j A *
1®
U.S. ENVIRONMENTAL PROTECTION AGENCY
OFFICE OF INSPECTOR GENERAL
Ensuring clean and safe water
EPA Region 6 Quickly Assessed
Water Infrastructure after
Hurricane Harvey but Can
Improve Emergency Outreach to
Disadvantaged Communities
July 16. 2019
Report No. 19-P-0236

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Report Contributors:	Stacey Banks
Kathlene Butler
Timothy Roach
Nirvair Stein
Khadija Walker
Abbreviations
EPA	U.S. Environmental Protection Agency
ESF	Emergency Support Function
FEMA	Federal Emergency Management Agency
OIG	Office of Inspector General
TCEQ	Texas Commission on Environmental Quality
Cover Image: Flood waters from Hurricane Harvey overwhelm a wastewater treatment plant
in Vidor, Texas. (Photo courtesy of Orange County Water Control and
Improvement District No. 1)
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At a Glance
Why We Did This Project
We conducted this audit to
determine how the
U.S. Environmental Protection
Agency's (EPA's)
preparedness and response
efforts for the three major
hurricanes of calendar
year 2017—specifically,
hurricanes Harvey, Irma and
Maria—protected human health
and water resources from
storm-related drinking water
and surface water
contamination. This report
addresses the Region 6
response to the drinking water
and wastewater facilities
impacted by Hurricane Harvey.
Hurricane Harvey made landfall
as a Category 4 storm on
August 25, 2017. In Texas
alone, Hurricane Harvey
claimed 68 lives, dropped
approximately 19 trillion gallons
of rainwater and caused
damages estimated at
$125 billion.
This report addresses the
following:
•	Ensuring clean and safe
water.
•	Partnering with states and
other stakeholders.
•	Operating efficiently and
effectively.
Address inquiries to our public
affairs office at (202) 566-2391 or
OIG WEBCOMMENTS@epa.gov.
EPA Region 6 Quickly Assessed Water Infrastructure
after Hurricane Harvey but Can Improve Emergency
Outreach to Disadvantaged Communities
What We Found
The EPA Region 6 water-related response
focused on determining the operational status of
drinking water and wastewater facilities over a
3-week period in the aftermath of Hurricane
Harvey. Extensive preparation activities and
close working relationships with state
emergency response partners enabled Region 6
to protect human health and water sector
resources as part of its Hurricane Harvey mission assignment. The Region 6
Superfund and Water Quality divisions coordinated with the Texas Commission
on Environmental Quality (TCEQ) to conduct drinking water and wastewater
facility reviews, as well as to perform limited on-site technical assistance. These
reviews enabled EPA and TCEQ response staff to successfully determine and
track the operational status of facilities.
Enhancements to
environmental justice
outreach efforts during
emergencies could improve
the public health
protections of communities
impacted by hurricanes or
other disasters.
While Region 6 successfully fulfilled its water sector mission assignment in the
aftermath of Hurricane Harvey, we identified one area for improvement—staff
outreach to residents of vulnerable communities—that would further enhance the
region's emergency response capabilities.
Recommendations and Planned Agency Corrective Actions
We recommend that the EPA Region 6 Regional Administrator (1) include
environmental justice outreach in planning and pre-landfall preparation exercises
by gathering data to determine the population, unique needs and challenges of
vulnerable communities; (2) revise the Region 6 pre-landfall hurricane plan to
incorporate environmental justice outreach; (3) implement the recommendations
to improve environmental justice outreach identified at a June 2018
environmental justice forum; and (4) prepare and produce all outreach materials
in advance, in sufficient quantities and in the region's prevalent languages, and
post all translated materials online.
EPA Region 6 agreed with three of our recommendations but requested a
modification to Recommendation 3. However, we determined a modification was
not needed, since the region's proposed corrective actions address the intent of
Recommendation 3. We therefore consider all four of our recommendations
resolved with corrective actions pending. Region 6 officials have agreed to
complete corrective actions by March 31, 2021.
List of OIG reports.

