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Website for Those Impacted by Hurricane Harvey
The EPA has useful information for residents and others impacted by Hurricane
Harvey on its Hurricane Harvey 2017 website.
Report Contributors:	Debra Coffel
Michael Davis
Heather Layne
Abbreviations
CFR	Code of Federal Regulations
EPA	U.S. Environmental Protection Agency
ESF	Emergency Support Function
FEMA	Federal Emergency Management Agency
OFPP	Office of Federal Procurement Policy
OIG	Office of Inspector General
Cover Photo: Depiction of local Emergency Operation Centers and FEMA Disaster
Recovery Centers joint efforts, set up at the Harris County Greensport Mall in
Houston, Texas, to disseminate information to residents. (EPA photo)
Are you aware of fraud, waste or abuse in an
EPA program?
EPA Inspector General Hotline
1200 Pennsylvania Avenue, NW (2431T)
Washington, DC 20460
(888) 546-8740
(202) 566-2599 (fax)
OIG Hotline@epa.gov
Learn more about our OIG Hotline.
EPA Office of Inspector General
1200 Pennsylvania Avenue, NW (2410T)
Washington, DC 20460
(202) 566-2391
www.epa.gov/oiq
Subscribe to our Email Updates
Follow us on Twitter @EPAoig
Send us your Project Suggestions
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U.S. Environmental Protection Agency
Office of Inspector General
At a Glance
20-P-0010
October 23, 2019
Why We Did This Project
The U.S. Environmental Protection
Agency's (EPA's) Office of
Inspector General (OIG) conducted
this audit to determine whether the
EPA, in its emergency response to
Hurricane Harvey, effectively
managed the Disaster Relief
Funding received from the Federal
Emergency Management Agency
(FEMA). We also sought to
determine whether the EPA
implemented necessary and
agreed-to corrective actions and
intended program improvements
resulting from prior OIG report
recommendations.
Hurricane Harvey struck primarily
Texas and Louisiana in late August
2017. FEMA tasked the EPA to
support Hurricane Harvey disaster
relief efforts. In all, 251 EPA staff
from headquarters and the regions
completed 281 deployments—for a
total of 3,585 days—in support of
the EPA's response efforts. The
EPA spent over $11 million in
FEMA Disaster Relief Funding for
the Hurricane Harvey response.
This report addresses the
following:
• Operating efficiently and
effectively.
EPA Adequately Managed Hurricane Harvey
Funding Received from FEMA
What We Found
We found that the EPA effectively
managed its Hurricane Harvey Disaster
Relief Funding. We did not identify any
significant issues in the EPA's
contracting, logistics or resource
acquisition processes. Prior to our
audit, the agency had already identified
strengths and areas for improvement
and had implemented corrective
actions in response to the OIG's recommendations in its 2006, 2008 and
2014 reports regarding its emergency responses. We did not identify any
significant issues during this audit and make no recommendations.
The EPA had policies and
procedures in place for
efficient and effective
management of over
$11 million in FEMA
Disaster Relief Funding for
the Hurricane Harvey
response.
Address inquiries to our public
affairs office at (202) 566-2391 or
OIG WEBCOMMENTS@epa.gov.
List of OIG reports.
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON, D.C. 20460
OFFICE OF
INSPECTOR GENERAL
October 23, 2019
MEMORANDUM
SUBJECT: EPA Adequately Managed Hurricane Harvey Funding Received from FEMA
Report No. 20-P-0010
FROM: Charles J. Sheehan, Acting Inspector General
TO:	Peter Wright, Assistant Administrator
Office of Land and Emergency Management
Donna J. Vizian, Principal Deputy Assistant Administrator
Office of Mission Support
Ken McQueen, Regional Administrator
Region 6
This is our report on the subject audit conducted by the Office of Inspector General (OIG) of the
U.S. Environmental Protection Agency (EPA). The project number for this audit was OA&E-FY18-0270.
This report represents the opinion of the OIG and does not necessarily represent the final EPA position.
You are not required to respond to this report because this report contains no recommendations.
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.
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We will post this report to our website at www.epa.gov/oig.
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EPA Adequately Managed Hurricane Harvey
Funding Received from FEMA
20-P-0010
Table of C
Purpose		1
Background		1
Responsible Offices		2
Scope and Methodology		2
Prior Reports		3
Results		4
EPA Acquisition Flexibilities Implemented		4
EPA Maintained Ample Supporting Documentation for Acquisitions		5
EPA Used Feedback, Surveys and After-Action Reports to Identify
Areas for Improvement		5
EPA Did Not Repeat Fiscal Responsibility Issues Previously Identified		6
Corrective Actions implemented for Prior Reports' Recommendations		7
Conclusion		7
EPA Response and OIG Evaluation		7
Appendix
A Distribution	 8
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Purpose
The U.S. Environmental Protection Agency's (EPA's) Office of Inspector
General (OIG) conducted an audit of the management of Federal Emergency
Management Agency (FEMA) funding received for the response to Hurricane
Harvey. The objective of this audit was to determine whether the EPA, in its
emergency response to Hurricane Harvey, effectively managed the Disaster Relief
Funding received from FEMA. This audit also followed up on previously issued
OIG reports about EPA emergency responses.
