OFFICE OF INSPECTOR GENERAL 

Catalyst for Improving the Environment 

Evaluation Report 

Lessons Learned: 

EPA’s Response to 

Hurricane Katrina 

 Report No. 2006-P-00033 

 September 14, 2006 
Report Contributors: Jim Hatfield 

 Geoffrey Pierce 

 Tim Roach

 Steve Schanamann

 Carolyn Blair

 Renee McGhee-Lenart 

 Julie Hamann

 Gerry Snyder 

 Steve Hanna

 Angela Bennett 

 Rick Beusse

 Dan Engelberg 

 Carolyn Copper 

Abbreviations 

ATSDR Agency for Toxic Substances and Disease Registry 

EPA U.S. Environmental Protection Agency 

ESF Emergency Support Function 

LDEQ Louisiana Department of Environmental Quality 

MDEQ Mississippi Department of Environmental Quality 

NPDES National Pollutant Discharge Elimination System 

NRP National Response Plan 

OIG Office of Inspector General 

PCIE President’s Council on Integrity and Efficiency 

RECAP Risk Evaluation/Corrective Action Program 

USACE U.S. Army Corps of Engineers 

Cover photo: Hurricane destruction in Biloxi, Mississippi, with water tower in background 

(EPA OIG staff photo). 
U.S. Environmental Protection Agency 2006-P-00033

Office of Inspector General September 14, 2006

At a Glance 

Catalyst for Improving the Environment 

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. 

Based on our prior reviews of 

the U.S. Environmental 

Protection Agency’s (EPA’s) 

response to Katrina, this report

identifies lessons learned from 

the Katrina response. We also 

examined whether EPA 

followed its emergency

response protocols, including 

those lessons learned from the 

World Trade Center collapse 

and the Agency’s

responsibilities as delineated in 

the National Response Plan, in

responding to Katrina. 

Why We Did This Review 

Background 

On August 29, 2005, Hurricane 

Katrina made landfall on the 

Mississippi coast. Katrina 

devastated the Gulf Coast of 

Mississippi and Southeastern 

Louisiana, and caused 

extensive flooding in New 

Orleans and extensive damage

to the environmental 

infrastructure in the region. 

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/ 

20060914-2006-P-00033.pdf 

Lessons Learned: EPA’s Response to 

Hurricane Katrina

 What We Found 

In our prior reports on EPA’s response to Katrina, we reported that EPA, 

Mississippi, and Louisiana took extraordinary efforts to assess and restore public 

drinking water supplies after Hurricane Katrina, and that EPA provided timely 

and quality information to address wastewater and hazardous materials and debris 

concerns. EPA generally followed its emergency response protocols to ensure 

that environmental concerns were addressed. Further, the actions taken by EPA 

and the States in response to Hurricane Katrina generally improved upon the 

lessons learned from EPA’s response to the World Trade Center collapse. EPA 

officials told us that planning and good working relationships with State officials 

were key factors in responding successfully to this emergency. While these 

efforts were generally successful, we identified three lessons learned. 

• Coordination within EPA, with State and local officials, and with the 

U.S. Army Corps of Engineers (USACE) could have been better. In some 

instances, coordination problems resulted in duplicative work being 

completed by EPA and Louisiana officials. EPA Region 4 and USACE 

officials confirmed the need for more interaction between USACE and EPA 

before the next emergency. 

• Initially, there were problems in New Orleans with the transport of drinking 

water in potentially hazardous tanker trucks. The Louisiana Department of 

Health and Hospitals, with assistance from EPA Region 6, established 

procedures, and EPA issued an administrative order to correct this situation in 

early October 2005. No adverse health effects were identified. 

• State of Louisiana officials reported problems querying and verifying the 

quality of data in EPA’s database used to collect floodwater results. 

EPA Regions 4 and 6 have initiated actions to address the issues noted in this 

report for responding to future disasters.

 What We Recommend 

We recommend that the Assistant Administrators for the Office of Solid Waste 

and Emergency Response and Office of Water, as part of the Agency's efforts to 

address lessons learned from Katrina, ensure that the corrective actions discussed 

in this report are implemented. EPA generally agreed with our recommendation. 
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

WASHINGTON, D.C. 20460 

OFFICE OF 

INSPECTOR GENERAL

September 14, 2006 

MEMORANDUM 

SUBJECT: Lessons Learned: EPA’s Response to Hurricane Katrina 

Report No. 2006-P-00033 

TO: Susan Bodine 

 Assistant Administrator for Solid Waste and Emergency Response 

 Benjamin H. Grumbles 

 Assistant Administrator for Water 

 James I. Palmer, Jr. 

 Regional Administrator, EPA Region 4 

Richard Greene 

Regional Administrator, EPA Region 6 

This is our final report on lessons learned during the U.S. Environmental Protection Agency’s 

(EPA’s) response to Hurricane Katrina. This evaluation contains findings that describe the 

problems the Office of Inspector General (OIG) has identified and corrective actions the OIG 

recommends. This evaluation report represents the opinion of the OIG and the findings 

contained in this report do not necessarily represent the final EPA position. Final determinations 

on matters in this evaluation report will be made by EPA managers in accordance with 

established resolution procedures. 

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

applicable daily full cost billing rates in effect at the time – is $59,440. 

Action Required 

EPA’s response to our draft report, dated August 22, 2006, addresses our findings and 

recommendation. Therefore, in accordance with EPA Manual 2750, we are closing out this final 

report upon issuance. As outlined in EPA Manual 2750, Agency management is responsible for 

tracking implementation of the recommendation in its Management Tracking System. We have 

no objections to the further release of this report to the public. For your convenience, this report 

will be available at http://www.epa.gov/oig. 
If you or your staff have any questions regarding this report, please contact Rick Beusse, 

Director for Program Evaluation, Air Issues, at (919) 541-5747 or beusse.rick@epa.gov; or Jim 

Hatfield, Assignment Manager, at (919) 541-1030 or hatfield.jim@epa.gov. 