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^EDSX
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I	|	UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
£	WASHINGTON, D.C. 20460
PRO^
OFFICE OF
INSPECTOR GENERAL
July 16, 2019
MEMORANDUM
SUBJECT: EPA Region 6 Quickly Assessed Water Infrastructure after Hurricane Harvey
but Can Improve Emergency Outreach to Disadvantaged Communities
Report No. 19-P-0236
FROM: Charles J. Sheehan, Deputy Inspector General
TO:	David Gray, Acting Regional Administrator
Region 6
This is our report on the subject assignment conducted by the Office of Inspector General (OIG) of the
U.S. Environmental Protection Agency (EPA). The project number for this audit was OPE-FY18-0005.
This report contains findings that describe the problems that the OIG has identified and corrective
actions the OIG recommends. 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 EPA Region 6 Regional Administrator is responsible for the issues discussed in this report.
In accordance with EPA Manual 2750, your office provided acceptable corrective actions and milestone
dates in response to OIG recommendations. All recommendations are resolved with corrective actions
pending, and no final response to this report is required. However, if you submit a response, it will be
posted on the OIG's 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 along with corresponding justification.
We will post this report to our website at www.epa.gov/oig.

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EPA Region 6 Quickly Assessed Water Infrastructure
after Hurricane Harvey but Can Improve Emergency
Outreach to Disadvantaged Communities
19-P-0236
Table of C
Purpose		1
Background		1
Scope and Methodology		2
Results		2
Region 6 Tracked Facility Status		3
Region 6 Staff Conducted Outreach to Vulnerable Communities		3
Region 6 Successfully Completed Mission Assignment		3
Area for Improvement		4
Recommendations		6
Agency Response and OIG Evaluation		6
Status of Recommendations and Potential Monetary Benefits		8
Appendices
A Initial Agency Response		9
B Supplemental Agency Response		13
C Distribution		16

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Purpose
The Office of Inspector General (OIG) conducted this audit to determine how the
U.S. Environmental Protection Agency's (EPA's) preparedness and response
efforts for the three major hurricanes of calendar year 2017—specifically,
hurricanes Harvey, Irma and Maria—protected human health and water resources
from storm-related drinking water and surface water contamination. This report
contains our findings and recommendations related to the EPA Region 6
emergency response activities for drinking water and wastewater facilities
impacted by Hurricane Harvey. Subsequent reports will address the response in
Regions 4 and 2 for hurricanes Irma and Maria, respectively.
Background
Hurricane Harvey made landfall in parts of Texas on August 25, 2017. The
National Hurricane Center rated the hurricane as a Category 4 storm.1 In Texas
alone, Hurricane Harvey claimed 68 lives, dropped approximately 19 trillion
gallons of rainwater and caused damages estimated at $125 billion.
With a few exceptions, the EPA responds to a disaster under the direction of the
Federal Emergency Management Agency (FEMA) and at the request of the states
experiencing the disaster. To facilitate an integrated approach, federal agencies
responding to a disaster adhere to the National Response Framework. The
National Response Framework contains 15 emergency support functions (ESFs)
to coordinate the resources and capabilities most needed in a national response
(Table 1). In response to the Hurricane Harvey federal disaster declaration,
FEMA activated EPA Region 6 under ESF #10—Oil and Hazardous Materials
Response—from August 25 through November 13, 2017. ESF #10 provides
federal support in response to an actual or potential discharge and/or release of oil
or hazardous materials.
Table 1: National Response Framework ESFs
#
Resource/capability
1#
Resource/capability
1
Transportation
9
Search and Rescue
2
Communications
10
Oil and Hazardous Materials *
3
Public Works and Engineering
11
Agriculture and Natural Resources
4
Firefighting
12
Energy
5
Information and Planning
13
Public Safety and Security
6
Mass Care, Emergency Assistance,
Temporary Housing and Human Services
14
Superseded by the National Disaster
Recovery Framework
7
Logistics
15
External Affairs/Standard Operating
8
Public Health and Medical Services

Procedures
Source: OIG analysis of U.S. Department of Homeland Security data.
* EPA-led ESF in response to Hurricane Harvey.
1 Per the National Hurricane Center's "Saffir-Simpson Hurricane Wind Scale" webpage. Category 4 hurricanes are
major storms in which catastrophic damage occurs and windspeeds can reach up to 156 miles per hour.
19-P-0236
1

