VIRGIN ISLANDS/ENVIRONMENTAL PROTECTION AGENCY AGREEMENT / - for WATER and AIR RELATED PROGRAMS SEPTEMBER 1979 ------- VIRGIN ISLANDS/ENVIRONMENTAL PROTECTION AGENCY AGREEMENT FOR WATER & AIR RELATED PROGRAMS September 1979 ------- RESPONSIVENESS SUMMARY RESPONSE TO WRITTEN COMMENTS and TESTIMONY PROVIDED IN PUBLIC HEARINGS on JULY 10, 1979 in ST. THOMAS and JULY 11, 1979 in ST. CROIX on the VI/EPA AGREEMENT for WATER and AIR RELATED PROGRAMS ------- The draft VI/EPA Agreement was made available for public review in June 1979 and public comment was received through July 1979. A number of comments were presented and various questions raised during the Public Hearings. In accordance with our standard practices we will not attempt to respond to each specific individual comment, but instead will respond categorically. Our review identified eight (8) major cate- gories into which most of the comments fell: the need for Improved/Expanded Public Participation Program the need for Resolution of Drinking Water Quality and Quantity Problems (Inaction by Virgin Island Government) the need for Development of a Comprehensive Water Resources Plan/Growth Management Plan the need for More Efficient and Effective Enforcement of all Programs (VI/EPA) : absence of timely information on the VI Program Grant Applications (CWA-106, CAA-105, SDWA) • lack of Participation by and commitments from VI Agencies other than DCCA in the development of the Agreement • the need for greater EPA Presence in the VI to Oversee Program Implementation • the need for improved Water Supply and Wastewater System Maintenance and Operation Table 1 is a Comment Matrix illustrating each commentor's focus with re- spect to the 8 major issues. Table 2 describes in detail the substance of the comment in each major category and the VI/EPA response. We recognize that this is the first time that such an Agreement has been negotiated under rules and procedures that provide for intimate public involvement. We see this as a first step in improving the public under- standing and trust with respect to the manner in which the Virgin Islands government manages environmental programs. We are very grateful for con- tributions that the public sector has made in developing this Agreement. We look forward to a greater and increasingly more enlightened commitment to public participation by all parties involved in future strategy and policy development. ------- The iSUES ^ tmpt ~9 Publ pati OWtENTORS nd Resources idatlon onservation !ety, St. Thomas Ibbean Research titute gue of Women era ants United for rness (St. Thomas) IFF) Conservation iety (St. Croix -pter) 1st Ian Community iscious Center, INC Housing Authority Ivate Citizens need for oved /Expand Ic Partlcl- on Program X X X X X X " X X 7 . , X The Need for Resolution of DM Quality & Quant. Prob. (Inact. by Gov) X X X X X X X TABLE 1 - Comment Matrix 'he Need for )eveloptnent f Corapre- enslve Water es. Plan/Growth Mgmt.Plan X X X X X X The Need for More Efficient & Effective EN- FORCEMENT of all Prog.(VI/EPA) X X X X X X X \bsence of Timely nformatlon on the VI Proeram Grant Anollcations CWA-106. CAA-105 SDWA) X Lack of Participation by and commitments from VI Agencies other than DCCA In the development of the Agreement X X X X . " X X X Need for EPA Presence In VI to Ovorsee Proeram Imple- mentation X X X The Need for 1m- jroved Water Supply and Wastcwnter System Operation and Maintenance X X X . X -2- ------- Table 2 MAJOR ISSUES PRESENTED IN PUBLIC TESTIMONY ON VI/EPA AGREEMENT VI/EPA RESPONSE 1 a. An Improved and expanded Public Participation Program should be developed In such detail as to 1) delineate roles and re- sponsibilities of V.I. Agencies and public Interest groups, 2) Identify funding and tlmeframes for program development, 3) assure creation of a Citizen Advisory Committee/Board, and 4) provide for effective education and dissemination of relevant information through press and varied media coverage. The public participation chapter of the draft agreement was rewritten to give the VI government and DCCA In particular lead responsibility for public participation in the Implementation of the agreement (see pages-14-17). EPA has committed $25,661 through Clean Water Act Section 106 and 208 funds and Clean Air Act Section 105 funds to public participation. The government of the VI has committed Itself to provide one DCCA staff member and to forming an Environmental Policy Advisory Committee (EPAC). The staff member Is charged with ensuring a meaningful and responsive public participation program, Including but not limited to establishing liaison with all the involved VI agencies and public Interest groups, establishing mailing lists, and using Improved notification procedures. EPAC Is charged with de- veloping Interagency agreements to delineate roles and responsibilities, and with Identifying needs for public education and staff training for public participation, EPAC is also to suggest additional advisory committees, one of which should be a representative Public Participation Advisory Committee to play a key role in the development and implementation of the comprehensive public participation program envisioned in the agreement including the Identification of public education needs and assisting the DCCA Public Participation Staff. A single public service information center serving all agencies Involved in the Implementation of the Agreement should be established so that complaints can be directed to the appropriate agency and response can be made within a reasonable period of time. The DCCA staff member committed for public participation under the agree- ment is responsible for establishing liaison between agencies and public Interest organizations, and for assisting the public In filing complaints and in receiving timely action and response (see page 151. ------- Table z luont1a; MAJOR ISSUES PRESENTED IN PUBLIC TESTIMONY ON VI/EPA AGREEMENT VI/EPA RESPONSE 2 a. Drinking water quality and quantity problems In the V.I. have been unresolved for years with little support for resolution from any segment of the V.I. government. Water supply, when available In public housing projects, Is In- sufficient and Is often unfit for human consumption. Dependency on a variety of unreliable sources such as de- sallnlzatlon, barging, bottled water and/or roof catchments is frustrating and burdensome for Virgin Islanders. Yet, what appear to be logical solutions (I.e. hillside rainwater catchments, salt flush toilets) have been de-emphasized. V.I. government agencies have been negligent in dealing with water quality problems and In making a commitment to develop a water resources plan which will guarantee a safe and adequate supply of potable water for all residents. The draft VI/EPA Agreement does not specify actions, timing, funding or those responsible for planning for and obtaining a safe and reliable drinking water supply and should be rewritten with more detail. EPA should also cease funding until the VI Government makes a commitment to Improve the water supply situation. The Water Supply Chapter has been rewritten with specific emphasis on actions to be taken to begin development of a Comorehenslve Water Resources Plan (CWRP^ for the Islands. Governor Luis has offlclallv dealenated DCCA as the Aeency responsible to carry out this task and Section 208 funds ($132,400) have been earmarked for specifIc -activi- ties leading up to the development of this CWRP. When EPA receives a revised work plan the $132,400 will be released. In addition, a Federal Regional Council (FRC) Strategy for Water Resources (see p. A-l) has been developed which identifies additional funding available from other Federal agencies to be used in conjunction with the 208 funds to develop the CWRP. The release of funds from these other Federal agencies is predicated on action by Governor Luis: within three months he will select a coordinator to work closely with the V.I. and Federal agencies to obtain and use these funds to solve the water supply problems. These funds can be used for water resource planning and implementation, and construction activities such as re- pair and rehabilitation of water distribution systems. Components of the CWRP Include evaluating various alternatives for water supply such as rehabilitation of rainwater catchments, ground- water management, reuse, salt water flushing, etc. For additional details on the CWRP development see Water Supply Chapter, pages 18-22 and FRC Strategy pages A-l - A-18. Based on a questionnarle distributed to 1,000 residents of public housing projects 902 of the residents indicated that water was unsuitable for drinking; 75/5 indicated that water was unsuitable for bathing and 80Z Indicated the unsultab- lllty for cooking. The tenants are disillusioned with local and federal laws guaranteeing a safe drinking water supply and see DCCA and EPA as being negligent In enforcing the law. Tenants have Indicated that public notifications of water supplies not meeting standards In January, do not appear in the newspaper until March, a time lapse well beyond human con- sumption. The tenants also feel that the monitoring program should be expanded. The Water Supply Chapter clearly defines actions that DCCA will take to improve it's oversight in the public water system supervision program. Improvement of cistern water quality through additional studies and distribution of educational materials for improved main- tenance, better follow-up procedures to ensure that the Public Housing Authority and other purveyors carry out their responsibilities for notifying customers when violations occur, and exploration of funding for operation and maintenance training are priority items described on pages 23-25. ------- Table 2 (Cont'd) AJOR ISSUES PRESENTED IN PUBLIC TESTIMONY ON VI/EPA AGREEMENT VI/EPA RESPONSE b. The V.I.H.A. hag asked for technical assistance Iron DCCA and EPA for training of staff and upgrading of the current distri- bution systems In the housing projects. In monitoring drinking water supplies, DCCA hag made a commitment to In- crease laboratory capabilities with respect to organlcs analysis, staff training and quality control. (See Monitoring and Surveillance Chapter pages 48-52). The lack cf enforcement by both DCCA and EPA for federal environmental laws Is one of the biggest problems In the Virgin Islands. VI agencies are reluctant to take legal action against each other and, In the past, when EPA should have assumed responsibility, EPA did nothing. Both EPA & DCCA have agreed that there Is a critical need to develop a formally structured enforcement "sub-agreement", so that the activities, tlmeframes for compliance review, monitoring and enforcement procedures that DCCA carries out will be done efficiently. EPA'9 responsibilities will also be clearly defined in this "sub-agreement". The Water Enforcement Chapter (p-45-47) provides more detail with respect to this Issue. Also see Air Enforcement Chapter (pages 74-77). If Individuals or public Interest groups see a need for enforcement action or see negligence on the part of EPA or DCCA, a mechanism for reporting and follow-up on the situation will be developed as part of the Public Participation Program. (see p. 15). 4. The FY 1980 Program Plans for the Clean Air Act (Section 105), the Clean Water Act (Section 106) and the Safe Drinking Water Act are not consistent with the draft VI/EPA Agreement. In addition, the Program Plans were not Initially distributed with the draft Agreement - thus there was not adequate time for review. For these reasons It Is necessary to have another Public Hearing on the Program Plans. The Section 105 Air Pollution Control Program Grant Narrative submitted June 1, 1979 with DCCA's 1980 grant application was not wholly consistent with the program plan described In the VI/EPA Agreement. Additional discussions between EPA and DCCA are planned to establish more specific program outputs for FY 1980. The Section 106 Water Pollution Control Program Plan has been rewritten to reflect the commitments made in the VI/EPA Agreement. The Safe Drinking Water Act Program Plan has been revised and is currently being reviewed by EPA to assure consistency with the VI/EPA Agreement prior to grant award for FY 1980. Based on modifications to workplans, a public hearing is not warranted. Every attempt will be made to coordinate the Agreement revision and Program Grant Application procedures for FY 1981. ------- Table 2 (Cont'd) MAJOR ISSUES PRESENTED IN PUBLIC TESTIMONY OH VI/EPA AGREEMENT VI/EPA RESPONSE A primary element missing from the VI/EPA Agreement Is a commitment from the prospective participating authorities, department and agencies. Every Commissioner and Director of the participating and Involved VI Government agencies should become signatory to the Agreement. 5. The Governor of the Virgin Islands, as slgnator of the Agreement, Is making a commitment ot Implement the Agreement on behalf of the entire VI Government which Includes all departments, authorities and agencies within his Administration. 6. The lack of direct effective EPA program oversight and monitoring in the Virgin Islands is one of the prime causes for lax technical program management and superficial public participation and enforcement programs. There is a need for greater EPA Involvement on a routine basts, preferably through the establishment of a full time permanent office on the V.I. Less acceptable alternatives could Include a commitment by the Caribbean Field Office to establish a temporary office In the Virgin Islands to be staffed at least one week each month or development of a designated watch-dog body in the Islands to monitor the implementation of the Agreement and the law. 6. As stated on page 3 of the Agreement, the VI/EPA Agreement is a'working document and as such is subject to revisions as priorities or program operations require. Quarterly meetings between EPA and DCCA have been set so that outputs and accomplishments can be evaluated. In this wav EPA18 Caribbean Field Office and Region II's New York staff will be orovldlne close supervision on a routine and frequent basis. The public will also be Involved In this process. This revision/review process, coupled with the "newly committed to" Public Participation Program (see Public Participation Chapter pages 14-17) should provide the mechanism for careful program supervision. Modifications to these procedures may be required in the future. However, until such time, the Caribbean Field Office and EPA Region II staff will continue to provide assistance in the manner defined above. 7. A need to improve the Operation and Maintenance (O&M) of water supply and wastewater facilities is critical. Water supply distribution systems leak and are in a severe state of disrepair, as are the desalinlzation plants and waste- water treatment facilities. 7. The Governor has made a commitment to seek continual funding In the V.I. Budget for Operation and Maintenance (O&M) activities and to redirect the efforts and priorities of DCCA and DPW In Improving the management of their facilities. In the Interim, potential funding for O&M activities has been identified in the Federal Regional Council (FRC) Strategy for Water Supply (pages A-l through A-18), and a commitment by the Governor to select a Coordinator to expedite the use of these funds has been made. More details can be found in the Water Supply Chapter (cage 25), the Construction Grants Chapter (pages 33-36), the VIPDES Chapter (pages 41-42) and the Water Enforcement Chapter (pages 45-47). ------- AGREEMENT ON THE DEVELOPMENT AND IMPLEMENTATION OF THE VIRGIN ISLANDS' WATER AND AIR RELATED PROGRAMS BETWEEN THE GOVERNOR OF THE VIRGIN ISLANDS AND THE REGIONAL ADMINISTRATOR, REGION II, UNITED STATES ENVIRONMENTAL PROTECTION AGENCY. The Regional Administrator of Region II of the United States Environmental Protection Agency (EPA) and the Governor of the Virgin Islands do hereby enter into an agreement for the development and implementation of the Virgin Islands' Water and Air Related Programs. SCOPE OF AGREEMENT The Scope of the Agreement consists of the following: (a) Summaries of Program Elements (b) Response to comments on the Virgin Islands/EPA Agreement. The responses are incorporated in the summary of Program Elements. (c) Summary of Funding Priorities - This contains funding amounts, sources and intended uses of Federal and Territory funds. The funds identified are subject to territory and Federal budgetary processes. BACKGROUND During May and July 1979, public meetings and hearings were held in the Virgin Islands on the draft VI/EPA agreement. The comments from both the meetings and hearings have been carefully reviewed and analyzed and incorporated into this document. Also completed are tables that establish the timing, costs and sources of funding for the activities presented in the agreement. -i- ------- NATURE OF AGREEMENT The Agreement provides a firm guide for the many program grant plans developed and underway in this fiscal year and for those under preparation now for the approaching fiscal year. The Territory/EPA Agreement shall be interpreted to be consistent with Federal and Territory Statutes and Regulations. To the extent the Agreement is inconsistent with Federal and Territory Statutes and Regulations, the Agreement shall not apply. This agreement shall take effect upon execution by both parties and remain in effect for one year unless terminated in whole or in part by either party, provided that thirty days written notice is given by the party initiating such termination to the other party, or until it is rescinded by mutual agreement. MODIFICATION This agreement shall be amended as necessary on an annual basis. This agreement may be amended at any time by formal written agreement of both parties. United States Virgin Islands Environmental Protection Agency Region II *v-*-%X^ Juan Francisco Luis Governor Date: Eckardt C. Beck Regional Administrator Date: ------- Virgin Islands/Environmental Protection Agency Agreement TABLE OF CONTENTS I. Introduction A. Agreement Overview 1. General 1 2. Revision Process 3 3. Content 4 i*. The Virgin Islands/EPA Agreement 5 Role in Future Planning for the Virgin Islands II. Water and Air Programs A. Virgin Islands Water & Air Quality Assessment 1. Coastal Water Quality 6 2. Groundwater Quality 10 3. Air Quality 12 B. Summary of Program with Detail Tables to Identify Actions, Needs, Agency, Timing, Funding and Associated Problems 1. Public Participation 14 2. Public Water Supply 18 3. Residuals Management 26 4. Construction Grants 33 5. Water Quality Management Planning 37 6. Virgin Islands Pollution Elimination Discharge System 41 (VIPDES) (Permits) 7. Water Enforcement 45 8. Monitoring and Surveillance 48 9. Nonpoint Source 53 10. Toxic Substances 59 11. Water Quality Standards 63 12. Air Abatement Planning 68 13. New Source Review 70 14. Air Enforcement 74 15. Air Monitoring 78 16. Noise 81 17. Radiation 82 18. Omnibus Territories Act 83 III. Appendix: FRC Strategy for Water Supply Assistance to the Virgin Islands A-l ------- UNIT 1 - INTRODUCTION A. Agreement Overview 1. General The Virgin Islands are presently blessed with high quality coastal waters which meet the National Water Quality Standards. In addition, the Islands may now boast the distinction of being the only area in EPA Region II that has attained Ambient Air Quality Standards. The success of these programs can be attributed to the concerted commitment and effort on the part of the Department of Conservation and Cultural Affairs (DCCA) and the Environmental Protection Agency (EPA) both of which are responsible by law to implement the Clean Water Act and Clean Air Act. Yet, there are still a number of air and water quality management problems and environmental issues that still need to be addressed. This is also true with respect to water supply, solid waste and residuals management and the control of toxic substances in order to achieve the goals and objectives of the Safe Drinking Water Act (SDWA), Resource Conservation and Recovery Act (RCRA) and Toxic Substances Control Act (TSCA) respectively. Since many of these programs are interrelated, the governor