VIRGIN  ISLANDS/ENVIRONMENTAL
     PROTECTION AGENCY
         AGREEMENT
/ -
             for
        WATER and AIR
      RELATED PROGRAMS
           SEPTEMBER 1979

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 VIRGIN ISLANDS/ENVIRONMENTAL
     PROTECTION AGENCY
         AGREEMENT
            FOR
WATER & AIR RELATED PROGRAMS
              September 1979

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                  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

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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.

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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-

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                                                                    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.

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                                                                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.

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                                                                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.

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                                                              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).

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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-

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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:

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           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

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                          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-

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    •    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-

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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"~

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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

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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-

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                         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-

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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-

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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

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           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.

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          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.

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           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  (

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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.

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            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

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          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-

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         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.

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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-

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   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.

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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-

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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-

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    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

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   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&

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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)

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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-

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    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

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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-

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               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

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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-

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    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

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              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

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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-

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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-

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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-

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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-

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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-

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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

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       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,

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                                                                     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.

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                                                                        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.

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                                                                 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.

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                                                                      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.

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                                                                      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.

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                                                                      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.

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                                                                      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.

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                                                                         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).

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                                                                         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.

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                                                                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.

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                                                                        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.

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                                                                 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.

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                                           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

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