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Under each ESF, FEMA issues mission assignments to federal agencies for
specific tasks, such as the cleanup of hazardous waste or the inspection of water
utilities. For Hurricane Harvey, part of the EPA's mission assignment under
ESF #10 focused on the water sector and included identifying affected drinking
water and wastewater systems, verifying their operational status, and offering
additional assistance necessary to restore services as quickly as possible.
When federal agencies respond to a mission assignment, the National Incident
Management System and the Incident Command System detail how the federal
government implements the National Response Framework. The National
Incident Management System is a systematic, proactive approach that enables all
levels of government, nongovernmental organizations and the private sector to
work together to prevent, protect against, mitigate, respond to and recover from
incidents. The Incident Command System is designed to enable effective and
efficient domestic incident management. It also establishes a chain of command
structure.
Scope and Methodology
We conducted our work from January 2018 to May 2019. We conducted this
performance audit in accordance with generally accepted government auditing
standards. Those standards require that we plan and perform the audit to obtain
sufficient, appropriate evidence to provide a reasonable basis for our findings and
conclusions based on our audit objective. We believe that the evidence obtained
provides a reasonable basis for our findings and conclusions based on our audit
objective.
The scope of this audit focused on how well the region accomplished its drinking
water and wastewater tasks under ESF#10.2We reviewed ESF #10 mission
assignments for Region 6; daily hurricane response activity reports; and
documents about federal emergency response, such as the National Response
Framework and ESFs. We interviewed Region 6 staff who participated in the
Hurricane Harvey response, as well as staff from the state's lead environmental
agency, the Texas Commission on Environmental Quality (TCEQ); local
environmental and human health nongovernmental organizations; and Houston-
area water and wastewater facility operators.
Results
Extensive preparation activities and close working relationships with state
emergency response partners enabled Region 6 to protect human health and water
sector resources under its Hurricane Harvey ESF #10 mission assignment. The
Region 6 Superfund and Water Quality divisions coordinated with the TCEQ to
2 EPA Region 6's response included soil, groundwater and surface water monitoring at Superfund sites. We did not
include those activities in this audit. See EPA's Hurricane Harvey website for a summary of EPA reports pertaining
to sampling at Superfund sites.
19-P-0236
2

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conduct drinking water and wastewater facility reviews as well as to perform
limited on-site technical assistance during a 3-week period in the aftermath of the
hurricane. These reviews enabled EPA and TCEQ response staff to determine and
track the facilities' operational status during the response period.
Region 6 Tracked Facility Status
As part of their Hurricane Harvey response efforts, Region 6 and the TCEQ
tracked the operational status of 2,238 drinking water facilities serving 11 million
residents and 1,743 wastewater facilities serving 10 million residents. Of these
3,981 facilities, regional and state staff conducted on-site reviews of 625 drinking
water and 441 wastewater facilities to verify their operational status.
In addition, EPA and TCEQ response staff performed 6,754 drinking water and
4,639 wastewater phone reviews.3 A total of 61 drinking water and 40 wastewater
facilities were deemed inoperable, and 203 boil water notices were issued by
drinking water facilities. All inoperable facilities except one wastewater system
returned to operations after the emergency response. The wastewater facility was
destroyed and not rebuilt.
Region 6 compiled the results of the facility reviews in the EPA's Response
Manager database. Management reports at the national headquarters level were
developed based upon the water and wastewater reviews data gathered in daily
situational awareness reports submitted by the region. Among the data reported
were the (1) progress of the EPA's response, (2) water and wastewater systems'
ability to provide safe and clean water, and (3) systems needing additional
technical assistance to become operational.
Region 6 Staff Conducted Outreach to Vulnerable Communities
In addition to and independent of the ESF #10 mission assignment, regional staff
from the Office of Communities, Tribes, and Environmental Assessment
conducted outreach to local communities that may be more vulnerable to the
impacts of natural disasters, such as immigrant communities where English is not
the primary language. For instance, regional staff disseminated informational
materials that described how to disinfect drinking water. These materials also
addressed concerns about operating private drinking water wells and septic
systems after a flood.
Region 6 Successfully Completed Mission Assignment
We identified three factors that contributed to Region 6 successfully completing
its mission assignment to assess drinking water and wastewater facilities:
3 Some facilities were reviewed on multiple occasions.
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3