of the Virgin Islands and the Regional Administrator of the U.S. Environmental Protection Agency (EPA) have agreed to identify in this document (to be called the Virgin Islands/EPA Agreement) the operational and environmental problems/priorities and the management and technical activities needed to resolve them. The Agreement will be the primary means of integrating the planning, management, implementation and evaluation of the regulatory programs mandated by federal environmental protection legislation, over a five- year planning horizon. It will serve to: • define the comprehensive strategies adopted to address water and air quality management problems, • identify the priority problems and the specific activities and projects to solve these problems, -1- ------- • estimate scheduling and funding needs and the priorities for funding, and • improve integration of the activities among Federal and Territorial agencies. The Agreement will also ensure that the funds awarded to the Virgin Islands agencies are used to solve priority environmental problems and produce tangible « ^ results. The Agreement will reflect important EPA and Virgin Islands policies on environmental, health and institutional problems, priorities, timing, responsibilities and allocation of resources. It will reduce the quantity of paperwork currently needed to comply with environmental requirements and reduce duplication of effort. Additionally, it will focus management attention on the major problems facing the Virgin Islands and will provide the framework for decision making. An important benefit of this process should be the strengthening of the capability of the Virgin Islands agencies to manage their environmental programs more effectively and efficiently. -2- ------- 2. Revision Process The Agreement is a working document and as such is subject to yearly revisions as program, environmental or institutional priorities are refocused, or as new or modified regulations or requirements dictate. The signing or effective date will coincide with the funding program fiscal requirements which begin in October of each year. It must be emphasized, however, that throughout the course of the year, quarterly meeting between EPA and the involved Virgin Islands' agencies will be held to evaluate the outputs and accomplishments of those activities defined and committed to in the Agreement. As part of this process the public will be advised of progress to date. At this same time, it is envisioned that additional needs for program revisions or modifications will surface. As the issues become clear, the Virgin Islands and EPA will begin the agreement revision process, one of evaluating and reevaluating the priorities identified to determine the extent to which the goals and objectives have been met and what issues and problems need to be reassessed for subsequent integration into the next revision of the agreement. The thrust of the evaluation activities should occur during March and April of each year. Public in-put will be sought at these early stages as well as during negotiations, new program identification, public meetings and agency coordination. These later activities will take place between May and September. The revised agreement will be signed prior to October first of each year. *"* %J"~ ------- 3. Content The Virgin Islands/EPA Agreement incorporates both air and water quality management related programs and has been developed to identify strategies/activities which will be implemented during the upcoming fiscal year and over a five year period. The Virgin Islands/EPA Agreement has been developed to deal with specific program issues and general environmental/institutional issues which relate to the Federal water and air programs. Problems have been identified which relate to technical/management aspects of program operation and the activities necessary to resolve these problems. In addition, specific general issues such as institutional arrangements and environmental concerns have also been highlighted and potential solutions identified. In effect, the Agreement is both program and issue oriented. A brief discussion of each program's needs and proposed solutions precedes a detailed Table which summarizes the specific activities committed to, the responsible agency, timing and costs. The costs identified on the Tables reflect the total project costs which include both EPA and VI contributions. Administration costs for the 105, 106, 208, SDWA and RCRA programs are not included in the Tables but can be found in the appropriate grant applications. The Agreement will serve as the narrative description of programs to be funded through the following Federal program grants: ® Safe Drinking Water Act » Clean Water Act Section 106 and 208 « Clean Air Act Section 105 9 Toxic Substances Control Act ------- 4. The Virgin Islands/EPA Agreement Role in Future Planning for the Virgin Islands The Virgin Islands/EPA Agreement which incorporates among its many aspects, planning functions such as the State Implementation Plan (SIP) (for air programs) and the Water Quality Management (WQM) planning process (208) can be an even more effective management and planning tool if it is used in conjuction with planning objectives set forth by the VI government. Presently this document addresses and responds to many of the programmatic and environmental issues surrounding EPA funded programs, issues which appear to be consistent with those identified by Federal and local agencies participating in program implementation as well as the public sector (as evidenced in the public information meetings and hearings held in May and July 1979). It is the hope of the signators that this Agreement will pave the way for a consolidated Federal and local approach to the planning for and implementation of environmentally sound economic development in the Virgin Islands. -5- ------- Unit II - Water & Air Programs A. Virgin Islands Water & Air Quality Assessment 1. Coastal Water Quality The Virgin Islands are located approximately 1400 nautical miles southeast of New York and about 900 nautical miles southeast of Miami, Florida. They are made up of three large, populated islands, St. Thomas, St. John, and St. Croix, and approximately fifty smaller uninhabited islands and cays. They are bounded on the north by the Atlantic Ocean and on the south by the Caribbean Sea. St. Thomas and St. John are part of the Puerto Rican bank of the Greater Antilles, on the geographical boundary between the Atlantic Ocean and the Caribbean Sea. St. Croix lies completely within the Caribbean Sea. The Virgin Islands were formed from a series of volcanic actions in the Atlantic Ocean. Basalt rocks were deposited by the volcanic activity. These rocks have been altered by folding, faulting, uplifting, erosion and by the formation of wave- cut terraces. In places, mainly on the Island of St. Crox, limestone has been formed by the accumulation of shoals and coral. Coral reefs have formed around portions of the island and carbonate sand has been created. The islands are mountainous in character with steep slopes falling off rapidly to the sea. This is particularly true of St. John and St. Thomas. St. John has an area of 20 sq. mi., St. Thomas 28 sq. miles, and St. Croix 84 sq. miles. The Virgin Islands Basin (EPA Storet System Basin No. 19) has been broken down into three segments as follows: a. Segment A - St. Thomas, 52.8 miles of shoreline. b. Segment B - St. John, 49.7 miles of shoreline. c. Segment C - St. Croix, 70.3 miles of shoreline. -6- ------- All of the coastal waters in Segments A, B, and C are maintained in compliance with the Virgin Islands' Water Quality Standards (12 V.I.C. Section 186). As a result, all coastal waters of the Virgin Islands currently meet or exceed the national water quality goal of fishable and swimmable water. Monitoring information contained in the 305(b) Report for 1978 shows that water quality has improved in both Segments A and C as a result of water pollution control programs over the last six years. The most improvement has occurred in the harbor of Charlotte Amalie in Segment A. This is a result of the construction of the Charlotte Amalie Sewerage System, which removed two and a half million gallons per day of raw sewage from the waters of the harbor. Three interceptors, two force mains and two pumping stations are utilized to collect and transport sewage, previously discharged into the harbor, to a primary sewage treatment plant. The treated effluent is discharged through an ocean outfall 2650 feet from shore at a depth of seventy feet. Fecal coliform counts have fallen from a high of 10,000 per 100 ml. to less than 70 per 100 ml. Average Secchi disc readings have increased from less than 3 meters to four meters showing improved water transparency and better reef protection. Dissolved oxygen levels have increased from an average of 6.0 ppm to an average of 6.6 ppm. - Water quality monitoring for Segment B indicates that water quality continues to be excellent in St. John. In Trunk Bay, St. John—where the standards require maintenance of natural conditions—the dissolved oxygen level is 6.5 mg/1. The prevailing total and fecal coliform levels are below 0.5 organisms per 100 ml. In Segment C, the greatest improvement in water quality has occurred along the south shore of St. Croix, where benthic communities, once severely damaged by faulty dredging practices, have shown substantial recovery since sediment control practices have been instituted. -7- ------- Dredging for development and maintenance of shipping channels to provide access to facilities owned by Hess Oil Virgin Islands Corporation in 1966-67 and Harvey Alumina Virgin Islands Corporation in 1963-64 distributed fine-grained clay deposits in a manner that caused extreme turbidity and excessive pollution along 13.8 miles, or about 47 percent, of the south coastline of the island. Concentrations of inorganic suspended solids, most assumed to be particles of clay, exceeded densities of 150,000,000 per liter. Water clarity was reduced as much as 95 percent in many places in these turbid reaches, and the turbidity extended seaward from shore up to distances estimated to be at least one mile. In this area, reefs were not readily visible, thus endangering navigation; recreational value was totally lost; sea food animals once abundant, were decimated to unharvestable levels; and land values seriously reduced. The turbidity terminated abruptly at Sandy Point near the southwest cape of St. Croix, where there was a dramatic increase in water clarity. Implementation of a dredging sediment control program has yielded dramatic results. Water quality adjacent to the industrial complex on the south shore of St. Croix is presently good. Average values for all water quality parameters in this area are approximately equal to average values observed in clean water elsewhere. Overall, the recent picture of water quality in the Virgin Islands is one of steady improvement. Except for those waters within areas of municipal and industrial development, water quality is essentially identical around all three islands. Water temperature averages 28.2°C (82.8°F) year-round. Dissolved oxygen varies from 4.4 to 8.9 mg/1. The mean dissolved oxygen level of 6.8 mg/1 is well above the 5.5 mg/1 required by the federally-approved water quality standards. Nitrate-nitrogen levels are generally less than 0.05 mg/1 and total Kjeldahl nitrogen (the sum of organic nitrogen and ammonia) ranges from 0.1 to 0.8 mg/1. -8- ------- The geologic history of the islands has had a significant influence on the marine water quality in regard to heavy metals. Normally-defined sea water background concentrations of some heavy metals are generally exceeded naturally throughout the islands. Recommended protective water quality criteria are exceeded for cadmium, lead, zinc and mercury. Since these high levels prevail naturally, indigenous aquatic life is likely to be acclimated to them. Water quality standards should reflect natural background levels of these metals. However, man made increases should be avoided and aquatic life should be surveyed periodically to signal possible bioaccumulation. Possibly unnaturally high concentrations of cadmium, lead and copper were found in localized areas in EPA's 1972 sampling studies and it would be wise to investigate these in further detail. -9- ------- 2. Groundwater Quality The groundwater of the Virgin Islands is an extremely limited resource. Water bearing formations are sparse and relatively unproductive. Nevertheless, well water is used on all three major islands to supplement public water supplies. On St. Croix, the possible groundwater production at five government well fields was estimated during April 1976. The possible yields ranged from 0.032 to 0.0^5 mgd, and the total for all five government well fields was 0.620 mgd. A rough estimate of additional yield from all private wells on St. Croix is 0.5 mgd. Assuming a population of about ^5,000, the total per capita groundwater is approximately 25 gallons per capita per day. Persent data indicate the per capita capacity on St. Croix is higher than that on the other islands, by a factor of two or more. Only about 0.5 mgd is available on St. Thomas in the dry season. The three major factors that affect the quality of groundwater are concentration, solution and seawater intrusion. The minerals contained in rainwater are concentrated by the high rate of evapotranspiration. The most significant of these is chloride, which originates from the sea. Groundwater is largely affected by solutions of minerals from various materials through which it passes in the ground before being recovered. It picks up additional carbon dioxide, tannic acid and organic matter from the decomposition of organic material in the soil, which lowers its pH. Saltwater intrusion occurs in the form of a seawater wedge moving inward into confined aquifers. Seawater intrusion can be aggravated by overpumping such aquifers. While the groundwater quality is quite variable and yields are small, the severe water shortages and increasing demand factors require pumping of all wells to the limit of the resource on both St. Thomas and St. Croix. There have been several cases of overpumping and subsequent contamination of aquifers by saltwater. -10- ------- Because mineralization increases with proximity to shorelines, the quality of water from upland wells is generally better than that from lowland wells in alluvial plains or near coastal marshes or lagoons. However, mineralization of groundwater in the few central valleys can also be high where evapotranspiration concentrates minerals carried in rainwater, and where septic tank effluents drain into valley alluvium. On St. Croix, an important well field is being recharged by land application of sterilized, tertiary treated effluent from an advanced wastewater treatment plant, which processes domestic sewage from the island. It is planned that this research facility be expanded to greater capacity and be operated on a commercial basis. Quality of groundwater on all three islands is adequate for watering livestock and for crop irrigation, and some wells on each island are pumped daily for these uses. -11- ------- 3. Air Quality The objective of both the Clean Air Act and the Virgin Island statutes is, ultimately, to protect and enhance the air resources so as to promote public health and welfare. In striving to meet this objective, the Virgin Islands and the Environmental Protection Agency (EPA) have taken regulatory steps to limit the -v types and amounts of pollution emitted. The territory of the United States Virgin Islands is primarily a resort area. The Island of St. John has virtually no industry. The island of St. Thomas has little heavy industry although several "point sources" are present, generally those involved in the construction industry; the Island of St. Croix, unlike St. Thomas and St. John, does have some heavy industry located on its southern shore. The official designation for the Virgin Islands with the exception of an area on the southern shore of St. Croix indicates attainment of national ambient air quality standards (NNAQS) for total suspended particulates, sulfur dioxide, nitrogen dioxide, hydrocarbons/ozone, and carbon monoxide. For the sourthern shore of St. Croix, the designation of "cannot be classified" identifies a need for further data gathering for total suspended particulates and sulfur dioxide. This effort is expected to be completed in late 1979. Based on preliminary data available to date, it is expected that the Virgin Islands will be classified as attaining all standards. With regard to lead, the lates pollutant for which an ambient standard has been promulgated (September 1978), all preliminary information indicates that no problem areas exist; however, additional monitoring efforts may be necessary to fully define the status. -12- ------- Both the Virgin Islands Department of Conservation and Cultural Affairs (DCCA) and the Environmental Protection Agency (EPA) are concerned with the overall impact of "air pollution," including control of "non-criteria" pollutants emitted into the ambient air. Control of these substances, including "hazardous" and "toxic" air pollutants, is being carried out as necessary, by special emphasis on potential sources. In view of the pristine level of air quality, as described above, the major emphasis of the air pollution control program must be aimed at maintenance of these air quality levels. In the following sections, program strategies for implementing this objective will be described. This is broken down by the following operating program elements: abatement planning, enforcement, new source review, and air monitoring. Through identification and delineation of the nature of environmental problems and program needs, as well as the opportunities and impediments to solutions, DCCA and EPA will provide a framework for program management. -13- ------- 1. Public Participation Today, a new emphasis on ensuring public involvement throughout project and program development has emerged hence the public is becoming more involved in early stages and throughout most project and program activities. The Government of the Virgin Islands (GVI) and the Regional Administrator of the EPA recognize that public participation in the broadest sense, including both public education and public involvement in all key decision-making, is essential for the successful implementation of water and air quality management programs in the Virgin Islands. Accordingly, public participation will become a key ingredient of every strategy described in this agreement, as well as in the development and annual revision of the agreement itself. GVI and EPA are committed to ensuring that all public participation activities are conducted in a meaningful manner for the public and all the involved government agencies. A formalized public participation program within OCCA's water and air related programs needs to be developed. In order to establish a structure for meaningful public participation in the Virgin Islands, the following activities will be undertaken by DCCA and EPA. • DCCA will provide staff and resources to develop and implement a public participation program. • DCCA (or the Governor's Office) will establish an Environmental Policy Advisory Committee (constituted from private and governmental sections) which will coordinate the activities of the government in the area of the natural and human environment as they relate to the needs of the public . • EPA in conjunction with the Environmental Policy Advisory Committee, will begin a serious appraisal of compliance options which are available to the Virgin Islands because of its unique environmental setting. • EPA will provide technical support to the VI in developing an effective public participation program. ------- STRATEGY/ACTIVITIES STATUS/NEEDS RESPON- J>IBLE AGENCY TIMING COST AND SOURCE ASSOCIATED WQM PROBLEM(S) I. GV1 and EPA will establish a mean- ingful public participation program- DCCA will identify a staff mem- ber who v/ill: « Establish liaison between DCCA" DFW, WAPA, VIPO, VIPA, Housing