Region 2’s Hurricanes Irma and Maria Response Efforts in Puerto Rico and U.S. Virgin Islands Show the Need for Improved Planning, Communications, and Assistance for Small Drinking Water Systems


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U.S. ENVIRONMENTAL PROTECTION AGENCY
OFFICE OF INSPECTOR GENERAL
Ensuring clean and safe water
Region 2's Hurricanes Irma and
Maria Response Efforts in Puerto
Rico and U.S. Virgin Islands
Show the Need for Improved
Planning, Communications, and
Assistance for Small Drinking
Water Systems
Report No. 21-P-0032
December 3, 2020
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Report Contributors:	Stacey Banks
Charles Brunton
Kathlene Butler
Lauretta Joseph
Timothy Roach
Jay son Toweh
Khadija Walker
Abbreviations
EPA	U.S. Environmental Protection Agency
FEMA	Federal Emergency Management Agency
OIG	Office of Inspector General
PRASA Puerto Rico Aqueduct and Sewer Authority
USVI	U.S. Virgin Islands
Cover Photos: Left to right: Hurricane Maria, a rural water system in Puerto Rico, and clean
drinking water. (Photos from the National Oceanic and Atmospheric
Administration, EPA OIG, and Centers for Disease Control and Prevention)
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U.S. Environmental Protection Agency
Office of Inspector General
At a Glance
21-P-0032
December 3, 2020
Why We Did This Audit
We conducted this audit to
determine how the
U.S. Environmental Protection
Agency's preparedness and
response efforts for the three
major hurricanes of 2017—
specifically, hurricanes Harvey,
Irma, and Maria—protected
human health and water
resources from storm-related
drinking water and surface water
contamination. This report
addresses the response to
drinking water and wastewater
systems impacted by hurricanes
Irma and Maria in Puerto Rico
and the U.S. Virgin Islands.
The OIG issued two previous
reports assessing EPA
Region 6's preparedness and
response efforts pertaining to
water issues associated with
Hurricane Harvey in Texas, and
EPA Region 4's preparedness
and response efforts pertaining
to water issues associated with
Hurricane Irma in Florida.
This audit addresses the
following:
•	Ensuring clean and safe water.
•	Partnering with states and
other stakeholders.
•	Operating efficiently and
effectively.
This audit addresses two top EPA
management challenges:
•	Overseeing states and
territories implementing EPA
programs.
•	Communicating risks.
Address inquiries to our public
affairs office at (202) 566-2391 or
OIG WEBCOMMENTS@epa.gov.
List of OIG reports.
Region 2's Hurricanes Irma and Maria Response
Efforts in Puerto Rico and U.S. Virgin Islands Show
the Need for Improved Planning, Communications,
and Assistance for Small Drinking Water Systems
What We Found
Before hurricanes Irma and Maria made
landfall, Region 2 established an incident
command structure and staffing plan to
direct and manage its emergency response
efforts. The region also contacted agencies
in Puerto Rico and the USVI to determine
the ability of the islands' drinking water and
wastewater systems to weather the storms.
Hurricane Irma approached Puerto Rico and the USVI on September 5, 2017,
as a Category 5 storm. Beginning on September 20, 2017, Hurricane Maria
struck the USVI as a Category 5 storm and Puerto Rico as a Category 4 storm.
After the hurricanes, regional emergency response staff performed operational
assessments of drinking water and wastewater systems; conducted water
sampling and analyses; and helped small, rural drinking water systems obtain
generators. Despite these regional efforts and the federal government's largest-
ever hurricane response, some small, rural drinking water systems in Puerto
Rico and the USVI still had not returned to normal operations more than nine
months after the storms made landfall. The damage caused by the hurricanes
and the pre-storm conditions of those systems complicated the response.
The EPA's internal review processes delayed distribution of public health
announcements, such as instructions on how to treat drinking water to reduce
risk of illness. In addition, Region 2 did not fully engage its local staff in Puerto
Rico and the USVI during hurricane preparations. By adjusting its review-and-
approval process for public outreach information; strengthening the capacities of
small, rural drinking water systems; and involving local EPA staff in the planning
stages, Region 2 can improve the effectiveness of its emergency response
efforts.
Recommendations and Planned Agency Corrective Actions
We made three recommendations to Region 2: first, develop and train staff on a
procedure to locally disseminate public health information after emergencies;
second, develop a supplemental emergency response plan that includes roles
for local staff and addresses specific geographic, logistical, and cultural
challenges; third, help improve the capacity and resilience of small, rural drinking
water systems.
The region agreed with the recommendations and provided estimated milestone
dates for its planned corrective actions. All recommendations are resolved.
Enhancements to water system
capacity and emergency
preparation for island response
could better protect the health
of communities impacted by
hurricanes and other disasters.

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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON, D.C. 20460
THE INSPECTOR GENERAL
December 3, 2020
MEMORANDUM
SUBJECT:
FROM:
TO:
This is our
U.S. Environmental Protection Agency. The project number for this audit is OPE-FY18-0005. This report
contains findings that describe the problems the OIG has identified and corrective actions the OIG
recommends. Final determinations on matters in this report will be made by EPA managers in accordance
with established audit resolution procedures.
The Region 2 regional administrator is responsible for the findings outlined in this report.
In accordance with EPA Manual 2750, your office provided acceptable planned corrective actions and
estimated milestone dates in response to OIG recommendations. All recommendations are resolved, and
no final response to this report is required. However, if you submit a response, it will be posted on the
OIG's website, along with our memorandum commenting on your response. Your response should be
provided as an Adobe PDF file that complies with the accessibility requirements of Section 508 of the
Rehabilitation Act of 1973, as amended. The final response should not contain data that you do not want
to be released to the public. If your response contains such data, you should identify the data for redaction
or removal along with corresponding justification.
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Region 2's Hurricanes Irma and Maria Response Efforts in Puerto Rico and U.S. Virgin
Islands Show the Need for Improved Planning, Communications, and Assistance for
Small Drinking Water Systems
Report No. 21-P-0032
Sean W. O'Donnell
Peter Lopez, Regional Administrator
Region 2
report on the subject audit conducted by the Office of Inspector General of the
We will post this report to our website at www.epa.gov/oig.