Sincerely, 

Bill A. Roderick 

Acting Inspector General 
Lessons Learned: EPA’s Response to Hurricane Katrina 

Table of Contents 

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

Scope and Methodology......................................................................................... 1 

Lessons Learned..................................................................................................... 2 

Coordination within EPA and with Others .................................................................. 3 

Use of Tanker Trucks to Transport Water.................................................................. 6 

Problems Using EPA’s SCRIBE Database ................................................................ 7 

Other Katrina Lessons Learned Reviews.............................................................. 7

Recommendation............................................................................................. 8 

Agency Response.................................................................................... 8

OIG Comment................................................................................................ 8

Status of Recommendations and Potential Monetary Benefits....................... 9 

Appendices 

A Hurricane Katrina Response in Relation to Lessons Learned 

from the EPA OIG World Trade Center Report........................................... 10

 Risk Communication ...................................................................................... 10 

Sampling for Environmental Contaminants .................................................... 12 

 Monitoring Capabilities ................................................................................... 14

 Short-Term Exposure Guidelines/Standards.................................................. 15 

Roles and Responsibilities ............................................................................. 17 

Handling of Competing Concerns................................................................... 18 

B Agency Response...................................................................................... 19

 C 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 Hurricane Katrina. 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 will be 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 EPA Office of Inspector General (OIG) 

conducted three separate evaluations related to EPA’s response that resulted in four separate 

reports: 

• Drinking Water - EPA’s and Mississippi’s Efforts to Assess and Restore Public Drinking 

Water Supplies after Hurricane Katrina (Report No. 2006-P-00011), February 14, 2006; 

and EPA’s and Louisiana’s Efforts to Assess and Restore Public Drinking Water Supplies 

after Hurricane Katrina (Report No. 2006-P-00014), March 7, 2006. 

• Wastewater - EPA Provided Quality and Timely Information Regarding Wastewater 

after Hurricane Katrina (Report No. 2006-P-00018), March 28, 2006. 

• Hazardous Waste and Debris - EPA Provided Quality and Timely Information on 

Hurricane Katrina Hazardous Material Releases and Debris Management (Report No. 

2006-P-00023), May 2, 2006. 

This memorandum addresses the fifth and final question of our drinking water evaluation – 

whether EPA followed its emergency response protocols, including those lessons learned from 

the World Trade Center collapse and its responsibilities as delineated in the National Response 

Plan (NRP), in responding to the Katrina disaster. Although this objective was not included in 

the scope of our other Katrina-related evaluations, this report includes relevant observations from 

those evaluations regarding our objective. In addition, this report presents lessons learned 

identified from all three Katrina-related evaluations. 

Scope and Methodology 

To assess whether EPA followed its emergency response protocols in responding to 

environmental concerns after Hurricane Katrina, we reviewed the NRP, EPA mission 

assignments, and recommendations related to lessons learned in the EPA OIG’s World Trade 

Center evaluation report.1

 Lessons learned were identified through interviews with EPA, State, 

and local officials. 

We compared EPA’s drinking water-related activities in responding to Hurricane Katrina to the 

roles and responsibilities identified in the NRP and mission assignments, and to the lessons 

1

EPA’s Response to the World Trade Center Collapse: Challenges, Successes, and Areas for 

Improvement (Report No. 2003-P-00012), August 21, 2003. 

1 
learned from the World Trade Center report response. We interviewed officials from EPA 

Region 4 (responsible for Mississippi) and Region 6 (responsible for Louisiana); the U.S. Army 

Corps of Engineers (USACE) in Vicksburg, Mississippi; the Louisiana State Department of 

Health and Hospitals; the Mississippi State Department of Health; and selected public drinking 

water systems in Louisiana and Mississippi. 

We also reviewed the results of our Wastewater and Hazardous Waste and Debris evaluations for 

information and observations relevant to the question of whether EPA followed the NRP and 

addressed lessons learned from the World Trade Center collapse in those responses. Those 

results were based on interviews with officials from the Louisiana Department of Environmental 

Quality (LDEQ) and Mississippi Department of Environmental Quality (MDEQ). We visited 

impacted areas in Louisiana and Mississippi, including wastewater treatment facilities, landfill 

sites, and a Superfund site. 

This report does not represent a comprehensive review of potential lessons learned during EPA’s 

response to Katrina, but is based upon issues brought to our attention during our prior reviews. 

In addition, only our drinking water evaluation included the objective to review EPA’s 

compliance with the NRP and lessons learned from the World Trade Center response; thus, our 

wastewater and hazardous waste and debris management evaluations were not designed to 

answer that objective. 

We conducted our field work from October 2005 through March 2006. This evaluation was not 

conducted in accordance with Government Auditing Standards, issued by the Comptroller 

General of the United States, but instead was a compilation of evaluations that were generally 

conducted in accordance with Government Auditing Standards. 

Lessons Learned 

Our four prior reports on EPA’s response to Katrina discussed examples where EPA’s response 

was generally successful. For example, EPA drinking water officials and their State, water 

system, and third party counterparts in Louisiana and Mississippi took extraordinary efforts to 

ensure that public water service was restored. These systems were cleared from boil water 

notices only after the States determined the drinking water systems could provide the public with 

safe drinking water. In our wastewater evaluation report, we noted that EPA provided quality 

and timely information regarding wastewater to States, wastewater treatment officials, and the 

general public. Further, in handling hazardous material and debris, we noted that EPA 

coordinated with State, local, and other Federal government agencies to rapidly identify, 

prioritize, and assess the nature, magnitude, and impact of hazardous material releases. EPA also 

provided quality and timely information and actions regarding the management of hazardous and 

non-hazardous debris and waste. 

Regional officials told us that the primary reasons the response to restoring drinking water 

supplies worked well were the good working relationships and collaborative planning between 

the State agencies and EPA regions prior to Hurricane Katrina. As a result of this planning, EPA 

staff were deployed to the impacted areas during the early stages of the hurricane response. This 

deployment included staff from other EPA regions who volunteered to assist State drinking 

2 
water programs. Other factors that contributed to an effective response included the use of 

common reporting protocols for tracking water system status, the deployment of EPA mobile 

laboratories and an EPA mobile command center, and the existence of protocols to notify the 

public about the boil water notices though various media outlets. 