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1.	Frequent and close communication and working relationships with the
state and other federal agencies. During the 3-week ESF #10 drinking
water and wastewater response period, two Region 6 staff members
worked at the TCEQ offices in Austin, Texas, to provide expertise and
facilitate communication between the two agencies. In addition, Region 6
used established relationships to communicate during the disaster,
including relationships solidified in the National Disaster Operational
Workgroup. This interagency workgroup comprises federal and state
agencies involved in disaster preparedness and response in Texas, and it
includes participants from the EPA, U.S. Coast Guard and TCEQ.
2.	Long-term and routine preparation, planning and exercises conducted by
the region. Region 6 participated in a routine tabletop exercise designed
for hurricane response in August 2017, just weeks before Hurricane
Harvey made landfall.4 This exercise increased preparedness because
participants learned what their roles would be during a hurricane disaster
response event. Region 6 and the TCEQ also relied on a draft pre-landfall
hurricane plan, which details when efforts will begin for an approaching
hurricane. In addition, Region 6 maintains staff response readiness levels
through Incident Command System training on the fundamentals of
emergency response. Since 2010, Region 6 has also held annual full-scale
exercises with its on-scene coordinators, as well as with other state and
federal emergency response staff, to practice skills and improve
coordination communications.
3.	Use of lessons learned to build upon and improve operations after
previous emergency responses. Region 6 staff had worked on previous
emergency response operations, including for hurricanes. Regional
managers said that they have been proactive in taking steps to improve
coordination for potential future disasters. After Hurricane Harvey, for
example, the region developed actions to track information on the status of
water facilities and expanded the emergency response database to include
data from facility reviews. The region will use these lessons learned to
improve emergency response activities.
Area for Improvement
While Region 6 successfully fulfilled its water sector mission assignment in the
aftermath of Hurricane Harvey, we identified one area for improvement—staff
outreach to residents of vulnerable communities—that would further enhance the
region's emergency response capabilities.
4 A tabletop exercise is an activity in which key personnel who have been assigned emergency management roles
and responsibilities gather to discuss, in a nonthreatening environment, various simulated emergency situations.
19-P-0236
4