Authority, EPA, and other- re- levent federal agencies. a Establish a mailing list of all public interest groups and interested., individuals in order to improve their noti- fication of all opportunities to comment (e.g. public meet- ings and hearings) on environ- mentally-related issues. • Establish liafeon with all task force, advisory committees, public interest organizations, and interested individuals. • Ensure adequate public noti- fication on GVI-and federal agency-sponsored opportunities to participate in decision- making, utilizing means not limited to legal notices and direct mailings. • Assist the public in reporting and finding solutions to prob- lems involving government agencies. • Coordinate and support the activities of the Environ- mental Policy Advisory Com- mittee. B. DCCA (or Governor's Office) will establish an Environmental Policy Advisory Committee (EPAC). The Improved and expanded public input is essential to the success of environmental programs. Developing a public participation program, j which emphasizes timely involvement of the public in program planning and implementation, will ensure that air- and water-related programs in the VI and meet local needs and complement other efforts like CZM, W£MF, etc. DCCA FV 80 all r.roblerr.s 2G8 3,661 ~105~ DCCA/VT Governor's Office FY 80 ------- RESPON- SIBLE AGENCY TIMING COST AND SOURCE ASSOCIATED WQ.V PROBLEMS) EPA DCCA/VI Governor's Office FY 80 FY 80 STRATEGY/ACTIVITIES Committee will: « Provide a forum for the devel- opment of interdepartmental cooperative agreements. • Provide access for EPA and the public to the development and implementation of environmental policy. • Coordinate the functions of existing advisory committees. • Identify the need for and sug- gest the make up of additional Task Forces and Advisory Com- mittees. It is anticipated that these subcommittees/task force of the Environmental Policy Advisory Committee will be constituted to accommodate specific goals outlined in thi agreement. • EPA will be responsible for ensuring inclusion of and par- ticipation by relevent Federal agencies. • The EPAC will develop an out- line of needs for public ed- ucation and agency and agency staff training to ensure publi understanding and agency com- pliance with environmental reouirements. STATUS/NEEDS ------- STRATEGY/ACTIVITIES EPA in conjunction with the EPAC begin a serious appraisal of compliance options which are avail- able to the VI because of its unique environmental setting- • EPA will identify areas where compliance alternatives exist • EPA will identify areas where legislative action will be required in order to provide alternatives. D. EPA will provide technical sup- port including training assist- ance, to the VI to develop an effective public participation program. STATUS/NEEDS RESPON- SIBLE AGENCY TIMING COST AND SOURCE ASSOCIATED V/QM PRO3LEMCS) EPA FY 80 EPA FY BO ------- 2. Public Water Supply Both EPA and the VI government agree that the provision of a reliable, safe, and healthful water supply is the most critical problem in the Virgin Islands. This view has also been strongly sustained by those citizens who testified at the public hearings in response to the development of this Agreement. In addition to the discomfort and distress that have been brought about by the frequent interruptions in supply, the record shows that contamination problems have resulted in numerous violations of the Safe Drinking Water Act's Interim Primary Drinking Water Standards. These are attributable to poorly functioning distribution systems, improper and inadequate maintenance of cisterns, unavailability of potable water for public housing projects and inconsistent and ineffective disinfection. Because the Safe Drinking Water Act requires full scale public notification of each instance of violation of the health protective primary standards, a continuation of the present conditions will undoubtedly lead to more citizen concern and possibly a serious reduction in tourism. EPA and the VI Government, represented by the Governor and the DCCA are committed to the following actions to resolve these water supply problems: • The DCCA will solicit and enlist the support and assistance of the Governor and the VI Legislature as well as various Federal and VI agencies in the development of a Comprehensive Water Resources Plan (CWRP). • The Governor will appoint a VI Coordinator to work directly with the Federal Regional Council and appropriate VI agencies to assure that available Federal funds will be applied for, obtained and used for water resources planning, implementation and construction activities. -18- ------- • The DCCA will, with EPA assistance, take the final steps in attaining primary enforcement responsibility under the Federal Safe Drinking Water Act (SDWA). This will require a mutual effort by DCCA and EPA to establish laboratory facilities capable of analyzing all contaminants identified in the Island's primary drinking water regulations. • DCCA wll improve follow-up procedures to ensure that the V.I Housing Authority as well as other purveyors carry out their responsibilities for notifying their customers of the results of samples taken. -19- ------- STRATEGY/ACTIVITIES STATUS/NEEDS RESPON- SIBLE AGENCY I TIMING COST AND SOURCE ASSOCIATED V/QM PROBLE.M(S) A. The VI government wilI ensure an adequate- and reliable water supply o i 1. Solicit and enlist Governor's support for de- velopment of Comprenensive Water Resources Plan (CWRP) for the Virgin Islands The comprehensive plan should include but not be limited to: • A needs analysis to include existing and future demand, quality, population etc. 25% of the authorized transfers ' (barging from P.R.) actually occur Existing desalinization plants are in extensive disrepair-production down by bO% distribution system unaccountable for 33% groundwater development potential nas not been fully realized. Current staffing and funding con- straints have prevented any de- velopment of a Comprehensive Water Resources Plan wnich previously was the responsibility of the VI.Planning Office. A Corps of Engineers study (esti- mated for completion Sept. 79) and the VI Coastal Zone Management (CZM) plan have generated some data An up-date is required as is an analysis and development of a de- mand component for the total plan. DCCA Lackof adequate water supply. DCCA lead other VI agencies and Federal agencies 1980 $22,400 208* (also see dis- cussion tables water supply pop. Land Use ) *208 Funds identified for portions of dev"1- opment of the Compre- hensive Water Resources Plan will supplement S be used in conjunction with other Federal and VI funding described in the Federal Regional Council strategy on Water Resources, (attached). ------- STRATEGY/ACTIVITIES STATUS/NEEDS RESPON- SIBLE AGENCY TIMING COST AND SOURCE ASSOCIATED \VQM PROBLEU(S) i ro An evaluation of supply alternatives (existing and projected) to include - groundwater - manufacture - cistern/catchments ' - waste alternative reclamation - importation - conservation An analysis of the present and future distribution and treatment system needs "lhe development of a technical plan An institutional/management/ financial assessment and development of this com- ponent of the plan. Creation of an organiza- tional framework and plan for implementation of CWRP Preparation of Final Com- prehensive Water Resources Plan An active public partici- pation effort in all phases of development USGS & HUD have generated data for groundwater conditions. Additional work may be required to fill in the gaps. An assessment of what data is needed, the actual gathering of that data and the development of the groundwater component of the CWRP, which includes a groundwater management sub-plan must be made. Support should be continued for the operation of the wastewater reclamation demonstration project on St. Croix so that this alterna- tive can be accurately evaluated. Numerous VI agencies have water resources responsibilities. There is a need to clearly define the roles and responsibilities of these agencies in implementing the- technical plan . Assembling the technical manage- ment, financial and institutional components is essential before the plan can be presented to the public for review. 1980-1981 DCCA FY 8U-8I $3U.QOO 2U3* (also see WQMP Tables) $133.107 106 (mon toring) $70.QUO 2U8* (also see WQMP tables $10.000 2U8* Ulso see WQMP table; ------- STRATEGY/ACTIVITIES STATUS/NEEDS RES PON- SISIE AGENCY TIMING COST AND SOURCE ASSOCIATED V/Q.V. PRO3L£.V.'S) ro ro i • Close coordination with local and Federal agencies (FRCJ in all aspects of plan develop- ment 2. (he Governor will designate DCCA as the lead agency in dev- eloping the Comprehensive Water Resources Plan (CHRP) - Roles and responsibilities of UPW, VIHA, wAPA, V1PO with relation to CWRP will be defined - Appropriate agencies will consolidate existing findings and provide technical assis- tance to DCCA - DCCA will utilize its public participation program (see public participation discussioi and tables) 3. The Governor and the FRC will appoint a VI Coordinator to work directly with the Federal Regional Council and appropriate Federal agencies to assure that available federal funds will be applied for, jobtained and used for water resource planning, implementation and con- struction activities - FRC will also provide training and technical assistance to the VI. A well-coordinated program to locate and utilize available Federal.fundin has been lacking in the VI. Conse- quently large sums of money which could greatly benefit the VI govern- ment in resolving its water resource program have been lost. VI Governor Vl Governor on-gol^ig FY 80 within '<>. months of signing of Agreement within 3 months of signing of Agreement VI Governor/ FRC within 3 months of sighing of Agreement Funds iden- tified in Public Participa- t.ion lables FRC ------- STRATEGY/ACTIVITIES STATUS/NEEDS RESPON- SIBLE AGENCY TIMING COST AND SOURCE ASSOCIATED V/QM PROBLEMS; •B. Ensure a safe potable water supply oo i 1. Final steps for the assump- tion of primary responsibility for public water system super- vision program will be complete « until DCCA can establish a certified lab. DCCA and EPA will pursue commitments with other agencies capable of meeting surveillance require- ments to meet primacy require- ments • EPA will provide staff train- ing in St. Thomas for organics analyses techniques. • St. Thomas & St. Croix supplies were not meeting SDWA Stds. in March. 79. • Co Iiform Bacteria growth not com- pletely responsive to high residua I. •Negative pressure in distribution system lead to quality deteriora- tion through backflows and cross- connections. • Cistern water quality not uniform- ly reliable. • Delivery trucks water quality shows elevated NO levels. •• Negotiations are currently underway for final steps in meeting lab certification requirements. DCCA/EPA EPA/DCCA DCCA/EPA FY79 FY79 FY79 $88,000 SDWA all funds identified as (SDWA) in Tables are part of this total sum. ------- STRATEGY/ACTIVITIES STATUS/NEEDS RESPON- SIBLE AGENCY TIMING COST AND SOURCE ASSOCIATED \VQ.V. PROBLE.V(S) i ro . * DCCA and Property Procurement will develop procedures to en- able procurement in a timely manner 2. DCCA will undertake a health survey to identify correlation . between illness and potable water supply violations. 3. DCCA will continue to inventory and assess pits, ponds and lagoons for integration into solid waste programs 4. DCCA will evaluate and recom- mend changes to legislation to accommodate 2° drinking water stds. 5. DCCA will initiate studies to evaluate the effectiveness of alternative actions to respond to high turbidity and high coll form counts in isolated cistern supplies. * Evaluate the cost/benefits of improving the cistern water quality - from the user perspective - from the monitoring and enforcement authority's persepctive. • Evaluate potential changes to local building codes. Currently procurement is conducted! on a case by case basis; therefore, there is no streamline procedure in place to process most program needs. No epidimological analysis has been done to date. No laws exist today which adequately respond to these stds. Cistern water quality ranges 875 bacti violation 513 turbidity violations nCCA/Propert 'rocurement DCCA lead DCCA/EPA DCCA DCCA DCCA FY 79 1984 Dec. 79 FY80 ongoing HY80 if funds allow $30,000 . SDWA SDWA SDWA ------- STRATEGY/ACTIVITIES STATUS/NEEDS RESPON- SIBLE ' AGENCY TIMING COST AND SOURCE • ASSOCIATED V/Q.V. PROBLEMS) i ro en i • tPA and other federal agencies will .provide technical assistance • DCCA develop and distribute educational material tp hotel mgrs to improve cistern maintenance program 6- DPW will pursue program to eliminate cross connection and distribution system infiltration 7. DCCA will continue monitoring of NOo in GW supplies and assist other agencies in overcoming pro- blems in this area. . • Identify sources of NOo contamination 8. DCCA will improve follow-up procedures to ensure that the Public Housing Authority as well as other purveyors carry out their responsibil itie.s for notifying theii customers of tne results of samples taken. 9.. DCCA/EPA/FRC will explore fundinc sources for operation and mainten- ance (O&M) training in procedures/ techniques for water supply I manufacture/treatment and distri- bution facilities Certain public housing project whicn utilize GW resources have high N03 problems. ihe public has not "received timely notification of drinking water supplies which do not meet VI or hederal drinking water standards. The need for O&M funding for waste- water facilities has been identi- fied in the Construction Grants dis- cussion, but sources for water supply related O&M have not. EPA DCCA DCCA DCCA/EPA/FRC •ongoing ongoing FY80 FY80 (SDWA) . (SDWA) (208, 106) SDWA ------- 3. Residuals Management Two laws which have direct impact on solid and hazardous waste management in the Virgin Islands are the Federal Resource Conservation and Recovery Act (RCRA) of 1976 and the Virgin Islands Bill Number 7932 of 1978 entitled Solid and Hazardous Waste Management. The need for developing regulations and programs to implement these laws is urgent as severe problems in the areas of potable water supply, available land for waste disposal sites and sources of adequate cover material for land disposal facilities are prevalent and need resolution. In order to alleviate many of these problems the VI Goverment will implement the following activities to protect public health and .the environment, and promote the conservation of material and energy resources* • Develop and implement comprehensive Solid Waste and Hazardous Waste Management programs. • Develop and implement a solid waste land disposal program, and resource conservation and energy programs. • Develop short and long-term actions to rectify incinerator/landfill problems. • Develop a DCCA/DPW agreement on implementation of actions to eliminate landfill fires. The previously described activities clearly demonstrate a need for a strong tie-in between Solid and Hazardous Waste Management and Water Quality Management (WQM) in the Virgin Islands. There appears to be a serious question as to how these programs can be effectively implemented under .the current separation of DPW and DCCA's responsibilities. To resolve this issue: • The Governor's Office will reassess the current distribution of responsibilities to determine whether it would be more efficient to restructure the local management of the residuals management program. -26- ------- STRATEGY/ACTIVITIES A. The Virgin Islands government will promote the protection of public health and the environment. 1. Develop a comprehensive Solid Waste Management Plan. Identification and designation of implementation boundaries. • Identification and designation of planning and implementation agencies. Identification of agency responsibilities. Assessment of solid waste regulatory program and develop- ment of necessary new legislation and regulations. Assess present and future solid waste disposal needs. Develop alternatives for residuals recovery and/or disposal. Public participation activities. Coordination with other government agencies. Mechanism for update/ revision of plan. Develop and implement surveillance and enforcement program. STATUS/NEEDS In Process Completed Completed Completed In Process In Process In Process In Process In Process In Process In Process RESPON- SIBLE AGENCY Ofc. of the Governor DPW DPW TIMING 1982 1978 1978 1978 78-82 78-82 78-82 78-82 78-82 78-82 78-82 COST AND SOURCE $ 259,000 i ASSOCIATED VVQ.'.S PROSLE.V.(S) i ------- STRATEGY/ACTIVITIES 2. The DPU will investigate and implement short and long term actions to rectify the incinerator/ landfill problems on St. John. DPW will take immediate short term corrective actions: • fill transported to site to cover exposed solid waste * DPW will continue to trans- port and stockpile fill ' DPW will seek ways to repair and modify existing incinerate * DPW will transport residuals to a.fill area • DPW will negotiate for addi- tional fill areas in same proximity * DPW will .implement a pre- ventive maintenance program DPW will seek to renovate the incinerator. DPW will explore the possibility of obtaining land from NFS for dis- posal of incinerator residue DPW will evaluate potential long term disposal sites, re- commend action and begin operation DPW will review'and implement, where applicable, corrective actions recommended by DCCA. STATUS/NEEDS SIBLE AGENCY TIMING COST AND SOURCE ASSOCIATED \VQM PROBLE.V(S) DPW ------- RESPON- SIBLE AGENCY TIMING COST AND SOURCE ASSOCIATED WQM PROBLEM(S) DCCA/DPW STRATEGY/ACTIVITIES 3. DCCA will continue to initiate discussion with the DPW .based on documented open burning violations,! and reach agreement with DPW to implement steps to eliminate open burning at landfills as high priority. - Develop a program plan as soon' as possible, including but no limited to Standard and Sanitary Operational Procedures. STATUS/NEEDS r ------- STRATEGY/ACTIVITIES STATUS/NEEDS j RESPON- ! SmiE j AGENCY j TIMING j COST AND ! SOURCE ASSOCIATED VVQ.M PRO::,LEV.(S) i OJ o i Any and all other actions necessary to correct all presently existing violations of Title 12 V.I.C. Chapter 9 and regulations promulgated pursuant thereto. 4. Develop and implement Solid Waste Land Disposal Program. Develop sufficient regulatory authority to undertake all activi- ties associated with land disposal. Undertake open dump inventory and classify land disposal facili- ties. - Develop criteria for open inventory. Close/upgrade open dump". - . Develop compliance schedules. Prohibit new open dump. . Develop permit system. 5. The Virgin Islands government will evaluate their potential and make recommendations for develop- ment and implementation of a Hazardous Waste Program. Determine resource capability and recommend agency for program responsibility. Develop adequate regulatory authority. Develop and undertake notification program. In Process In Process In Process In Process In Process In Process In Process In Process In Process In Process rt In Process EPA 1979-83 79-83 79-83 79-83 79,-83 79-83 1979-83 79-83 79-83 79-83 $ 228,000 #540,000 ------- I 00 STRATEGY/ACTIVITIES -- Plan and implement hazard- ous waste facility permit system. - Prepare and undertake manifest system. * - Prepare emergency response • plan. - Develop and implement surveillance and enforcement program. - Prepare and implement public participation program. - Develop comprehensive •hazardous waste management .training program. - Develop and submit an authorization plan. - EPA will ensure that Virgin Islands government has sufficient notification before compliance deadlines. B. The Virgin Islands government will strive to conserve valuable material and energy resources. 1. The Virgin Islands government will develop and implement a Resource Conservation and Recovery Program. - encourage use of recycled goods in Virgin Islands government operations. - Develop procedures to imple- ment procurement policy. STATUS/NEEDS In Process In Process In Process In Process In Process In Process In Process In Process In Process rt In Process RESPON- SIBLE AGENCY ' EPA • TIMING 1979-83 • 79-83 79-83 79-83 79-83 79-83 79-83 80 79-83 79-83 79-83 . COST AND SOURCE • * 56, 000 .