EPA followed its emergency response protocols, as delineated in the NRP, to address drinking 

water concerns. Further, many of the concerns raised in EPA’s response to the collapse of the 

World Trade Center towers did not become significant issues in responding to Katrina. In some 

respects this can be attributed to the fact that EPA and States have experience in responding to 

hurricanes and have addressed lessons learned from those prior hurricanes. In our opinion, the 

importance placed on the lessons learned from the collapse of the World Trade Center towers by 

the EPA Administrator also helped EPA respond successfully to Hurricane Katrina. Key lessons 

learned from the World Trade Center response and how EPA’s actions in responding to Katrina 

correspond with those lessons learned are described in Appendix A. 

While EPA’s response after Hurricane Katrina was generally successful, lessons were learned 

during this response indicating where actions could be taken to improve future response 

operations. We identified three such issues during our evaluation. 

• Coordination within EPA, as well as EPA’s coordination with State and local officials 

and the USACE, could have been better. In some instances, coordination problems 

resulted in duplicative work being completed by EPA and Louisiana officials. 

• Initially, there were problems in New Orleans with the transport of drinking water in 

potentially hazardous tanker trucks. The Louisiana Department of Health and 

Hospitals, with assistance from EPA Region 6, established procedures and EPA issued 

an administrative order to correct this situation in early October 2005. No adverse 

health effects were identified. 

• Louisiana officials experienced problems in querying data and in verifying the quality 

of data in EPA’s database used to collect floodwater results. EPA Region 6 officials 

said that they have provided training and a Users Guide to State officials in order to 

correct this problem. 

The following sections discuss in detail these three issues and EPA’s efforts to address them. 

Coordination within EPA and with Others 

EPA officials told us that, in some instances, coordination could be improved for future disaster 

responses. Areas where coordination could be improved occurred with respect to both the 

drinking water and wastewater responses. 

Drinking Water Response 

EPA regional officials and USACE district officials informed us of coordination 

problems between the EPA and USACE at the beginning of the response. 

3 
USACE has lead responsibility for administering the NRP’s Emergency Support 

Function (ESF)-3. This ESF provides Federal support to address public works 

and infrastructure damage, including public drinking water systems, in an 

emergency. EPA has a support role under this ESF. 

EPA Region 6 officials said initial attempts to coordinate their drinking waterrelated work with the responsible USACE district were unsuccessful in part due to 

all of the parties’ limited understanding of each other’s roles in providing 

assistance under ESF-3. Region 4 officials noted the USACE district running the 

response in Mississippi was not aware of Region 4’s scientific and engineering 

expertise in problem-solving for drinking water and wastewater facilities 

damaged by a hurricane. Consequently, EPA Region 4 officials had to 

aggressively assert themselves into the process. 

A USACE district official confirmed that his organization was not fully aware of 

EPA’s expertise and experience with drinking water systems prior to Hurricane 

Katrina. This person indicated the need for more interaction between USACE 

and EPA before the next emergency was a lesson learned. According to EPA 

Region 4, prior experience with hurricanes improves coordination. For example, 

Region 4 officials noted the region had established a good working relationship 

with the USACE district responsible for hurricane response activities in Florida, 

and that the Florida USACE district is fully aware of EPA’s regional capabilities 

for assisting in drinking water system recovery. 

We found no evidence that hurricane response activities were negatively impacted 

by these coordination issues. For example, EPA Regions 4 and 6 used ESF-10 to 

obtain the necessary funding to get their personnel into the field. According to 

EPA Region 4 officials, ESF-10 (which EPA leads and involves responding to Oil 

and Hazardous Materials emergencies) was modified after prior hurricanes to 

provide initial response funding to allow EPA to quickly assess drinking water 

conditions after a hurricane. 

With respect to improving coordination with USACE, Region 6 told us that it 

plans to conduct a series of interagency planning meetings to establish 

coordination protocols under a Memorandum of Understanding with USACE. 

Similar efforts are also planned with the Federal Emergency Management 

Agency. In an effort to prepare for future events of national significance, 

Region 6 noted that there will be additional training for EPA Region 6 and State 

staff on the Incident Command System, the NRP, and ESF support functions. The 

February 2006 White House report, The Federal Response to Hurricane Katrina: 

Lessons Learned, also addressed this coordination issue, and recommends that 

agencies: 

. . . develop integrated operational plans, procedures and 

capabilities for their support to the base NRP and all ESFs and 

Support Annexes.... Each primary department or Agency for each 

4 
ESF and support annex should develop a detailed operations plan 

on how they will become operational and coordinate with other 

annexes and ESF’s during a major incident. 

Region 4 officials concurred that there is a need for EPA to play a more direct 

role in responding with USACE to water issues under ESF-3, similar to what is 

currently done with the U.S. Coast Guard support to EPA under ESF-10. 

Region 4 suggested a coordinated EPA effort, including headquarters support, to 

work with USACE to address mission assignments and interagency agreements. 

As it has done in the past for other hurricanes, Region 4 has started a lessons 

learned review that it plans to share with other EPA regions. 

Wastewater Response 

From our review of wastewater issues, we found at times that parts of EPA were 

not communicating. We also found that EPA could coordinate its work better 

with the States and with local wastewater facilities. According to LDEQ officials, 

parts of EPA – Region 6 National Pollutant Discharge Elimination System 

(NPDES) Permits and Region 6 Water Enforcement Branches – were not always 

talking or working together, and had asked for similar information from the State 

instead of coordinating with each other to get the information. According to 

LDEQ officials, there was also some duplication of effort in collecting 

information on the status of wastewater treatment facilities. EPA was primarily 

calling wastewater treatment facilities and Louisiana to determine the status of 

facilities. Louisiana was visiting facilities and flying aerial reconnaissance to 

determine the status of wastewater treatment facilities. However, the two 

agencies did not coordinate their efforts. 

