I
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OFFICE OF INSPECTOR GENERAL
roving tin' 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
US EPA Headquarters Ubraiv
Mail code 3404T
1200 Pennsylvania Avenue
Washington, DC 20460
202-566-0556
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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)
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I
U.S. Environmental Protection Agency
Office of Inspector General
At a Glance
2006-P-00023
May 2, 2006
L'titulyst for Imprnviii" the Einitonnu'iit
EPA Provided Quality and Timely Information on Hurricane
Katrina Hazardous Material Releases and Debris Management
i
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:
• 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.
• 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:
• 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.
• 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.
• 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.
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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,
Roderick
Acting Inspector General
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Table of Contents
At a Glance
Purpose
Background
Scope and Methodology
1
2
EPA Provided Quality and Timely Information on the Nature,
Magnitude, and Impact of Hazardous Material Releases
Sediment Contamination.... 4
Superfund Sites 5
Operational Facilities 7
Underground Storage Tanks 7
Oil Spills 8
EPA Provided Quality and Timely Information and Actions Regarding
Management of Hazardous and Non-Hazardous Debris and Waste
10
Hazardous Debris Management 11
Non-Hazardous Debris Management 13
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
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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:
• 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?
• 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
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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:
• Addressing threats from actual or potential releases including oil spills, sediment
contamination, and hazardous substances.
• 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.
• 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:
• 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.
• 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
17* 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:
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• 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.
• 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.
• Underground Storage Tanks (USTs): USTs as identified by State and local programs.
• Oil Spills: Spills in navigable waters and land releases.
• 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.
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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.
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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 long-
term (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
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.
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
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 O1G)
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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 post-
hurricane 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 Criteria* 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
- Delarte 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.
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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.
Figure 2- A chemical manufacturing facility in Mississippi after
the hurricane. (Source: EPA)
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.
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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
Figure 3 - Storm-damaged UST in Mississippi.
(Source: MDEQ)
Figure 4 - Twisted UST vent lines in a debris pile.
(Source: MDEQ)
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
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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).
Bass Enterprises
Table 1 - Louisiana Oil Spills
%l!fl$fa^&M@l&ffiB&$5^*^^y:ffi$f5i$$k$E&rF'
^^^^^^jjjp^^^S^jmKat^^^
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).
Figure 5 - Murphy Oil and adjacent residential area. (Source: EPA)
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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 short-
term 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:
Figure 6 - Debris field resulting from storm surge through a
residential neighborhood in Waveland, Mississippi.
(Source: EPAOIG)
Direct oversight of hazardous waste management.
Management of household hazardous waste collection.
Management of electronics collection.
Management of white goods, including removal and recycling of Freon.
Oversight of the segregation of hazardous and non-hazardous waste and debris.
Guidance to State and local governments in managing non-hazardous solid waste.
EPA's Public Web site for Murphy Oil Spill - http://www.epa.gov/katrina/testresults/murphy/index.html
10
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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 non-
hazardous 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:
Figure 7 - Segregation of household hazardous waste at an
EPA collection site. (Source: EPAOIG)
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
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Hazardous Waste
(cumulative number of Drums, propane tanks, cylinders, smaH containers, batteries, etc.)
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 can
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.
3,000,000
2,500.000
2.000,000
1,500.000-
1,000,000
500,000
Sept 05 OctOS NovOS Dec 05 Jan 06 Feb06
Figure 8 - EPA hazardous waste collection volume.
(Source: EPA OIG analysis of data from EPA Situation Reports)
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.
Figure 9 - Electronic waste at curbside.
(Source: EPA OIG)
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
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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: EPAOIG)
Louisiana White Goods Collection
NovOS
Dec 05
Jan 06
Feb06
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.
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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:
• Vegetative debris (trees, bushes, and shrubs, etc.)
• Municipal Solid Waste (typical household and commercial garbage)
• 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.
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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 #3 - Public Works and
Engineering
ESF#4-Firefighting
ESF #5 - Emergency
Management
ESF #8 - Public Health and
Medical
ESF #10 - Oil and Hazardous
Materials Response
ESF #11 -Agriculture and
Natural Resources
ESF #12 -Energy
ESF #13 -Public Safety
and Security
ESF #14 -Long-Term
Community Recovery
ESF #15 - External Affairs
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
Technical assistance for fires involving hazardous materials and
also assistance in identifying uncontaminated water sources for
firefighting.
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.
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.
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.
Technical assistance for biological and chemical agents
regarding environmental monitoring, contaminated
crops/animals, and food/product decontamination.
Response to State/local requests for fuel waivers to address fuel
shortages.
Assistance through specialized evidence response teams who
can work in a contaminated environment, investigation of
criminal violations of environmental statutes, and forensic
analysts of industrial chemicals.