(RCRA-D) #210,000 (Urban Policy) . \ • ASSOCIATED V/QM PRO3LEMCS) ! .. ------- STRATEGY/ACTIVITIES STATUS/NEEDS RESPON- SIBLE AGENCY TIMING COST AND SOURCE ASSOCIATED V/Q.V; PROBLEMS) .The Virgin Islands Governor will identify the Agency(ies) responsible for development and implementation of the Residuals Management Plan. GO ro i 1. The governor's office will re- assess the current distribution of responsibilities to determine whether it would be more efficient to restructure the management of the Residual Waste Program. • Consolidation of enforcement • responsibilities for the solid and hazardous waste management programs must be agreed to and implemented * Identification of the man- agement agency responsible for the implementation of resource/energy recovery programs must be finalized * Determination of lead agency in hazardous waste permit program must be made There is a strong tie in between Solid and Hazardous Waste Manage- ment- and Water Quality Management in the Virgin Islands. However, these programs are currently separated between DCCA & DPW.' There is a need to determine whether this approach is the most viable one. Governor of Virgin Islands Within 3 months of signing of Agreement ------- 4. Construction Grants The management and implementation of the Construction Grants program in the Virgin Islands has been both efficient and effective. However, both EPA and GVI agree that additional construction monies are needed and should be made available by the US. Congress to finance municipal wastewater facilities now designed or undergoing design. The DCCA, is responsible for carrying out the duties and responsibilities of the local certifying agency as well as those of the grantee. However, once facility construction is complete and successfully operating, the DCCA turns the facility over to the Department of Public Works (DPW) which then assumes the responsibility for operation and maintenance. It is at this juncture where many problems have surfaced. It has been EPA and GVI's observation that the publicly owned wastewater treatment facilities and pumping stations are operating at sub-standard levels and are in a state of general disrepair. This condition is due to inadequate operation and maintenance practices and the lack of adequate resources for the O&M of these facilities. Problems stem from inadequate operator training, the lack of adequate surveillance procedures, disregard for daily operating procedures, poor disinfection and sludge handling practices, budgeting, and in general a lack of preventive maintenance. Inadequate O&M results not only in violations of water quality standards and permits but also in a shortening of the useful life of the equipment and plant structures, often requiring excessive expenditures to compensate. O&M funding needs to be elevated to a priority position in the Department of Public Work's budget. -33- ------- The EPA and the GVI have agreed to the following activities: • The VI Governor will redirect funding and program operation priorities so that the attainment and utilization of continual funding for the Operation and Maintenance (O&M) off wastewater and water supply treatment and distribution facilities will be a prime focus and commitment. Action required would include local agencies participation in improving facilities management, selection of an FRC Coordinator to expedite use of available federal funding, the development of a user charge system and initiation and support of VI legislation to ensure the longevity of this priority. • DCCA will continue to operate the Municipal Facilities Program as part of its on-going program management activities. • EPA will provide Construction Grant funds for on-site operator training and O&M manuals in the re-design of the St. Thomas facility. • EPA and DCCA will work in concert with DPW, WAPA and VIHA to develop a high caliber, continuous training program for personnel involved in environmental protection programs in the VI and will seek to obtain the necessary funding and resources to carry it out. -34- ------- STRATEGY/ACTIVITIES STATUS/NEEDS RESPON- SIBLE AGENCY TIMING COST AND SOURCE ASSOCIATED V/Q.V, PROBLEM(S) i OJ en i A. The VI Governor will redirect funding and program operation priorities so that the attainment and utilization qf continual funding for Operation and Maintenance (O&M) activities .for wastewater & water supply facilities will be a prime focus and commitment. The Governor will redirect the efforts of DCCA and DPW in environmental program activities toward improved management of thei facilities. The Governor will select a Coordinator to expedite use of federal funds for O&M and other water resources related activities. • C&M activities are not presently- funded as priority items. Deterioration of treatment and distribution facilities has resulted in inefficient plant operation, contamination of public water • supplies and .loss of water resources. The Federal Regional ..Council (FRC) has developed a Water Resources Strategy Document which identifies ivailable funding for C&M activities is well as a Coordinator 'Concurrent with the FRC activities the Governor .will initiate, and •support legislation to make available, on a' continuous basis, additional funds for O&M.' DCCA & DPW will develop an EPA approved User Charge System for Operation & Maintenance costs. This activity will be given top priority and will be funded by EPA Construction Grant Funds. Legislation needed to implement User Charge System will be developed. Negotiations are underway with a consulting engineer to develop a user charge system as soon as feasible. New grants for construc- tion will not be made and payments for ongoing construction will be discontinued. VI Governor Immediate VI Governor immediate DCCA/DPW FY 79-80 FY 80 Municipal discharges FRC 201 funds ------- STRATEGY/ACTIVITIES STATUS/NEEDS RESPON- SIBLE AGENCY TIMING COST AND SOURCE ASSOCIATED V/QM PR03LE.VCS) B. DCCA will continue to Operate the Municipal Program Facilities C. Improve O&M Management and Design Considerations to reduce maintenance. 1. On-site training at the STP sites will be provided. 2. Spare parts inventories will be provided for all new treatment facilities. 3. Improved materials will be used in construction to combat the climatic conditions encountered in the Virgin Islands. 4. EPA DCCA will work in concert • with DPW, WAPA & VIHA to develop a high calibre, continuous training pro'gram for personnel involved in environmental protection programs in the VI. D. EPA will continue to support actions which will provide for more funds to the Virgin Islands. 1. All proposed legislation offering greater financial assistance to Insular Areas will be supported 2. EPA Headquarters will continue to be reminded of the funding problem in the Virgin Islands through memos and waiver requests. This is an on-going program which. administers the Construction Grants program Development Treatment facilities are generally inadequately operated, maintained and funded. .An operator certifi- cation program does not exist, and funds are not available for main- tenance. Lack of Federal funding is creating delays in key water pollution con- trol projects. Approximately $5 million is needed for immediate corrective measures. DCCA DCCA DPW EPA FY 80 1980 and oncoming after 1980 1980-84 $20.600 106 201 funds $45.600 106* 201 funds *106 funds training a and mainte Municipal discharges Municipal discharges Sludge disposal Municipal facilities Municipal discharges Sludge disposal nclude d operation ance programs. ------- 5. Water Quality Management Planning Section 208 of the Clean Water Act requires that State/Territory water quality management plans (WQMP) be prepared and contain "alternatives for waste treatment management, and be applicable to all wastes generated within the area involved". These WQMPs, prepared pursuant to Section 208, must be fully coordinated with other on-going planning programs to ensure integrated and consistent programs. The Coastal Zone Mangement (CZM) plan has been completed for the Virgin Islands and is a typical example of a program which contains numerous environmental policy statements that could be incorporated into the WQMP. WQM plans encompass a large array of components, some of which are pertinent to the Virgin Islands, i.e., sediment reduction, on-lot disposal, water resources planning, land use and economic projections and water quality assessments. The following activities will be carried out by DCCA in the development of the VI Water Quality Management Plan. • Develop a management process for the effective coordination and integration of the numerous environmental activities in the Virgin Islands into the WQMP planning process. • Prepare a biennial 305(b) report to serve as the Water Quality Assessment. • Develop Phase II Sediment Reduction Program, on-lot waste disposal management system, and regulatory and management program to control vessel wastes. • Participate in development of technical components of Comprehensive Water Resources Plan and take lead in entire plan development. -37- ------- STRATEGY/ACTIVITIES STATUS/NEEDS RESPON- SIBLE AGENCY TIMING COST AND SOURCE ASSOCIATED WQM PROBLEM(S) A. Program Coordination The CPP regs (40 CFR 130.34) re- quire that the DCCA coordinate water quality management plans and describe the relationship between the WQMP and affected local and. Federal programs, with special emphasis placed on the CZM program. 1. DCCA & EPA will evaluate the CZM program and begin procedures to adopt the CZM Plan or relevent portions of the plan as part of the WQMP. - population, land use, and economic projections shall be obtained from CZM plan and future land use plan arid integrated into the WQMP. • 2. .The following should be done as an essential step in ensuring integrated water quality manage ment programs : - identify V.I. agencies responsible for implementing various environmental programs. - describe on-going programs. - define relationship between those on-going programs and WQMP being developed by DCCA. This is an important step that must be taken in developing the Interagency Agreements ensuring effective program integration and avoiding duplication. Adopting portions of the CZM plan would eliminate duplication of planning efforts. DCCA FY'80 $15,000 208 Program Management FY'80 DCCA FY'80 Program Management ------- STRATEGY/ACTIVITIES STATUS/NEEDS RESPON- SIBLE AGENCY TIMING COST AND SOURCE ASSOCIATED \VQ\! PROBLE.V(S) i 00 B. 3. DCCA will develop and execute memoranda of understanding with the various potential management agencies that would be designated by the Governor as the responsible agencies implementing portions of the WQMP. 4. DCCA as the designated water quality management planning agency responsible for the overall management and coordination of the V.I. WQMP will negotiate with and enter into formal agree- ments with the appropriate V.I. government agencies that are identif. ashaving planning or implementation responsibili ties for portions of the WQMP. Program Development The following program components will be developed'as part of the total WQMP. 1. Preparation of biennial 305(b) report.. 2. Development of the Phase II Sediment Reduction Program for the V.I. as part of the on-going and previously funded 208 program. 3. Development of an on-lot waste disposal management system. This activity is needed to establish the framework which will set forth specific activities to be identified in the Interagency agreements. Formal agreements must be entered into with a number of Virgin Island agencies that will manage or im- plement pieces of the WQMP. This is a key element of the management strategy. Agencies will define in detail their one year/five year commitments. The report will serve as the Water Quality Assessment for WQM planning purposes. Details of the Sediment Reduction Program were not adequately de- fined in the 208 work plan. See non-point source tables, Chapter 8 for further details. DCCA DCCA DCCA DCCA FY'80 FY'80 $10,000 106 40,000 208) $10,000 (208) Program .'1anage".ent Program Management nonpoint source pollution - sedimenta- tion. nonpoint source pollution - on-lot disposal . ------- STRATEGY/ACTIVITIES STATUS/NEEDS RESPON- SIBLE AGENCY TIMING COST AND SOURCE ASSOCIATED V/QM PROBLE.V.(S) o i Development of the com- prehensive water resource plan for the V.I. as part of the on-going and previously funded 208 program. 5. Development of a regulatory and management program to control vessel wastes in Virgin Islands harbor waters, 6. Development of executive summary /environmental assessment. C. Update and coordination of implementation of VI/EPA Agreement Details of the water supply planning tasks were not adequately defined in the 208 work plan.. See Public Water Supply tables Chapter 2 for further details VI/EPA Agreement is a working docu- ment for water and air programs and as such must be revised to reflect changing objectives and activities DCCA DCCA DCCA DCCA FY'80 FIT'80 FY180-81 quarterly 208 (Costs det- ailed in '/at.Supply) See discussion and table on Public Water Supply $5.000 water supply protection and conservation. (208) $5.000 (208) $12,400 106 nonpoint source . pollution - vessel wastes all problems ------- 6. Virgin Islands Pollution Elimination Discharge System (VIPDES) As mandated in the Clean Water Act (CWA) Public Law 92-500, the National Pollution Discharge Elimination System (NPDES) program has direct regulatory control over all surface water dischargers, i.e., the permit program. EPA delegated authority for this program to the VI government on 3uly 1, 1976. The VIPDES permit program originally was designed to control municipal, industrial and commercial facilities which discharge to surface waters. The jurisdiction of this program however has been expanded in the 1977 amendments to the CWA to include federal facilities. The VIPDES program as is it currently exists is in need of improvement in terms of exchange of information. There have in the past been problems identified with respect to the communications between both DCGA and EPA. A commitment to a timely delivery to EPA of basic information and data needed to carry out the VIPDES program is necessary. In addition, there is a need for EPA to develop a more efficient in-house mechanism to ensure better communications. With relation to additional permitting activities, EPA believes that an effort should be undertaken to assess the few remaining municipal and non-municipal treatment facilities to determine whether a VIPDES application is needed. The cumulative effect of these unreported discharges to the surface as well as groundwater may be significant and should be evaluated. A commitment to full implementation of the Memorandum of Agreement between EPA and DCCA should resolve most of the issues/problems identified. Hence the following activities will be pursued: • DCCA, DPW and EPA will improve coordination/communication and program effectiveness in carrying out the VIPDES program through better reporting, efficient permit reissuance and a commitment to improved O&M activities. • DCCA will ensure a more efficient VIPDES program through increased permit activities and sampling inspections. ------- STRATEGY/ACTIVITIES STATUS/NEEDS RESPON- SIBLE AGE.NCY 'A. DCCA, DPW and EPA will improve coordination/communication and program effectiveness. 1. EPA will develop an inhouse mechanism to ensure better communications among inter- related media affecting permits. 2. i -pa IN5 I 4. The DCCA will improve its communications with EPA. - DCCA will improve its quarterly non-compTiance reporting program. The Department of Public Works (DPW) must establish priorities for funding of operation and maintenance activities for municipal treatment systems, and solid waste facilities. Priorities will be estab- lished to. assure effective permit development and reissuance. EPA needs to improve its inhouse" communication activities so that information transmitted from the DCCA is forwarded to the various EPA offices in a timely fashion. EPA The DCCA should forward immediately to the Permits Administration Branch! (PAB) of EPA all new VIPDES appli- ] cations, Public Notices, draft and j final permits, fact sheets, and rationales, the DCCA should for- malize its reporting system to EPA and address its permits activities solely to PAB. In addition, the ! DCCA needs to establish'a program I for non-compliance. DCCA TIMING I COST AMD SOURCE within 3 months of signing Agreement funds identi fied in Section B (next page ASSOCIATED WQfV\ PROBLEM(5) DPW must identify and earmark JV.I. specific funds to carry out its i governor maintenance activities. DPW must prc-l DPW/DCCA vide proper Operation and Maintenancb(See of POTVJ's. The DCCA will provide Construction DFW technical assistance in determi- grants ning this funding. discussion I and Tables) Inventories are required of in- | DCCA dustries discharging toxics and an evaluation as to the proximity to water supplies should be made. Immediate Within 4 months tof signing of agreement ------- STRATEGY/ACTIVITIES SI AGENCV TIMING',£2?AND DCCA will ensure a more efficientVIPDES program. 1. Permits'will be issued/re- issued, incorporating BATyBC or territorial water quallt standards. 2. DCCA will Identify the few remaining discharges, and determine if aVIPDES appli- cation is required. 3. DCCA will increase sam- pling Inspections of munic- iple and Industrial per- mittees. 4. DCCA and DPI! shall develop legislation and establish procedures to transfer to OPW the responsibility for operation, maintenance and securing of permits for all major municipal wastewater treatment facilities. 5. Evaluate the possibility of permit consolidation (water, air, and solid waste permits). 6. Develop controls for indirect discharges. Permits need to be Issued and re- issued as they expire to continue effective discharge control . The second round of permit issuance must now be implemented since per- mits will be expiring in 1980. Better program Implementation Is needed in these areas. Sampling inspections are needed to ensure compliance by permittees and to monitor water quality. DPW operates and is responsible for all minor plants. Because DCCA has enforcement responsibility apainst Itself, 1t appears that there would be greater contlnunity and more efficient program opera- i tion 1f DPW has responsibility for major plants. Fragmented permit program may not be as efficient as a "one stop" program. The DCCA needs to develop a com- prehensive pre-treatment strategy. DCCA DCCA DCCA " I SOURCE Continuous 3 months i $51 ,500 106 PROBLEM(S) Municipal Discharges. Industrial Discharges. Non-municipal Sewage Discharges. DCCA/DPW DCCA DCCA 3 months 1 year •Municipal Discharges Industrial Discharges None 4 months 6 months Industrial Discharges. Municipal Discharges. Municipal Discharges. Indirect Industrial Discharges. ------- STRATEGy/ACTJVlTIES STATUS/NEEDS SJSLE . AGENCY TIMING- I COST AND j SOURCE ASSOCIATED V/QM PROBLEN(S) 7. DCCA will continue to en- courage the complete use of wastewater facility efflu- ent. 8. DCCA in preparation for reissuance will perform inventories of industries discharging toxics. i -pa The. recycling of wastewater effl-u- ent by numerous hotels on the islands, has resulted in a decreased need for permits. Need for better understanding o-f economic stability of industries as well as proximity to water supply intakes. DCCA DCCA Continuous 6 months (Also see Tcxic ubstances iscussion & tables) Municipal Discharges Industrial Discharges Industrial Discharges ( ------- 7. Water Enforcement The VIPDES permit program is the only water enforcement program for which the Virgin Islands has been delegated primary enforcement responsibility. Yet, one of the major complaints made during the public hearings of July 10 and 11 with relation to this Agreement was that both DCCA and EPA had failed to carry out their enforcement responsibilities when facilities owned or operated by VI Government agencies violated their operating and discharge requirements. This criticism substantiates a concern which EPA has had that DCCA by itself may not have the appropriate resources and power to deal with some of the more difficult enforcement problems. During this Agreement negotiation, both EPA and DCCA have recognized that there is a need to develop a formally structured enforcement program. The following activities will be carried out by DCCA and EPA in an effort to ensure that an effective enforcement program is implemented: • A formal enforcement sub-agreement will be developed by DCCA and EPA to identify activities and time frames for compliance review, monitoring, and enforcement procedures. • The establishment of enforcement priorities will be coordinated between EPA and DCCA through quarterly meetings. • The Governor, DCCA and DPW will work together to redirect funding and program operation priorities to ensure proper operation and maintenance of the municipal treatment plants for which the DPW is responsible. • EPA will re-evaluate options which entail federal assumption of enforcement or withdrawal of approval of the NPDES permit program if the Virgin Islands government does not fully support the implementation of a formal enforcement program. ------- STRATEGY/ACTIVITIES STATUS/NEEDS RESPON- SIBLE AGENCY TIMING COST AND SOURCE ASSOCIATED WQM PROBLEM(S) -£» CT1 I A. DCCA and EPA will develop a formal enforcement agreement. 