According to Region 6 officials, the NPDES Permits and Water Enforcement 

Branches were jointly charged with putting together an assessment of the 

wastewater facilities in Louisiana. Region 6 noted that in the first few days there 

was a huge gap in the information available, and that staff were unable to contact 

the facilities themselves. As a result, EPA staff charged with getting the 

information utilized all the resources available to them, which included trying 

different points of contact. Region 6 officials believe these efforts may have led 

to some appearance of duplication of efforts. Region 6 officials further explained 

that within a week, as information became clearer, EPA assigned separate and 

specific followup tasks to personnel in the branches. Region 6 officials noted that 

both LDEQ and EPA had a statutory role in implementing the program. Both 

staffs were co-located in LDEQ offices in Baton Rouge, Louisiana, and staff 

freely shared information. With respect to both coordination issues discussed, 

Region 6 informed us that, to the extent there was any duplication of effort, it was 

only a result of an attempt to ensure that all wastewater facilities were reached, 

evaluated, and assisted as quickly as possible. 

5 
Communication is a key component of emergency response. In two instances 

brought to our attention, EPA visited two municipal wastewater facilities, asked if 

their facilities needed assistance, and were told that they needed generators. One 

facility never received the generators and the other received the generators too 

late to provide assistance. EPA officials informed us that they worked with 

USACE and Mississippi to develop a master list of needs that gave appropriate 

priority to water and wastewater services, and that the Army 249th Prime Power 

group that supports the USACE in providing generators for critical infrastructures 

used the master list. The EPA officials believe that the 249th power group used 

the master list to provide as timely service as possible to high and low priority 

facilities when scheduling daily site visits. 

EPA regional officials concurred that coordination issues existed following 

Hurricane Katrina. EPA Region 4 and 6 officials said that they have been 

proactive in taking steps to improve coordination for potential future disasters. 

According to Region 4 officials, Region 4 has or will be doing the following: 

• Providing training to senior officials on their roles and responsibilities in the 

incident command structure system; 

• Ensuring that additional resources are available for future disasters; 

• Establishing teams comprised of both drinking water and wastewater 

experts, which will be pre-deployed with the on-scene coordinators in future 

disasters; 

• Working with public health specialists who play a prominent role in national 

emergency situations; and 

• Working with its State partners to better document and define each agency's 

responsibilities and expectations for future disasters. 

Region 6 officials said they have established a senior liaison position between 

Region 6 and Louisiana, defined roles and responsibilities between EPA and the 

States, and developed a DVD that addresses emergency response activities. 

Use of Tanker Trucks to Transport Water 

Trucks were used to supply New Orleans hotels with water while the public drinking water 

system was inoperable. This water was pumped into hotel plumbing systems for use and 

consumption by hotel guests. There were concerns with the safety and suitability of the trucks 

used to transport this water. In some instances, water intended for public use was transported in 

tanker trucks previously used in oil fields or other commercial activities. 

EPA and the Louisiana Department of Health and Hospitals addressed the problem of improper 

water handling once it was discovered. Louisiana posted procedures to prevent potentially 

contaminated water trucks from delivering drinking water to hotels. At the request of the 

Louisiana Department of Health and Hospitals, EPA issued emergency administrative orders to 

the two companies involved in improper water transport. The order required both companies to 

6 
stop using non-food-grade trucks for transporting water. Both companies complied with the 

orders issued by EPA. In addition, EPA provided contract services to inspect trucks used to 

transport water for public consumption in New Orleans. 

Mississippi officials told us they were only aware of one instance where a tanker truck was used 

to transport water. In this instance, trucks were used to provide water to a public hospital. 

Mississippi officials told us that the hospital was under a boil water notice at the time. In 

addition, Mississippi officials tested the water from inside the hospital and did not identify any 

concerns. 

According to EPA Region 6 officials, the procedures developed by the Louisiana Department of 

Health and Hospitals for inspecting tanker trucks will be made available to other EPA regions 

and States. Additionally, Region 4 noted that it is developing procedures covering the 

emergency use of tanker trucks on tribal lands, where EPA Region 4 is responsible for 

administering the drinking water programs. 

Problems Using EPA’s SCRIBE Database 

During emergencies such as Hurricane Katrina, there is an immediate need for decision makers 

at various levels of government to have reliable water quality data. One of the databases used by 

EPA to store floodwater data is the SCRIBE database.2 EPA provided access to the data to 

officials at the State level and New Orleans parishes. However, Louisiana officials had trouble 

querying the database due to a lack of training and had trouble verifying the quality of data due 

to inconsistent data entry. Set protocols would address these types of issues. 

EPA regional officials concurred that problems existed with querying SCRIBE. Region 6 

officials said they have taken actions to correct these issues. This included querying the database 

on behalf of Louisiana until the issue was resolved to ensure Louisiana obtained the information 

it needed. This also included Region 6 providing training on the use of SCRIBE and making a 

SCRIBE user guide available to State officials. 

Other Katrina Lessons Learned Reviews 

EPA’s Office of Solid Waste and Emergency Response is also conducting a “lessons learned” 

review. As part of this effort, the Office developed a database for recording lessons learned from 

the Katrina response. In addition, Congress has held testimony on lessons learned and the White 

House recently issued a lessons learned report in February 2006, The Federal Response to 

Hurricane Katrina: Lessons Learned. Congressional testimony and the White House report 

discussed the impact that damage to communication infrastructure had on the response. 

EPA regional officials concurred that tremendous communication issues existed following 

Hurricane Katrina. Both Regions 4 and 6 indicated they have taken a number of steps to 

2

 SCRIBE is a software tool to assist in managing environmental data. SCRIBE can electronically import sampling, 

observational, and field sampling data, including air, soil, water, and biota sampling, and can record the global 

positioning system coordinates for the location where a sample was obtained. 

7 
improve communication during future disasters, including upgrading the current 

telecommunications equipment, planning to deploy additional staff during the next disaster, and 

reevaluating current communication standard operating procedures. 

Recommendation 

2-1 We recommend that the Assistant Administrators for the Office of Solid Waste and 

Emergency Response and Office of Water, as part of the Agency's efforts to address lessons 

learned from Katrina, ensure that the corrective actions discussed in the report are 

implemented. Specifically, these planned corrective actions include: 

• Conducting interagency meetings and establishing coordination protocols with the 

USACE; 

• Conducting training for EPA Region 6 and State staff on the Incident Command System, 

the NRP, and ESF support functions; 

• Sharing the procedures developed for handling tanker truck support of water in 

Louisiana with other EPA regions and States; 

• Sharing the Region 4 Katrina Lessons Learned review with other regions; and 

• Developing procedures for the appropriate use of emergency tanker trucks in tribal lands 

in Region 4. 