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The Houston area has the country's third-largest populations of both Vietnamese
and Mexican immigrants. For the first time during a hurricane response, Region 6
deployed environmental justice5 liaisons to communities impacted by Hurricane
Harvey. EPA Region 6 also established a telephone hotline and email account to
provide updates on the response and receive environmental justice concerns. The
community liaisons discussed residents' concerns and handed out information
pamphlets about a variety of topics, including disposing of hazardous waste,
disinfecting drinking water and working with septic systems after a flood. The
liaisons distributed storm-related pamphlets written in English, Spanish and
Vietnamese.
However, not all residents in Houston-area communities received this information
because regional staff did not have sufficient quantities of translated pamphlets. In
addition, not all pamphlets were translated into Spanish (Table 2). Further, none
of the information pamphlets posted on the Region 6 "Hurricane Harvey 2017"
response webpage were available in Vietnamese and only one was available in
Spanish.
Table 2: Availability of translated EPA information pamphlets
Pamphlet title
Spanish
Vietnamese
Online
Print
Online
Print
Emergency Disinfection of Drinking Water
Yes
Yes
No
Yes
Private Wells - What to Do After a Flood
No
No
No
Yes
Septic Systems - What to Do After a Flood
No
No
No
Yes
Source: OIG analysis of the Region 6 emergency response website and pamphlets provided
by the region.
It is not known how many people needed translated materials but did not receive
them. The shortage of printed translated pamphlets as well as a lack of translated
versions of the pamphlets posted online for Houston communities meant that non-
native English speakers may have lacked essential public safety information
regarding the risks of floodwaters and how to disinfect drinking water.
In June 2018, Region 6 held an environmental justice forum that included
presentations from federal, state and local officials. There were discussions about
air monitoring in environmental justice communities, water system lead pipe
replacement activities, and Hurricane Harvey preparation and response activities.
These discussions included a community service perspective. At the forum,
Region 6 identified four recommendations for improving environmental justice
outreach for disaster response:
1. Establish an environmental justice staffing and support function within the
incident command structure.
5 According to the EPA, environmental justice is the fair treatment and meaningful involvement of all people
regardless of race, color, national origin or income with respect to the development, implementation and
enforcement of enviromnental laws, regulations and policies.
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2.	Add environmental justice training for the response support corps,
Incident Command System and other stakeholders.
3.	Communicate the need to address environmental justice concerns to
emergency operation centers.
4.	Provide printed copies of cleanup and safety literature to impacted
communities rather than weblinks.
These enhancements could improve the public health protections of communities
impacted by hurricanes or other disasters.
Recommendations
We recommend that the Regional Administrator, Region 6:
1.	Include environmental justice outreach in planning and pre-landfall
preparation exercises by gathering data to determine the population,
unique needs and challenges of vulnerable communities.
2.	Revise the Region 6 pre-landfall hurricane plan to incorporate steps based
on the results of outreach conducted during the planning and pre-landfall
preparation exercises.
3.	Implement the recommendations to improve environmental justice
outreach identified at the June 2018 environmental justice forum.
4.	Prepare and produce all outreach materials—including the cleanup
literature identified in the June 2018 environmental justice forum—in
advance, in sufficient quantities and in the region's prevalent languages,
and post all translated materials online.
Agency Response and OIG Evaluation
The acting Regional Administrator provided two responses to this draft report: an
initial response covering all recommendations (see Appendix A) and a
supplemental response providing additional details on recommendation 1 (see
Appendix B). Based on the two responses, Region 6 concurred with
Recommendations 1, 2 and 4, and provided acceptable planned corrective actions
and planned milestone dates. Recommendations 1, 2 and 4 are resolved with
corrective actions pending.
The region requested a modification to Recommendation 3, but we determined
that this modification was not needed for the following reasons:
• The region's planned corrective actions to address Recommendations 1, 2
and 4, when implemented, will address three of the four June 2018
19-P-0236
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environmental justice forum recommendations: to add environmental
justice training for the response support corps, Incident Command System
and other stakeholders; to communicate the need to address environmental
justice concerns to emergency operation centers; and to provide printed
copies of cleanup and safety literature to impacted communities rather
than weblinks.
• In its response to our draft report, the region indicated that the remaining
June 2018 environmental justice forum recommendation—to establish an
environmental justice staffing and support function within the incident
command structure—is being modified. That structure is established at a
national level and cannot be altered by the EPA. Instead, the region
committed to implementing a "Management Objective" during future
emergency response events to integrate environmental justice concerns
into the entire command structure and the after-action report process.
These planned corrective actions meet the intent of our recommendation, and we
therefore consider Recommendation 3 to be resolved with corrective actions
pending.
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Status of Recommendations and
Potential Monetary Benefits
RECOMMENDATIONS






Potential





Planned
Monetary
Rec.
Page



Completion
Benefits
No.
No.
Subject
Status1
Action Official
Date
(in $000s)
Include environmental justice outreach in planning and pre-	R Regional Administrator, 9/30/20
landfall preparation exercises by gathering data to determine the	Region 6
population, unique needs and challenges of vulnerable
communities.
Revise the Region 6 pre-landfall hurricane plan to incorporate R Regional Administrator, 3/31/21
steps based on the results of outreach conducted during the	Region 6
planning and pre-landfall preparation exercises.
Implement the recommendations to improve environmental	p Regional Administrator 3/31/20
justice outreach identified at the June 2018 environmental justice	Region 6
forum.
Prepare and produce all outreach materials—including the	R Regional Administrator, 3/31/20
cleanup literature identified in the June 2018 environmental	Region 6
justice forum—in advance, in sufficient quantities and in the
region's prevalent languages, and post all translated materials
online.
C = Corrective action completed.
R = Recommendation resolved with corrective action pending.
U = Recommendation unresolved with resolution efforts in progress.
19-P-0236
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Appendix A
Initial Agency Response
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION 6
*	1201 ELM STREET. SUITE 500
X	DALLAS, TEXAS 75270
June 7,2019