1. Virgin Islands' government will perform compliance reviews, monitor and enforce permits in accordance with the following: - VI will submit a complete inventory of point source discharges - Compliance and non- compliance reports will be submitted - For each .violation, VI will describe action to be taken for compliance and will issue a publicly, available notice to the Agency in violation clearly describing the courses of action that wil1 follow and the • ramifications associated with each action, Copies will be sent to EPA. - Copies of all compliance monitoring will be sent to EPA 2. The establishment of enforce- ment priorities will be coordinated quarterly by DCCA and EPA. An enforcement program is less than effective in the VI .and a more clearly defined action program is needed. DCCA FY'80 A combined effort with staff from DCCA and EPA should provide a more efficient program. DCCA/EPA FY'80 $35,300 106 ------- STRATEGY/ACTIVITIES STATUS/NEEDS RESPON- SIBLE AGENCY TIMING COST AND SOURCE ASSOCIATED \VQ.V. PROBLEV.(S) i -P. 3. The Governor of the VI, the Commissioner of the Department of Public Works (DPW) and the Commissioner of the DCCA will develop an effective program to ensure that the DPW operates and maintains the municipal treatment.plants and pumping stations properly and in compliance with MPDES permits 4. EPA will re-evaluate options which entail federal assumption of enforcement or withdrawal of approval of the VIPDES permit program if the VI government does not fully support implementation of a formal enforcement program Budget monies must be allocated (by DPW and the VI Government) to . operate and maintain all municipal. treatment plants. 'he Governor PW/DCCA EPA FY'80 FY'80 (See Construction grants discussi on and tables) ------- 8. Monitoring and Surveillance The Federal and Virgin Islands water pollution control and drinking water legislation requires that comprehensive monitoring programs be established in the Virgin Islands for ambient monitoring. Virgin Islands Pollution Discharge Elimination System (VIPDES) surveys, drinking water monitoring and data quality assurance. The ambient monitoring program includes routine coastal water quality and biological monitoring as well as intensive routine surveys in certain areas of unique character. In addition, special studies related to discharges of upland sediments and the affects on coastal water quality and biological communities are also performed. The VIPDES compliance monitoring of industrial and municipal discharges is used to determine whether effluent limitations are consistent with the priorities issued. Monitoring of all public water supplies is performed to determine compliance with the interim primary standards of the Safe Drinking Water Act. To insure the accuracy of all these programs, a data quality assurance program has been developed. There are portions of each of the monitoring programs where deficiencies exist. The ambient program does not include sampling of the Basic Water Monitoring Program stations. The VIPDES compliance monitoring program needs closer coordination between DCCA and EPA. The Drinking Water Monitoring Program presently suffers from lack of laboratory capability which has hindered EPA Region II from granting full certification and has been an obstacle to DCCA's receiving primary enforcement responsibility. The Data Quality Assurance Program has recently been staffed by a quality assurance coordinator, but still will require further expansion to meet EPA requirements. -48- ------- To resolve these problems, the following activities will be pursued: • DCCA will improve the efficiency of the laboratory and program operations through increased lab capability, implementation of the Basic Water Monitoring Program, and formalization and expansion of the quality assurance program. • The VI Government agencies will expand their coordination efforts in monitoring program activities. • DCCA will ensure that a toxic monitoring capability exists and is available. -49- ------- STRATEGY/ACTIVITIES STATUS/NEEDS RESPON- SIBLE AGENCY TIMING COST AND SOURCE PROSLEV.(S) i tn O i A. Improve efficiency of laboratory and program operations. 1. DCCA will increase the lab- oratory capabilities in the areas ofvIPDES monitoring, ambient monitoring, the basic water'mon- itoring program and drinking watejr monitoring analysis. Acquire reliable boats Develop a faster and more efficient laboratory material procurement procedure. -. Conduct organic analysis training for DCCA personnel at DCCA laboratory facilities Conduct training for other parameters needed for BWMP.VIPDES, SDWA Monitoring analyses. 2. DCCA will implement the Basic Water Monitoring Program in .the areas of quality assurance, ambient monitoring parameter coverage,VIPDES compliance moni- toring reporting and intensive surveys. The ambient monitoring parameter coverage, will be initiated. The Quality Assurance procedures will be followed (see Activity 3). TheVIPDES reporting pro- cedures will be followed (see Strategy B.I.) - Sampling activities have decreasec - DCCA is presently exploring feasi- , bility of modifying existing procurement procedure. - On the job training (OJT) is cur-. rently being provided by EPA Office of Drinking Water (Cincin- nati) with follow up by Region II. - No training ongoing Ten basic monitoring stations were established in October 1978, how- ever, sampling has not started. DCCA DCCA EPA/DCCA EPA/DCCA FY 79-80 Sept. 1, 79 July 1, 79 DCCA/EPA DCCA/EPA $101 .000 106 This is for the entire monitoring proaram strategies A-C" ------- I en STRATEGY/ACTIVITIES STATUS/NEEDS Kiiii-ON- SIBLE AGENCY All intensive surveys wil be reported using BWMP pro- cedures. Routine water quality bio- logical monitoring of terri- torial coastal waters will continue. 3.. The DCCA and EPA will formali; and expand the present quality assurance program to cover all aspects of water data collection. DCCA will appoint and train a QA co-ordinator. DCCA will issue a QA . Policy Statement. •». DCCA will develop and' implement a QA Plan for each water monitoring program. -. DCCA will maintain the quality assurance program. I B. Expand coordination efforts of agencies involved in monitoring program activities. 1. DCCA will establish a program for improved coordination between DCCA and EPA regarding UPDES com- pliance monitoring activates. - There is a need for special studi in Altona Lagoon and Salt River Estuary; St. Croix; Lindberg Bay, St. Thomas and Coral Bay, St. John. - QA Co-ordinator recently appointee Requires training ait EPA, Edison; EPA, Cincinnati and attendance at at semi-annual state QA Co-ordin- ators at Edison, NJ. - Mori existent to date - 85% completed. Presently in operation but needs formalization and expansion. DCCA DCCA . DCCA/EPA DCCA DCCA DCCA TIMING COST AND SOURCE FY 79-80 FY 80-85 Oct. 30, 79 Oct. 1, 79 Dec. 1, 79 On-going ASSOCIATED ?RG5LE.V.:S) ------- STRATEGY/ACTIVITIES STATUS/NEEDS Ktil'UN- SIBLE AGENCY TIMING COST AND SOURCE ASSOCIATED V/QM PROBLEM(S) i en - DCCA will - . 'develop a quarterly report) ing system of surveys completed during each quarter as required by the Basic Water Monitoring Program. FileVTPDES Compliance monitoring reports with EPA and DCCA within six months of survey completion. -. EPA will monitor 20% of the Virgin IslandsVIPDES sur- veys by actually performing follow-up surveys, to ensure the accuracy of the Virgin Islands surveys. C.Ensure that a toxic monitoring capability is available. a. DCCA/EPA will determine toxic monitoring needs and prioritize needs. b. DCCA/EPA will develop a source for doing toxics analysis. This may be accomplished through agreement with. EPA Region II or other oontractural agreement. c. DCCA will maintain a Toxic Monitoring Program. d. Ensure that Quality Assurance requirements are imposed on all grants, contracts and monitoring data generated under regulation. DCCA/EPA Surveys being completed but report are not being filed. s DCCA/EPA EPA No analysis of toxic needs has been.made to date. DCCA/EPA Jan. 1, 80 Also See Toxic Substances discussion and Tables DCCA/EPA On-going ------- 9. Nonpoint Source The requirements for developing State/Territory water quality management plans are contained in Section 208 of the Clean Water Act. This section requires that the plan be applicable to all wastes generated within the area involved. This includes the identification of and the establishment of control mechanisms for nonpoint sources of pollution. The nonpoint source unit of this Agreement has identified a number of nonpoint sources of pollution as water quality management problems. These are: construction sediment; urban stormwater, vessel wastes, on-lot sewage disposal and oil and hazardous materials spills. The on-lot disposal problem has resulted from failing septic systems, the cause of which is primarily poor soil conditions for improper septic system operation. This problem may become more acute when examined within the context of future growth and increased water usage. The construction sediment problem has caused some degradation of water quality, clogged drainage guts and has impacted some of the coral reefs. Vessel wastes originating from the numerous foreign pleasure craft operating within the Virgin Islands coastal waters have caused water quality problems in some of the harbors. While the US Coast Guard has requirements for certain US made craft and pleasure vessels, there are none that apply to most foreign pleasure craft used in the Virgin Islands. The DCCA and DPW will implement as part of the Water Quality Management/Non Point Source program the following activities: • DCCA will develop an effective management and regulatory program for the siting, design, installation, inspection and maintenance of septic systems. Provisions must be made for future growth and increased water consumption. -53- ------- • DCCA will develop a more effective regulatory program for the control of construction sediment for all projects in the second tier of the Coastal Zone. • DPW will improve enforcements of existing sediment control regulations. • DCCA will develop a regulatory program to control waste discharges from all pleasure craft operating within Virgin Island's coastal waters. -54- ------- STRATEGY/ACTIVITIES STATUS/NEEDS RESPON- SIBLE AGENCY TIMING COST AND SOURCE ASSOCIATED V/QV. PROBLEMS) i en en i A. The following non-point source programs will be implemented by DCCA: 1. Sediment Reductions (construct!on) The goal iVto 'improve ex- isting regulatory programs for control of sediment resulting from construction activities in the second tier of the coastal zone. - Establish and define criteria to specify re- quired levels of control. of construction sediment for various categories of receiving waters. This 1s .usually defined as allowab' sediment yield (tons/acre •of disturbed land. - A cost effectiveness study of various levels of con- trol should be carried out by taking into account the sensitivity of the receiving waters and the magnitude of the project. - Develop manual of practice specifying levels of con- trols, BMP specifications, procedures for permits, etc A program presently exists.to.con- trol sedilment from construction projects. DCCA FY'80 $40,000" 208 Nonpoint Source pollution * These same funds are identified in the UQMP discussion and table. ------- STRATEGY/ACTIVITIES STATUS/NEEDS RESPON- SIBLE AGENCY TIMING COST AND SOURCE ASSOCIATED \VQM PRO3LEV(S) i en - Upon completion of above activities, develop agree- ments with appropriate management agenc'ies covering assigned responsibilities for control of sediment from publicly financed constructior establish annual goals; the program reporting system to used; adequate field in- spection procedures; legal authority; final responsibility for implementation assuming funds for control programs are made available. - Develop a supportive 'technology transfer program for the sediment reduction program.- Develop technical and informational material and establish operational procedures for transfer sessions. 2. Ch-Tot disposal An effective management system and regulatory program must be established to control pollution resulting from failing on-lot systems. - Maps should be prepared defining sewer service areas, showing population, sewered areas. Maps should also b'e prepared showing,proposed or potential sewer service areas and show unsewered population distribution. A program is needed to effectively plan for future growth and in- creased water supplies, resulting in a need for a septic system management program DCCA FY'80 $10,000* 208 Nonpoint Source pollution ------- STRATEGY/ACTIVITIES STATUS/NEEDS RESPON- SIBLE AGENCY TIMING COST AND SOURCE ASSOCIATED V/QM PROBLEMS) en - Maps of moderate & severe so.il conditions relative to unsewered or unconnected areas should be prepared. - Identify the current operational procedures in- cluding but not limited to: methods used to select sites; design systems; installation procedures; inspection & maintenance programs etc. - Information should be presentee documenting known failures of septic systems, their locations & water quality problems re- sulting from system failures or lack of systems. - Assuming that there are some significant on-lot problems, an individual systems manage- ment agency should be identified to provide such functions as' pump out service, licensing, design assistance, siting assistance, general. technical supervision, inspections & a procedure to locate failing systems. 3. Vessel Wastes A regulatory and management program must be developed for pleasure craft in the harbor waters of the Virgin Islands. - Assess water quality impact from pleasure craft. DCCA FY'80 $5 .OOP11 208 ------- STRATEGY/ACTIVITIES STATUS/NEEDS RESPON- SIBLE AGENCY TIMING COST AND SOURCE ASSOCIATED \'/QM PROBLEMS) un 00 I - project future water quality impacts - evaluate current laws and regulations - draft appropriate legislation - perform economic, social & environmental assessment. ------- 10. Toxic Substances Within the framework of the Toxic Substances Control Act (TSCA), the Virgin Islands has no responsibility. The TSCA is a strong Federal mandate that in most cases actually pre-empts state action where controls under the law have been imposed. However, the toxic substances control responsibilities pursuant to other laws are varied depending on the particular statute and its applicability in the Virgin Islands. : Little has been done in water programs in the Virgin Islands to date, with regard to toxics identification and program integration. There are no known hazardous waste disposal sites, no problems with respect to industrial discharges to municipal sewage treatment plants and no water quality standards criteria for toxics. Indeed, at the present time, there are very few sources that would be expected to pose toxic substance discharge related problems. The following activity will be pursued to address the toxics issue: • The DCCA will develop and implement a toxic substances control strategy that coordinates Virgin Islands' efforts to limit exposure of man and the environment to toxic substances. As part of this program, a plan to respond to health emergencies and situations involving imminent substantial endangerment to health or environment will be developed. -59- ------- STRATEGY/ACTIVITIES A. Protect human health and the environment from insult by toxic substances 1. Develop and implement toxic substances control strategy that coordinates .the Virgin Islands' effort; to limit exposure of man and the environment to toxic substances. a. Review and summarize existing environmental and source related toxic substance data (inventories, etc.) and identify potential problem areas. b. Utilize existing pro- grams to evaluate potential toxics problems and impose appropriate controls on problem sources. These efforts would focus on the follow- ing areas: • Air: NAAQS (lead) and other toxic substance emissions. • Water: VIPDES/NPDES permit effluent limitations; Water Quality Standards; other controls developed through the 208 planning process. STATUS/NEEDS Status; Inventories and other data in various stage of completion. DCCA in cooperatio th affec ed VI agencies Status; Ongoing program focus on toxics. Needs; Program focus on toxics. RESPON- SIBLE AGENCY TIMING FY-80-85 FY-80 FY-80 FY-80-85 COST AND SOURCE ASSOCIATED WQM PROBLEM(S) funds will be drawn from 105/106/ SDWA/RCRA Interface air and water sampling and monitoring program operation requires an integrated approach to the problem. ------- STRATEGY/ACTIVITIES STATUS/NEEDS • Solid Waste: Hazard- ous waste manage- ment pursuant to Section 3000 of RCRP • Water Supply: Pri- mary 'drinking water standards. c~. Assure the capability for toxics monitoring where needed, either by VI agency or through contract or interagency agreement as appropriate. d. Assure coordinated enforcement of toxic substance controls. e. Develop and implement a mechanism to assure multi-media review and coordinated toxic sub- stances, control action with respect to new sources, and growth- related, environ- mental situations. f. Develop and implement mechanism for coordin- ated response to health emergencies and situations involving imminent substantial endangerment to health or environment. Laboratory capability non- existant for toxics in the Virgin Islands Status; Ongoing Needs; Assure multi-media coordination of enforcement "action. Status; Various activities performed on a media specific basis. 'Needs: Mechanism for inte- grated" coordination of toxic substances control activities required. Although.the VI government has an emergency response program, there is a need to assure integration of environmental programs identified in this Agreement. RESPON- SIBLE 'AGENCY DCCA/EPA TIMING COST AND SOURCE ASSOCIATED WQM PROBLEV.