Agency Response 

The Agency agreed with the draft report’s findings and recommendation and has initiated actions 

to implement the recommendation. With respect to coordinating emergency response efforts 

with USACE, EPA noted that it met with representatives from USACE to discuss emergency 

response roles. The USACE created new draft ESF-3 pre-scripted mission assignments that 

include language for activating EPA support representatives to the ESF-3 team, and for 

providing direct Federal and technical assistance to States and drinking water and wastewater 

utilities. EPA met with USACE and other ESF-3 support agencies on August 17, 2006 to discuss 

roles and capabilities. EPA also reported that Region 6 plans to provide Incident Command 

System and NRP training for all of the Region 6 Response Support Corps staff. In addition, 

EPA’s Office of Water is sponsoring 24 workshops around the country to help drinking water 

and wastewater utilities, States, and regional EPA staff better understand and implement the 

Incident Command System. EPA also responded that Region 4 is finalizing its Katrina After 

Action Report and plans to distribute the final report to EPA Headquarters and regional offices in 

September 2006. Also, on August 31, 2006, EPA Region 6 distributed procedures for handling 

tanker truck support for drinking water to the other regions. Region 4 will work with the Office 

of Water to develop a tanker truck policy for tribal lands across the nation. The policy 

development is anticipated to begin in the fall of 2006. 

OIG Comment 

We believe that the actions taken and planned by EPA sufficiently address our recommendation. 

8 
Status of Recommendations and 

Potential Monetary Benefits 

POTENTIAL MONETARY 

RECOMMENDATIONS BENEFITS (in $000s)2 

Rec. 

No. 

Page 

No. Subject Status1 Action Official 

Planned 

Completion 

Date 

Claimed 

Amount 

Agreed To 

Amount 

2-1 8 As part of the Agency's efforts to address lessons 

learned from Katrina, ensure that the corrective 

actions discussed in the report are implemented. 

Specifically, these planned corrective actions 

include: 

• Conducting interagency meetings and 

establishing coordination protocols with the 

USACE; 

• Conducting training for EPA Region 6 and State 

staff on the Incident Command System, the 

NRP, and ESF support functions; 

• Sharing the procedures developed for handling 

tanker truck support of water in Louisiana with 

other EPA regions and States; 

• Sharing the Region 4 Katrina Lessons Learned 

review with other regions; and 

• Developing procedures for the appropriate use 

of emergency tanker trucks in tribal lands in 

Region 4. 

O Assistant Administrators for 

the Office of Solid Waste and 

Emergency Response and 

Office of Water 

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

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

 U = recommendation is undecided with resolution efforts in progress. 

2 Identification of potential monetary benefits was not an objective of this evaluation. 

9 
Appendix A 

Hurricane Katrina Response 

in Relation to Lessons Learned from the 

EPA OIG World Trade Center Report 

The following sections describe key lessons learned based on our EPA OIG review of EPA’s 

response following the attack and collapse of the World Trade Center towers in New York, and 

the applicability of these lessons learned in responding to environmental concerns after 

Hurricane Katrina. In general, many of the concerns raised in EPA’s response to the collapse of 

the World Trade Center towers did not become an issue in responding to Katrina. This can likely 

be attributed to three factors: (1) some issues were not applicable to Katrina due to the 

uniqueness of the World Trade Center disaster; (2) for some issues that were applicable, EPA 

applied the lessons learned from the World Trade Center experience; and (3) unlike the World 

Trade disaster, EPA and States had experience in responding to prior hurricane disasters that 

helped prepare them to respond to Katrina. Each section below describes a key World Trade 

Center lessons learned, and how these concerns were handled, if applicable, with respect to the 

three major areas of the Katrina response we evaluated: drinking water, wastewater, and 

hazardous waste and debris management. 

Risk Communication 

In the World Trade Center evaluation report, we noted EPA did not communicate information 

that sufficiently characterized the health risk to the public, and its communications to the public 

were sometimes inconsistent with other EPA information. A combination of EPA employing the 

lessons learned from the World Trade Center response and the fact that some programs already 

had risk communication procedures in place for emergencies appear to have minimized this issue 

as an area of concern after Katrina. 

Drinking Water 

Based on our work in EPA Regions 4 and 6, and with selected public water systems in 

areas of Louisiana and Mississippi impacted by Hurricane Katrina, the public was 

provided with timely, accurate information about the quality of their drinking water and 

procedures (boil order notices) to minimize risks. For example, on August 31, 2005, less 

than 48 hours after Katrina made landfall, the Mississippi Department of Health issued a 

blanket boil water notice for all public water systems in the State’s six most impacted 

counties, located in the coastal region. Similarly, by August 31, the Louisiana 

Department of Health and Hospitals had issued boil water orders for the 15 parishes 

affected by the hurricane. A boil water notice alerts the public and informs them to boil 

their water to prevent health impacts from drinking water potentially contaminated with 

bacteria. In accordance with its established procedures for issuing boil water notices, the 

Mississippi Department of Health and the Louisiana Department of Health and Hospitals 

issued boil water notices to radio and television stations and through daily press briefings, 

the States’ Websites, and other methods. 

10 
EPA also provided information to the public regarding the treatment of drinking water. 

For example, according to EPA staff, 59,620 drinking water flyers were distributed in 

Louisiana parishes affected by the hurricane. Two publications related to drinking water 

protection, What to Do after the Flood and Emergency Disinfection of Drinking Water, 

were published in English, Spanish, and Vietnamese. 

Wastewater 

The damage to the wastewater treatment facilities and their collection systems resulted in 

the potential for people living in impacted communities to be exposed to raw sewage. 

Due to the risk of serious illness associated with exposure to raw sewage, local 

decisionmakers needed information to be able to evaluate the potential risk of exposure 

and take steps to protect their citizens. EPA did a good job supporting States and local 

communities in this function. The information that EPA provided to the public was 

augmented by significant efforts by other Federal agencies, State agencies, and the 

communities themselves. For example, on September 6, 2005, shortly after the hurricane 

hit, EPA and the U.S. Department of Health and Human Services issued a news release 

about the dangers of floodwater due to potentially elevated levels of contamination 

associated with raw sewage and other hazardous substances. 