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Region 2's Hurricanes Irma and Maria Response	21-P-0032
Efforts in Puerto Rico and U.S. Virgin Islands Show
the Need for Improved Planning, Communications,
and Assistance for Small Drinking Water Systems
Table of C
Chapters
1	Introduction		1
Purpose		1
Background		1
Responsible Offices		5
Scope and Methodology		6
Prior Reports		6
2	EPA Needs to Improve Its Emergency Response Planning,
Communications, and Assistance to Small Water Systems		8
Conditions in Puerto Rico and USVI Slowed Response to
Hurricanes Irma and Maria		8
EPA Emergency Response Personnel Provided Critical Help		10
Hurricane Preparation and Response Activities Should Include
All Local EPA Staff and Follow Cultural Norms		13
EPA Could Better Inform the Public and Prepare Small Water Systems
in Puerto Rico and USVI		14
Conclusion		16
Recommendations		17
Agency Response and OIG Assessment		17
Status of Recommendations and Potential Monetary Benefits		18
Appendices
A Initial Agency Response to Draft Report	 19
B Second Agency Response to Draft Report	 24
C Distribution	 28

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Chapter 1
Introduction
Purpose
The U.S. Environmental Protection
Agency's Office of Inspector General
conducted an audit to determine how the
EPA's preparedness and response efforts
for the three major hurricanes of 2017—
specifically, hurricanes Harvey, Irma, and
Maria—protected human health and water
resources from storm-related drinking
water and surface water contamination.
This report contains our findings and recommendations related to EPA Region 2's
response efforts in Puerto Rico and the U.S. Virgin Islands after hurricanes Irma
and Maria. On July 16, 2019, the OIG issued Report No. 19-P-0236 assessing
EPA Region 6's preparedness and response efforts pertaining to water issues
associated with Hurricane Harvey in Texas. On October 7, 2019, the OIG issued
Report No. 20-P-000I assessing EPA Region 4's preparedness and response
efforts pertaining to water issues associated with Hurricane Irma in Florida.
Background
Hurricane Irma began to impact Puerto Rico and the USVI on September 5, 2017,
as the storm approached and passed over the islands. It was rated as high as a
Category 5 storm with wind speeds up to 185 miles per hour. On September 20,
2017, Hurricane Maria struck the USVI as a Category 5 storm with wind speeds
of up to 175 mph. Later that day, Hurricane
Maria struck Puerto Rico as a Category 4 storm
with wind speeds up to 155 mph.
The resulting hurricane damage led the Federal
Emergency Management Agency to initiate an
emergency response that became the longest
sustained air mission of food and water delivery
in its history. Many lives were lost in the wake
of these hurricanes. According to various news
outlets, the government of Puerto Rico initially
reported the official death toll as 64, but
researchers at the George Washington University's Milken Institute School of
Public Health estimated that 2,975 people in Puerto Rico died after Hurricane
Maria. The official USVI toll of those who died as a direct result of the hurricanes
Top Management Challenges
This audit addresses the following top
management challenges for the Agency, as
identified in OIG Report No. 20-N-Q231.
EPA's FYs 2020-2021 Top Management
Challenges, issued July 21, 2020:
•	Overseeing states and territories
implementing EPA programs.
•	Communicating risks.
Oceanic arid Atmospheric Administration photo)
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was five, but the American Journal of Public Health reported that 49 others died
after being medically evacuated from the USVI. In addition, the storms severely
damaged drinking water and wastewater infrastructure. The U.S. Government
Accountability Office reported the overall repair costs to be $132 billion for Puerto
Rico and total damages of $10.7 billion for the USVI.
Drinking Water and Wastewater Systems
Water systems are considered one of the nation's critical infrastructures. They
provide water for drinking and other household and commercial uses, as well as a
means for treating our wastewater. Drinking water and wastewater systems are
vulnerable to service interruption during and following extreme weather events,
such as hurricanes.
A public drinking water system provides water for human consumption through a
distribution system to at least 15 service connections or to an average of at least
25 people for at least 60 days a year. Distribution systems consist of an
interconnected series of components, including pipes, storage facilities, and other
components, that convey drinking water. A public drinking water system may be
publicly or privately owned.
The EPA classifies public drinking water systems according to the number of
people they serve and whether they serve the same customers year-round or on an
occasional basis. Typically, very small systems serve 25 to 500 people and small
systems serve 501 to 3,300 people. Throughout this report, we refer to both small
and very small systems as "small" systems. A public water system that supplies
water to the same population year-round is referred to as a "community water
system."
A public wastewater system treats water that has been used for various purposes
by residences, businesses, and industry. Sewers collect wastewater and deliver
that water to a treatment plant for processing, so that it can be safely be reused or
returned to lakes, rivers, and streams. Some wastewater systems have sewers that
collect both storm water and wastewater. These are known as "combined sewer
systems."
Technical, Managerial, and Financial Capacities of Water Systems
Improving the technical, managerial, and financial capacities of water systems
contributes to their resilience. Resilience is the ability of a water system to
withstand and recover from disasters, such as hurricanes. In general, water
systems in rural locations face longstanding capacity issues, thus hindering
resilience.
Technical, managerial, and financial capacity issues can cause noncompliance
with and violations of drinking water regulations. Some of the limitations are:
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•	Technical capacity limitations, wherein systems lack the proper equipment
or personnel to operate and maintain the equipment.
•	Managerial capacity limitations, wherein systems lack accountable
owners or adequate staffing and organization.
•	Financial capacity limitations, wherein systems lack proper fiscal
management and controls, such as the ability to collect payments from
customers or apply for financial assistance.
Water systems are subject to laws and regulations governing safety and resilience.
In 1972, the Clean Water Act was enacted to protect the waters of the United
States. The EPA implements the Clean Water Act by establishing wastewater
standards and water quality criteria, as well as by regulating discharges of
pollutants. In addition, Congress passed the Safe Drinking Water Act in 1974 to
ensure that public drinking water systems deliver safe water to their consumers.
Under the Safe Drinking Water Act and its amendments, the EPA established
protective drinking water standards for more than 90 contaminants.
America's Water Infrastructure Act of 2018, which amended the Safe Drinking
Water Act, outlines strategies to address drinking water system resilience in the
face of disasters and provides tools for improving resilience, including at small,
rural drinking water systems. The 2018 Act requires the EPA administrator to:
[PJrovide guidance and technical assistance to community water
systems serving a population of less than 3,300 persons on how to
conduct resilience assessments, prepare emergency response plans,
and address threats from malevolent acts and natural hazards that
threaten to disrupt the provision of safe drinking water or
significantly affect the public health or significantly affect the
safety or supply of drinking water provided to communities and
individuals.
Water and Wastewater Services in Puerto Rico and USVI
The Puerto Rico Aqueduct and Sewer Authority provides most of Puerto Rico's
3.19 million residents with drinking water and wastewater services.1 PR AS A
manages 114 community water systems, which at the time of hurricanes Irma and
Maria served 97 percent of the island's residents (Figure 1). Drinking water for
the remaining 3 percent of the population, about 76,000 people when the
hurricanes made landfall, was provided by 237 small community water systems,
which are commonly referred to as "non-PRASA" systems. In addition, as shown
in Figure 1, PRASA operates 51 wastewater systems serving 60 percent of Puerto
1 July 2019 U.S. Census data.
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Rico's population. The remaining 40 percent of the island's population uses
private septic systems for wastewater services.
Figure 1: Puerto Rico population served by PRASA systems
Drinking water systems	Wastewater systems
40%
Non-PRASA
PRASA serves
PRASA serves
of Puerto Rico
^ residents.
of Puerto Rico
„ residents.
Source: OIG analysis based on a 2018 EPA Caribbean Environmental
Protection Division presentation. (EPA OIG image)
The USVI has nearly 106,000 residents, with 77 community water systems
serving drinking water to approximately 81,000 people. Two large water systems
serve the majority of residents (69,000). The remaining 75 are small systems that
supply drinking water to a total of approximately
12,000 people. Despite the availability of these
water systems, 90 percent of houses in the USVI
rely on rainwater catchment systems, such as
cisterns, as their main residential water supply
(Figure 2). A cistern is an underground or
aboveground vessel attached to a home or
business that stores rainwater collected from a
rooftop drainage system. Cisterns are not
regulated under the Safe Drinking Water Act
unless these sources regularly serve at least
25 individuals. The USVI Waste Management
Authority provides wastewater services to
60 percent of the residents through eight
municipal wastewater treatment plants.
EPA Responds to Hurricane Disasters Under FEMA Direction
and at Request of States or Territories
The EPA responds to disasters under the direction of FEMA and at the request of
the states or U.S. territories experiencing the disaster. To facilitate a consistent
federal approach to emergency response, all federal agencies adhere to the
National Response Framework. The framework includes 15 emergency support
functions under which federal agencies coordinate the resources and capabilities
most needed in a national response (Table 1).
Figure 2: USVI dependency on
rainwater catchment systems
i®%
of houses in USVI
rely on rainwater
L catchment systems
for residential
water supply.
Source: OIG analysis based on
2019 USVI Department of Health
Cistern Study. (EPA OIG image)
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Table 1: National Response Framework emergency support functions
#
Resource/capability
1#
Resource/capability
1
Transportation
9
Search and Rescue
2
Communications
10
Oil and Hazardous Materials*
3
Public Works and Engineering
11
Agriculture and Natural Resources
4
Firefighting
12
Energy
5
Information and Planning
13
Public Safety and Security
6
Mass Care, Emergency Assistance,
Temporary Housing and Human Services
14
Superseded by the National Disaster
Recovery Framework
7
Logistics
15
External Affairs/Standard Operating
8
Public Health and Medical Services

