EPA spill response plans are too sprawling, say auditors
Environmental Protection Agency oil and hazardous substance spill contigency plans have grown too large and varied for the agency to adequately maintain, says the agency's office of inspector general.
In a Feb. 15 report (.pdf), auditors say EPA regional divisions have expanded contingency plans and created new plan subareas and strategies in response to needs they determined, but that these plans have become unwieldy because of struggles to keep them up-to-date and uniform.
Some of the information plans require, such as lists of available equipment, continuously change and regional divisions can't properly track the equipment with their limited staff and resources available, says the report. Other regional plans lack required information, such as lists of available personnel or procedures for volunteers, while some are out-of-date, say auditors. One plan auditors reviewed had not been updated since 1998.
The agency's Office of Solid Waste and Emergency Response, which provides policy and guidance for EPA emergency response, told auditors that the agency needs to focus on consolidating and coordinating its contingency planning efforts because "funding for area contingency planning is not sufficient to meet its broad based goals."
Plans also do not always adhere to a uniform standard, says the report, which can make some information difficult to location. Three of the reviewed regional contingency plans did not include economic or environmental importance factors, but auditors were able to find this information in subarea plans or elsewhere.
The regional and area contingency plans reviewed averaged more than 575 pages, says the report, so missing or misplaced information can make these documents difficult to use.
Auditors suggest the agency assess its resources available to develop and maintain contingency plans and use this analysis to develop a workforce plan to distribute contingency planning resources. Guidance from OSWER also should include a mechanism for regions to keep critical planning information up to date, says the report.
Auditors also suggest reviewing options to move away from written plans to using new technologies. However, auditors say that would first require the agency to update its contingency plan guidance. When updating the guidance, auditors also suggest EPA add in a process to incorporate lessons learned from exercises and events across its regions.
- download the IG report, 13-P-0152 (.pdf)