Many of EPA’s news releases provided a daily update of the response activities. These 

daily updates emphasized the activities conducted each day and included summary 

information about the number of wastewater treatment facilities that had resumed 

operation. 

Hazardous Waste and Debris Management 

Based on our work in Regions 4 and 6, EPA coordinated with State, local, and other 

Federal government agencies to assess potential environmental and human health impacts 

from Hurricane Katrina. EPA also provided quality and timely information for 

determining risks and impacts in EPA’s areas of responsibility and oversight. 

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, had taken 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 the Federal Emergency Management Agency 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 

Websites as they became available. Public service announcements were promptly issued 

11 
regarding precautions related to the now receded floodwaters and the cleanup of 

sediments. Additionally, EPA continues to post sediment sampling results to its Website 

as they become available. 

EPA promptly identified, prioritized, and assessed all Superfund National Priorities List 

sites in the affected areas of Louisiana and Mississippi. EPA generally provided quality 

and timely 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 Website. 

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. 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 

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 

short-term protectiveness related to the Murphy Oil Spill are posted on EPA’s public 

Website as the information becomes available. 

Sampling for Environmental Contaminants 

Two issues related to sampling were identified in the World Trade Center report. First, we 

recommended that EPA develop a sampling plan to assess environmental conditions after a 

large-scale disaster, and ensure adequate sampling for the contaminants of concern. Second, 

sampling results were not timely reported to the public. After the World Trade Center response, 

EPA officials said they would develop templates to enable them to report sampling data quicker. 

The lack of sampling plans was not an issue for the drinking water response, since these 

programs already had emergency response sampling plans in place as part of the program 

structure. For the wastewater and hazardous waste response, while EPA did not have predeveloped sampling plans in place, EPA developed quality assurance project plans for sampling 

these areas of concern and had these plans reviewed by EPA’s Science Advisory Board. 

Drinking Water 

The adequacy of environmental sampling was not a concern in responding to drinking 

water issues after Katrina. To test for the presence of bacteria in drinking water, 

Mississippi and Louisiana generated a sampling plan that was patterned after the drinking 

water sampling requirements that already existed under the Total Coliform Rule. In 

addition, public drinking water supplies must comply with standards for almost 80 

contaminants that address health risks from long-term exposure. These standards remain 

in force and local systems will continue to test for compliance with these standards, as 

they did before the hurricane, to ensure that public drinking water supplies are safe. 

12 
Public notification of sampling results was not a focus in responding to Hurricane Katrina 

drinking water issues because of the nature of drinking water sampling. The total 

coliform test provides a positive or negative result, indicating the presence (or absence) 

of bacteria; it is not a numerical result subject to interpretation on whether a health-based 

standard is exceeded. After Hurricane Katrina, if a positive result was obtained, the 

water system was not cleared from the boil water notice. Therefore, the results were not 

subject to interpretation as to what level was safe. While not provided with individual 

sampling results, the public was informed whether to continue boiling their water. 

Wastewater 

EPA played a major role in sampling floodwaters in New Orleans and coastal water in 

Mississippi for a variety of contaminants. LDEQ officials used water quality data 

collected by EPA to evaluate the potential health risks associated with short-term 

exposure to floodwaters for a variety of contaminants, including bacterial contamination 

from malfunctioning wastewater systems. Louisiana officials also used this data to make 

decisions regarding the level of protection required for rescue workers. Region 4, in 

cooperation with Mississippi, sampled its coastal waters for the presence of pollutants 

likely to be released as a result of flooding caused by Hurricane Katrina. EPA’s Science 

Advisory Board commented on the Quality Assurance Project Plan. 

Hazardous Waste and Debris Management 

The adequacy of environmental sampling was not a concern in responding to hazardous 

waste and debris management issues after Katrina. 

To assess sediment contamination, Region 6 focused its 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 plan that includes screening levels, 

quality assurance measures, and data validation requirements. 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. 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. 

With respect to Superfund sites 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 sitespecific operations and maintenance monitoring plans. 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. 

13 
Region 6 received, evaluated, and promptly posted validated analytical data results on the 

Agency’s public Website. 

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. 

To address oil spills, EPA, working closely with LDEQ, is also overseeing ongoing 

sampling activities of residential and other properties, and is performing independent 

sampling activities in a residential neighborhood. 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 (a site where a 

significant oil spill occurred adjacent to a residential neighborhood). 

Monitoring Capabilities 

Our World Trade Center report noted that monitoring immediately after the collapse of the 

World Trade Center towers was hampered by a lack of power, equipment, and analytical 

capacity. Lessons learned from the World Trade Center response appear to have helped in 

responding to monitoring concerns after Katrina. After the World Trade Center response, EPA 

expanded its mobile laboratory program. These mobile laboratories played a significant role in 

providing monitoring assistance to Louisiana and Mississippi after Katrina. 

Drinking Water 

Although the analytical capacity for Mississippi and Louisiana was diminished after 

Katrina, EPA Regions 4, 6, and 8 addressed this by providing mobile laboratories and 

staff to Mississippi and Louisiana to provide monitoring and analytical support for 

drinking water. Though Region 8 was not impacted, it provided a mobile laboratory. 

Wastewater 

From our limited review of wastewater facilities impacted by Katrina, we did not find 

any issues with Federal and State monitoring capabilities. EPA and the States conducted 

some preliminary water quality monitoring to assess impacts to the environment resulting 

from the hurricane. 

EPA Region 4 and Mississippi conducted water quality monitoring to assess the impacts 

of Hurricane Katrina on the Gulf environment. A report was released on October 28, 

2005, titled Water Quality Study of Bays in Coastal Mississippi Water Quality Report, 

documenting the results, which showed few detectable priority pollutant compounds on 

the impacted bays and rivers. 

