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U.S. ENVIRONMENTAL PROTECTION AGENCY
OFFICE OF INSPECTOR GENERAL
Catalyst for Improving the Environment
Evaluation Report
EPA Actively Evaluating
Effectiveness of Its
BP and Enbridge Oil Spill
Response Communications
Report No. 11-P-0273
June 23, 2011
NO RIVER USE
NHL FURTHER NOTICE
DUE TO ONGOING
OIL SPILL RESPONSE
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Report Contributors: Laurie Adams
Dan Carroll
Jerri Dorsey
Jeffrey Harris
Denton Stafford
Abbreviations
EPA U.S. Environmental Protection Agency
ERT Environmental Response Team
NCP National Contingency Plan
NRT National Response Team
OIG Office of Inspector General
OSC On-Scene Coordinator
RRT Regional Response Team
USCG U.S. Coast Guard
Cover photos: from left: Water warning near Battle Creek, Michigan (EPA OIG photo);
air sampling station near Port Fourchon, Louisiana (EPA photo).
Hotline
To report fraud, waste, or abuse, contact us through one of the following methods:
e-mail: OIG Hotline@epa.gov write: EPA Inspector General Hotline
phone: 1-888-546-8740 1200 Pennsylvania Avenue NW
fax: 703-347-8330 Mailcode 8431P (Room N-4330)
online: http://www.epa.gov/oig/hotline.htm Washington, DC 20460
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U.S. Environmental Protection Agency
Office of Inspector General
At a Glance
11-P-0273
June 23, 2011
Catalyst for Improving the Environment
Why We Did This Review
The purpose of this review was
to determine what actions the
U.S. Environmental Protection
Agency (EPA) took to
communicate oil spill risk to
affected communities near the
Gulf of Mexico and Michigan's
Kalamazoo River.
Background
When a major oil spill occurs
in the United States,
coordinated teams of local,
state, and national personnel
are called upon to help contain
the spill, clean it up, and ensure
that damage to human health
and the environment is
minimized. EPA's emergency
response played an integral role
in two recent oil spills. On
April 20, 2010, the Deepwater
Horizon mobile offshore
drilling unit exploded, resulting
in an oil spill in the Gulf of
Mexico, known as the BP oil
spill. On July 26, 2010, the
Enbridge oil spill occurred,
releasing oil into Michigan's
Kalamazoo River.
For further information,
contact our Office of
Congressional, Public Affairs
and Management at
(202)566-2391.
The full report is at:
www.epa.gov/oiq/reports/2011/
20110623-11-P-0273.pdf
EPA Actively Evaluating Effectiveness of Its
BP and Enbridge Oil Spill Response
Communications
What We Found
We concluded that EPA is actively evaluating the effectiveness of its spill
response communications activities. Because we found that the Agency has
several ongoing efforts focused on lessons-learned activities, we did not
continue into a field work phase of this assignment to evaluate the
effectiveness of the Agency's communication efforts. We are closing this
assignment upon issuing this report.
The results and the interpretation of all data collected by EPA at the BP and
Enbridge oil spills were shared with state and local decisionmakers, as well as
the impacted communities, in a number of ways. EPA developed Quality
Assurance Sampling Plans to collect further data on the chemical
contamination in air, water, and sediments. EPA communicated with the
general public via press conferences, fact sheets, community meetings, and the
Internet and social networking media. Data results and interpretations were
posted on the Internet. The results were also communicated to local and state
decisionmakers to inform their decisions on actions such as voluntary
evacuations and drinking water advisories to protect public health. In addition,
EPA issued a request for proposals for grants totaling up to $300,000 to further
communication efforts in the environmental-justice-designated communities
impacted by the BP oil spill. EPA's response communications assisted states
and other federal agencies in understanding the immediate and long-term
impacts of oil contamination.
EPA is completing lessons-learned exercises to evaluate the effectiveness of its
response to both oil spill incidents. These retrospective reviews address, in
part, the effectiveness of EPA's communication strategy and activities. The
lessons-learned activities will allow the Agency to identify areas of success, as
well as areas that could be improved upon in responding to future emergency
situations.