(S) FY-80 appropri- ate VI agencies DCCA in. coopera- tion with VI agen- cies; EPA FY-80-85 FY-80 FY-80 $3,8QO 106 ------- STRATEGY/ACTIVITIES A. (continued) 2. Respond to health emergencies and situations involving imminent sub- stantial endangerment to health or environment. Status; Ongoing STATUS/NEEDS Needs: Response as needed in coordinated fashion. RESPON- SIBLE AGENCY DCCA in coopera- tion with affected VI a'gencies; EPA TIMING COST AND SOURCE ASSOCIATED WQM PROBLEMS) FY-80-85 VI, 105, 106, RCRA SOWA, as appropri- ate. ------- 11. Water Quality Standards Water quality standards are necessary to establish enforceable water quality goals and to define the physical, chemical and biological conditions necessary to achieve those goals. The Clean Water Act requires the states to review water quality standards every three years. The Virgin Islands last established water quality standards in July 1973. In order to ensure that currently high water quality is maintained in its coastal waters, and to comply with Federal Legislative requirements, the Virgin Islands' water quality standards must be reviewed during FY '80. Key issues in this review should include protection of subtropical coastal waters and coral reefs, and consideration of water quality criteria for toxic substances. In order to ensure the Virgin Islands' limited groundwater resources are maintained and enhanced to a maximum practicable extent for use as a supplemental source of water supply, a groundwater management program, which includes groundwater quality standards, must be developed. Groundwater quality criteria should consider background quality. Groundwater quality standards should also consider groundwater usage practices consistent with the management program. A long-range management program is essential for preservation of the shore- building mangrove swamp ecosystems, and coastal lagoons, wetlands and grassbeds. While water quality standards eventually should have a place in such a program, there is currently a lack of reliable information on appropriate water quality criteria. Coastal zone and land use management appear to be more promising than water quality standards as mechanisms for providing the needed protection at this time. -63- ------- To enable the water quality program to provide effective support for water quality management, the following activities will be pursued: • Revise water quality standards to ensure protection of recreational and aquatic life value of the coastal water resource. • Develop groundwater quality standards for adoption in accordance with groundwater management program to ensure protection of groundwater resources for supplementary water supply. Appropriate revision of water quality standards and adoption of groundwater standards will provide the essential background and goals for water quality management in the Virgin Islands. -64- ------- STRATEGY/ACTIVITIES STATUS/NEEDS RESPON- SIBLE AGENCY TIMING COST AND SOURCE ASSOCIATED \VQ'.: PROBLEMS) A.. Ensure protection of recreational and aquatic life value of the coastal water resource. 1. Revise Water Quality Stand- ards - Solicit all available in- formation on water quality requirements for coral reef protection and sub- tropical coastal watersj and grass beds. - Assess exiting informatior for applicability to the environmental and water quality characteristics of the VI and identify 'data gaps. - Develop water quality cri- teria consistent with the assessment findings and recommendations, including water quality criteria reflecting natural back- ground levels where avail- able criteria documentaticti is inadequate. - Prepare revised water quality standards proposec for public hearing, hold hearing and adopt revised standards. Current standards adequately cover traditional polluting substances. The coastal water standards need to be revised to include relevant toxic substances.and to provide more speci fie protection for sub-tropical con reefs. a. This might be done by con- tract depending upon results of an information scan. b. Same information is already available from Puerto Rico and Florida research, espe- cially for solids and tur- bidity. Federal water quality criterijDCCA/EPA for coastal waters are scarce Recommended heavy metals criteria might be inappropria for VI, and natural backgroun 1 levels might be more realist1 Toxic organics criteria shoul be adopted as recommended by EPA. ' d. Clean Water Act requires hearing be held as soon as possible^ DCCA /EPA Library 9/79 10/79 11/79 12/79 $20,000 106 Municipal Discharges Industrial Discharges Urban Runoff Stormwater Runoff Oredging Activities Residual Waste This figure will cover Water Quality Standards strategies A.B.C. ------- STRATEGY/ACTIVITIES STATUS/NEEDS RESPON- SIBLE AGENCY TIMING COST AND SOURCE ASSOCIATE: PROBLEMS) ON EL Ensure protection of groundwater resources. 1. Adopt groundwater quality standards. - Amass all available VI groundwater quantity and quality data. - Assess and compare these data with the IPDWS and with water supply criteri recommendations of EPA and the National Academy . of Sciences. - . Develop groundwater quali criteria reflecting this • assessment. - Prepare groundwater quali standards for proposal" at public hearing.. This strategy should be part of a ' broader strategy for developing a comprehensive groundwater management program to ensure effective usage of this resource and integrated manage- ment of all activities affecting groundwater quantity and quality. a. Significant data is available from USGS, from the St. Croix Recharge Study and from EPA. Other Sources should be ex- plored. b. Inorganic substances in VI groundwaters may exceed recommended criteria. Re- commendations for organic toxicants should be adhered to. y c. Natural background levels of various inorganic toxics may exceed criteria. d. A balance must be struck between allowable concentra- tions resulting from natural conditions, conditions result- ing from recharge enhancement practices and achievable ef- fluent quality. If blending of rainwater with groundwater will ultimately be necessary to achieve IPDUS, this should be considered in standards development. DCCA 208 (Also see °ublic Water Supply dis- cussion and tables) Land Application 'Subsurface Disposal Residual i-iaste Rural Waste Irrigation Practices Water Supply DCCA./USGS 12/79 DCCA 2/80 DCCA/EPA DCCA 6/80 ------- STRATEGY/ACTIVITIES STATUS/NEEDS RESPON- SIBLE AGENCY TIMING COST AND SOURCE J ASSOCIATED V.'C.V. PROBLEMS) C. Encourage and ensure the protec- tion of the mangrove swamps and coastal lagoons. 1 . Water quality standards shou be considered to play a real, but minor role in this strategy. This strategy should be considered part of land use management at this ti me. DCCA "2Q& ------- 12. Air Abatement Planning In 1971, the Virgin Islands Department of Health (predecessor to the Virgin Islands Department of Conservation and Cultural Affairs (DCCA) prepared a plan for attainment and maintenance of national ambient air quality standards for six criteria pollutants: total suspended particulates, sulfur dioxide, nitrogen dioxide, hydrocarbons, ozone and carbon monioxide. As a result of implementation of this plan, improvements in the ambient air quality have been achieved to the extent that now the levels are generally meeting Federal standards. However, continued attention will be necessary to assure continued effectiveness to provide for maintenance of the progress made to date. In addition, the abatement planning program element must provide for recognition, assessment and response to new emerging issues, including Federal promulgation of new or revised ambient air quality standards. The activities developed to respond to these needs are: • DCCA will continue to participate in A-95 review process, through island wide project review and sign off. EPA will also utilize the A-95 review mechanism to assure comprehensive Federal coordination. • DCCA will provide input to the VI Planning Office for the development of a comprehensive growth management plan. -68- ------- STRATEGY/ACTIVITIES A. Ensure coordination of all air- related programs. 1. DCCA will continue to partici- pate in A-95 revtew process, through island wide project review and signoff. EPA will also ' utilize the A-95 review mechanism to assure comprehensive Federal coordination. 2. The effectiveness and efficien cy of oversight/advisory boards will be improved by assuring common representation on present!) instituted boards &wil.l be reviewec and modified accordingly. B. Ensure comprehensiveness of EPA- approved .implementation plan. 1. DCCA will provide input to the •VI Planning Office for the develof ment .of a comprehensive growth management plan. . . 2. DCCA will perform an annual assessment of the implementation plan to ensure that it provides effective mechanisms to address local concerns(e.g. growth incre ments, efficient control require* ments representing"state of the art")as well as to correct any deficiencies reflected by EPA di approval of SIP components. 3. DCCA will undertake revision the SIP to address new standards promulgated by EPA. EPA will pro vide technical assistance and expertise as necessary. STATUS/NEEDS RESPON- SIBLE AGENCY DCCA is involved in coordinating activities with other territory agencies, but the process must be improved. ' • . DCCA presently actively reviews all proposals and projects for complian with the laws and regulations. There is no comprehensive growth management plan which exists for the Virgin Islands. If is the responsibility of the Virgin Island Planning Offi'ce to develop'such a plan. Portions of the implementation plan are currently hot approved. EPA is expectedrtto promulgate a num ber of new ambient air quality standards or standard revisions wit i in the next five years. It is the 'responsibility of DCCA to respond t these plan revision needs. DCCA DCCA TIMING COST AND SOURCE continuing continuing $36,607 105 ASSOCIATED WQM PROBLEVi(S) ------- 13. New Source Review DCCA is responsible for reviewing and approving applications for construction of new sources and/or modifications to existing sources which will emit air pollutants as specified in Public Law 95-96 (Clean Air Act as amended August 7, 1977). The DCCA has promulgated regulations for the Virgin Islands pertaining to the review of new sources in ss 206-20 through 206-31 of the Virgin Islands Code for Air Quality Control. Limited authority to enforce National Emission Standards for Hazardous Air Pollutants (NESHAPS) and New Source Performance Standards (NSPS) regulations in conjunction with New Source Review (NSR) activities has been delegated to the DCCA. To date DCCA has not promulgated Prevention of Significant Air Quality Deterioration (PSD) regulations and is presently forwarding applications for PSD affected projects to EPA for review. DCCA performs an engineering review and analysis of all permit applications with the exception of those programs not delegated and those requiring an impact analysis. When necessary, DCCA utilized EPA modeling expertise for permit evaluation since these modelling capabilities do not exist in the Virgin Islands. The delegation of PSD and those NSPS and NESHAPS not previously delegated will be an important first step in assuming complete program responsibility. The DCCA will implement a number of activities in the area of New Source Review. • The DCCA will continue to move toward assuming full responsibility for processing of permit applications. • The DCCA will continue to develop a more comprehensive program in the identification of new sources and will also continue to work more closely with other VI Government agencies to exchange information on prospective new business ventures in the VI. • The DCCA will ensure implementation of new programs as required by law and will evaluate effectiveness of on-going programs on an annual basis. In addition, DCCA will discuss with EPA the need for changes, alterations, delegations or additions. -70- ------- STRATEGY/ACTIVITIES STATUS/NEEDS RESPON- SIBLE AGENCY TIMING COST AND SOURCE A. The DCCA will continue to move toward assuming full responsibility for the processing of permit applica^ tions. 1 . Responsible personnel involved in permit activities will partici- pate in training courses, workshops, etc.. 2. EPA will provide financial and technical support, as necessary, to ensure activity 1. B. The DCCA will continue to develo a more comprehensive program in the identification of new sources. 1. In an effort to identify those sources which are operating without a valid permit, DCCA inspectors will during source inspections ensure that source owners or operators comply with §206-20(C) which require: that the source either display a yal id permit (or facsimile) on the poll-- •jtant emitting device or have it read- ily available for viewing. EPA'in- I specters will similarly adhere to fhis inspection procedure. 2. The DCCA will continue to work more closely with other VI governmen agencies to exchange information on prospective new business ventures in the VI. - The DCCA in conjunction with the other agencies, will evaluate and recommend a media for disseminating information regarding new business and will take the initiative in implementing the procedures. Currently the DCCA administers this program and forwards permits to EPA fop information purposes. Training opportunities will enable DCCA personnel to conduct detailed permit reviews. At the present time the practice of DCCA looking for valid Certificates to Operate 1s not strictly adhered to and there is a need to stream- line 'update of permits. Although the present level of industrial growth 1s minimal 1t 1s important that lines of communicatl are established between VI agencies responsible for attracting new in- dustries and issuing permits. DCCA DCCA/ EPA FY 80 FY 80 $ 27,127 105 DCCA •ongoing DCCA and other agenc FY 80 es ------- STRATEGY/ACTIVITIES STATUS/NEEDS RESPON- SIBLE AGENCY TIMING COST AND SOURCE - The lead agency will be identi- fied and should be commerce orientet but all agencies which issue permit: or analagous construction approvals should have input and be part of the inter-agency mailing list. 3. DCCA will continue to contact the Division of Trade and Industry of the Virgin Islands Department of Commerce and initiate inter-agency procedures for informing new in- dustry of environmental permit requirements as part of the Department of Commerce industrial licensing process. 4. EPA will continue to provide support and encouragement, to the extent possible, to assist the DCCA in establishing effective inter-agency communication procedun with regard to the Virgin Islands. industrial development. C. DCCA will ensure implementation of new programs, as required by law and will evaluate effectiveness of on-going programs. 1. •DCCA will actively undertake the steps necessary to prepare and submit a revision to the Virgin Islands' SIP to implement the PSD program as set forth at 40 CFR §51.24. EPA will work closely in an advisory capacity to assist in this effort, and will provide computer modeling support and meterorlogical expertise for the required air quality reviews once the DCCA has the necessary regula- tory authority to implement a PSD program. The present review procedures only assess the effectiveness of the air program in terms of compliance with grant requirements. DCCA/EPA FY 80 ------- STRATEGY/ACTIVITIES STATUS/NEEDS 2. The OCCA will assess the ef- fectiveness of the strategies in the above areas on an annual basis,| and will discuss with EPA tlie need for changes, alterations, delegatio or additions. 3-. DCCA will undertake request for full delegation of NSPS and NESHAPS as resources allow. RESPON- SIBLE AGENCY TIMING COST AND SOURCE ------- 14. Air Enforcement The Clean Air Act requires each State (as defined in the Act) to adopt a plan to be Used by the State as a means of attaining national ambient standards of air quality to ensure that both the public health and welfare are protected. The Virgin Islands Government, through its Department of Conservation and Cultural Affairs (DCCA), has the primary responsibility for assuring compliance with the Virgin Islands State Implementation Plan (SIP). Compliance determinations are made through inspections, stack tests, field surveillance activities, and review of special reports submitted to DCCA by a number of major air pollution sources. Violations of the regulations are discovered and documented in the course of field activities, inspections, and review of the special reports noted above. Notices of Violation (NOV) are issued to violators and appropriate enforcement action is taken. The DCCA has, for the most part, aggressively pursued violations and achieved satisfactory results. However, EPA and DCCA agree that there are two major areas of enforcement concerns which can be resolved through the implementation of the following activities: • DCCA will revise legislation and techniques to ensure consistency with Federal regulations. • DCCA will ensure the protection of the health and welfare of VI residents through enforcement activities. Close coordination with other VI Agencies will be a prime focus. Enforcement responsibilities will also cover federal facilities. -74- ------- STRATEGY/ACTIVITIES i vi A . DCCA will revise legislation and techniques to ensure consis- tency with Federal regulations. 1 . DCCA will revise §§204-22 and 204-28 such that EPA Method 9 pro- cedures are accepted as the approv- ed method for measuring the opacity of visible emissions to determine compliance with these regulations. EPA will provide legal/technical guidance as required by DCCA. 2 . DCCA will in the future use forms for recording visual opacity measurements performed by a certi- fied smoke observer which comply with EPA requirements. -DCCA'has already adopted the form .to meet these needs. B. DCCA will ensure the protection of the health and welfare of the VI citizens through enforcement activities. i. DCCA will continue to initi- ate discussion with the VI DPW, based on documented open burning violations, and reach an agreement with DPV/ to implement the necessary steps to eliminate open burning at the landfills as a high priority item. Long range planning efforts for solid waste disposal will be initiated in conjunction with the EPA. Office of Solid Waste Manage- ment and other appropriate VI agen- cies. STATUS/NEEDS DCCA's opacity regulations are out- dated and do not reflect the cur- rent approved method of documenting compliance (EPA Method 9) The DPW in the past has not been complying with the DCCA request to eliminate open burning at the VI sanitary landfills. A long range solid waste management program is being developed. KhbPON- SIBLE AGENCY DCCA DCCA DCCA/DPW/ EPA/VI Dept of Energy TIMING FY '80 FY '80 FY '80 COST AND SOURCE ASSOCIATED \VQ.\5 PROBLE.V.(S) ------- RESPON- SIBLE AGENCY TIMING COST AND SOURCE ASSOCIATED WQM PROBLEM(S) STRATEGY/ACTIVITIES a. Develop a program plan as soor possible, including but. not limit* to: Standard & Sanitary Operationa Procedures. x b. Any and all other actions necessary to correct all present!} existing violations of Title 12 V.I.C. Chapter 9 and regulations promulgated pursuant thereto. 2. DPW will investigated and imple ment short and long term actions to rectify the incinerator/landfill problems on St. John. a. DPW will take immediate short term corrective action (see Residuals Table Strategy A.2) b. DPW will, evaluate potential long term disposal sites, rec- •ommend action and begin opera- tion. c. DPW will review and Implement where appropriate, corrective actions recommended by DCCA. 3. DCCA will continue to conduct surveillance of mobile sources such as buses and trucks, as well as smaller sources such as hotels and other business establishments, as 1' deems necessary. They will also initiate enforcement action as deem* appropriate. • . • STATUS/NEEDS ------- STRATEGY/ACTIVITIES STATUS/NEEDS RESPON- SIBLE AGENCY TIMING COST AND SOURCE ASSOCIATED PRODLEM(S) 4. DCCA will continue to enforce regulations pertaining to. smoke opacity from ships. 