 1 

FROM: Sus 

Assistant Administrator 

TO: Bill A. Roderick 

Acting Inspector General 

Thank you for the opportunity to review the draft report on the subject evaluation 

conducted by the Environmental Protection Agency's (EPA) Office of Inspector Gencl-al 

(OIG). EPA's response to Hurricane Katrina has been a major undertaking, involving 

staff from across the country and at Headquarters. As you note in the draft report, EPA 

has worked with the Federal Emergency Management Agency (FEMA) and other 

Federal, State and local agencies, providing support under various Emergency Support 

Functions (ESF) in the National Response Plan. The response to Hurricane Katrina was 

also an opportunity for EPA to implement its National Approach to Response, including 

the use of the Incident Command System and support to Regions 4 and 6 by professiosial 

responders and volunteers from several other Regions. 

This response includes the Regions' comments as well. 

I acknowledge and agree with OIG's positive assessment of: (1) EPA's quality 

and timely approaches for rapidly identifying, prioritizing, and assessing the nature, 

magnitude and impact of hazardous material releases; and (2) EPA's provision of quality 

and timely information for determining risks and impacts. We provided information to 

the public on our Website as well as in printed flyers distributed in the area affected by 

Katrina. 

I also acknowledge with appreciation that OIG provided suggestiosis to EPA 

concerning better informing the public about the means of disposal of electronic waste 

(page 12) and concerning controls at the St. Bernard Parish landfill staging areas (pagc 

14). 

Internet Address (URL) http://www.epa.gov 

Recycled/Recyclable Printed with Vegetable Oil Based Inks on 100% Postconsumer, Process Chlorine Free Recycled Paper 

21 
Replying to your request in your April 7, 2006, memorandum that I address the 

factual accuracy of the draft report, I offer the following comments: 

1. On page 2 the report references the "Oil Pollution Control Act of 1990." I believe 

that "Control" is not part of the name of that legislation. 

2. On page 5, paragraph 3 concerning "should an area be found to pose an 

unacceptable risk," it would be more accurate to say that we will work with the 

State of Louisiana to "determine appropriate next steps." 

3. On page 8 the report states: "Under the National Response Plan, the U.S. Coast 

Guard is the lead agency for ESF #10 responses in coastal zones, while EPA is the 

lead agency for inland zones." You might want to modify the first sentence in the 

"At a Glance" page to indicate that EPA's leadership is in the inland zones. 

4. On page 10, first paragraph: the first sentence states that "EPA . . . is performing 

independent sampling activities . . ." in the residential area. This is not accurate. 

We suggest: "EPA . . . is performing independent analysis of samples taken by 

Murphy Oil with EPA oversight." 

5. On page 10, second paragraph: the second sentence should be corrected for 

accuracy with the addition of the phrase as follows: "ATSDR concluded that 

short- and long-term exposures to sediments in the oil spill area below LDEQ 

RECAP standards do not pose a public health hazard." 

6. On page 10, the last bullet on the page: We give guidance for solid waste, but our 

oversight is limited to the segregation of hazardous and non-hazardous waste. 

7. On page 13, last paragraph: please refer to the above comment. We suggest 

deleting "and assistance in non-hazardous debris management, particularly." The 

last sentence would then read, "This is being accomplished through EPA's 

oversight in the segregation of hazardous debris from non-hazardous debris at 

landfill and staging areas." 

8. The report discusses sediment sampling, but does not mention that we also 

sampled flood water (474 samples) and soil (645 samples). We are also doing 

extensive and continuous air sampling, with results being reported on EPA's 

Katrina web site. If you want to use the most current numbers for sediment, as of 

April there are 1410 samples in the database. 

Should you have questions, please call Deborah Dietrich, Director of the Office of 

Emergency Management, at 202-564 8600. 

cc: Richard Greene, Regional Administrator, Region 6 

Jimmy Palmer, Regional Administrator, Region 4 
Appendix G 

Distribution 

EPA Headquarters 

Office of the Administrator 

Assistant Administrator, Office of Solid Waste and Emergency Response 

Agency Followup Official (the CFO) 

Agency Followup Coordinator 

Audit Followup Coordinator, Office of Solid Waste and Emergency Response 

Associate Administrator for Congressional and Intergovernmental Relations 

Associate Administrator for Public Affairs 

General Counsel 

Acting Inspector General 

EPA Region 4 

Regional Administrator 
 

Deputy Regional Administrator 
 

Regional Audit Followup Coordinator
 

EPA Region 6 

Regional Administrator 
 

Deputy Regional Administrator 
 

Regional Audit Followup Coordinator
 

23