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U.S. Environmental Protection Agency
Office of Inspector General
At a Glance
13-P-0152
February 15, 2013
Why We Did This Review
The National Oil and
Hazardous Substances
Pollution Contingency Plan
(NCP) establishes federal roles
for oil spill response and
requires area and regional
planning by the U.S.
Environmental Protection
Agency (EPA) and other
stakeholders. A prior audit on
the 2010 Deepwater Horizon oil
spill in the Gulf of Mexico noted
that some contingency plans
were out of date. We initiated
this review to determine
whether the contingency
planning structure for
responding to oil spills and
hazardous substance releases
is effective, and whether plans
are updated to reflect lessons
learned from recent major
events and new developments
or industry trends.
This report addresses the
following EPA Goal or
Cross-Cutting Strategy
• Cleaning up communities
and advancing sustainable
development
For further information, contact
our Office of Congressional and
Public Affairs at (202) 566-2391.
The full report is at:
www.epa.aov/oia/reports/2013/
20130215-13-P-0152.pdf
EPA Could Improve Contingency Planning for
Oil and Hazardous Substance Response
What We Found
EPA regions have expanded contingency planning by creating additional
plans and materials, but regions cannot maintain this large volume of
information with their limited resources. Regions have created subarea
contingency plans, geographic response plans and strategies, and various
web-based tools. This structure exceeds the three levels of plans
established in the Oil Pollution Act, which revised the NCP to expand the
response system. The NCP requires national planning in the form of an
NCP, regional planning by each Regional Response Team in the form of
Regional Contingency Plans, and area planning by Area Committees in the
form of Area Contingency Plans. Regions developed additional plan
materials because regional On-Scene Coordinators find them necessary to
respond to incidents. Some written plans miss some NCP requirements,
contain duplicative information, and are out-of-date. Technological
methods—instead of revising written plans—would enable EPA to maintain
current information needed to efficiently respond to spills.
Recommendations and Planned Agency Corrective Actions
We recommend that the Assistant Administrator for Solid Waste and
Emergency Response (1) issue guidance to regions on working with their
Regional Response Teams and Area Committees to use the most efficient
method available to address NCP requirements, (2) require regions to keep
critical planning information up-to-date and avoid unnecessary duplication,
(3) work through the office's National Response Team capacity to develop a
process to regularly incorporate lessons learned from national exercises into
contingency plan reviews and updates, and (4) assess the resources
necessary to develop and maintain contingency plans and use the results to
develop a workforce plan to distribute contingency planning resources. The
Agency agreed with our recommendations and plans to address them by the
end of fiscal year 2013.
Noteworthy Achievements
EPA regions apply an inclusive approach toward contingency planning by
working closely with other federal agencies, states, tribes, and industry
representatives. Regions also use technological methods—such as
Geographic Information Systems maps, web-based lists, and electronic
tools—to address some NCP requirements.

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