Chapter 7: EPA Should Continue Efforts to Improve Contingency Planning
The events of September 11 represented an attack on the U.S. mainland not previously experienced in this country’s history. The response to this tragedy was trying and difficult for all parties involved, including environmental professionals. Many of the persons we interviewed spoke highly of the response of EPA and its employees. Still, lessons were learned from the September 11 response that can be used to improve the Agency’s ability to respond to future disasters. The primary lessons learned from our evaluation relate to:
• Contingency planning
• Risk assessment and characterization
• Risk communication
An overriding lesson learned was that EPA needs to be prepared to assert its opinion and judgment on matters that impact human health and the environment. Although many organizations were involved in addressing air quality concerns resulting from the WTC collapse, subsequent events have demonstrated that, ultimately, the public, Congress, and others expect EPA to monitor and resolve environmental issues. This is the case even when EPA may not have the overall responsibility to resolve these issues or the necessary resources to address them. Various Actions Initiated
EPA and several non-EPA groups and individuals prepared “lessons learned” reports on the government’s response to environmental issues resulting from September 11. We generally agree with the recommendations made in these reports. A summary on the previous lessons learned areas follows in Table 7-1. Further details on the lessons learned as part of both EPA and non-EPA reviews are in Appendix N.
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Table 7-1: Previous Lessons Learned Reviews
Type of Review / Lessons Learned Areas
EPA Office of Solid Waste and Emergency Response, per request by EPA Administrator, determined lessons learned between September 11, 2001, and October 19, 2001. Results were summarized in a final report dated February 1, 2002. / • Decision making and communication
• Emergency response structure and plans
• Data analysis and information management infrastructure
• Public information dissemination
• Safety and security
• Environmental vulnerabilities
EPA Region 2 conducted a region- specific lessons learned analysis. The Region held an “after action session” in Edison, New Jersey, on January 9- 10, 2002, and issued a final report dated January 8, 2003. / • Overarching Recommendation Areas
• Resources Specific Recommendation Areas
• Public risk communication
• Data management
• Regional crisis management structure
EPA Office of Research and Development held a data-oriented lessons learned workshop in November 2002. The report was still in draft as of our review. / • Quality assurance project plan
• Mechanism for tracking monitoring tasks
• Improved health-related benchmarks for asbestos and short-term exposures of pollutants in general
• Identification of technical expertise teams that could be called on to assist with technical decisions
Environmental experts and others prepared lessons learned reports from September 2002 to December 2002. • Better risk communication
• Health-related benchmarks assessing exposure
• Clearer lines of authority between government agencies in responding to environmental issues
In September 2002, EPA issued its “Strategic Plan for Homeland Security,” which outlines the Agency’s plan for meeting its homeland security responsibilities. This Strategic Plan includes many proposed actions recommended in EPA’s February 2002 Lessons Learned report. The goals of the plan are grouped under four major mission areas:
• Critical Infrastructure Protection
• Preparedness, Response, and Recovery
• Communication and Information
• Protection of EPA Personnel and Infrastructure
The second and third mission areas – “Preparedness, Response, and Recovery” and “Communication and Information” – are particularly relevant to the issues
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discussed in this report.  Within these two major areas, the Homeland Security plan lists several actions that were recommended in the February 2002 Lessons Learned Report as well as issues identified in this report.OIG Observations for Improving Emergency Response
Observations developed by our evaluation, as well as any Agency actions already underway to address these observations, are summarized in Table 7-2, and discussed in detail in the sections that follow.
Table 7-2: Summary of OIG Observations Contingency Planning
• Environmental Threats from Potential Terrorist Attacks Need to Be Assessed
• Roles and Responsibilities Within EPA Need to Be Delineated
• Roles and Responsibilities With Outside Agencies Need to Be DelineatedRisk Assessment and Characterization
• Health-Based Benchmarks Needed
• Sampling and Data Collection Protocols Needed
• Monitoring Capabilities Need to Be IncreasedRisk Communication
• Better Communication Policies, Procedures, and Guidance Needed
• Risk Communications Need to Acknowledge Uncertainties
• Procedures Needed to Ensure Consistency in Communications
• Communications Need to Identify External Influences
• Environmental Data from Sources Outside EPA Need to Be Addressed
EPA has many years experience in responding to environmental emergencies and has established policies and procedures to deal with such emergencies. EPA’s Lessons Learned Report identified issues related to contingency planning and made recommendations for improvements in this area. Additionally, EPA’s Homeland Security strategy includes actions to address this area. Notably, the Agency has started efforts to upgrade the National Incident Coordination Team, which coordinates EPA’s response to large-scale emergencies. The events of September 11 demonstrate the following areas where the Agency’s emergency response mechanisms can be improved.
