U.S. ENVIRONMENTAL PROTECTION AGENCY

OFFICE OF INSPECTOR GENERAL

Quick Reaction Report: 

EPA Oversight Needed to 

Ensure Beach Safety in

U.S. Virgin Islands 

Report No. 14-P-0155 March 31, 2014 

Scan this mobile 

code to learn more 

about the EPA OIG. 
 

 

 

Report Contributors: Kathlene Butler

 Allison Dutton 

 Dan Engelberg 

 Fred Light 

Abbreviations 

BEACH Act Beaches Environmental Assessment and Coastal Health Act of 2000 

DPNR U.S. Virgin Islands Department of Planning and Natural Resources 

EPA U.S. Environmental Protection Agency 

OIG Office of Inspector General 

USVI U.S. Virgin Islands 

Cover photo: A view of Magen’s Bay in St. Thomas, U.S. Virgin Islands. (EPA OIG photo) 

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Washington, DC 20460
 Washington, DC 20460 
 

 

U.S. Environmental Protection Agency 14-P-0155 

March 31, 2014 Office of Inspector General 

At a Glance 

Why We Did This Review 

This is a quick reaction report 

that addresses requirements 

under the Beaches 

Environmental Assessment and 

Coastal Health Act of 2000 

(BEACH Act). Based on a 

request from the U.S. 

Environmental Protection 

Agency’s (EPA’s) Region 2 

Administrator, we are 

evaluating whether programs 

that the U.S. Virgin Islands 

(USVI) operates meet EPA 

requirements, and what steps 

EPA Region 2 has taken to 

ensure the programs have 

achieved the intended benefits. 

Region 2 provided to USVI a 

grant of more than $300,000 for 

weekly monitoring of USVI 

beaches over fiscal years 2013 

and 2014. Any issues to report 

on the territory’s overall 

performance in the BEACH Act 

or other environmental 

programs will be reported 

separately. 

This report addresses the 

following EPA themes: 

	 Making a visible difference 

in communities across the 

country. 

	 Protecting water: A 

precious, limited resource. 

For further information, 

contact our public affairs office 

at (202) 566-2391. 

The full report is at: 

www.epa.gov/oig/reports/2014/ 

20140331-14-P-0155.pdf 

Quick Reaction Report: EPA Oversight Needed to 

Ensure Beach Safety in U.S. Virgin Islands 

What We Found 

In violation of its agreement under the BEACH Act The lapse in sampling of grant with the EPA, the USVI Department of USVI beaches created risk 

Planning and Natural Resources (DPNR) did not that the public was 

monitor the beaches on St. Thomas and St. John exposed to unsafe levels 

for pathogens between February 3–16, 2014. of bacteria and the 

Under the grant, beach sampling is supposed to environment may have 

been endangered. occur on a weekly basis at 23 beaches on these 

two islands to identify any harmful levels of 

contamination in the water. In response to our draft report, Region 2 is acting to 

oversee and assess the USVI beach monitoring program. Region 2 took 

immediate action to address the lapse in sampling and asked the DPNR to 

develop a plan for notifying the EPA if sampling ceases again. Region 2 is also 

working to address the lack of a contract to conduct beach sampling. 

The DPNR restarted beach sampling on February 17, 2014. The lapse in 

sampling posed potential health hazards to humans and may have endangered 

the environment. The DPNR issued press releases, which two USVI newspapers 

printed on February 7 and 14, 2014, indicating that beaches in St. Thomas and 

St. John had not been monitored the previous week. This action was consistent 

with DPNR procedures for public notification. However, this may not be adequate 

notice for tourists visiting the USVI, as they may not read the local newspapers. 

 Recommendations and Corrective Actions 

We recommended that the EPA Regional Administrator, Region 2: 

	 Immediately take steps to ensure that the USVI beach monitoring and public 

notification meet EPA guidelines and continue. 

	 Determine whether the DPNR has a sustainable beach monitoring program 

in place (for example, with valid contracts for sampling and lab analysis) that 

will provide continuous beach monitoring and adequate public notification. 

If it is determined that the USVI beach monitoring program is not 

sustainable, the EPA should manage the program according to the BEACH 

Act until the DPNR can demonstrate it can meet all BEACH Act 

requirements and EPA guidance. 