Background
Three major hurricanes, Harvey, Irma and Maria, made historic landfalls in the
United States in 2017. Hurricanes Harvey and Irma marked the first time two
Atlantic Category 4 1 hurricanes hit the continental United States during the same
season; with "nearly 4.5 feet of rain and 130 mph winds, Hurricane Harvey
propelled a disaster response that was the largest in Texas state history," as
reported by FEMA.2 Hurricane Maria made landfall in Puerto Rico with
sustained winds of 155 mph.
A major disaster was declared for Texas on August 25, 2017, and for Louisiana
on August 28, 2017, because of Hurricane Harvey. Under the Stafford Act,3
FEMA is authorized to task other federal agencies using a "mission assignment."
FEMA coordinates disaster response efforts through mission assignments—work
orders that direct another federal agency to utilize its authorities and the resources
granted to it under federal law.
FEMA tasked the EPA, using
mission assignments under the
Emergency Support Function
(ESF) #10—Oil and Hazardous
Materials Response—on
August 28, 2017, to support the
Hurricane Harvey disaster relief
efforts. The EPA's mission under
ESF #10 focused on the
detection, identification, clean up
and/or disposal of hazardous
waste and materials (see Table 1).
Table 1 - EPA's activities under FEMA's ESF #10
Detect, identify, contain, clean up or dispose of
released oil or hazardous materials.
Remove drums, barrels, tanks or other bulk
containers that contain oil or hazardous materials.
Collect household hazardous waste.
Monitor debris disposal.
Monitor and protect water quality monitoring and
protection.
Conduct sampling and monitoring for air quality.
Protect natural resources.
Source: EPA Order #2071, National Approach to
Response.
1	Per the National Hurricane Center's "Saffir-Simpson Hurricane Wind Scale" webpase. Category 4 hurricanes are
major storms in which catastrophic damage occurs and wind speeds can reach up to 156 miles per hour.
2	See FEMA, Historic Disaster Response to Hurricane Han'ev in Texas, FEMA HQ-17-133, September 2017.
3	The act's full title is the Robert T. Stafford Disaster Relief and Emergency Assistance Act.
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The EPA's response to Hurricane Harvey lasted 35 days, from August 24, 2017,
to September 28, 2017. EPA Region 6 was tasked to lead the EPA's Hurricane
Harvey response, with support from offices and personnel agencywide. In all,
251 EPA staff from headquarters and the regions completed 281 deployments—
for a total of 3,585 staff days—in support of the EPA's response efforts.
Responsible Offices
The EPA offices responsible for the issues in this report are the Office of
Emergency Management, within the Office of Land and Emergency Management;
the Office of Mission Support; and Region 6's Emergency Management Branch,
within the Region 6 Superfund Division.
Scope and Methodology
We conducted this audit from
September 2018 to June 2019 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 objectives. We believe that
the evidence obtained provides a
reasonable basis for our findings and
conclusions based on our audit
objectives.
To address our objectives, we reviewed the following relevant laws, regulations,
procedures and guidance:
•	Stafford Act, Title V, Emergency Assistance Programs, Section 501.
•	48 CFR Chapter 1, Federal Acquisition Regulation, Parts 1 and 18.
•	48 CFR Chapter 15, Environmental Protection Agency Acquisition
Regulation.
•	Emergency Acquisitions Guide, Office of Federal Procurement Policy
(OFPP), Office of Management and Budget (Jan. 14, 2011).
•	Various EPA procedures and guidance, including:
o EPA Emergency Contracting Procedures.
o EPA Acquisition Guide.
o EPA Order 2071, National Approach to Response.
EPA and Texas Commission on Environmental
Quality command posts. (EPA photo)
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We reviewed the EPA's mission assignments, contracts and expenditures related
to the EPA's emergency response to Hurricane Harvey that FEMA reimbursed
and the associated documentation to determine whether purchases were made in
accordance with laws, regulations and EPA policies, procedures and guidance.
We interviewed EPA staff from the responsible offices in headquarters and
Regions 4 and 6 to obtain an understanding of the nature of the program related to
EPA's disaster response to Hurricane Harvey. We cross-referenced the data
collected with the information in the EPA's Acquisition System4 and Financial
Data Warehouse. Specifically, we performed the following actions:
•	Assessed whether the controls had been properly designed and
implemented.