Procedures
Source: OIG analysis of U.S. Department of Homeland Security data. (EPA OIG table)
* EPA-led emergency support function in response to hurricanes irma and Maria.
Under each emergency support function, FEMA issues mission assignments to
federal agencies for specific tasks, such as the cleanup of hazardous waste or the
inspection of water systems. For hurricanes Irma and Maria, FEMA activated
Region 2 with mission assignments under Emergency Support Function #10, Oil
and Hazardous Materials Response, from October 30, 2017, through
September 15, 2018. ESF #10 activities can expand beyond oil and hazardous
materials to include monitoring more broadly for environmental contamination.
For Region 2, this FEMA assignment included the sampling and monitoring of
drinking water and wastewater systems in Puerto Rico and the U.S. Virgin
Islands. At its peak, approximately 450 EPA staff participated in the emergency
response.
Responsible Offices
The Region 2 Superfund and Emergency Management Division, which has staff
in New York, New York, and Edison, New Jersey, implements the National
Response Framework and provides emergency response services during
environmental incidents, including hurricanes. The division is also responsible for
emergency response planning, preparedness, and prevention activities.
The Region 2 Water Division, based in New York, New York, implements
environmental statutes that protect water, such as the Clean Water and Safe
Drinking Water acts. The Division also supports cross-cutting, water-related
programs and provides financial and technical assistance to states and localities.
The EPA Office of Water headquarters, based in Washington, D.C., is also
responsible for implementing the Clean Water and Safe Drinking Water acts and
works with the EPA's ten regional offices.
The Region 2 Caribbean Environmental Protection Division implements a variety
of environmental programs from its main office in Guaynabo, Puerto Rico, and a
field office in St. Thomas, USVI. The Division implements water protection
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programs in Puerto Rico and the USVI through permitting, grant administration,
compliance assistance, and enforcement.
Scope and Methodology
We conducted this performance audit from July 2018 to August 2020 in
accordance with generally accepted government auditing standards. Those
standards require that we plan and perform the audit to obtain sufficient,
appropriate evidence to provide a reasonable basis for our findings and conclusions
based on our audit objective. We believe that the evidence obtained provides a
reasonable basis for our findings and conclusions based on our audit objective.
We reviewed the EPA's management and situation reports about hurricanes Irma
and Maria, as well as documents about federal emergency response. We
interviewed Region 2 staff who participated in the response for hurricanes Irma
and Maria; staff from Puerto Rico's and the USVI's environmental agencies; staff
of a nongovernmental organization that provides support for public,
environmental, and economic health in Puerto Rico and the USVI; and drinking
water and wastewater system operators. The scope of our audit did not include
examining Region 2's emergency response related to the monitoring of air
quality, the remediation of household hazardous waste, or the assessment of oil
and hazardous materials releases.
Prior Reports
The OIG published reports about other EPA hurricane response activities related
to hurricanes Katrina, Harvey, and Irma. After Hurricane Katrina in 2006, we
reported that the EPA could improve its coordination with state and local
officials.2 In the aftermath of the 2017 hurricane season, when hurricanes Harvey
and Irma made landfall in the United States, we reported that Regions 4 and 6 had
forged close working relationships with state emergency response partners.3 This
preparation enabled these regions to protect human health and water sector
resources. We recommended that both regions improve their emergency response
training and planning and that Region 6 improve its communications with
non-English-speaking communities. According to the Agency's audit tracking
system, as of November 2020, Region 4 had completed all corrective actions,
while Region 6 had completed two recommendations and had corrective actions
pending for two recommendations.
In the aftermath of Hurricane Harvey, we reported that we did not identify
significant issues in the EPA's contracting, logistics, or resource acquisition
2 OIG, Lessons Learned: EPA 's Response to Hurricane Katrina, Report No. 2006-P-00033. September 14, 2006.
3 OIG, Region 6 Quickly Assessed Water Lnfrastructure after Hurricane Harvey but Can Lmprove Emergency
Outreach to Disadvantaged Communities, Report No. 19-P-0236. July 16, 2019; Region 4 Quickly Assessed Water
Systems After Hurricane Lrma but Can Lmprove Emergency Preparedness, Report No. 20-P-0001. October7, 2019.
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processes, and we did not make any recommendations in that report.4 In a
subsequent report, we did find that state, local, and EPA mobile air monitoring
activities were not initiated in time to assess the impact of toxic air emission
incidents occurring within a five-day period of the hurricane's landfall.5
Additionally, once started, monitoring efforts did not always generate data
considered suitable for making health-based assessments, in part because there
was no guidance outlining how to monitor air quality following an emergency.
We recommended that the EPA develop guidance for emergency air monitoring
and provide public access to those data. As of November 2020, two of the six
recommendations were resolved with corrective actions completed. Resolution
efforts are underway for the remaining four recommendations.
4	OIG, EPA Adequately Managed Hurricane Harvey Funding Received from FEMA, Report No. 20-P-0010.
October 23, 2019.
5	OIG, EPA Needs to Improve Its Emergency Planning to Better Address Air Quality Concerns During Future
Disasters, Report No. 20-P-0062. December 16, 2019.
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Chapter 2
EPA Needs to Improve Its Emergency Response
Planning, Communications, and
Assistance to Small Water Systems
Hurricanes Irma and Maria severely damaged the water, electricity,
communication, and transportation infrastructures in Puerto Rico and the USVI.
This damage affected the EPA's ability to carry out FEMA mission assignments
by hindering and delaying the deployment of response personnel and the
Agency's access to communications and other equipment. Some drinking water
systems in Puerto Rico and the USVI still had not returned to normal operations
more than nine months after the storms made landfall. Despite these challenges,
EPA staff prepared for and fulfilled their response roles performing operational
assessments; conducting water sampling and analyses; and helping small, rural
drinking water systems become operational after the storms. EPA Region 2 did
not, however, optimally use the technical expertise and cultural awareness of its
local employees when preparing for and responding to the hurricanes. In addition,
pre-storm conditions rendered many small drinking water systems vulnerable to
storm damage. Additional attention to advance planning can correct issues with
small drinking water system resilience, public information dissemination,
engagement of local EPA personnel, and awareness of cultural norms.
Conditions in Puerto Rico and USVI Slowed Response to
Hurricanes Irma and Maria