17 OIG has ongoing and planned work to evaluate EPA’s efforts related to the other major homeland security missions not addressed in this report.
Report No. 2003-P-00012Environmental Threats from Potential Terrorist Attacks Need to Be Assessed
It is understandable that the government and others were not fully prepared for what happened on September 11. Now that the country has experienced such an attack and lives under the threat of future attacks, it is important that the Agency anticipate and plan for different disaster scenarios. To the extent that EPA can anticipate various scenarios and plan for the type of environmental response needed before a disaster strikes, the Agency’s response efforts can be more focused on appropriate implementation and avoid making interpretative, technical, and policy-setting decisions with potential public health implications during the stressful and time-demanding circumstances created by an emergency.
The experience of September 11 has provided the Agency with considerable information on what to expect of a large-scale disaster involving office and multi- family residential buildings in a densely populated urban environment. However, disasters involving other scenarios, other types of targets, and other locations may present different challenges. For example, New York City has significant emergency response and environmental resources - other cities may not and may require more assistance from EPA. In addition, EPA Region 2’s office was located within New York City and close to the disaster site, and EPA’s national Environmental Response Team was located in nearby Edison, New Jersey, approximately 30 miles away. This was important, because air travel was curtailed for several days after the attacks. EPA may not be as closely located to the next disaster.
Disasters in different parts of the country could present different, perhaps greater, environmental exposures than at WTC. EPA researchers told us the tall buildings in New York City combined to create a “chimney effect” that helped to push air and pollutants upward and away from street level. Winds also helped disperse and dilute WTC airborne emissions, and rain during the first week helped alleviate dusty conditions. If a similar disaster were to strike in a city with different geography and weather patterns, a more serious exposure scenario could develop.
Accordingly, EPA should work with the Department of Homeland Security and other agencies to share information on high-risk targets and areas, and develop plans for responding to an emergency situation in those areas. These plans should address the different scenarios anticipated from a disaster involving these targets and how EPA, other Federal, and the appropriate State and local agencies should respond to these different scenarios.
Report No. 2003-P-00012Roles and Responsibilities Within EPA Need to Be Delineated
EPA needs to delineate roles and responsibilities for its various programs offices when responding to emergencies, including how these roles and responsibilities fit within the incident command structure. Despite the commendable actions of many EPA personnel, the Agency should outline roles and responsibilities for its program offices beforehand to provide a more efficient and coordinated response to future disasters.
For example, within 3 days of the disaster, EPA officials within the Office of Radiation and Indoor Air and the Office of Air Quality and Planning Standards had developed a web site with such captions as “Protecting Yourself from Asbestos Exposure,” “Health Effects of Dust and Smoke,” and “Strategies for Clean Up Inside Residences and Businesses.” However, this web site was not activated and made available to the general public. One EPA official told us there was an overwhelming amount of activity going on and that this information probably “got lost in the fray.” EPA Region 2 officials could not recall why the web site was not activated.
Also, although EPA’s National Exposure Research Laboratory team made it to New York on September 16 to help implement an ambient monitoring network, they were unable to gain access to the site and start monitoring until September 21. The Laboratory’s monitoring team’s abilities were especially needed since they had air monitoring equipment that could run on both electrical and battery power, and they had airborne particulate matter monitors.