14 
On December 6, 2005, EPA released a report assessing floodwaters in Louisiana, titled 

Environmental Assessment Summary for Areas of Jefferson, Orleans, St. Bernard, and 

Plaquemines Parishes Flooded as a Result of Hurricane Katrina. The assessment found 

that floodwater samples revealed elevated bacteria levels associated with untreated 

sewage. It also found that floodwaters no longer serve as a source of exposure to 

residents returning to impacted areas. 

Wastewater treatment facility operators were required to conduct self-monitoring of 

effluent at wastewater treatment facilities under the State-operated NPDES programs in 

Louisiana and Mississippi. Facilities in Louisiana were expected to continue regular 

reporting of their effluent water quality, and facilities in Mississippi were given 30 days 

to resume monitoring and reporting. 

Hazardous Waste and Debris Management 

With respect to hazardous waste and debris management, we did not identify any issues 

with monitoring capabilities. EPA utilized its mobile equipment in the initial assessment 

period. Details of the monitoring activities are provided above. 

Short-Term Exposure Guidelines/Standards 

This issue relates to the existence of guidelines for making public health protection decisions. 

In the World Trade Center report, we noted that short-term or acute standards or guidelines did 

not exist for some pollutants of concern, and thus had to be developed to address the health 

effects from exposure to the contaminants of concern. Lack of short-term exposure guidelines 

was not a significant concern in the Katrina response. While the World Trade Center response 

dealt with indoor contamination concerns from many pollutants without short-term exposure 

guidelines, short-term exposure guidelines were already in place as part of the overall program 

structures for drinking water and wastewater. In the case of hazardous waste, EPA and ATSDR 

used existing guidelines or developed exposure models based on current available toxicity 

information to determine associated risk. 

Drinking Water 

This was not a concern after Katrina since EPA had already established acute exposure 

standards for total coliform in 1989. Mississippi and Louisiana used the EPA total 

coliform standard and a modified testing regimen to test drinking water safety after 

Katrina. 

Wastewater 

With respect to wastewater, this was not a concern after Hurricane Katrina, as EPA had 

already established recommended levels of exposures to e-coli, a pollutant commonly 

found in untreated or partially treated wastewater. 

15 
Hazardous Waste and Debris Management 

The existence of short-term exposure guidelines and standards was also not an issue with 

the response to hazardous wastes and the management of debris. 

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. 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 for sediment contamination, 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 long-term (i.e., 30-year) 

exposures to children and adults in a residential setting. Although the levels in some 

samples exceeded RECAP standards, they fell 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. EPA has found this risk level acceptable in other contexts. 

EPA’s conclusions regarding potential impact of the hurricane on Superfund sites were 

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

values defined for the site, or past sample data. In addition, the results in Mississippi 

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 Website. 

The results of EPA’s sampling activities for oil spills show that the primary contaminants 

detected include arsenic, polycyclic aromatic hydrocarbons, 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 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 

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.

16 
performed, and recommendations for short-term protectiveness are posted on EPA’s 

public Website as the information becomes available. 

Roles and Responsibilities 

Our World Trade Center report noted that there were sometimes overlapping and confusing roles 

and responsibilities for the various organizations responding to the collapse of the towers. 

Responders’ lack of understanding of roles did not appear to be a significant concern in 

responding to Katrina. We believe this is primarily because the three areas of the response we 

evaluated – drinking water, wastewater, and hazardous waste and debris management – are all 

programs in which management of the program, including responding to emergencies, has been 

delegated to the States by EPA. 

Drinking Water 

Except for some coordination issues with respect to EPA and USACE, as noted in this 

report, this was not an issue when assessing and restoring drinking water supplies after 

Katrina. Louisiana and Mississippi had previously been delegated responsibility for 

administering the drinking water systems in their States. EPA’s delegation of drinking 

water primacy to the States clearly establishes that this delegation remains in force during 

emergencies. Accordingly, EPA fulfilled a support role in the Katrina response, and 

Louisiana and Mississippi maintained their delegated roles of administering the program. 

As noted in the previous Katrina drinking water reports, both States took steps to protect 

the public by issuing boil water notices and overseeing the recovery of water systems. 

Wastewater 

From our limited review of wastewater issues, we found at times that parts of EPA were 

not communicating. We also found that EPA could coordinate its work better with the 

States and local wastewater facilities. The communications issues we observed are 

detailed earlier in this report. 

Hazardous Waste and Debris Management 

We did not identify any coordination issues with the response to hazardous waste and the 

management of debris. Similar to drinking water, we found that Mississippi and 

Louisiana had previously been delegated responsibility for administering the 

Underground Storage Tanks programs in their States, including emergencies. As such, 

EPA fulfilled a support role in the Katrina response, while the States maintained their 

delegated roles of administering the program. Additionally, EPA primarily fulfilled a 

support role to the U.S. Coast Guard in response to oil spills. For Murphy Oil, one of the 

five major oil spills reported, the U.S. Coast Guard, with support from EPA, conducted 

initial response and assessment efforts. 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 

17 
oversight of cleanup in residential areas accessible to the public (e.g., parks, school yards, 

roads, highway median strips, and sidewalks). 

Handling of Competing Concerns 

This issue pertains to the existence of political or economic concerns that would potentially 

impact the information provided to the public. In the World Trade Center evaluation, it was 

noted that there were competing economic pressures to reopen lower Manhattan. While, 

according to media accounts, political and business leaders wanted to reopen New Orleans as 

soon as possible after Katrina, these desires did not appear to influence the health decisions we 

reviewed. In particular, EPA’s public pronouncements regarding conditions in New Orleans 

expressed caution with respect to re-inhabiting the city. Competing concerns did not appear to 

be an issue for other locations we reviewed. 

Drinking Water 

While public officials desired to have New Orleans opened to the public as soon as 

possible after Hurricane Katrina, for the systems reviewed we did not find that the desire 

to reopen New Orleans to the public influenced the decisions made by officials 

responsible for deciding when to remove boil water notices for public water systems. We 

also did not identify any undue influences in removing boil water notices for Louisiana 

systems outside of New Orleans. In Mississippi, neither State officials nor local officials 

for the four systems reviewed told us of any attempts to influence removing boil water 

notices because of political or economic concerns. 