MEMORANDUM
SUBJEC1
Response to the Office of Inspector General Draft Report No. OPE-FY18-0005 "EPA
Region 6 Preparation fcfoand Response to Hurricane Harvey."' dated May 20. 2019
FROM: David W. Graj^yJ.^
Acting Regional Adinini
TO:	Kevin Christensen
Assistant Inspector General
Office of Audit and Evaluation
Office of Inspector General
Thank you for the opportunity to respond to the issues and recommendations in the subject audit
report. Following is the United States Environmental Protection Agency, Regions 6's responses
to the report recommendations. For those report recommendations with which the Region agrees,
we have provided the intended corrective actions and estimated completion dates. For the report
recommendation with which the Region does not agree, we have explained our position and
proposed an alternative to recommendations.
AGENCY'S OVERALL POSITION
The U.S. Environmental Protection Agency, Regions 6 agrees with Recommendations 1, 2, and 4
in the report and partially agrees with Recommendation 3 in the report.
19-P-0236

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AGENCY'S RESPONSE TO REPORT RECOMMENDATIONS
Agreements
No.
Recommendation
High-level Intended
Corrective Actions
Estimated
Completion
1.
Include environmental justice
outreach in planning and pre-
landfall preparation exercises by
gathering data to determine the
population, unique needs and
challenges of vulnerable
communities.
1.1 The Region 6 Office of
Communities, Tribes and
Environmental Assessment (OCTEA)
will provide a list of vulnerable
communities in Region 6 to the
Emergency Management Branch.
1st Quarter FY 2020
December 31st
1.2 The Region 6 Emergency
Management Branch will use the list
of vulnerable communities to identify
ones which are within jurisdictions
where it will conduct planning and
pre-landfall preparation exercises and
ensure these communities are
considered during these events.
4th Quarter FY 2020
September 31st
2.
Revise the Region 6 pre-landfall
hurricane plan to incorporate
steps based on the results of
outreach conducted during the
planning exercises in
Recommendation 1.
The Emergency Management Branch
will revise pre-landfall hurricane
plans based on the results of the
planning and pre-landfall activities
conducted as part of
Recommendation 1.
2nd Quarter FY 2021
March 31st
3.
Implement the
recommendations to improve
environmental justice outreach
identified at the lune 2018
environmental justice forum.
3.1 During an event, (OCTEA) will
hold regular calls with affected
vulnerable communities to identify
concerns and issues. These concerns
and issues will be provided to
Incident Command for evaluation
and action as needed.
For an incident, Region 6 will
establish a Management Objective on
environmental justice. This will
ensure environmental justice is a
specific consideration for the entire
command structure and the After
Action Report process.
N/A
3.2 The Emergency Management
Branch will add the topic of
environmental justice to training for
Incident Management Teams and
Response Support Corps personnel.
2nd Quarter 2020
March 31st
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3.3 The Emergency Management
Branch will provide a list of Local
Emergency Planning Committee
(LEPC) contacts to OCTEA. OCTEA
will provide the appropriate LEPC
contact information to
representative(s) of vulnerable
communities to facilitate planning
and preparedness.
Activities under Corrective Action 1.2
will also address this
recommendation.
4th Quarter FY 2019
September 31st
3.4 This is covered in the response to
Recommendation 4.
N/A
4.
Prepare and produce all
outreach materials—including
the cleanup literature identified
in the June 2018 environmental
justice forum—in advance, in
sufficient quantities and in the
region's prevalent languages,
and post all translated materials
online.
The Region 6 OCTEA will develop a
list of existing EPA outreach
materials that have been cleared by
EPA's Office of Public Affairs for
distribution and will provide this list,
including the languages each
document needs to be translated into,
to the Region 6 Office of External
Affairs.
The Region 6 Office of External
Affairs will have documents
translated, ensure there is a link to
each document on the EPA webpage,
and establish a process to make
printed copies available when
needed.
4th Quarter FY 2019
September 31st
2nd Quarter 2020
March 31st
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Disagreements
No.
Recommendation
Agency
Explanation/Response
Proposed Alternative
3.
Implement the
recommendations to improve
environmental justice
outreach identified at the
June 2018 environmental
justice forum: Establish an
environmental justice staffing
and support function within
the incident command
structure.
All Incident Command Systems
nationwide have the same defined
organizational structure to ensure
uniform management of
decisions, resources, and
personnel during an emergency.
Region 6 believes establishing a
Management Objective rather
than establishing a specific
environmental justice support
function within the Incident
Command System structure is a
better way to ensure
environmental justice concerns
are integrated into the entire
command structure and the After
Action Report process. A
Management Objective will better
serve the goal of a defined ICS
management structure.
Region 6 will establish a
Management Objective
related to environmental
justice.
CONTACT INFORMATION
If you have any questions regarding this response, please contact Mr. Arturo Blanco, Director,
Office of Communities, Tribes and Environmental Assessment at (214) 665-3182, or Mr. Carl
Edlund, Director, Superfund and Emergency Management Division at (214) 665-8124.
19-P-0236
12