In its lessons learned report, EPA Region 2 recommended that the Region identify a team of dedicated people who will respond in the event of a new crisis. In our opinion, other EPA regions should follow Region 2’s lead and identify specific areas of expertise that may be needed in the event of an emergency, and assemble teams of experts that can be mobilized to quickly provide this support. These areas may include specialized sampling techniques, exposure modeling and assessment, and risk assessment. Also, EPA Headquarters should develop national teams to support or augment Regional response when needed, including guidelines for determining when a response should be elevated to a national level.Roles and Responsibilities With Outside Agencies Need to Be Delineated
A response to an event the size of the WTC incident requires the efforts and coordination of numerous government organizations, including Federal, State, and local governments. Our discussions with EPA and non-EPA officials, as well as WTC “lessons learned” reports from other organizations, indicated that there were overlapping and sometimes confusing roles and responsibilities for the various responding organizations. For example, early in the response, various agencies were conducting numerous sampling efforts. Particularly for asbestos, different
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sampling methods were being used with the results being reported in different metrics, which made the results more difficult to interpret. A senior New York City Office of Emergency Management official told us that roles and responsibilities of the Federal, State, and local agencies in responding to a disaster were unclear on September 11, 2001, and were still unclear when we met with him during the summer of 2002.
EPA has addressed coordination with other organizations in both its Headquarters and Region 2 lessons learned reports. For example, the Headquarters Report recommended that EPA collaborate with OSHA and the Department of Health and Human Services to clarify the Agency’s role in protecting the health and safety of responders, and that EPA coordinate with Department of Homeland Security to develop a coordination strategy for all responders during national emergencies. Region 2 management and staff recommended that their Region clearly identify scope and boundaries of their work in an emergency; and educate EPA and other Federal and State officials about the scope, boundaries and authorities of the various emergency response plans and systems. We agree with these recommendations. These coordination efforts should also take place in all EPA regions and include FEMA, and should address likely sources of funding for these activities.Risk Assessment and Characterization
The WTC disaster pointed to the need for better risk assessment and characterization procedures and tools for addressing the types of environmental concerns resulting from large-scale disasters. A significant challenge encountered by EPA and other organizations was how to characterize health risks to the public in the absence of health-based benchmarks. The need for consistent sampling protocols and special monitoring requirements was also demonstrated.Health-Based Benchmarks Needed
Government entities, such as EPA, OSHA, ATSDR, and NIOSH, have developed guidelines for many of the contaminants found in Lower Manhattan. However, existing health benchmarks were not applicable to exposures experienced by the general public in Lower Manhattan. Many of the benchmarks available at that time to assess the exposure risks for contaminants found in the ambient air were: occupational standards based on an 8-hour-per-day exposure; guidelines based on long-term exposures; or standards, such as those for asbestos, that were not health based. Details on some of these issues are in Chapter 2.
OSHA and NIOSH have developed occupational standards to protect industrial workers from pollutant exposures, but these standards are based on an 8-hour-a- day exposure. In general, these standards were not applicable to characterizing risks for residents who experienced exposures greater than 8 hours a day in indoor
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and outdoor settings. Some of the screening levels developed to assess the sub-chronic risks from the contaminants created by the WTC collapse were developed by adjusting emergency removal guidelines listed in EPA’s Hazard Evaluation Handbook to take into account shorter exposure periods. These guidelines are based on a 30-year exposure period and correspond to a 1-in-10,000 increased lifetime cancer risk for carcinogens.
Further, some of the benchmarks used to assess air quality and bulk dust in Lower Manhattan were criteria- or condition-based standards and not health-based standards. For example, the benchmark used to assess asbestos risk from WTC dust was developed to determine when asbestos containing material was subject to demolition and renovation regulations. For future disasters, health benchmarks are needed to address the types of exposures experienced at the WTC site, which included:
• acute or high concentration exposures up to 8 hours
• sub-chronic (2 weeks to 1 year) exposures
• indoor air exposures
• exposure to asbestos
• synergistic or multiple pollutant exposures
Details on each of the above benchmarks are in Appendix O.
We recognize that it is not possible to anticipate all the scenarios and develop standards that address all possible pollutants that may result from a disaster. Thus, we believe an agreed-upon framework for quickly developing additional guidelines and benchmarks in an emergency situation is needed. This process could include a panel of scientific experts that would be available in an emergency to analyze the available risk data and establish appropriate health-based benchmarks for the pollutants of concern.