Wastewater 

Based on our limited review of wastewater facilities we visited in Mississippi and 

Louisiana, we did not find that political or economic concerns influenced the decisions 

made by wastewater officials responsible for determining when residents should be 

allowed to repopulate impacted areas. 

Hazardous Waste and Debris Management 

For the hazardous waste and debris management areas reviewed, we did not find that the 

desire to reopen New Orleans to the public influenced the decisions made by officials 

responsible for making public health and safety decisions. In Mississippi, we also did not 

see evidence of competing concerns influencing officials’ decisions to allow residents to 

return to the locales we visited. 

18 
Appendix B 

Agency Response 

August 22, 2006 

MEMORANDUM 

SUBJECT: Response to the Draft Evaluation Report: 

 ”Lessons Learned: EPA’s Response to Hurricane Katrina” 

 Assignment No. 2006-001197 

FROM: Susan Parker Bodine/s/ 

 Assistant Administrator 

Office of Solid Waste and Emergency Response 

 Benjamin H. Grumbles/s/ 

 Assistant Administrator 

 Office of Water 

TO: James L. Hatfield 

Office of Inspector General 

This memorandum is in response to the Office of Inspector General’s (OIG’s) draft 

Evaluation Report dated July, 21, 2006 ” Lessons Learned: EPA’s Response to Hurricane 

Katrina.” 

EPA manual 2750 requires the Agency to provide a written response to the findings and 

recommendations. This response has been coordinated with representatives from Regions 4 and 

6. EPA concurs with the recommendations included within the report. Our specific responses to 

the corrective actions are provided in the Attachment. 

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’s response to 

Hurricane Katrina reflects that we did learn lessons from our response to the World Trade Center 

in 2001. Our response to Hurricane Katrina reflected the progress we have made in 

implementing an agency-wide National Approach to Response. 

We would like to thank you for incorporating into the report considerations we presented 

to you following review of the discussion draft version. In particular, we appreciate your noting 

on page 4 regarding interaction with the U.S. Army Corps of Engineers: “We found no evidence 

that hurricane response activities were negatively impacted by these coordination issues.” We 

suggest that this sentence could also be included in the first bullet of the “At a Glance” section of 

the report. 

19 
If you have questions, please contact Deborah Dietrich, Director of the Office of 

Emergency Management at 202-564-8600 or Nance Gelb, Deputy Director of the Office of 

Ground Water and Drinking Water at 202-564-3754. 

Attachment 

cc: Richard Greene, Regional Administrator, Region 6 

Jimmy Palmer, Regional Administrator, Region 4 

20 
Attachment 

 Response to OIG Draft Evaluation Report “Lessons Learned: EPA’s

Response to Hurricane Katrina” 

Recommendation 2.1: We recommend that the Assistant Administrators for the Office of Solid 

Waste and Emergency Response and Office of Water, as part of the Agency’s efforts to address 

lessons learned from Katrina, ensure that the corrective actions discussed in the report are 

implemented. Specifically, these planned corrective actions include: 

• Conducting interagency meetings and establishing coordination protocols with the U.S. 

Army Corps of Engineers (USACE). 

Response: EPA met with representatives from USACE in May to discuss emergency response 

roles and responsibilities that pertain to drinking water and wastewater systems. USACE and 

EPA agreed that the USACE ESF-3 Standard Operating Procedures (SOP) guidance should 

include drinking water and wastewater system assessment and repair, and that additional 

mechanisms (such as pre-scripted Mission Assignments) should be identified to facilitate this 

mission. Following the meeting, USACE created new draft ESF-3 pre-scripted mission 

assignments that include language for activating EPA support representatives to the ESF-3 Team 

and for providing direct federal and technical assistance to states and drinking water and 

wastewater utilities. EPA will meet with USACE and other ESF #3 support agencies in August 

to discuss ESF-3 agency roles and capabilities and will continue to work with USACE to ensure 

that current ESF #3 SOPs can be appropriately updated and revised. 

• Conducting training for EPA Region 6 and State staff on the Incident Command System 

(ICS), the National Response Plan (NRP) and ESF support functions. 

Response: EPA Region 6 has plans underway to require and provide ICS 100/200 level training, 

as well as training on the National Response Plan for all of the Region 6 Response Support 

Corps Staff. EPA’s Office of Water is also sponsoring 24 1-day workshops around the country 

to help drinking water and wastewater utilities, states and regional EPA staff better understand 

ICS, how to implement ICS within emergency response plans (ERPs), and how to integrate with 

other first responders within an expanding ICS structure. 

• Sharing the procedures developed for handling tanker truck support of water in Louisiana 

with other EPA Regions and States. 

Response: Region 6 procedures for handling tanker truck support of water in Louisiana will be 

provided to other EPA Regions during the week of August 21, 2006. 

• Sharing the Region 4 Katrina Lessons Learned review with other Regions. 

Response: Region 4 is in the process of finalizing the Katrina After Action Report. It is 

anticipated to be completed in September 2006 and will be distributed to Headquarters and 

Regional Offices. Work on improvements identified in this process is already underway through 

21 
the Region 4 Regional Incident Coordination Team (RICT) and through participation on 

National Approach to Response (NAR) workgroups. 

• Developing procedures for the appropriate use of emergency tanker trucks in tribal lands 

in Region 4. 

Response: The Region 4 Water Management Division will work with the EPA Headquarters 

Office of Water to develop a policy on a nationwide basis for the application of this 

recommendation for all federally recognized tribal lands across the country. The policy 

development is anticipated to begin in the fall of 2006. 

22 
Appendix C 

Distribution 

EPA Headquarters 

Office of the Administrator 

Assistant Administrator for Water 

Assistant Administrator for Solid Waste and Emergency Response 

Agency Followup Official 

Agency Followup Coordinator 

General Counsel 

Associate Administrator for Congressional and Intergovernmental Relations 

Associate Administrator for Public Affairs 

Director, Office of Regional Operations 

Audit Followup Coordinator, Office of Water 

Audit Followup Coordinator, Office of Solid Waste and Emergency Response 

Acting Inspector General 

EPA Region 4 

Regional Administrator 

Regional Audit Followup Coordinator 

EPA Region 6 

Regional Administrator 

Regional Audit Followup Coordinator 

23