Technical assistance for planning for contaminated debris
management and environmental remediation.
Appropriate support as required.
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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
Toxic Release Inventory
Risk Management Plans
Biennial Reports on
hazardous waste
Inventory Update Rule
Section Seven Tracking
System
National Response Center
discharges reported
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.
Businesses that use specified flammable and toxic substances.
Includes hazard assessments with a worst-case scenario, prevention
programs, and emergency response programs.
Quantitative hazardous waste generation and disposal volumes from
large generators and treatment, storage, and disposal facilities.
Manufacturing volumes from large chemical manufacturers.
Production volumes of pesticides reported by pesticide
manufacturers.
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, Poxl-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.
Situation Reports are internal briefing documents used by the Regions to document and track operational activities.
16
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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 Board 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.
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Appendix C
Sediment Sampling Sites
in Flooded Areas of New Orleans
Sediment Sampling Sites
09/10/05 to 12/1V06
Sedlmeflt Sample Location 12/11/05
A Sediment sample Lpciion9flOfl)5 to 12HCW35
• RoodedArea S":t° • •<•• • •
I lap code - '
1«14 *Tf4«t I me
/BCM: K 1*
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Appendix D
Mississippi Household Waste Collection Flyer
HOUSEHOLD HAZARDOUS WASTE
COLLECTION DAY
Items Accepted
Aerosols, All Purpose Cleaners, Ammonia, Anti-Freeze, Automobile Cleaners,
Batteries, Brafce Fluid. Charcoal Lighter Fluid, Chlorine Bleach. Detergents,
Disinfectants, Drain Opener, Furniture PoBsh, GasoKne, Glut Cleaner. Herbicidef.
Insecticides, Mothballs, Motor Oil, Own Cleaner, Paint, Pafc* Thinner, P«ddd«.
Pool ClMRiicali, Rodent Poisons, Rubber Ccnwnt, Rog* Upholstery Cleaner,
Scouring Powder, Silver Polish, Snail * Sh» KiNen, To8*t Bo»H Cleaner, TrammisiMn
FkMTub* rdeCleaiMr, Turpentine, VamisK Water SuJ, Wood Finish, Cooking Oil
Annual M«Burt< carcasses
We CANNOT accept:
Home Ws, tubinc or dial\-li3 Bjmpment
aiarovN«edl«
foiled {bod/mold damagedi
Toxic
Waste
In Its Place
Hau<*lu*M Hax
Unused or teftover porttore of praducti containing toxic diemioB «nd any product which it
bbeted CAUTION, POISONOUS, TOXIC, FLAMMABLE or CORROSIVE.
A iifcjtterrertive to a toxic product F«± sheets ire watobte to hdp you reduce the
use of toxics wd minimize health risks.
teivinj products hi the or^u) container! and miking sure ttat the containers are
sealed so ttnttheyw* not leak Tnraport containers h the trwkor in the back
of the vehicle »wty from passenjen.
DO NOT THANWORT OVER S GALLONS OR SO POUNDS AT OWE TIME
Prop«r Dttpotal h...
EXTK1MCI.Y IMrXMITANT.
It is dangerous to dBcard hazardous he
ehoM
materiats ki die trash or down the drain. Instead use up the product u intended,
or take the unused portions to the scheduled event
HOUSEHOLD
HAZARDOUS
WASTE
COLLECTION DAY
Plp.i<;<> tin tt tu i>r
l
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Appendix E
Curbside Waste Segregation Instructions
>• toy det)n» ptefflt from fte
Following these specific guidlines
when hauling hurricane-related
debris and household garbage
to the curl) will make for
a speedier removal
process
HomeowMn *re ttemg asked to separate
debris W6 tl» foUwlr« eaegonw:
ComnreMdiu ; >• Wjtertieilsri
; »Carpel
paced curt** Ow njM ! > Furmure
belors the schedule) : >• Mmresus
i >• PlutntMsg
Reprinted with permission from The Times-Picayune
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON, D.C. 20460
Appendix F
APR 26 2005
OFFICE OF
SOLID WASTE AND
EMERGENCY RESPONSE
MEMORANDUM
SUBJECT:
FROM:
TO:
Draft Evaluation Report:
EPA Provided Quality and Timely Information on Hurricane Katrina
Hazardous Releases and Debris Management
Assignment No. 2005-001751
Assistant Administrator
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 General
(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 professional
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 suggestions 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 (pa^c
14).
Internet Address (URL) • http://www.epa.gav
Raeycled/RacycleMe • Printed with Vegetable Oil Based Inks on 100% Posteonsumer, Process Chlorine Free Recycled Paper
21
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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 IDEQ
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
U.S EPA Headqy§ftef| Llfirary
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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
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