As discussed above, a multi-agency workgroup developed health-related benchmarks for six pollutants of concern related to indoor environment contamination from the WTC collapse that underwent peer review in October 2002. We believe the Agency should expand on these efforts to identify benchmarks for other pollutants of concern and for outdoor and indoor exposures based on threat assessments discussed earlier in this chapter. Related to this effort, EPA should collect information on background levels (i.e., pollutant concentrations under normal conditions), to properly assess the impact that a disaster has on the concentration of these pollutants of concern in the environment.
Report No. 2003-P-00012Sampling and Data Collection Protocols Needed
EPA, other government organizations, and non-governmental organizations undertook extensive monitoring efforts in the months following September 11. Extensive sampling was done around the work zone to monitor conditions for first responders. To assess ambient conditions for the general public, EPA established an ambient monitoring network in coordination with New York City and New York State officials. EPA also developed a draft Quality Assurance Project Plan for the WTC ambient monitoring network; however, the plan was not finalized.
A comprehensive Quality Assurance Project Plan outlines the objectives of the monitoring, identifies the monitoring and sampling methodologies, identifies the siting of monitors, and outlines monitoring exit strategies. In essence, the Plan helps to ensure that sufficient data is collected of adequate quality for the decisions to be made.
The Quality Assurance Project Plan should also address the format and means of transmitting data. In the WTC response, various government agencies collected a large amount of environmental data for Lower Manhattan in the months following September 11. The Office of Environmental Information maintains the New York City Response Monitoring Data Retrieval database, which stores the monitoring data collected by the various Federal, State, and City environmental agencies involved in the response. According to a report prepared by an EPA contractor that analyzed trends in the data, the database contained 263,000 monitoring results for 605 contaminants through April 24, 2002. Because the data came in different formats, consistent sampling, monitoring, and quality assurance information was not provided for each of the pollutants monitored, and in many instances this data was not provided. Our review of information in the database confirmed the trends noted by the contractor.
Providing standardized guidance for the organizations reporting data to EPA would improve the consistency of the data. A complete data set would make future assessments of the data easier to complete. Both EPA Region 2 and EPA Headquarters’ Lessons Learned reports made recommendations to improve data collection. The Region 2 Lessons Learned report recommended that all organizations submit data in an electronic format, and standardized formats should be used as much as possible. The report also recommended that easy-to- understand context and explanations be provided for the data, to allow data and risk assessments to be released to the public more quickly.
EPA’s Office of Environmental Information has created a standardized template for future responses by making a generic shell of the New York City Monitoring Database. This Office is also exploring longer-term improvements. With regard to WTC data, Region 2 officials have been working to improve the data in the “NYC Response” database by requesting that organizations perform a quality assurance review of the data they submitted to EPA. Once this process is
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completed, the data will become available to the public on a CD-ROM. We agree that EPA should continue to explore long-term improvements for data collection.Monitoring Capabilities Need to Be Increased
The amount of monitoring data for pollutants other than asbestos was limited in the first few weeks following September 11. In the beginning, monitoring efforts were hampered by several factors. There were difficulties associated with getting access and security, power supply sources, equipment availability, and analytical capacity. One environmental monitoring expert who participated in environmental sampling and analysis after the WTC collapse suggested that emergency response monitors must be improved and recommended that lightweight and manageable battery operated air samplers be developed that are able to measure a wide range of particles and gaseous substances.
In the case of a major disaster that causes a significant dispersion of particulates, the levels of TSP can be a concern, particularly in regard to acute respiratory symptoms. However, in the WTC response, these particles were not monitored because of a lack of TSP monitors. The availability of TSP monitors has decreased over time as EPA’s National Ambient Air Quality Standards program has shifted its focus from measuring TSP to measuring smaller particles. While health studies support measuring smaller particles from the standpoint of the National Ambient Air Quality Standards program, experts told us that it is useful to measure the levels of TSP in a disaster to determine potential short-term or acute health effects.