We found the reasons for the EPA's delay in responding to the hurricanes'
aftermath in Puerto Rico and the USVI were not fully within the control of the
Agency's emergency response personnel. For example:
•	Most Puerto Rico and USVI residents did not have electricity after
Hurricane Irma made landfall on September 5, 2017. In the USVI,
98 percent of electrical service was not restored until February 2018, five
months after the two storms. Full electrical service was not restored for most
Puerto Rico residents until August 2018, almost one year after the storms.
•	Damage to transportation infrastructure lengthened travel time across Puerto
Rico and the USVI and prevented access to many rural communities.
•	In the aftermath of Hurricane Maria, approximately 95 percent of the cell
towers in Puerto Rico were out of service, and approximately 77 percent
of cell towers in the USVI were out of service (Figure 3). According to a
2018 Federal Communications Commission report, cell service on the
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islands was restored gradually over a six-month period, considerably
longer than for any other storm. This limited service hindered
communication among emergency responders.
Figure 3: Cell service three weeks after Hurricane Maria
Puerto Rico	U.S. Virgin Islands
Sep. 21,2017	Sep. 21,2017
77% 1
of cell towers
out of
service
r 95% i
of cell towers
out of
k service j
Source: OIG analysis of Federal Communications Commission data. (EPA OIG image)
•	As Hurricane Maria approached the islands, the EPA evacuated its
response personnel who had been deployed to the USVI after Hurricane
Irma.
•	There were not enough supplies available—such as water, meals, medical
kits, and tarps—for distribution after Hurricane Maria made landfall
because FEMA distributed the majority of its inventory from its Caribbean
warehouse after Hurricane Irma struck.
•	The EPA assisted the U.S. Coast Guard with over 700 sunken vessels, as
well as with the resulting debris and oils spills.
In addition, the hurricanes exacerbated pre-storm conditions in Puerto Rico and
the USVI. Technical, managerial, and financial capacity limitations preceding the
storms not only left water systems vulnerable to storm damage but also placed
residents' health at risk. Almost one year
after the hurricanes made landfall in
Puerto Rico, some non-PRASA drinking
water systems were still dealing with
hurricane damage, such as (1) power
restoration taking months in some rural
areas or (2) damage to the distribution
system, such as broken aboveground
plastic pipes, like the one pictured here.
Aboveground drinking water distribution
pipe in rural Puerto Rico broken as a
result of a hurricane. (EPA OIG photo)
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Many of the water systems in isolated rural areas of
Puerto Rico and the USVI—such as the small, rural
drinking water system pictured here, with its treatment
chemicals unsecured and exposed to the elements—
generally lack full operational capacity even in
nonemergency situations. The aftermath of hurricanes
Irma and Maria demonstrated that small, rural drinking
water systems lack the resilience to protect human health
from drinking water contamination in the event of a
disaster. This lack of resilience persists despite Region 2
working for years to address compliance and capacity
problems at small drinking water systems in Puerto Rico.
In contrast, even though the 2017 hurricanes in Texas (Hurricane Harvey) and
Florida (Hurricane Irma) were among the most powerful and damaging in
U.S. history, the response on the mainland was quicker. In both Texas and
Florida, EPA emergency response personnel immediately assessed the status of
drinking water and wastewater systems by telephone and in person. As a result,
the impacted residents of both states were served by operational drinking water
and wastewater systems within days or weeks of the storms.
EPA Emergency Response Personnel Provided Critical Help
Prior to the hurricanes, Region 2 established an incident command structure and
staffing plan to direct and manage its response to the storms. In response to the
FEMA mission assignment, the EPA provided emergency response assessments of
drinking water and wastewater systems, as well as assistance to non-PRASA
drinking water systems. These efforts helped water and wastewater systems in
Puerto Rico and the US VI return to operations in the aftermath of the back-to-back
hurricanes.
EPA Made Emergency Response Preparations in Anticipation
of Storms
Before the start of the 2017 hurricane season, the EPA's emergency response staff
routinely participated in training sessions, preparation exercises, and other
meetings. In anticipation of Hurricane Irma's arrival, Region 2 emergency
response staff engaged in prelandfall and predeployment activities by establishing
an incident command structure and a staffing plan to direct and manage response
efforts. They also established data collection tools for the EPA's drinking water
and wastewater assessment teams.
As part of those emergency response preparations, Region 2 developed a regional
operations plan for the hurricane, which subsequently became the Regional
Operations Plan and Multiple Disaster Contingency Plan for the Hurricane
Irma/Maria Response. This emergency response plan supported the deployment
Small, rural drinking water system in
Puerto Rico with treatment chemicals
improperly stored outside and exposed.
(EPA OIG photo)
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of EPA staff and resources to FEMA's San Juan office, the Puerto Rico
Environmental Quality Board office, and the US VI Department of Planning and
Natural Resources office. The plan addressed preparations and administrative
needs for response efforts involving public health and the environment.
Region 2's Emergency Response Personnel Evaluated Drinking
Water and Wastewater Systems After Storms
As part of the FEMA mission assignments in Puerto Rico and the USVI, Region 2
evaluated the operational status of drinking water and wastewater systems and
tracked the progress of systems returning to operational status. In Puerto Rico, EPA
emergency response personnel and PRASA staff conducted 284 on-site assessments
of drinking water systems and 233 on-site assessments of wastewater systems by
the end of November 2017 to determine operational status.6 Some systems were
assessed multiple times. The EPA also helped 21 small, rural drinking water
systems remain operational by fueling and maintaining their generators.
In the USVI, EPA response personnel conducted 1,282 on-site assessments of
drinking water systems, the majority of which were cisterns, and 33 on-site
assessments of wastewater systems, by the end of November 2017. Some of these
systems were also assessed multiple times. In the USVI, more than 2,400 drinking
water samples were collected for analysis.
Tables 2 and 3 detail the systems' progress in returning to operational status, as
recorded in EPA management reports until June 2018. These reports did not
contain information about the percentage of population with water services, only
the percentage of drinking water and wastewater systems returning to pre-storm
operational levels. From July 2018 until the conclusion of the Agency's mission
assignment in September 2018, the EPA reported the remaining operational needs
of individual drinking water systems, rather than reporting the overall number of
operating drinking water and wastewater systems.
Table 2: Puerto Rico—operational status of drinking water and wastewater systems