We make no recommendations in this report, and the Agency did not formally
respond to a draft version of this report. A representative of EPA's Office of
Emergency Response did state that the report was a good summary of spill
response, coordination, and followup actions.
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON, D.C. 20460
THE INSPECTOR GENERAL
June 23, 2011
MEMORANDUM
SUBJECT: EPA Actively Evaluating Effectiveness of Its BP and Enbridge Oil Spill
Response Communications
Report No. ll-P-0273
FROM: Arthur A. Elkins, Jr.
Inspector General
TO: See Below
This is our report on the subject evaluation conducted by the Office of Inspector General (OIG)
of the U.S. Environmental Protection Agency (EPA). This report describes what the OIG found.
This report represents the opinion of the OIG and does not necessarily represent the final EPA
position. Final determinations on matters in this report will be made by EPA managers in
accordance with established audit resolution procedures.
The estimated direct labor and travel costs for this report are $229,777.
Action Required
Because this report contains no recommendations, you are not required to respond to this report.
However, if you submit a response, it will be posted on the OIG's public website, along with our
memorandum commenting on your response. Your response should be provided as an Adobe
PDF file that complies with the accessibility requirements of Section 508 of the Rehabilitation
Act of 1973, as amended. The final response should not contain data that you do not want to be
released to the public; if your response contains such data, you should identify the data for
redaction or removal. We have no objections to the further release of this report to the public.
We will post this report to our website at http://www.epa.gov/oig.
If you or your staff have any questions regarding this report, please contact Wade Najjum at
(202) 566-0832 or naiium.wade@epa.gov. or Jeffrey Harris at (202) 566-0831 or
harris.ieffrev@epa.gov.
Addressees:
Mathy Stanislaus, Assistant Administrator for Solid Waste and Emergency Response
Gwendolyn Keyes Fleming, Regional Administrator, Region 4
Susan Hedman, Regional Administrator, Region 5
Al Armendariz, Regional Administrator, Region 6
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EPA Actively Evaluating Effectiveness of Its 11 -P-0273
BP and Enbridge Oil Spill Response Communications
Table of Contents
Purpose 1
Background 1
Federal Emergency Response to Major Oil Spills 1
Risk Communication During an Oil Spill 2
Recent Oil Spill Incidents 2
Scope and Methodology 3
Results of Review 4
EPA Communicates With State and Local Decisionmakers 5
EPA Communicates With Impacted Communities 5
Lessons-Learned Activities Conducted by EPA 6
Agency Comments and Office of Inspector General Evaluation 6
Status of Recommendation and Potential Monetary Benefits 7
Appendix
A Distribution 8
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Purpose
The purpose of this review was to determine what actions the U.S. Environmental
Protection Agency (EPA) took to communicate oil spill risk to communities near
the Gulf of Mexico and Michigan's Kalamazoo River.
Background
Federal Emergency Response to Major Oil Spills
When a major oil spill occurs in the United States, coordinated teams of local,
state, and national personnel are called upon to help contain the spill, clean it up,
and ensure that damage to human health and the environment is minimized. In the
United States, the system for organizing responses to major oil spills is called the
National Response System. There are three components of the National Response
System: (1) on-scene coordinators (OSCs), (2) the national response team (NRT),
and (3) regional response teams (RRTs).
On-Scene Coordinator: The OSC is the federal official responsible for
monitoring or directing responses to all oil spills and hazardous substance
releases reported to the federal government. The OSC coordinates all
federal efforts with, and provides support and information to, local, state,
and regional response communities. In general, the OSC's key
responsibilities during and after a response to a hazardous substance
release or an oil spill are (1) assessment, (2) monitoring, (3) response
assistance, and (4) evaluation.
National Response Team: The NRT is an interagency group that
provides guidance prior to an incident and, when requested, technical and
financial assistance during an incident. EPA chairs the NRT, and the U.S.
Coast Guard (USCG) serves as the vice chair.