EPA Headquarters’ Lessons Learned Report addressed equipment needs and recommended that EPA clearly identify such needs. In addition, the Office of Air Quality and Planning Standards acquired funding for a Mobile Rapid Response Laboratory to collect data quickly in emergency situations and transmit data to a central database via satellite. The Office of Air Quality and Planning Standards plans to establish two such mobile laboratories.Risk Communication
The collapse of the WTC towers disrupted normal communication infrastructures, yet required that difficult decisions about the condition of the environment be made quickly and under extreme stress. Under these conditions, EPA made extraordinary efforts to successfully assemble an extensive amount of information on its web site and otherwise communicate to the public. Despite these efforts, the information EPA communicated was in some cases inconsistent with prior Agency positions, inconsistent with other communications regarding the WTC disaster, or incomplete. Some of these communication problems may have been avoided if the Agency had updated policies and procedures in place for communicating to the public and had followed existing risk communication
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guidelines established for the Superfund program. Based on its experience with the WTC response and the subsequent anthrax contamination responses, EPA has initiated various actions to improve its communication practices.Better Communication Policies, Procedures, and Guidance Needed
Officials from EPA’s OCEMR and its successor office, the Office of Public Affairs, in Washington, D.C., were not able to provide us with current written policies or procedures for communicating with the public. Although not established as official Agency communication policy, EPA’s Superfund program has issued several guidance documents regarding risk communication. EPA’s risk communication principles and recommended practices are contained in EPA’s Superfund Community Involvement Handbook. This Handbook identifies the “Seven Cardinal Rules of Risk Communication,” presented in Chapter 2. As explained in the following, EPA’s risk communications did not consistently adhere to the principles and guidelines discussed in its Superfund guidance.Risk Communications Need to Acknowledge Uncertainties
EPA’s Superfund Community Involvement Handbook specifically discusses uncertainties (“Be willing to discuss uncertainties”), and the fourth rule states:
If you do not know an answer or are uncertain, acknowledge it and respond with the answer as soon as possible. Do not hesitate to admit mistakes or disclose risk information. Try to share more information not less; otherwise, people may think you are hiding something.
As detailed previously in this report, EPA’s statement that the air was safe to breathe was not qualified (except for rescue and cleanup personnel at Ground Zero). Further, EPA’s press releases did not discuss any of the uncertainties associated with this statement.
Dr. Peter Sandman, founder of the Environmental Communication Research Program at Rutgers University, provided 26 recommendations for risk communication. These include that one should “acknowledge uncertainty” and urged “never using the word ‘safe’ without qualifying it.”Procedures Needed to Ensure Consistency in Communications
EPA communications after the WTC catastrophe sometimes gave conflicting information in regard to the same issue or were inconsistent with prior Agency positions. Specifically, information provided orally about cleaning of indoor spaces was not consistent with the messages given in Agency press releases.
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Also, EPA communications about the risk from asbestos were not entirely consistent with prior Agency public positions regarding asbestos risk.
EPA’s communications during the WTC crisis – that the general public did not need to be concerned about short-term exposure to WTC asbestos – were inconsistent with the Agency’s prior position that all asbestos exposure is hazardous to human health. EPA’s historical position, as detailed in the Federal Register, has been that:
. . . short-term occupational exposures, have also been shown to increase the risk of lung cancer and mesothelioma. In addition, there are many documented cases of mesothelioma linked to extremely brief exposure to high concentrations of asbestos or long-term exposure to low concentrations. . . . EPA has concluded that it is prudent to treat all fiber types as having equivalent biological activity...Available evidence supports the conclusion that there is no safe level of exposure to asbestos. (April 25, 1986 Federal Register Volume 51, page 15722)
However, EPA’s position in its September 13, 2001, press release was that the public did not need to be concerned about short-term exposure to WTC asbestos. The confusion of some residents may have been reflected at a May 8, 2002, press conference, when the questioner quoted EPA’s 1986 position and asked the Region 2 Administrator:
Available evidence supports the conclusion that there is no safe level for exposure to asbestos. So what science are you citing that there is a safe level?
The EPA Region 2 Administrator replied:
We are talking about very short term exposure to quantities of [unintelligible word] that - we know exactly that these buildings came down and they contained asbestos. There are other places in the country perhaps where people have been exposed over long periods of time - based on using substances containing asbestos - and breathing them - as part of their household. We know this was a one time - you know buildings came down, and that is what needs to be cleaned up so there is not that risk of long term exposure.