•	Determined whether the EPA's planning efforts before the emergency
were adequate and what problems the EPA encountered.
•	Reviewed and analyzed all FEMA mission assignments.
•	Reviewed and analyzed all acquisition purchases, contracts and expenses
related to the EPA's emergency response to Hurricane Harvey and the
associated documentation to determine compliance.
•	Reviewed sources of funding, including amounts billed and collected from
FEMA's funding.
Prior Reports
We followed up on the prior EPA OIG reports below that relate to hurricane and
emergency response topics (Table 2):
Table 2: Prior EPA OIG reports reviewed
Report no.
Report title
Date issued
14-P-0109
Internal Controls Needed to Control Costs of
Emergency and Rapid Response Services
Contracts, as Exemplified in Region 6
February 4, 2014
08-P-0055
EPA Should Continue to Improve Its National
Emergency Response Planning
January 9, 2008
2006-P-00038
Existing Contracts Enabled EPA to Quickly
Respond to Hurricane Katrina; Future
Improvement Opportunities Exist
September 27, 2006
2006-P-00033
Lessons Learned: EPA's Response to
Hurricane Katrina
September 14, 2006
Source: EPA OIG website.
4 The EPA's Acquisition System serves as a modern, integrated, web-based, centralized system for all of the EPA's
products and services acquisitions. It enables all stakeholders in the procurement process to use one automated
system throughout the acquisition life cycle, from requisitioning to contract closeout.
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Results
Our audit found that the EPA effectively managed its Hurricane Harvey Disaster
Relief Funding. We did not identify any significant issues in the EPA's
contracting, logistics or resource acquisition processes. Prior to our audit, the
agency had already identified strengths and areas for improvement. Specifically,
the EPA performed the following tasks:
•	Used existing Emergency and Rapid Response Services and Superfund
Technical Assessment and Response Team contracts to avoid awarding
new contracts.
•	Maintained documentation that showed the EPA was effectively awarding
and managing its Hurricane Harvey contract acquisitions.
•	Used feedback, surveys and after-action reports to identify strengths,
weaknesses and corrective actions.
The EPA implemented corrective actions in response to the recommendations in
our 2006, 2008 and 2014 reports of the EPA's management of Disaster Relief
Funding.
EPA Acquisition Flexibilities Implemented
In September 2017, the EPA issued an internal notice titled Hurricane Harvey
Special Emergency Acquisition Flexibilities. This document implemented
acquisition flexibilities available to EPA Contracting Officers—as outlined in
Part 18 of the Federal Acquisition Regulation, OFPP's Emergency Acquisition
Guide and EPA's Emergency Contracting Procedures—to obtain supplies or
services in support of its Hurricane Harvey response. The majority of the EPA's
spending in support of Hurricane Harvey resulted from five contracts. Table 3
details the EPA's Hurricane Harvey disaster response spending, all of which was
approved and reimbursed by FEMA.
Table 3: EPA's Hurricane Harvey spending
Category
Total Expended
Personnel compensation and benefits
$1,664,024.86
Travel subject to ceiling
660,019.49
Site-specific travel
7,006.98
Expenses
35,122.21
Contracts
8,668,404.42
Total
$11,034,577.96
Source: OIG analysis of EPA's spending detailed in the Financial Data Warehouse.
When exercising this acquisition authority, the agency required Region 6 personnel
to log all purchases made and specify how each purchase directly supported
Hurricane Harvey response efforts, as outlined in Table 4. The EPA reported its
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acquisitions via the Federal Procurement Data System, which showed specifically
how contracting actions directly supported the response to Hurricane Harvey.
Table 4: Hurricane Harvey acquisition documentation requirements
Prices were reasonable.
Small businesses were used to the maximum extent practicable.
Preference was given to local firms.
Periods of performance were brief. Contracts under this authority should not go any
longer than necessary to respond to the emergency.	
If making a purchase at the request of another agency, the requesting agency had the
authority and funding authorization to make the purchase.	
Source: EPA, Hurricane Harvey Special Emergency Acquisition Flexibilities.
EPA Maintained Ample Supporting Documentation for Acquisitions
We reviewed contract files to verify that the EPA's activities were consistent with
emergency acquisition requirements. We found that those contract and project
files included the following information:
•	Acquisition planning information and purchase requests.
•	Justification and approvals.
•	Original contract award, modifications and supporting documents.
•	Cost/price proposals and analyses.
•	Scopes of work.
•	Cross-references to pertinent documents filed elsewhere.