Regional Response Teams: RRTs are interagency groups that consist of
representatives from federal, state, and local governments. They conduct
preresponse planning and preparedness activities, as well as coordinate
and provide advice during response actions. The two principal components
of the RRT are 13 standing teams, which provide regionwide support on
communications, planning, coordination, training, evaluation, and
preparedness; and incident-specific teams for which participation depends
on the technical nature and location of the incident.
The purpose of the National Oil and Hazardous Substances Pollution Contingency
Plan, also known as the National Contingency Plan (NCP), is to provide the
organizational structure and procedures for preparing for and responding to
discharges of oil and releases of hazardous substances, pollutants, and
contaminants. It was developed to ensure that the resources and expertise of the
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federal government would be immediately available for major incidents that
require federal or regional response. The NCP provides the federal government
with a framework for notification, communication, and responsibility for oil spill
response. It creates and implements a Unified Command, which coordinates the
responsible party with federal and state officials in the spill response. The NCP
also established additional technical and support response teams: (1) the Coast
Guard National Strike Force, (2) the Coast Guard Public Information Assist
Team, (3) the National Oceanic and Atmospheric Administration's Scientific
Support Coordinators, (4) National Resource Trustees, and (5) the EPA
Environmental Response Team (ERT).
The ERT is a group of EPA technical experts who provide around-the-clock
assistance at the scene of hazardous substance releases, offering expertise in such
areas as treatment, biology, chemistry, hydrology, geology, and engineering. The
ERT provides support to the full range of emergency response actions. The ERT
can provide support for site assessments, health and safety issues, action plan
development, and contamination monitoring.
Risk Communication During an Oil Spill
During oil spill recovery, the NCP states that it is imperative to give the public
prompt, accurate information on the nature of the incident and the actions
underway to mitigate the damage. According to the Centers for Disease Control
and Prevention, crisis and emergency risk communication combines the urgency
of disaster communication with the need to communicate risks, benefits, and
needed action to stakeholders and the general public. Typically, communications
during an emergency response focus on quickly disseminating information to
warn of the potential threats and explain the protective measures being taken. This
communication allows for the communities to be aware of any dangers or
potential health effects possible due to the toxicity of the oil spill.
Recent Oil Spill Incidents
Gulf of Mexico
On April 20, 2010, the Deepwater Horizon mobile offshore drilling unit exploded,
resulting in a severe fire. Two days later, the unit sank and began releasing several
thousand barrels of crude oil per day into the Gulf of Mexico. The Secretary of
the U.S. Department of Homeland Security classified this oil discharge as a "Spill
of National Significance"1 and designated the USCG Commandant as the
1 A "Spill of National Significance" is a spill that, due to its severity, size, location, actual or potential impact on the
public health and welfare or the environment, or the necessary response effort, is so complex that it requires
extraordinary coordination of federal, state, local, and responsible party resources to contain and clean up the
discharge.
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National Incident Commander.2 The USCG led the federal environmental
response actions in the coastal zone and oversaw all response operations,
including those of BP. EPA assigned some of its staff to the Unified Command
and some to the local incident command posts. EPA also developed monitoring
and assessment plans for surface and subsurface dispersant application, and
provided technical assistance, air monitoring, and water quality sampling at
several locations in Louisiana, Mississippi, and Alabama to assist in the oil spill
response. EPA's Crisis Communication Plan establishes the process for
communicating environmental information to the public and coordinating public
information among EPA field operations, regional offices, and headquarters
during a response to a national significant incident. The plan indentifies the roles
and responsibilities of EPA communication personnel.
Kalamazoo River
Enbridge Energy Partners reported a 30-inch pipeline rupture on July 26, 2010,
near Marshall, Michigan. The release, estimated to be 819,000 gallons, entered
Talmadge Creek and flowed into the Kalamazoo River, a Lake Michigan
tributary. On July 27, 2010, EPA issued a legal order under the authority of the
Clean Water Act directing Enbridge to conduct removal actions. As the federal
OSC, EPA Region 5 was in charge of the response to the Enbridge oil spill. EPA
assumed a leadership role in the Unified Command and mobilized an Incident
Management Team made up of federal, state, and local agencies. EPA provided
air monitoring, sediment sampling, and water quality sampling.