Number of
systems
assessed
Percentage of systems o
perational by:
10/20/17
11/20/17
12/20/17
1/22/18
6/6/18
PRASA drinking
water systems
*114
60%
81%
93%
96%
99%
Non-PRASA drinking
water systems
237
No data
81%
86%
87%
95%
Wastewater systems
51
80%
92%
100%
98%
100%
Source: OIG analysis of EPA management reports. (EPA OIG table)
* EPA reports varied in the number of PRASA drinking water systems assessed: 121 in
October 2017, 115 in November and December 2017, and 114 thereafter. The percentage of
systems operational is based upon the number of systems reported as assessed.
6 Region 2's comments to the draft report noted that the Puerto Rice Department of Health also participated in
on-site assessments of drinking water and wastewater facilities.
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Table 3: USVI—operational status of drinking water and wastewater systems

Number of
systems
assessed
Percentage of systems o
perational by:
10/20/17
11/20/17
12/20/17
1/22/18
6/6/18
Public drinking water
systems*
**344
No data
74%
74%
80%
85%
Private cisterns
***2Q7
No data
95%
95%
84%
91%
Wastewater systems
8
No data
63%
100%
100%
100%
Source: OIG analysis of EPA management reports. (EPA OIG table)
* Management reports did not distinguish between community water systems and noncommunity
water systems, such as hospitals, schools, and gas stations.
** The EPA reported 344 systems assessed until its June 2018 report, which reported 338. The
percentage of systems operational is based upon the number of systems reported as assessed.
*** Management reports varied in the number of nonutility drinking water systems assessed:
207 in January 2017, 191 in November and December 2017, and 170 thereafter.
As shown in Table 2, when the EPA stopped tracking Puerto Rico's water and
wastewater systems in June 2018, which was nine months after the first storm,
nearly all systems had achieved pre-storm levels of operation. As shown in
Table 3, 85 percent of public drinking water systems in the USVI had returned to
pre-storm levels of operation by June 2018. Because at least 95 percent of the
USVI's residents use private cisterns, many still had access to drinking water after
the public water and power systems became inoperable; however, even in
June 2018, 9 percent of private cisterns remained nonoperational.
EPA Provided Direct Assistance to Non-PRASA Drinking
Water Systems
The EPA provided direct assistance to non-PRASA drinking water systems to fuel
and maintain temporary generators. The widespread power outages in Puerto Rico
after the hurricanes particularly affected non-PRASA drinking water systems.
These remote systems were in areas where electricity was not restored for several
months.
After the hurricanes, the owners or operators of drinking water systems could
request generators through the FEMA Public Assistance grant program. FEMA
Public Assistance provides federal funding to help communities respond to and
recover from disasters, such as hurricanes. Not all Puerto Rican and USVI water
systems were able to qualify for such assistance, however. As noted previously,
non-PRASA systems face technical, managerial, and financial capacity limitations
for both day-to-day operations and after weather emergencies, such as hurricanes.
These capacity limitations contributed to the systems' inability to qualify for
assistance from FEMA because water system operators could not provide the
necessary documents to qualify for the Public Assistance grants. For example,
before hurricanes Irma and Maria, many non-PRASA water systems were not
incorporated, which is a requirement to obtain FEMA Public Assistance grants.
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With EPA assistance, 68 percent (161) of the 237 non-PRASA water systems
obtained certification during the EPA's emergency response period. Some of
those systems then obtained temporary generators from FEMA to operate their
water systems. In addition, as part of the Agency's mission assignments, EPA
emergency response staff and contractors fueled and maintained 21 generators at
non-PRASA systems until September 2018. The priority for generators was
hospitals, PRASA systems, and power stations. As a result of prioritizing other
facilities, not all non-PRASA systems needing generators received them due to a
shortage of generators on the island.
Hurricane Preparation and Response Activities Should Include All
Local EPA Staff and Follow Cultural Norms
While Region 2 devised an emergency response plan prior to the arrival of the
storms to help guide its response efforts, it did not specify roles for the 45 local
EPA staff in Puerto Rico and the two local EPA staff in the USVI (Figure 4).
Staff we interviewed from the EPA's Puerto Rico office said that they participated
in some preparations or emergency response activities. The two EPA staff
stationed in the USVI said that they had limited or no involvement in preparation
or response activities.
Figure 4: Local EPA staff
PUERTO RICO
45 employees
U.S. VIRGIN ISLANDS
2 employees
Source: Data from July 2018 meeting with Agency. (EPA OIG image)
Staff told us that some EPA emergency response personnel did not follow some
cultural norms on the islands. For example, we were told that exchanging personal
greetings regarding family or health before meetings begin is a cultural norm in
the USVI but that EPA emergency response personnel did not always follow this
etiquette. EPA response personnel also took photographs without the permission
of local USVI residents, which was described to us as not in keeping with local
cultural norms.
The local EPA staff were familiar with island geography and cultural norms, and
they had logistical and technical expertise. Region 2 would have benefited from
their knowledge and skills when preparing and, to the extent local EPA staff were
safely available, in the immediate aftermath of the storms. Region 2 could
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strengthen cultural understanding by using local EPA staff expertise in disaster
preparation activities and response efforts. These staff could help enhance
understanding by mainland-based emergency response personnel about local
cultural norms.
To address the lack of cultural awareness during the response effort, Region 2
staff created and distributed an etiquette document: Things to Know Working in
the Virgin Islands. This document highlighted USVI cultural norms and suggested
how to sensitively interact with residents.
The EPA's Office of Emergency Management reviewed the Agency's response
activities for hurricanes Harvey, Irma, and Maria and the California wildfires. The
resulting 2017 Hurricane and Wildfire Response After-Action Report, dated
September 2018, identified strengths, areas for improvement, and
recommendations to improve the EPA's emergency response. The report
identified local staff involvement in response operations as an area for
improvement and recommended that the EPA delineate roles and responsibilities
for local staff in future disasters. The report also suggested that "guidance on
cultural attitudes in communication" be included in predeployment packages
going forward.
EPA Could Better Inform the Public and Prepare Small Water Systems
in Puerto Rico and USVI
Although Region 2 fulfilled its FEMA water sector mission assignment, we
identified two additional areas for improvement that would further enhance the
region's emergency response capabilities and would better prepare small, rural
drinking water systems in Puerto Rico and the USVI to protect human health.
Specifically, the EPA could improve its processes for informing the public about
protecting health and for assisting small, rural drinking water systems with
developing resilience.
Public Health Messages Delayed Because of EPA Procedures
In the USVI, most residents relied on cisterns as their drinking water source after
hurricanes Maria and Irma caused power outages, which made public water
systems nonoperational. In Puerto Rico, the damage to distribution systems and
power outages after the hurricanes made small, rural drinking water systems
inoperable, and residents either relied on alternative sources for water, such as
artesian wells, or traveled several kilometers to obtain water. To reduce the risk of
illness following disasters, residents need to know how to disinfect drinking water
obtained from sources other than regulated public drinking water systems.