5. DCCA's responsibilities for enforcement will include all federal facilities. . ' 6. DCCA will continue enforcement of VI codes pertaining to operation and maintenance of landfills and incinerator in the VI. The DCCA is enforcing opacity standards against ships and other smal-1 sources, primarily on St. Thomas. This activity should be- come part of the VI work plan for FY'80.. DCCA FY'80 ------- 15. Air Monitoring The ambient air and source monitoring programs of the Virgin Islands were established by authority of Section 109 of the Clean Act (CAA) as amended 1970 and 1977 - which provides for ambient air quality monitoring programs to determine whether the National Ambient Air Quality Standards (NAAQS) are being attained and maintained. State. Air, Monitoring, Working Group (SAMWG) requirements establish a uniform basis, nationwide, for determining the attainment and maintenance of the NAAQS. This program also entails the upgrading of all State monitoring programs so that the ambient data available to EPA will be valid and representative of the area where they were obtained. One of the ambient air quality studies currently in progress is a joint program between DCCA/EPA and the Hess Oil and Martin Marietta Alumina (MMA) companies on St. Croix. The purpose of this study is twofold: to establish the ambient total suspended particulate level for the South Shore Industrial Complex portion of the St. Croix Air Quality Control Region (AQCR) and to gather sufficient SO air quality data to provide Hess and MM A with a basis for a request for a variance to burn fuels with a higher sulphur content than presently allowed. In addition to its participation in the joint air monitoring study the DCCA is currently conducting the requisite sampling program and the regulatory requirements are being met. There are two activities which will be pursued by the DCCA to improve their air monitoring program: • Develop ambient air monitoring capabilities, compliance with SAMWG regulations, verification of compliance with emission standards, evaluation of new construction, and special sampling. • Develop program to ensure reliability of data, and optimum program operation through quality assurance program development. -78- ------- STRATEGY/ACTIVITIES STATUS/NEEDS RESPON- SIBLE AGENCY TIMING COST AND SOURCE ASSOCIATED \VQ.M ?RO31E.\!(£) A . To ensure the protection of the health and welfare of the citizens of the Virgin Islands. 1 . The DCCA will continue tc develop its ambient air monitoring capabilities. 2. DCCA will continue to comply with the State Air Monitoring Working Group (SAMWG) regulations at 40 CFR 58. 3 . DCCA will continue to review the SAMWG program to determine adequacy. 4 . DCCA will make applications in its 105. grant request for equip- ment and training needed to imple- ment SAMWG requirements. 5. Review (2) as needed. 6- DCCA will review and evaluate the effectiveness of the program on an annual basis. 7. DCCA will follow-up if any deficiencies or changes are re- quired. 8. EPA will provide funding and support as needed to implement and operate the SAMWG program. B. To ensure reliability of data 1. DCCA will witness the stack tests and review test results for compliance with EPA test methods and the specific test protocol. 2. EPA will provide funding for necessary training and equipment. Develop a monitoring program consistent with EPA regulations and the special needs of the Virgin Islands. Verification of compliance with emission standards is an important enforcement activity. Data reli- ability is essential. DCCA/EPA FY 80 DCCA/EPA FY 80 S63.47b 105 ------- STRATEGY/ACTIVITIES STATUS/NEEDS RESPON- SIBLE AGENCY TIMING COST AND SOURCE ASSOCIATED V/Q.V PROBLEM(S) oo o 3 . EPA will provide funds for train ing and equipment to DCCA for developing this capability. C . Ensure optimum program operation 1 . DCCA will continue to participate in the ambient sampling study currently in progress in the South Shore area of St. Croix. a, EPA will provide funds and support as necessary. 2 . DCCA will develop a quality assurance program to include: a . Appoint and train a quality assurance (Q.A.) director. b . Issue a Q.A. policy statement. c . Develop and implement a source monitoring Q.A. program. d . Ensure that Q.A. requirements are imposed on all grants, contracts, and monitoring data generated. e . Maintain the on-going activities of the Q.A. program EPA will provide funds to support this activity. There is a need to conduct ambient air quality studies to monitor the impact of new construction to ensure that the NAAQS will not be violated. The credibility of all data, whether acquired thru source or ambient sampling, is based on the quality of the data. To ensure that the data and sampling procedures is of high quality, the DCCA will formalize and expand the present quality assurance (QA) program to cover all aspects of air data collection. This will Include appointing and training a Q.A. director, issuing.a Q.A. policy statement, dev.elop and implement a source monitoring Q.A. program, • ensure that Q.A.•requirements are imposed on all grants, contracts and monitoring data generated under regulation, and maintain the on- going activities of the Q.A. program DCCA/EPA FY 30 DCCA/EPA FY 81 ------- 16. Noise The EPA Region II Office of Noise Programs has provided technical assistance to the Virgin Islands Department of Conservation and Cultural Affairs, primarily in the form of noise data. Noise level measurements were performed in 1976 at various sites on St. Thomas and St. Croix. Noise sources of significance in the Virgin Islands include: motor vehicles, aircraft, industrial sources and outdoor parties. There is a particular need for noise to be considered in land use planning on St. Croix, due to the existence of large undeveloped tracts of land in the vicinities of Alexander Hamilton Airport and the existing industries. EPA encourages the Virgin Islands to develop and implement a noise control program. However, limited funding is available for these activities under the Quiet Communities Act of 1978. Although the DCCA has not expressed interest in the level of funding available, it has indicated the intention of proceeding with a noise control program. In order to assure that future development of the VI progresses in a manner consistent with the protection of public health and welfare, it is essential that the quality of the noise environment be considered in the earliest stages of the planning process. The following criteria shall be considered prior to EPA funding of any project which would be likely to result in residential or other noise sensitive development. Ldn 55 Minimal Noise exposure 55 Ldn 65 Moderate noise exposure Efforts to minimize noise exposure should be addressed in planning process. 65 Ldn 70 Significant noise exposure - Development is discouraged. Shall proceed only with approval of Regional Administrator Ldn 70 Severe Noise Exposure - Incompatable with noise sensitive development. -81- ------- 17. Radiation The Virgin Islands currently operates a standby Environmental Radiation Ambient Monitoring System (ERAMS) Station for the Environmental Protection Agency. The station utilizes a high volume air sample to take radioactive particulate samples during radiation incidents, emergencies, and tests. The Natural Resources Management Group in the Department of Conservation and Cultural Affairs (DCCA) are the designated operators. The DCCA is currently considering proposed radiation standards. These will probably emphasize x-ray exposure control (a function of FDA). However, we strongly suggest that if comprehensive radiation standards are adopted by the DCCA, they include general population exposure standards similar to those contained in 10CFR 20. Radiation standard setting, should it occur, would bridge the responsibilities of several Federal Agencies. To this end the Interagency Radiological Liaison Group should probably convene its Radiation task group to aid the Virgin Islands in said standard setting activities. -82- ------- 18. Omnibus Territories Act The Omnibus Territories Act (P.L. 95-134) was passed on October 15, 1977. Title V of the Act pertains to grants made to insular areas which includes Virgin Islands. The purpose of the act is to minimize the burden caused by separate application and report procedures for each categorical grant program. In order to achieve this goal, the act requires agencies making grants to insular areas to: Provide for consolidation of any grants with a single application and report; Provide Federal funds equal to the amount the grantee would receive if programs were not consolidated. The act also authorizes the grantor agency to: Waive any requirement for matching funds even though they were required by some other law. Waive a requirement of submitting an application or report in writing. In addition, the act requires the grantee to: Expend funds for the purpose and programs of the grants being consolidated; Maintain adequate procedures for accounting, auditing, evaluation and reviewing any program or activity being consolidated. -83- ------- EPA Implementation Guidance Authority exists for consolidated grants in Part 30 of EPA grant regulations. By memorandums of June 22, 1978 and November 27, 1978, EPA Administrator authorized the Regional Administrators to waive matching requirements for construction grants for the V.I. This waiver can only apply to construction grants awarded after October 15, 1977. By memorandum of January 18, 1979 the EPA Administrator delegated the Regional Administrators the authority to reprogram up to 20 percent of the annual allotments for program grants that are combined. This process must be in response to unique environmental priorities. The memorandum also provides for a waiver of statutory or regulatory requirements, providing that the V.I. maintain a base level of support. Program Strategies The program narrative for the FY 1980 grant applications for the air pollution control program under Section 105, PL -91-604, the water pollution control program under Sections 106 and 208, PL 92-500, and the public water system supervision program under Section 1443, PL 93-523 are contained in the VI/EPA Agreement. In subsequant years it is our intent to continue this practice whereby the narrative contained in the VI/EPA Agreement will constitute the program descriptions for federal program grant applications. By July 1, 1980, V.I. will apply for a consolidated grant for fiscal year 1981 which combines at least the air pollution control program under Section 105 PL 91-604, the water pollution control program under Sections 106 and 208, PL 92-500, and the public water system supervision program under Section 1443, PL 93-523. EPA will issue guidance for preparation of the FY 1981 consolicated grant during the mid-year review of the 1980 programs. -84- ------- The baseline for the consolidated grant shall be the total of the recurrent of non-Federal expenditures for fiscal year 1978 for those programs being consolidated. The baseline will be reassessed each year during the mid-year review for the following grant year. All statutory/regulatory requirements for matching share other than the baseline requirements cited above are hereby waived for non-construction grants. The V.I. is authorized to reprogram up to 20 percent of their annual allotment for program grants that are combined to meet unique environmental priorities. The transfer shall be identified and justified in the application. In addition, payments, technical and financial reports for those programs combined will be presented in a single report. At the mid-year review, the V.I. and EPA will evaluate effectiveness and potential for future expansion and determine what efficiencies have resulted. -85- ------- FRC STRATEGY FOR WATER SUPPLY ASSISTANCE TO THE VIRGIN ISLANDS A critical water supply quantity and quality problem currently exists in the U.S. Virgin Islands. At least seven federal agencies and four territorial departments, with fragmented responsibilities and authorities, are involved in planning and implementing solutions to the problem. Therefore the Federal Regional Council has undertaken the task of developing a strategy with two objectives. (1) 'To outline a coordinated program of federal assistance which has been or can be made available to the Virgin Islands govern- ment to facilitate the development and implementation of a comprehensive water resources management plan for the Islands. Implementation, in this context, includes short term measures to alleviate the current water supply crisis while concurrently developing the plan. (2) To recommend steps which the Virgin Islands government can take to ensure that the available federal assistance is granted and is efficiently utilized to solve the Island's1 water supply problems. This strategy is designed to help overcome the technical, management, financial, and institutional problems which contribute to the overall water supply quantity and quality problems of the Virgin Islands. Examples of existing problems include the following: - Lack of a reliable, safe and healthful supply of drinking water. Severe disrepair of water supply production and distribution facilities. Lack of coordinated federal programs. Lack of a coordinated Virgin Islands response to federal programs. Loss of available federal grant funds due to inaction on the part of the Virgin Islands government. In order to present the FRC strategy for dealing with these and other water supply problems, Figure 1 has been developed to outline the steps involved in developing and implementing a comprehensive water resources management plan for the Virgin Islands. The steps outlined in Figure 1 provide the framework for Table 1. Table 1 outlines ongoing and future required planning and implementation activities and summarizes federal assistance which has been or can be made available to complete the activities. Table 2, summarizes those federal funds which the Virgin Islands government can use to meet planning and implementation funding needs. The right hand column of Table 1 highlights actions which are required of the federal and Virgin Islands governments to ensure best use of the available federal assistance. As shown in Table 1, many of the required planning and implementation activities are presently underway. Notwithstanding, a commitment is required by the involved federal and Virgin Islands agencies to coordinate these ongoing programs, to complete the outstanding actions for short term implementation and to prepare the comprehensive water resources plan. The public is to be intimately involved in all planning and implementation activities. Key recommended actions include the following: Virgin Islands Government o The Governor in consultation with the FRC will select a VI/FRC Water Resources Coordinator (Coordinator) who will have overall responsibility to identify, coordinate, and manage the securing of federal resources (financial and technical support) available to the responsible Virgin Islands agencies for water resources management in the Virgin Islands. A-l ------- - The Coordinator will report directly to the Governor. The Coordinator will work in close cooperation with the existing VI Water Resources Commission, DCCA, and the other involved VI agencies. - The Coordinator will have the additional functions specified in Table 1. The Coordinator will take the lead in identifying and obtaining available federal assistance to conduct those activities required to insure the development of a comprehensive plan and the imple- mentation of short term measures required to alleviate the current water supply crisis. The following activities identified in Table 1 may require additional federal assistance: o Rehabilitation of the water distribution and treatment systems. o Development of an equitable allocation system for imported water. o An educational program for the operation and main- tenance of private cisterns. o Staff support for the Coordinator. o Development of selected components of the comprehensive water resources management plan. - Manufacturing component including a training program for operation and maintenance - Technical groundwater component Cistern/catchment component Conservation component - Water distribution component - Importation alternatives. The Governor will designate DCCA as the VI agency responsible for developing the comprehensive water resources -management plan for the Virgin Islands. DCCA will submit a unified workplan to EPA and WRC describing how it will integrate the individual plan components into a comprehen- sive water resources management plan. A specific breakdown of EPA 208 and WRC funded elements will be included in the unified workplan submission. DCCA, WAPA, DPW, VIPO, VIHA, and the VI Water Resources Commission will work cooperatively to develop and implement the comprehensive plan and short term measures, as necessary, to alleviate the water supply crisis. The Coordinator will ensure that maximum use is made of the A-95 process to guarantee that projects submitted by Virgin Islands applicants for federal funds are reviewed, by the appropriate Virgin Islands water resources agencies, for consistency with this strategy, and the developing water resources plan for the Islands. A-2 ------- Federal Government The FRC will make an IPA available to the V.I government to act as the Coordinator, if requested. The FRC will work with the Coordinator to ensure that the available funds summarized in Table 2, as well as additional .available funds, are granted to the appropriate Virgin Islands agencies to perform the key required activities outlined in this strategy. All federal agencies signatory to this agreement agree that the delivery of financial and technical water resources assistance to the VI government will be consistent with this agreement. Each individual agency will be responsible for ensuring this consistency. At the discretion of each agency it may submit a project or grant proposal to appropriate members of the existing FRC VI Water Supply Task Force who will ensure a review is made for consistency and/or technical merit when requested. All federal agencies signatory to this agreement will ensure compliance with all pertinent federal laws and Presidential Executive Orders, such as the National Environmental Policy Act and Executive Order 11988 on Flood Plain Management. All federal water resources related projects and assistance to the Virgin Islands will be coordinated through the FRC. In order to ensure effective coordination: - All projects and grant proposals will be submitted to the FRC for the use of'the Task Force. - The role of the Task Force will be one of oversight. - The Task Force will technically audit projects and grant proposals, as appropriate, in order to ensure that the FRC strategy is working effectively. The Task Force will be responsible for periodically updating the FRC strategy for water supply assistance to the Virgin Islands. The Task Force will meet periodically with appropriate VI water resources agencies to obtain their technical input. A-3 ------- Needs Supply Alternatives (Existing and Projected) Distribution and Treatment Systems 10/01/79 Existing and Future demands Quality - Groundwater - Manufacture - Cisterns/Catchments - Wastewater Reclamation - Importation - Conservation - Existing Systems - Mew Systems FIGURE 1 Technical Plan Organizational Framework and Plan VIRGIN ISLANDS COMPREHENSIVE WATER RESOURCES MANAGEMENT PLAN Long Term Plan Implementation - Institutional - Management - Financial During the period 10/01/79-09/30/81 the VI government will develop a comprehensive plan and concurrently implement short term measures to alleviate the current water sjp.ply crisis. Public participation in plan review Selection of technical plan alternatives Selection of organizational framework Presentation of recommended legislative changes to VI legislature Identification and implementation of VI agency priorities 09/30/81, ------- TABLE 1 ISSUE AGENCIES ACTIVITY PROJECT TIME FRAME PROJECT FUNDING COMMENTS/NEEDS REQUIRED ACTIONS A. Needs 1. Existing and Future Demand a) DOC/DCCA/ VIPO b) COE c) EPA/DCCA > d) WRC/DCCA Coastal Zone Management Plan for the Virgin Islands. Plan Approv- ed June 1979 Contract to Priede-Sedgewick to compile all past litera- ture on all water resources: assessment of present and .future demands and sources based solely on existing information. Development of the demand component of the Comprehen- sive Water Resources Management Plan(CWRMP) for the Virgin Islands. Updating of the demand component of the Comprehensive Plan. FY-79 $25,000 FY-80/ 81 FY-81 and beyond EPA 208 WRC The CZM plan which was completed in May 1979 is the only comprehensive planning guide to land use in the Virgin Islands. The population and land use projections contained in the plan, updated as necessary, will pro- vide the demographic basis for project- ing water supply needs. The Virgin Islands Planning Office is charged with the responsibility for developing an Islandwide land use plan. There is a need to examine immigration patterns in the V.I. in the context of water resource needs. This project should be completed by Sept. 1979. It will not offer new data, just new assessment of data gathered over past several years. There is a need for DCCA to evaluate