The research community has not reached consensus on the relative risk to human health from exposure to different types and sizes of asbestos, and EPA’s approach has been to not distinguish between fiber types and sizes when characterizing the risk from asbestos exposure. Many experts and studies support the general message EPA conveyed about asbestos exposure and risk after the WTC catastrophe, and research may ultimately prove these statements correct. However, this position was different from prior Agency pronouncements, and can create doubts in the public’s mind about EPA’s statements.Communications Need to Disclose External Participation
As discussed previously in this report, EPA officials were not the sole determiners of the information that was included in its press releases, nor the information that was excluded. This was demonstrated by the EPA OCEMR Associate Administrator’s statement that residential cleaning instructions were deleted from a draft press release by the CEQ contact official. The extent of outside influence was further illustrated by the statement from the EPA Administrator’s Chief of Staff that she could not claim ownership of EPA’s early WTC press releases because “the ownership was joint ownership between EPA and the White House.”
In a time of disaster, EPA officials should be careful to ensure that EPA’s press releases reflect EPA’s professional judgment based on sound science, acknowledge the participation of outside parties, and provide accurate information about the environment to the public in accordance with EPA’s mission.Environmental Data from Sources Outside EPA Need to Be Addressed
In the aftermath of the WTC collapse, several entities were involved in collecting data on environmental conditions. This included private firms; research organizations; Federal agencies; and State, local, and city governments. Several days after the attacks, EPA was designated as the lead agency for collecting and storing all of the WTC monitoring data. This designation did not include being the sole spokesperson for communicating the results of this monitoring data.
EPA was subsequently criticized for not including other organizations’ monitoring results in its public communications. For example, EPA was criticized for not putting the results of sampling done by the U.S. Geological Survey on EPA’s web site, or at least discussing this data. The U.S. Geological Survey monitoring had found high pH levels in the WTC dust, which reportedly contributed to the burning of respiratory pathways experienced by first responders and others who breathed WTC dust. An EPA spokesperson stated that EPA had not intended to keep the information from the public, and EPA thought the information had been posted on the U.S. Geological Survey’s web site. EPA officials also told us that the high levels of pH found in the dust was to be expected because of the pulverized concrete.
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Another monitoring study was highly publicized by the media, but was not discussed in EPA communications. This study was conducted by a collaborative association of aerosol scientists that specialize in fine particulate ambient monitoring techniques. This group found that the air around Lower Manhattan contained high levels of fine particulates and metals, particularly in readings taken on October 3, 2001. We spoke to the author of this study who told us that he had tried to work with EPA regarding his group’s test results before releasing it to the press, but was unsuccessful. EPA correspondence indicated the EPA officials were invited to the press release for this study, but were not aware of the study prior to that invitation.
EPA needs to develop a policy, in conjunction with other Federal agencies, outlining how organization(s) will coordinate the reporting of environmental data after a disaster. This policy should address the State and local government role in these communications, as well as how to address data collected by research or academic organizations.EPA Actions to Improve Its Communications
Both EPA’s Headquarters and Region 2 Lessons Learned Reports address communication issues and provide recommendations to improve the Agency’s response in this area. EPA’s Headquarters report recommended that EPA develop policies and procedures for disseminating public information during national emergencies within the established emergency response plans and structures. The report also recommended that EPA coordinate with other organizations outside to identify and address obstacles to timely and consistent presentation of environmental information during national emergencies. In regard to releasing monitoring data, the report recommended that EPA clearly define a process for approving and coordinating the release of information to other agencies and the public. Also, EPA’s Lessons Learned report recommended that EPA work with the Department of Homeland Security to have EPA designated the lead agency for environmental data during national emergencies when both EPA and other agencies are conducting environmental analyses.
Region 2’s lesson learned report recommended that Region 2 develop a comprehensive approach to handling crisis communications, and that this approach include other Federal and State partners. In addition, mechanisms should be in place for resolving differences about the interpretation of risk and the appropriate response.
These recommendations, if properly implemented, should help ensure technical consistency and accuracy in the Agency’s public information, and accountability for press release content.
Report No. 2003-P-00012Recent Developments
In May 2003, EPA participated in a Department of Homeland Security-administered Top Officials exercise with other Federal, State, local, and Canadian government organizations. This exercise simulated weapons of mass destruction incidents with the goals of: (1) improving the nation's capacity to manage extreme events; (2) creating broader frameworks for the operation of expert crisis and consequence management systems; (3) validating authorities, strategies, plans, policies, procedures, and protocols; and (4) building a sustainable, systematic national exercise program to support the national strategy for homeland security.