We verified that the EPA Acquisition System and the hard-copy files contained
documentation to support the EPA's Hurricane Harvey Special Emergency
Acquisition Flexibilities requirements affirming prices were reasonable and local
and small businesses were used. Contract periods of performance were
reasonable, with the one exception discussed in the following sections.
EPA Used Feedback, Surveys and After-Action Reports to identify
Areas for Improvement
The Office of Emergency Management solicited input from responding and
impacted personnel through interviews, surveys and feedback to provide an
overall review of the EPA's emergency response efforts. This information was
consolidated into the 2017 Hurricane and Wildfire Response After-Action Report
that highlighted strengths, best practices, areas for improvement and corrective
action recommendations. We concluded that the EPA collected feedback on its
relief efforts, which can impact future disaster relief efforts.
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Dive team assessing the San Jacinto River Waste Pits Superfund site. (EPA photo)
EPA Did Not Repeat Fiscal Responsibility Issues Previously Identified
During the Hurricane Harvey audit, we noted two potentially relevant issues
identified in OIG Report No. 2006-P-00038 pertaining to price reasonableness
determinations and longer-than-necessary contract performance periods.
The EPA obtained trailers to house its Hurricane Harvey responders—including
EPA employees and contractors—for the following reasons indicated in the 2017
Hurricane and Wildfire Response After-Action Report.
•	A room block was not available to EPA responders to make hotel
reservations at a government rate.
•	EPA contractors did not have the authority to obtain hotel rooms.
In its 2017 Hurricane and Wildfire Response After-Action Report, the EPA stated,
"While obtaining trailers through the logistics contract provided flexibility, given
the costs of approximately $2,110,000, other options should have been explored."
The report further mentioned that some staff beli eved the trailers were too
expensive. During our audit, we found that the Contracting Officer performed
market research and obtained quotes and cost estimates, consistent with Federal
Acquisition Regulation Section 15.404-1, to make an adequate determination of
price reasonableness for the trailers.
We did find that the contract for the trailers was longer than necessary. The EPA
contracted lodging trailers for 60 days, but the EPA's disaster relief efforts did not
last the entire length of the contract. EPA staff told us that they believed the relief
efforts would last at least 60 days based on experience. However, although the
contract period for the trailers (60 days) extended beyond the response period
(35 days), the EPA determined that it would have spent more money to terminate
the contract. While the EPA could have established a shorter period of
performance up front, we found overall that the EPA's management of Disaster
Relief Funding did not repeat issues concerning fiscal responsibility that were
raised in prior OIG reports.
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Corrective Actions Implemented for Prior Reports' Recommendations
Office of Management and Budget requirements emphasize the need for
management to take corrective actions when issues or deficiencies are identified.
Per the EPA's Management Audit Tracking System, the EPA implemented
corrective actions in response to the OIG's recommendations in our 2006, 2008
and 2014 reports on the EPA's management of Disaster Relief Funding. These
reports all addressed—either in part or in whole—financial issues and contract
management.
Conclusion
Overall, we found that the EPA's management of Disaster Relief Funding did not
repeat issues concerning fiscal responsibility that were identified in prior OIG
reports. As a result, we concluded that the EPA had corrected issues found in
prior reports, had policies and procedures in place for emergency acquisition
flexibilities to effectively manage Disaster Relief Funding received from FEMA,
and adequately documented the support needed for the EPA's Hurricane Harvey
acquisitions. Therefore, we make no recommendations resulting from this audit.
EPA Response and OIG Evaluation
We issued a discussion document presenting our audit results to the EPA on
June 18, 2019. In addition, we met with the EPA on June 27, 2019, to discuss our
audit results. The EPA concurred with our results and with proceeding directly to
a final report. The EPA elected not to provide a written response.
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Appendix A
Distribution
The Administrator
Assistant Deputy Administrator
Associate Deputy Administrator
Chief of Staff
Deputy Chief of Staff
Assistant Administrator for Land and Emergency Management
Assistant Administrator for Mission Support
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
Principal Deputy Assistant Administrator for Land and Emergency Management
Deputy Assistant Administrator for Land and Emergency Management
Principal Deputy Assistant Administrator for Mission Support
Deputy Assistant Administrator for Administration and Resources Management,
Office of Mission Support
Deputy Regional Administrator, Region 6
Director, Office of Continuous Improvement, Office of the Administrator
Director, Office of Emergency Management, Office of Land and Emergency Management
Director, Office of Acquisition Solutions, Office of Mission Support
Director, Office of Resources and Business Operations, Office of Mission Support
Director, Office of Regional Operations
Director, Superfund Division, Region 6
Audit Follow-Up Coordinator, Office of the Administrator
Audit Follow-Up Coordinator, Office of Land and Emergency Management
Audit Follow-Up Coordinator, Office of Mission Support
Audit Follow-Up Coordinator, Region 6
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