Scope and Methodology
We conducted this evaluation in accordance with generally accepted government
auditing standards. Those standards require that we plan and perform the
evaluation to obtain sufficient, appropriate evidence to provide a reasonable basis
for our findings and conclusions based on our objectives. We believe that the
evidence obtained provides a reasonable basis for the results reported based upon
our objectives. Because we found that the Agency has several ongoing efforts
focused on lessons-learned activities, we did not continue into a field work phase
of this assignment to evaluate the effectiveness of the Agency's communication
efforts. We performed our evaluation from September 2010 through June 2011.
Our evaluation included two recent oil spills in which EPA's emergency response
played an integral role. The two oil spills covered in our review were in the Gulf
of Mexico, known as the BP oil spill, and in Michigan's Kalamazoo River, known
as the Enbridge oil spill. To determine what actions EPA took to communicate oil
spill risk to communities near the Gulf of Mexico and the Kalamazoo River, we
met with staff from EPA Regions 4, 5, and 6, in Atlanta, Georgia; Chicago,
2 According to the NCP, the National Incident Commander was to "assume the role of the [federal OSC] in
communicating with affected parties and the public, and coordinating federal, state, local, and international
resources at the national level."
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Illinois; and Dallas, Texas, respectively. We also met with headquarters staff from
the Office of Water; Office of Air; Office of Solid Waste and Emergency
Response, including the Office of Emergency Management; Office of Compliance
and Enforcement Assurance, including the Office of Environmental Justice; and
Office of External Affairs and Environmental Education. Additionally, we
attended a community update meeting in Battle Creek, Michigan, which was
conducted primarily by EPA officials.
We also analyzed EPA planning and implementation documents. We reviewed
applicable laws and regulations. Specifically, we reviewed the Crisis
Communication Plan, the Clean Water Act, the Clean Air Act, the National
Contingency Plan for Oil Spills, and the Oil Pollution Act of 1990. We also
reviewed guidance documents related to communicating risk as well as the
following past audit reports in this area:
• National Commission on the BP Deepwater Horizon Oil Spill and
Offshore Drilling, Report to the President: National Commission on the
BP Deepwater Horizon Oil Spill and Offshore Drilling, January 2011.
• EPA Office of Inspector General, EPA Should Continue to Improve Its
National Emergency Response Planning, Report No. 08-P-0055,
January 9, 2008
• EPA Office of Inspector General, Lessons Learned: EPA 's Response to
Hurricane Katrina, Report No. 2006-P-00033, September 14, 2006
• EPA Office of Inspector General, EPA 's Response to the World Trade
Center Collapse: Challenges, Successes, and Areas for Improvement.,
Report No. 03-P-00012, August 21, 2003
Results of Review
We concluded that EPA is actively evaluating the effectiveness of its spill
response communications activities. We are closing this subject assignment upon
issuing this report. The results and the interpretation of all data collected by EPA
at the BP and Enbridge oil spills were shared with state and local decisionmakers,
as well as the impacted communities, in a number of ways. EPA developed
Quality Assurance Sampling Plans to collect data on the chemical contamination
in air, water, and sediments and provided technical assistance, air monitoring, and
water quality sampling in response to both oil spills. EPA communicated with the
general public via press conferences, fact sheets, community meetings, and the
Internet and social networking media. Data results and interpretations were posted
on the Internet. The results were also communicated to local and state
decisionmakers to inform their decisions on actions such as voluntary evacuations
and drinking water advisories to protect public health. In addition, EPA took steps
to issue grants to assist in communication efforts in the environmental-justice-
designated communities impacted by the BP oil spill. EPA's response
communications assisted states and other federal agencies in understanding the
immediate and long-term impacts of oil contamination.
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EPA Communicated With State and Local Decision makers
During the recent oil spill incidents, EPA conducted sampling and monitoring of
air, water, and sediment, and these results were communicated to local and state
decisionmakers who in turn made the decisions regarding actions to protect public
health (e.g., voluntary evacuations, drinking water advisories, and beach
closures).