According to EPA response staff, such public health information was delayed
after hurricanes Maria and Irma because, in part, of the Agency's vetting process.
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As part of pre-storm preparations, Region 2 and headquarters implemented EPA
Order 2010, Crisis Communication Plan. According to the Crisis Communication
Plan, messages should be "conveyed to the public quickly, accurately, and
consistently by working with the media and sharing information externally." The
EPA had previously developed public health messages to distribute after disasters
regarding how to disinfect drinking water. These messages, dated June 2015, were
previously used in the Hurricane Harvey response efforts, which occurred less
than two weeks before Hurricane Irma.
As specified in the EPA's Crisis Communication Plan, public health outreach
messages are subject to review and approval by headquarters, even if they contain
previously approved information, before they are distributed to the public. In
response to hurricanes Irma and Maria, multiple headquarters offices were
involved in the review-and-approval process for these messages: the Office of
Public Affairs, which was identified as the lead reviewing office; the Office of
General Counsel; and the Office of Water. According to Region 2, this required
vetting process led to delays in the delivery of the public health messages in Puerto
Rico and the USVI. The delayed dissemination of this information, however, was
not in accordance with the Crisis Communication Plan's directive to provide
messages to the public quickly. In response to our draft report, Region 2 stated that
in addition to internal vetting, it was necessary that messaging also be coordinated
with other response partners, including the Puerto Rico Department of Health.
The EPA's 2017 Hurricane and Wildfire Response After-Action Report also
identified the distribution of public health messages as an area for improvement.
Any delay in distributing public health information puts residents at risk if they do
not know how to treat water that does not come from a regulated water system.
America's Water Infrastructure Act Could Help Vulnerable Systems
Region 2 has worked for years to address capacity problems at small, rural
drinking water systems in Puerto Rico and the USVI. Despite this assistance,
many small, rural drinking water systems lack the technical, managerial, and
financial capacity to recover quickly from disasters, such as the two back-to-back
hurricanes that devastated the islands in 2017.
In September 2018, Region 2 agreed to participate in a Memorandum of
Understanding to enhance the resilience of non-PRASA systems in Puerto Rico.
The memorandum establishes working relationships among Region 2, a university,
and six nongovernmental organizations, with the intent to "build capacity, develop,
and implement equitable, reliable, and resilient solutions" to non-PRASA and
other unregulated drinking water systems in remote areas of Puerto Rico.
Implementation of the America's Water Infrastructure Act could further help
vulnerable systems. The Act requires that the EPA provide guidance to small
drinking water systems "on how to conduct resilience assessments, prepare
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emergency response plans, and address threats from [disasters] that threaten to
disrupt the provision of safe drinking water." In response, the Office of Water:
•	Issued instructions in July 2019 for water systems on how to develop
emergency response plans.
•	Issued guidance in May 2020 for small community water systems on how
to conduct risk and resilience assessments.
•	Developed risk assessment and emergency response plan training for
systems that service over 3,300 people.
•	Planned workshops for the fall of 2020 to help small water systems
comply with the America's Water Infrastructure Act.
America's Water Infrastructure Act also established an annual grant program of
up to $10 million to provide technical assistance grants to small drinking water
systems to conduct resilience assessments, prepare emergency response plans, and
address threats from malevolent acts and natural hazards. While Congress has, to
date, not funded this grant program, Congress appropriated $3 million for fiscal
year 2020 to fund a separate grant program for increasing drinking water
resilience to natural hazards.7 Small, rural drinking water systems in Puerto Rico
and the USVI would benefit from this aid, which is consistent with the goals
established in the 2018 Memorandum of Understanding.
Conclusion
The EPA's preparations for the 2017 hurricane season enabled EPA emergency
response staff to complete their FEMA mission assignments in the aftermath of
two back-to-back hurricanes. Specifically, the EPA assessed the status of drinking
water and wastewater systems, collected and tested drinking water samples, and
provided assistance to small drinking water systems in Puerto Rico and the USVI.
However, the severity of the consecutive storms; the logistical difficulties the
storms caused; the geographic isolation of the islands; the pre-storm operating
challenges of some small, rural drinking water systems; and cultural differences
complicated and prolonged the emergency response efforts, especially compared
to the 2017 hurricane response efforts in Texas and Florida.
Region 2 can better protect human health after future disasters in Puerto Rico and
the USVI by working with the Office of Water to improve the resilience of small,
rural drinking water systems through implementing the America's Water
Infrastructure Act. Additional improvements to the Region 2 emergency response
planning processes can improve communications during the response, engage
local EPA staff, and inform response personnel on local cultural norms.
7 Appendix B contains Region 2's technical description of these two new grant programs that were created by the
America's Water Infrastructure Act to support resiliency and federal appropriations for those activities.
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Recommendations
We recommend that the Region 2 regional administrator:
1.	Develop and implement a written regional procedure for the timely
approval and dissemination of predrafted public health messages in the
aftermath of a disaster so that impacted communities receive critical
information in a timely manner, in accordance with EPA Order 2010,
Crisis Communication Plan. After this procedure is developed, also:
a.	Train regional emergency response personnel on the procedure.
b.	Include the procedure in disaster planning and response documents
and exercises.
2.	Develop and implement a supplement to Region 2's emergency response
plan to describe and address the specific geographic, logistical, and
cultural norms applicable to disaster response in Puerto Rico and the
U.S. Virgin Islands. This supplement should include local EPA staff roles
and responsibilities, as well as address the likely limitations to
transportation, communications, and power in the aftermath of disasters.
3.	In coordination with the Office of Water, implement America's Water
Infrastructure Act in Puerto Rico and the U.S. Virgin Islands by:
a.	Developing and implementing a strategy to provide training,
guidance, and assistance to small drinking water systems as they
improve their resilience.
b.	Establishing a process for small drinking water systems to apply
for America's Water Infrastructure Act grants. This process should
include (1) implementing the EPA's May 2020 guidance provided
to small drinking water systems regarding resilience assessments
and (2) establishing a public information campaign to inform small
drinking water systems of the America's Water Infrastructure Act
grant opportunity, qualifying requirements, and application
deadlines.
Agency Response and OIG Assessment
The Region 2 regional administrator provided an initial response (Appendix A) to
our draft report on October 22, 2020, as well as a second response (Appendix B)
on November 2, 2020, regarding Recommendation 3. Region 2 also provided
technical comments, and we made changes to our report where appropriate. The
region provided acceptable planned corrective actions and estimated milestone
dates in response to our recommendations. All recommendations are resolved.
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Status of Recommendations and
Potential Monetary Benefits
RECOMMENDATIONS