Further, on June 27, 2003, EPA issued the EPA National Approach to Response Policy to implement a new approach to responding to Nationally Significant Incidents. The Policy calls for a multi-faceted and coordinated approach to managing EPA’s emergency response assets during a Nationally Significant Incident. A key aspect of the policy is that it requires EPA to operate under an Incident Command System approach based on the National Interagency Incident Management System. EPA plans to supplement the Policy with guidance to fully characterize roles and responsibilities within the Agency to manage a Nationally Significant Incident. As noted in the Policy, Homeland Security Presidential Directive-5 calls for the development of a new National Response Plan and a single, comprehensive National Incident Management System. As standards, guidelines, and protocols are developed to implement the national system, EPA will modify its National Approach to Response Policy as necessary. Conclusions
Although many organizations were involved in addressing air quality concerns resulting from the WTC collapse, subsequent events have demonstrated that, ultimately, the public and others expect EPA to monitor and resolve environmental issues, even though EPA may not have the overall responsibility to resolve these issues or the necessary resources to address them. These issues range from collecting, interpreting, and communicating environmental information to cleaning up any environmental contamination. EPA must be prepared to take a leadership role, within the evolving framework established by the Department of Homeland Security and existing statutes, in fulfilling its mission of “protecting human health and the environment,” if another large-scale disaster occurs.
Report No. 2003-P-00012Recommendations
This chapter summarizes observations based on work conducted to answer the objectives discussed in Chapters 2 through 6. These prior chapters contain recommendations that address specific issues related to those objectives. Recommendations to address observations not covered in the prior chapters are included in this chapter.
We recommend that the EPA Administrator:
7-1. Work with the Department of Homeland Security and other agencies to share information on likely targets and threats and collaboratively develop approaches to address these threats. Such approaches should include, at a minimum:
a. Identifying the pollutants expected to be emitted from such targets,
b. Assessing the pathways of human exposure to those pollutants,
c. Developing approaches to monitoring and assessing environmental contamination from those targets, and
d. Establishing plans of action for reducing human exposure from these pollutants.
7-2. Define and clarify internal EPA organizational roles and responsibilities in responding to large- scale disasters. This should include designating teams of Agency experts – at both the National and Regional level – that can be mobilized to quickly provide needed technical support during a response. These areas may include specialized sampling techniques, exposure modeling and assessment, and risk assessment.
7-3. Develop and improve health-related benchmarks that can be used to assess health risk in emergencies. Specifically:
a. Continue agency work on Acute Exposure Guideline Levels,
b. Develop sub-chronic exposure guidelines for pollutants determined to be a high priority as a result of terrorist attacks or other large-scale disasters,
c. Develop health-related benchmarks for asbestos in air,
d. Develop benchmarks for assessing potential exposure from contaminant levels in dust,
e. Continue to develop and refine benchmarks for COPCs in indoor environments,
f. Conduct research to determine the synergistic impact of exposure to multiple pollutants, and
g. Develop expert panels that can be used to quickly develop health- related benchmarks in emergency situations.
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7-4. Develop an emergency quality assurance sampling plan to be used as a guidance for monitoring environmental conditions after a large-scale disaster. This plan should address:
a. Monitoring objectives,
b. Preferred sampling and analytic methods for high-priority pollutants,
c. Siting of monitors,
d. Quality control, and
e. Data reporting formats
7-5. Improve monitoring capabilities by:
a. Making TSP monitors available for use in emergency situations, and acquiring other monitors as determined,
b. Continuing the mobile monitoring laboratory project, and
c. Exploring new technologies for monitoring in extremely dusty conditions
7-6. Require that the Office of Public Affairs develop emergency communications policy and procedures consistent with the principles of risk communication provided in EPA’s “Seven Cardinal Rules of Risk Communication.”Agency Comments and OIG Evaluation
The Agency generally agreed with the recommendations in this Chapter. With respect to the conclusion, the Agency emphasized that it exercised its opinions and judgments on matters impacting human health and the environment and will continue to do so within the context of its authorities and its role under the Federal Response Plan. The Agency’s complete written response to our draft report and our detailed evaluation of that response are contained in Appendices Q and R, respectively.
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