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Appendix B
Supplemental Agency Response
? \	UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
| S	REGION 6
/	1201 ELM STREET, SUITE 500
% PH01#V	DALLAS, TEXAS 75270
July 3 2019	Oflca of the Regional Administrator
MEMORANDUM
SUBJECT; S^plememal Response lo the Office of Inspector General Draft Report No.
dated n1^20°^0 19 PA Regl°n ^ Preparati°n for and ResPonse t(-"> Hurricane Harvey ^
FROM:
TO;
David W. Gray
Acting Regional Administrator
Kevin Christensen
Assistant Inspector General
Office of Audit and Evaluation
Office of Inspector Genera!
Thank you for the opportunity to respond to the issues and recommendations in the subject audit
report. The following is to supplement our June 7, 2019 response regarding Recommendation 1.
AGENCY'S OVERALL POSITION
The U.S. Environmental Protection Agency, Regions 6 agrees with Recommendations 1.
19-P-0236
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AGENCY'S RESPONSE TO REPORT RECOMMENDATIONS
Agreements
No.
Recommendation
High-level Intended
Corrective Actions
Estimated
Completion
1.
Include environmental justice
outreach in planning and pre-
landfall preparation exercises
by gathering data to determine
the population, unique needs
and challenges of vulnerable
communities.
1.1 The Region 6 Office of Communities,
Tribes and Environmental Assessment
(OCTEA) will provide a list of
vulnerable communities in Region 6 to
the Emergency Management Branch.
•	OCTEA in Region 6 uses its EI
network list to develop a list of
vulnerable communities. The list
includes contacts with locally or
regionally focused community
interests, working together to
help communities with
environmental needs in the
specific area where those
contacts serve, such as areas in
Houston, Beaumont and Port
Arthur.
•	The list will include the general
service area of each contact on
the list, their type of service, and
generally known and relevant
vulnerabilities in the community
they serve. Depending on the
location and nature of the
anticipated or actual emergency,
other tools such as ElScreen may
be used to more specifically
delineate relevant information.
Regional staff will use EISCREEN to collect
relevant information as part of regional
emergency preparation activities or during a
response. Specifically, staff will query
EISCREEN for population and language data
information for a given location and
determined radius in the authorized response
area. Population and language data query
results will be used to estimate the number of
people in a given area and identify language
requirements in order to determine the amount
of materials to have ready for distribution in
the impacted area.
1st Quarter FY 2020
December 31st
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CONTACT INFORMATION
If you have any questions regarding this response, please contact Mr. Arturo Blanco, Director,
Office of Communities, Tribes and Environmental Assessment at (214) 665-3182, or Mr. Carl
Edlund, Director, Superfund and Emergency Management Division at (214) 665-8124.
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Appendix C
Distribution
The Administrator
Associate Deputy Administrator and Chief of Operations
Chief of Staff
Deputy Chief of Staff
Assistant Administrator for Land and Emergency Management
Assistant Administrator for Water
Regional Administrator, Region 6
Agency Follow-Up Official (the CFO)
Agency Follow-Up Coordinator
General Counsel
Associate Administrator for Congressional and Intergovernmental Relations
Associate Administrator for Public Affairs
Deputy Assistant Administrator for Land and Emergency Management
Principal Deputy Assistant Administrator for Land and Emergency Management
Deputy Assistant Administrator for Water
Principal Deputy Assistant Administrator for Water
Deputy Regional Administrator, Region 6
Director, Superfund and Emergency Management Division, Region 6
Director, Water Division, Region 6
Director, Office of Continuous Improvement, Office of the Administrator
Audit Follow-Up Coordinator, Office of the Administrator
Audit Follow-Up Coordinator, Office of Land and Emergency Management
Audit Follow-Up Coordinator, Office of Water
Audit Follow-Up Coordinator, Region 6
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