the CZM plan, the COE Priede-Sedgewick report and other Water Quality ac- tivities to determine further required work to develop an accurate estimate of water resource needs. There is a need for future updating of the demand component as population, land use/ conservation and other factors change. The Coordinator will seek fund- ing to update population pro- jections as necessary. See Table 2 for sources of funding DCCA to update projections. The land use plan developed by VIPO will be integrated into the projections for water supply needs prepared by DCCA. DCCA will incorporate in its WRC/ 208 workplan, the activities that will be undertaken to complete the demand component of the CWRMP prior to re- ceiving EPA authorization to expend the funds. DCCA to include this activity in a future grant proposal to WRC, as part of WRC/208 workplan. ------- TABLE 1 ISSUE AGENCIES ACTIVITY PROJECT TIME FRAME PROJECT FUNDING COMMENTS/NEEDS REQUIRED ACTIONS a) EPA B. Supply Alternatives 1. Groundwater a) USGS b) USGS C) USGS St. Croix-Ground water assessment-quality and quantity. St. Thomas-surface water and groundwater assess- ment; qua!ity and, quantity-(stream gaging, precipitation records, and monitoring new and existing wells). Compilation of data re- lated to water use (all islands) and source. FY-76- 79 FY-79- 81 FY-79 - $12,000 FY-79 $60,000 FY-79- 80 FY-79 $22,000 The quality of potable water required is specified in the federal and Virgin Islands drinking water standards. Last year of a 3 year study to update report published by USGS in 19.71 (data collected 1967). No new results are expected; primarily to substantiate 1971 report by comparing present out- flows with past yields. First of a three year study to es- blish the sustained yield of river basins on St. Thomas. FY-80 funds are $80,000. USGS match 50% with college of the Virgin Islands (25%) and VI Department of Public Works (25%). Chlorides, dissolved solids, hardness tests can be done at USGS lab. in San Juan, P.R. Establishment of a central data bank to reduce overlap in gathering water data in the V.I. ------- TABLE 1 ISSUE AGENCIES ACTIVITY PROJECT TIME FRAXE PROJECT FUNDING COMMENTS/NEEDS REQUIRED ACTIONS d) e) HUD EPA/ USGS/ DCCA Nitrate removal system at Tutu Public Housing. Development of the groundwate management component of a Water Resources Management Plan for the Virgin Islands. FY-79 FY-80/ 81 $200,000 USGS National Allocation EPA 208 f) g) h) i) HUD HUD HUD DOC/ DPW Well drilling at Donoe and Bovoni Public Housing. Bournefield Potable Water (Well drilling) Mon Bijoi Cruz Bay Turpentine Run FY-79 FY-80 FY-80 $100,000 $250,000 See C.4. (Table 1) $32,000 FY-78 discretionary CDBG funds for pilot project to remove nitrates from groundwater so that groundwater could be used for flushing, bathing, etc... DCCA, in consultation with EPA and USGS will evaluate existing informatior to determine further required technical information, determine groundwater management planning needs, and develop a groundwater management plan. FY-78 Entitlement CDBG funds. 50% complete to date. Work is Coordinator to take lead in identifying and applying for available USCG funds to meet technical needs. DCCA will submit as part of the WRC/ Section 208 workplan the activities necessary to dev- elop a groundwater management plan utilizing all available information.. Technical imput from an FRC Task Force representative indicates that this project should not be completed. 'The VI applicant should reconsider completion of the project. These FY-78 funds to be transferred to other well drilling points in low income areas. Well drilling, storage, and distribution See C.4. (Table 1). Wellfield. No final report ever submitted to EDA. DPW to submit final report to EDA. ------- TABLE 1 ISSUE AGENCIES ACTIVITY PROJECT TIME FRAME PROJECT FUNDING COMMENTS/NEEDS REQUIRED ACTIONS 2.0 Manufacture 2 .1 New Desalination Plants a) WAPA Three 1.25 mgd multi- effective distillation plant^ Two for St. Thomas; one for St. Croix. FY81-82 $15.1 mil- lion bond issue b) WAPA Three 550,000 gpd multi- effective distillation plants - (IDE) St. Thomas-2; St. Croix-1. FY80-81 Government of VI bond issue to pay for purchase and installation of Israeli Desalination Engineering (IDE) plants. Sites are to be pro- vided by WAPA (old submarine base on St. Thomas). WAPA personnel will operate. St. Thomas plant I may be in production by May 1981, St. Thomas II by November 1981 and St. Croix by May 1982. These plants, originally scheduled for Iran, have been offered to the VI by IDE. WAPA will provide sites. IDE will deliver, install, operate and maintain for seven years, selling water to WAPA at $4.00/1000 gallons. WAPA will provide steam, power, and chemical at <$3.00/1000 gallons. After 7 years, ownership would transfer to WAPA. These plants could be operational by 1980. Pres- ently, work is held up due to dis- cussions in the VI Senate. WAPA to ensure inclusion of training for operators as part of IDE contract. ------- TABLE 1 ISSUE AGENCIES ACTIVITY PROJECT TIME FRAME PROJECT FU:JDI;;G COMMENTS/NEEDS REQUIRED ACTIONS c) OWRT A reverse osmosis pilot plant at Pearson Gardens Public Housing, St. Thomas. FY-79 $500,000 d) 2.2 Existing Desalination HUD Plants a) OWRT/WAPA Rehabilitation of building which xtfill house reverse osmosis plant at Pearson Gardens. Inspection and evaluation of existing desalination plants. FY-78 $75,000 b) HUD Envirogenics Desalination Plant repairs. FY 80 400,000 This plant will use a seawater well. WAPA to maintain and operate plant under OWRT direction. WAPA will provide site, chemicals, steam and power. Agreement signed July 17, 1979 (ORT, WAPA, VIHA and VI Government). This plant has a desalting capacity of 80,000 gpd. The Federal Emergency Management Agency identifies this project as being located' in an area subject to the 100 year flood. FY-78 CDBG (discretionary funds) to rehabilitate building so that it can house R-0 plant installed by OWRT. Inspections have been performed in the past but did not utilize non- destructive test techniques (NDTT). Course of action has not yet been agreed upon by OWRT and WAPA. Discussions are ongoing and should be completed by mid-August 1979. NDTT could be undertaken and complete within 30 days after that. Reprogrammed CDBG funds. OWRT to install a reverse osmosis pilot plant at Pearson Gardens and train WAPA operators. WAPA will ensure that non- destructive testing of exist- ing desalination plants will be performed by contract. ------- TABLE 1 ' ISSUE AGENCIES ACTIVITY PROJECT TIME FRAME PROJECT FUNDING COMMENTS/NEEDS REQUIRED ACTIONS 2.3 Long Term Planning for Manufacture WAPA/OWRT Select future manufacturing process(es) FY 80/81 See Table 2 3. Cisterns/Catchments b. EPA HUD DCCA Educational materials to hotels/private homeowners to improve cistern maintenan Gravity cistern at Bovoni 'Public Housing Develop cistern/catchment component of water resources management plan. ongoing FY 79 FY 80/8] SDWA $135,000 See Table 2 Evaluate alternative technologies (distillation, reverse osmosis, etc.) and select most reliable and cost effective process for future manufacturing. EPA has developed educational materials for hotels. An education program for private homeowners is not covered under the SDWA. FY 78 entitlement CDBG funds to con- struct gravity cistern which is replacing a reverse osmosis plant originally scheduled for Bovoni. Cisterns/catchments have historically played a major role in meeting the water supply needs of the Virgin Islands. Deteriorating conditions have taken the major catchments out of use. There was a 1978 offer by COE to assess conditions and potential for water catchments. A response for Gov. Luis on 7/6/78 declined offer, but indicated that cisterns if cleaned and repaired could add 12 million gallons of storage capacity. This was estimated to cost $600,000. Coordinator to take lead in identifying and applying for available funds (See Table 2) to study alternatives and select the most reliable and cost effective manufacturing process. WAPA to consult with OWRT. Coordinator to seek funds for an educational program for private cistern operation and maintenance. (See Table 2) Coordinator to take lead in identifying and applying for available funds (see Table 2) to develop cistern/catchment plan. ------- TABLE 1 ISSUE AGENCIES ACTIVITY PROJECT TIME FRAME PROJECT FUNDING COMMENTS/NEEDS REQUIRED ACTIONS 4. WasteWater Reclamatio b. HUD EPA 5. Importation VIDPW b. COE Waste Water Recycling Plant at Donoe Public Housing Project St. Croix Demonstration Plant for potable water Barging water from Puerto Rico to the V.I. FY 79 $115,000 Ongoing initiate FY 79 EPA Puerto Rico/Virgin Islands Pipeline Study FY 78-82 FY 78 Discretionary CDBG funds allocation. Construction plans are completed; bids are expected thru August 1979. Construction is expected to start Sept. 1979. Demonstration tertiary treatment plant; has added some potable water supplies through recharge. DPW pays private contractor to barge water from P.R. to V.I. US Navy loads barges in P.R. They know how much they load (app. 500,000 gallons/ 2 days) but DPW has no accounting system during disbursement. First come, first served; rates vary from $14.00-$20.00/1000 gallon. This is the second year of study- expected completion by 1982- five dam sites are being examined in Puerto Rico. Importation of water is but one option for meeting water supply demand. As part of the Comprehensive. Water Resources Manage- ment Plan for the Virgin Islands; DCCA will evaluate the various supply alternatives and recommend the ap- . propriate role for importation. Coordinator to take lead in obtaining federal funds (See Table 2) to develop an equitable allocation system for imported water. DPW to conduct study. DCCA and COE to work cooperatively in deter- mining the appropriate role for importation in the Comprehensive Water Resources Management' Plan for the Virgin Islands. ------- TABLE 1 ' ISSUE AGENCIES ACTIVITY PROJECT TIME FRAME PROJECT FUNDING COMMENTS/NEEDS REQUIRED ACTIONS 6. Conservation DCCA/EPA/ WRC Development of VI Conservat- ion Policy and Plan. FY 80/81 EFA 201, 106, 208, WRC C. Distribution/Treatment System DPW/DCCA 4. 5. 6. 7. DPW/DCCA HUD HUD HUD HUD HUD Evaluate existing distributio and treatment system and develop long range water distribution/treatment plan Short term rehabilitation of water distribution system Hannah's Rest/ Stoney Ground Mon Bijoi Water Distribution Cruz Bay Water District Lindberg Bay | Estate Strawberry FY 80/81 FY 80/81 See Table 2 See Table 2 150,000 200,000 1,112,000 234,000 j 246,000 The President and the Governor have both set water conservation as a top priority. There is a need for: o A public education program. o Examination of distribution system for leaks and cross connections. o Examination of water-pricing as a potential for water conservation o An evaluation of the utility of metering. Distribution system is operating at 30-50% of its rated capacity. Loss of supply & infiltration have led to contamination problems. VI/EPA agreement indicates need for feasibility study on dual system for potable/non- potable water. o Locate and repair leaks and stop illegal connections. o repair broken meters. o Establish new meters for unmetered FY 78 funds being used to connect housing units to island supply lines. Connecting into island system. Well drilling, pipes, storage systems. 3/4 completed. Pipeline connections to island systems Potable water lines in St. Croix. VI/FRC to identify federal funds (See Table 2) which can be used by DCCA in developing the conservation program of the Comprehensive Water Resources Management Plan. Coordinator to obtain appropriate federal funding for the develop- ment of an effective water distribution and treatment plan (See table 2 WRC.HUD-CDBG). Coordinator to obtain appropriate federal funding for short term rehabil- itation of the water distribution and treatment system (See Table 2 FmHA, EDA). ------- TABLE 1 ISSUE AGENCIES ACTIVITY PROJECT TIME FRAME PROJECT FUNDING COMMENTS/NEEDS REQUIRED ACTIONS D. Management Financial and Institutional Framework 1. Coordination of federal Governor's- assistance to the Virgin Office Islands for water resources management. I H* U} 10/79 and con- tinuing FRC-IPA WRC 1. A high level VI/FRC Water Resources Coordinator reporting directly to the Governor should be selected to coordinate and manage the grant activities between the Federal and VI Agencies. This person will work in close cooperation with the existing VI Water Resources Com- mission, DCCA & the VI legislature. o Appropriate staff will be assigned to assist the Coordi- nator in capitalizing on all available Federal funding. - funding for staff resources could be provided through a joint effort of Federal Agencies participating in the FRC. 2. The Coordinator and staff function will also involve a close working relationship with ongoing regulatory programs in the VI. o maintain close communication with WAPA, DCCA.DPW, VIHA and VIPO to ensure consistency and elimination of duplication. o maximize utilization of the A-95 process to ensure consistency with this strategy, & the developing water resources plan. Governor and FRC to identify a high level VI/FRC Water Resource.' Coordinator. ------- TABLE 1 ISSUE AGENCIES ACTIVITY PROJECT TIME FRAME PROJECT FUNDING COMMENTS/NEEDS REQUIRED ACTIONS I H* •F- 2. DCCA/ EPA/ WRC Development of management, financial and institutional components of the Compre- hensive Water Resources Management Plan for the VI. FY80/81 WRC EPA 208 o assist in public participation activities and development of public participation program at Governor's level. o report to Governor and legislature on key issues. o disseminate new or modified federal and local legislation/ regulations. 3. The Coordinator and staff will work intimately with the agency (ies) (DCAA as recommended by VI/ EPA Agreement) to develop the Comprehensive Water Resources Plan 4. The Coordinator and staff will ensure that all three islands are accurately and equitably informed on ongoing activities. 5. The Coordinator and staff will work closely with all Federal agencies in every aspect of program development and shall inform other agencies of ongoing actions (newsletter etc.). Numerous Virgin Islands executive branch agencies have water resources responsibilities. There is a need to improve communication and clearly define the roles of these agencies (management, financial, and institu- tional) in implementing the technical plan. VI/FRC Coordinator to obtain necessary funds from EPA/WRC. DCCA will integrate within its WRC/208 workplan, activities to be undertaken to develop a management, financial and institutional plan. ------- TABLE 1 ISSUE AGENCIES ACTIVITY PROJECT TIME FRAME PROJECT FUNDING COMMENTS/NEEDS REQUIRED ACTIONS 3. EPA/ DCCA/ WAPA/ DPW/ VIHA Development of a continuing operation and maintenance (0 & M) program. FY80 EPA 106 see also Table 2 E. Preparation of Virgin Islands Comprehensive Water Resources Management Plan EPA WRC DCCA Integration of Comprehensive Plan components FY80-81 EPA 208 WRC H1 Ul Continuous training and retraining of personnel in water resource program operations are crucial to the efficient operation of water manufacturing, treatment and distri- bution facilities. A local training program to achieve this objective must be developed and institution- alized. As shown in Figure 1: Needs, Supply Alternatives and Distribution/Treatment Systems need to be integrated into the Technical Plan. Institutional, Management, and Financial issues must be combined into the Organizational Framework and Plan. All components must be brought together into a unified Comprehensive Plan. Putting together plan includes activities such as: VI/FRC Coordinator to identify and obtain available federal assistance to develop training program for 0 & M. Virgin Islands Governor to designate DCCA to be recipient of WRC funding DCCA will develop a single integrated work- plan for the development of a Comprehensive Water Resources Management Plan for the Virgin Islands. The workplan will identify those activities and costs to be funded by WRC and those to be funded by EPA 208. ------- TABLE 1 ISSUE AGENCIES ACTIVITY PROJECT TIME. FRAME PROJECT FINDING COMMENTS/NEEDS REQUIRED ACTIONS Public participation in plan review Selection of technical plan alternatives Selection of organizational framework Presentation of recommended legislative changes to Virgin Islands legislature Identification and implementation of Virgin Islands agency priorities DCCA will submit a grant proposal to WRC with the integrated workplan. DCCA" will incorporate this integrated workplan in the overall EPA 208 wokplan. ------- TABLE 1 ISSUE AGENCIES ACTIVITY PROJECT TIME FRAME PROJECT FUNDING COMMENTS/NEEDS REQUIRED ACTIONS Implementation of Virgin Islands Comprehensive Water Resources Plan. VI Governor FRC/VI Governor DCCA DPW WAPA VIHA VIPO Designate Agencies to carry out specific tasks Identify sources of fund- ing for plan implementation Draft and submit legis- lation to assign neces- sary legal authorities for implementation including funding of: operation and maintenance (O&M). source development. - management. Promulgate implementation regulations. Establish budget and resources for plan implementation. Within 3 month: of com- pletion of plan Within 6 month: of com- pletion of plan Within 6 month of com- pletion of plan Responsibilities for implementation must be clearly defined at on-set of plan implementation. Funding must be sought to insure plan implementation.. The three activities defined are essential to any plan implementation. FRC Coordinator will work with VI' Governor to seek sources of funding. FRC Coordinator will make available model legislation, regulations, etc. to facilitate these activities. ------- TABLE 2 Available Federal Funding AGENCY FUNDING TITLE FY 79 FY 80 CONSTRAINTS HUD . CDBG Sec. Desc.. .Funds .to solve loc'al-ly determined 778,.OQO . not known development problems. .-Funds can be carried over yearly. Uncommitted prior year funds '.-:-. can be reallocated. USDA 1. Water & Waste Loans Grants 2. Community Facility Loans 3. Industrial Dev. Grants Total 960,000 300,000 255,000 25,000 1,540,000 710,000 315,000 230,000 25,000 1,280,000 Funds set aside for the VI from FmHA regional allocations. No yearly carry-over. Construction only. Note: Grants are up to 75% of total project cost. (estimated) Loans are usually 5% for up to a 40 year term. USGS Water Resources Investigations Funds come from a national pool. Applications are accepted throughout the fiscal year. EDA Public Works - Title I (Direct Grants- (up to 50%) and Loans) 500,000 (estimated) Can be used for any project aimed at improving infra- structure to aid in economic & commercial development. No specific set-aside are available. EPA Sec. 208 Water Pollution Control - State & Area Wide Water Management Planning Grants Sec. 106 Water Program Support Grant Construction Grants for Wastewater Treatment Works Drinking Water Supply- Technical Assistance 160,000 from FY 77 funds 2,740,000 SDWA .81,800 1,500,000 SDWA $130,000 available for water supply planning activities. Grant has been made. Expenditure of funds has not been authorized. Projects must be selected from construction grants priority list. Future allocations could be used for wastewater related drinking water projects. WRC Water Management and Conservation Technical Assistance Grant (Note: pending before Congress) 50% matching grant. Only 250,000 for planning, regulation, (estimated) and enforcement (not for construction). For develop- ment and implementation of a Comprehensive T'ater Resources Management .Program 5Q% of funds for water conservation, 50% of funds for water resources management. COE Section 22 PL 93-251 Up to Planning Assistance to 200,000 states. COE does work per year on request from state. Corps must put funds in budget cycle. Potential exists for FY'81 (possibly too late) or FY'82 funds. Project Each proj'ect constructed under funds specific Congressional auth- orization and appropriation. FY 80-$4M authorized under House(_, version of Corp's Omnibus Bill for rehab of VI Water Supply distribution system. A-18 ------- |