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