Potential





Planned
Monetary
Rec.
Page



Completion
Benefits
No.
No.
Subject
Status1
Action Official
Date
(in $000s)
17 Develop and implement a written regional procedure for the
timely approval and dissemination of predrafted public health
messages in the aftermath of a disaster so that impacted
communities receive critical information in a timely manner, in
accordance with EPA Order 2010, Crisis Communication Plan.
After this procedure is developed, also:
a.	Train regional emergency response personnel on the
procedure.
b.	Include the procedure in disaster planning and response
documents and exercises.
17 Develop and implement a supplement to Region 2's emergency
response plan to describe and address the specific geographic,
logistical, and cultural norms applicable to disaster response in
Puerto Rico and the U.S. Virgin Islands. This supplement should
include local EPA staff roles and responsibilities, as well as
address the likely limitations to transportation, communications,
and power in the aftermath of disasters.
17 In coordination with the Office of Water, implement America's
Water Infrastructure Act in Puerto Rico and the U.S. Virgin
Islands by:
a.	Developing and implementing a strategy to provide training,
guidance, and assistance to small drinking water systems as
they improve their resilience.
b.	Establishing a process for small drinking water systems to
apply for America's Water Infrastructure Act grants. This
process should include (1) implementing the EPA's May 2020
guidance provided to small drinking water systems regarding
resilience assessments and (2) establishing a public
information campaign to inform small drinking water systems
of the America's Water Infrastructure Act grant opportunity,
qualifying requirements, and application deadlines.
Region 2 Regional
Administrator
9/30/21
Region 2 Regional
Administrator
6/30/23
Region 2 Regional
Administrator
12/31/22
C = Corrective action completed.
R = Recommendation resolved with corrective action pending.
U = Recommendation unresolved with resolution efforts in progress.
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Appendix A
Initial Agency Response to Draft Report
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION 2
290 Broadway, New York, NY 10007-1866
MEMORANDUM
DATE: October 22, 2020
SUBJECT: Response to Office of Inspector General Draft Report for
Project No. OPE-FY18-0005:
"Region 2's Response Efforts in Puerto Rico and U.S. Virgin Islands
Need Improved Planning, Communications, and Assistance for Small
Drinking Water Systems," dated September 1,2020
UsoxtzA,	for:
FROM: Peter D.Copez
Regional Administrator
TO:	Kathlene Butler
Director, Water Directorate
Office of Evaluation
Office of Inspector General
Thank you for the opportunity to respond to the issues and recommendations in the
subject audit report. Following is a summary of our overall position. More detailed,
specific comments and suggestions are included in a Technical Comments Attachment,
below.
We agree with Recommendation 1 and 2, and we have provided an accounting of
current management strategies/actions along with additional high-level
intended corrective management initiatives. Please note that we have provided
estimated completion dates to the maximum extent possible.
Recommendation 3 involves EPA's Office of Water (OW). In consultation with OW, we
expect to provide additional comments about that recommendation (including factual
corrections about AWIA and resilience grants) by October 30.
^60 ST«f
or
ISE2 J
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AGENCY'S OVERALL POSITION
Region 2 appreciates the Office of Inspector General's initiative to undertake an
assessment and reporting of the Region's hurricane response efforts in Puerto Rico
(PR) and the U.S. Virgin Islands (USVI), and for acknowledging the severity of the
consecutive storms and their disastrous impacts; the geographic isolation of the
islands; the pre-storm operating and economic challenges of numerous small, rural
drinking water systems; as well as cultural differences which complicated and
prolonged the emergency response efforts.
EPA also thanks the OIG for its gracious acknowledgement of the additional and
creative efforts made by EPA to respond to the urgent needs and unusual circumstances
faced by the people of the Caribbean as we worked to stabilize and support both PR's
and USVI's efforts to protect public health and the environment in the wake of the twin
storms.
In response to the recommendations made by the OIG in this report, EPA respectfully offers
the following:
Region 2 agrees that additional attention should be given to expediting the
approval and dissemination of public health messages.
In this regard, however, EPA emphasizes that the pervasive and prolonged
disruption of communications, power and transportation infrastructure systems
provided serious challenges to advancing broad-based and rapid deployment of
health information and services.
While more effective protocols and systems can be established between EPA, the
Commonwealth and local governments, it is imperative to recognize that local
staffing and fiscal limitations present additional challenges to ensuring rapid,
consistent response capabilities. As such, EPA intends to advance its capacity
building efforts, even as it continues to coordinate closely and amplify the work
of local health department systems.
EPA concurs with the importance of ensuring rapid consensus on public health
messages and the delivery of the same in coordination with other federal
agencies such as the Federal Emergency Management Agency (FEMA) and
Health and Human Services (HHS).
EPA also agrees that the Region 2 emergency response plan could be enhanced
by engaging its local staff and reducing the challenges to support disaster
response typically caused by the specific geographic, logistical, cultural norms,
and language barriers in PR and USVI. With that said, it is imperative to note
that Region 2's plans must allow flexibility, allowing for the likelihood of
limited availability of local staff from the Region's Caribbean Environmental
Protection Division (CEPD) due to likelihood of staff being heavily impacted by
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a disaster, as they were in the 2017 hurricane season. It should also be noted that
EPA's local staff in PR will invariably have responsibilities to continue to
manage important ongoing environmental programs and, therefore, may not be
able to assume disaster response functions.
Region 2 is proactively advancing actions to strengthen the capacity and
resilience of small, rural drinking water systems in PR and USVI, and will
continue to provide training and technical assistance for system operators, and
financial assistance as available and authorized by law.
Our existing Memorandum of Understanding (MOU, see attachment
3), established a framework that supports collaborative working
relationships between non-governmental organizations (NGOs), academia, and
EPA that have joined efforts to build capacity, and develop and implement
equitable, reliable and resilient solutions to help these remote drinking water
systems continue achieving improved capacity and resilience. This MOU led to
the creation of the Water Coalition, which further expands this collaboration with
the PR Department of Health, the U.S. Department of Agriculture Rural
Development, and other representatives from academia and the not-for-profit
sector. Region 2 will continue to use its best efforts to ensure a reliable provision
of safe drinking water to these communities.
Notably, this collaboration is furnishing additional support through USDA in the form of
staff persons to serve as "circuit riders" responsible for providing a broad range of
continuous, dedicated technical support to the small, non- PRASA community water
systems. This initiative is being further augmented through the announcement of additional
circuit rider contracting support funded through EPA's Office of Enforcement and
Compliance Assurance (OECA) to provide compliance assistance to 45 non-PRASA
systems in Puerto Rico.
AGENCY'S RESPONSE TO REPORT RECOMMENDATIONS
Agreements
No.
Recommendation
High-Level Intended Corrective Action(s)
Estimated Completion
by Quarter and FY
1.
Develop and implement a written
regional procedure for the timely
approval and dissemination of pre-
drafted public health messages in
the aftermath of a disaster so that
impacted communities receive
critical information in a timely
manner in accordance with EPA
Order 2010, Crisis Communication
Plan.
EPA is currently updating its Crisis Communications Plan to
refine the plan and ensure that it clearly lays out the process