Specifically for the BP oil spill, EPA's monitoring and sampling activities
provided the USCG, states, and local governments with information about the
potential impacts of the oil spill. EPA collected samples along the shoreline and
beyond to test for chemicals related to oil and dispersants in the air, water, and
sediment; supported and advised USCG efforts to clean the oil and waste from the
shoreline; and closely monitored the effects of dispersants in the subsurface
environment. Each state sets water quality baselines for closure of fishing areas
by fish/shellfish category, and EPA's water quality data contributed to the State of
Louisiana's decision to close certain fishing areas.
During the Enbridge oil spill, EPA provided the results of its monitoring and
sampling to local agencies. Local officials then made decisions regarding the
health and safety of the affected communities. EPA's air monitoring after the
Enbridge oil spill showed one chemical, benzene, at a level of potential health
concern. Based on these concerns, the local health department issued a voluntary
evacuation notice for people living in the most highly impacted areas. In addition,
EPA's surface water samples provided information on oil-related chemicals found
in Talmadge Creek and the Kalamazoo River. Based on results of water sampling,
state and local agencies issued a ban on surface water activities, including
swimming, wading, fishing, boating, canoeing, and kayaking.
EPA Communicated With Impacted Communities
EPA made environmental data available to the public. EPA utilized various media
to disseminate the information. EPA used such tools as Google Earth, Facebook,
and Twitter to communicate with the public. The results and the interpretation of
all data collected by EPA were posted on its website to ensure that residents in
affected areas had access to information about the quality of their water. EPA
regularly updated its website with sampling results and information regarding
health questions and ecological concerns.
The Agency also conducted or participated in numerous press conferences. Fact
sheets were prepared and disseminated to the public covering topics such as air,
water and sediment quality, and the cleanup process. Additionally, EPA issued
request for proposals totaling $300,000 in grants to further communication efforts
in the environmental-justice-designated communities impacted by the BP oil spill.
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Lessons-Learned Activities Conducted by EPA
EPA conducted various lessons-learned exercises to help evaluate the
effectiveness of its response to both oil spill incidents. These reviews looked at a
number of components such as communication, staffing/logistics, and the crisis
communication plan. Lessons-learned activities included the following:
• Region 4 sent a blind survey to all EPA employees who worked on the BP
spill, regardless of their regional location. This survey focused on several
topic areas such as deployment, operations, communication, and data
management.
• Region 5 led a hot wash, or performance review, of its Enbridge response
and plans to conduct another one to obtain feedback from nonfederal
responders.
• Headquarters also completed a hot wash and developed a public
information officer summary of lessons learned from the BP spill.
These lessons-learned activities should allow the Agency to identify areas of
success, as well as areas that could be improved upon in responding to future
emergency situations.
Agency Comments and Office of Inspector General Evaluation
We make no recommendations in this report, and the Agency did not formally
respond to the draft version of this report. A representative of the Office of
Emergency Response did provide technical comments and described the report as
a good summary of spill response, coordination, and followup actions. The
technical comments were addressed in the final report as appropriate.
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Status of Recommendations and
Potential Monetary Benefits
POTENTIAL MONETARY
RECOMMENDATIONS BENEFITS (in $OOOs)
Planned
Rec. Page Completion Claimed Agreed-To
No. No. Subject Status1 Action Official Date Amount Amount
No recommendations
1 0 = 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
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Appendix A
Distribution
Office of the Administrator
Assistant Administrator for Solid Waste and Emergency Response
Regional Administrator, Region 4
Regional Administrator, Region 5
Regional Administrator, Region 6
Agency Followup Official (the CFO)
Agency Followup Coordinator
General Counsel
Associate Administrator for Congressional and Intergovernmental Relations
Associate Administrator for External Affairs and Environmental Education
Audit Followup Coordinator, Office of Solid Waste and Emergency Response
Audit Followup Coordinator, Region 4
Audit Followup Coordinator, Region 5
Audit Followup Coordinator, Region 6
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