for communicating during an emergency.
Part of the challenge during the response to Maria and Irma
was that some EPA responders were not familiar with the
EPA Crisis Communications Plan. To rectify this, EPA
Region 2 will ensure that the plan is provided as part of the
mobilization/orientation package given to responders,
particularly those who will serve as community liaisons in the
field. Further, Region 2 will ensure that in the summary of
preparations a responder should make before arriving on
scene the crisis communications plan is noted, and responders
are encouraged to familiarize themselves with the plan.
2"1 Quarter FY 2021
3"1 Quarter FY 2021
4,j Quarter
FY 2021, contingent
upon F1Q fmalization
and availability of
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To address any delays in getting materials approved for public
dissemination particularly on major incidents like Hurricanes
Irma and Maria, Region 2 will embed an Assistant Public
Information Officer (PIO) in the incident who will focus on the
EPA approval process and will serve as a liaison to get
materials approved as quickly as possible. This Assistant PIO
would also help coordinate, through EPA' Office of Public
Affairs, messaging with other federal agencies.
In addition, Region 2 will provide the latest version of the EPA
Crisis Communications Plan to relevant emergency response
and response corps members and also ensure that it is discussed
during training sessions or exercises so that all responders will
better understand the expectations set forth in the plan.
the updated Crisis
Management Plan in 2"1
Quarter FY 2021
2.
Develop and implement a
supplement to Region 2's
emergency response plan to
describe and address the specific
geographic, logistical, and cultural
norms to disaster response in Puerto
Rico and the U.S. Virgin Islands.
This supplement should include
local EPA staff roles and
responsibilities, as well as address
the likely limitations to
transportation, communications, and
power in the aftermath of disasters.
Region 2 agrees with the recommendation. The Region 2
emergency response program has initiated the
development/implementation of plans to respond to emergency
and disaster responses in the Caribbean. Discussions include
the development and scope of a training, workshop and
exercise program to better coordinate and integrate local
personnel into the region's response structure. This initiative
would include training on EPA's various roles, responsibilities
and procedures, as well as identification of ways to effectively
utilize CEPD personnel capabilities and expertise, especially
during the early stages of a response to address limitations to
transportation, communications, and power in the aftermath of
disasters. Further development of cultural awareness guidance
developed during the response to Hurricanes Irma and Maria
and strategies for addressing language barriers would also
be addressed and included in deployment materials. Region
2's plans must allow flexibility since limited availability of
local staff must also be considered, as the majority of CEPD
staff will likely be heavily impacted by a
disaster, as they were in the 2017 hurricane season. In addition,
capabilities of the EPA local staff in PR and USVI may be
limited due to existing responsibilities managing environmental
programs.
3"1 Quarter
FY 2023
The implications of
travel restrictions due to
COVID, and also
diversion of resources
to disaster responses
within the region or
nationally, may delay
this completion date.
Please refer to Attachment 2 for additional information that could provide context and
background information for the above responses.
Recommendation 3 involves EPA's Office of Water (OW). In consultation with OW,
we expect to provide additional comments about that recommendation (including
factual corrections about AWIA and resilience grants) by October 30.
CONTACT INFORMATION
If you have any questions regarding this response, please contact let me know or have
your staff contact Arlene Chin, Region 2's Audit Coordinator, at (212) 637-3408 or
Chin.Arlene@epa.gov. or Rudnell (Rudy) O'Neal, Chief, Grants and Audit
Management Branch, Mission Support Division, at (212) 637-3427 or
Oneal.Rudnell@epa.gov.
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Attachments
cc: Doug Benevento, Associate Deputy
Administrator Mandy Gunasekara, Chief of
Staff
David Ross, Assistant Administrator, Office of Water
Dennis Lee Forsgren, Jr., Deputy Assistant Administrator, Office of Water
Anna Wildeman, Principal Deputy Assistant Administrator, Office of Water
Susan Bodine, Assistant Administrator, Office of Enforcement & Compliance
Assurance
James Hewitt, Associate Administrator, Office of Public Affairs
Nancy Grantham, Principal Deputy Associate Administrator, Office of Public
Affairs
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Appendix B
Second Agency Response to Draft Report
$t
-------
Puerto Rico and the U.S. Virgin Islands do not serve more than 3,300 people, so AWIA
certification requirements do not apply to them. However, EPA encourages drinking water
systems of all sizes to perform risk and resilience assessments and, in addition to the risk and
resilience checklist specifically designed for use by small systems that serve 3,301-49,999
people, EPA plans to publish guidance for systems serving less than 3,300 people in 2021.
EPA also plans to conduct outreach to primacy agencies, including Puerto Rico and U.S.
Virgin Islands, and via press release or social media when the competitive announcement for
the resilience grant program authorized under the Safe Drinking Water Act (SDWA) section
1459A(1) (AWIA Section 2005) opens.
TECHNICAL COMMENTS ON THE REPORT (Related to Recommendation #3)
The discussion in the report regarding resiliency grant programs authorized under AWIA
is unclear. AWIA amended SDWA in a number of ways, including establishing two new
paragraphs that authorized two separate grant programs to support resiliency:
• 1433(g) - Technical Assistance Grants to implement the Drinking Water Infrastructure
Risk and Resiliency Program and
• 1459A(1) - Drinking Water Infrastructure Resilience and Sustainability Grant to assist
small and disadvantaged in increasing resilience to natural hazards.
No funding has been appropriated for the grant program authorized under Section 1433(g)
of SDWA. EPA recommends clarifying that the recommendations and report do not relate
to this program. For fiscal year 2020, Congress appropriated $3 million to fund grants
authorized under 1459A(1). This program was not established to implement the programs in
Section 1433 of SDWA.
AGENCY'S RESPONSE TO REPORT RECOMMENDATION 3
Agreements
No.
Recommendation
High-Level Intended Corrective Action(s)
Estimated Completion by
Quarter and FY
3.
In coordination with the Office of Water,
implement America's Water
Infrastructure Act in Puerto Rico and the
U.S. Virgin Islands by:
a. Developing and implementing a
strategy to provide training,
guidance, and assistance to small
drinking water systems as they
improve their resilience.
b. Establishing a process for small
drinking water systems to apply for
EPA Office of Water will be promoting
and conducting a series of AWIA
section 2013 virtual workshops during
January through March 2021 aimed at
systems serving 3,301- 49,999 people,
including a workshop focused on Region
2 water systems, to include Puerto Rico
and U.S. Virgin Islands. Small water
systems and technical assistance
providers in Puerto Rico and the U.S.
Virgin Islands are welcome to attend
these workshops to assist them in
developing risk and resilience
assessments and emergency response
plans.
Since small drinking water systems in
Conduct training
by end of Quarter
2 of FY 2021.
Publish guidance for
systems serving 3,300
or fewer customers by
end of Quarter 1 of
FY 2022.
Conduct outreach when
Request for Applications
is released for the AWIA
Drinking Water
Infrastructure Resilience
and Sustainability Grant
by end of Quarter 1 of FY
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America's Water Infrastructure Act
Puerto Rico and the U.S. Virgin Islands
2022.

grants. This process should include
do not serve more than 3,300 people,

(1) implementing the EPA' s
AWIA certification requirements do not

May 2020 guidance
apply to them. However, EPA

provided to small
encourages drinking water systems of all

drinking water systems
sizes to perform risk and resilience

regarding resilience
assessments and has developed a risk

assessments and
and resilience checklist specifically

designed for use by systems that serve

3,301-49,999 people.

While the May 2020 guidance was