The agency agreed with our recommendations and said actions it already has 

underway achieve the purpose of the recommendations. In response to 

recommendation 1, Region 2 stated it held a conference call with the DPNR to 

discuss the lapse, and requested DPNR prepare a contingency plan. In response 

to recommendation 2, EPA Region 2 described several areas where the region 

and the DPNR are working to address the beach monitoring program deficiencies. 
 

 

Judith A. Enck, Regional Administrator 

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

WASHINGTON, D.C. 20460 

THE INSPECTOR GENERAL 

March 31, 2014 

MEMORANDUM 

SUBJECT: Quick Reaction Report: EPA Oversight Needed to Ensure Beach Safety in 

U.S. Virgin Islands 

Report No. 14-P-0155 

FROM: Arthur A. Elkins Jr. 

TO: 

EPA Region 2 

This is a quick reaction report prepared by the Office of Inspector General (OIG) of the 

U.S. Environmental Protection Agency (EPA). The report addresses monitoring requirements 

under the Beaches Environmental Assessment and Coastal Health Act of 2000 (BEACH Act). 

This report represents the opinion of the OIG and does not necessarily represent the final EPA 

position. Final determinations on matters in this report will be made by EPA managers in 

accordance with established audit resolution procedures. 

Purpose, Scope and Methodology 

Based on a request from the EPA Region 2 Regional Administrator, the OIG is currently 

conducting an evaluation into the U.S. Virgin Islands (USVI) environmental programs. Our 

overall objectives are to assess whether programs that the USVI has implemented on the EPA’s 

behalf have met programmatic requirements, and what steps Region 2 has taken to ensure that 

the programs have achieved the intended environmental and human health benefits. As part of 

this review, the OIG is evaluating the USVI’s performance under the BEACH Act. The OIG may 

have additional issues to report on the territory’s overall performance in implementing the 

BEACH Act. These issues and our report on other environmental programs will be reported 

separately. 

We performed our work from November 2013 through February 2014 in accordance with 

generally accepted government auditing standards. Those standards require that we plan and 

perform our work to obtain sufficient, appropriate evidence to provide a reasonable basis for our 

findings and conclusions based on our audit objectives. We believe that the evidence obtained 

provides a reasonable basis for our conclusions based on our evaluation objectives. 

To evaluate the BEACH Act program operated by the USVI, we reviewed documents, conducted 

interviews with personnel and officials from the EPA and the USVI Department of Planning and 

14-P-0155 1 
 

 

 

Natural Resources (DPNR), interviewed the sampler for beach monitoring, and assessed data 

collected under the beach monitoring program. 

Background 

In 2000, the BEACH Act amended the Clean Water Act to address health problems arising out of 

contamination of public beaches from pathogens, such as disease-causing bacteria. It requires 

that states, territories and tribes adopt water quality criteria and standards and develop water 

quality monitoring and notification programs for beaches, including sampling and lab analysis. 

To carry out these tasks, the EPA provides states and other authorized government entities with 

federal grant money for monitoring tasks, to develop lists of beaches for sampling and criteria for 

identifying contaminants. In 2012, the EPA distributed $9.8 million in grants among U.S. states, 

territories and tribes to help protect America’s beaches. 

The USVI accepted an EPA grant of $303,000 for fiscal years 2013 and 2014 for weekly 

monitoring of 43 of its 148 beaches on the islands of St. Croix, St. John and St. Thomas. Under 

the grant, the DPNR is responsible for analyzing the monitoring results and informing the public 

of instances of beach contamination. The BEACH Act states that, “In the case of a State that has 

no program for monitoring and notification that is consistent with the performance criteria... 

the Administrator shall conduct a monitoring and notification program for the listed waters.”1 

The USVI coastline is dotted with numerous public beaches. Approximately 200,000 tourists 

frequent USVI beaches each month. Of the USVI 43 monitoring beaches, 23 are on St. Thomas 

and St. John while the remaining 20 are on St. Croix. The Virgin Islands Beach Monitoring 

Program evaluates nearshore water quality by analyzing samples collected from designated 

beach swimming areas along the shoreline. The sampling program determines whether human 

pathogenic water quality impairment exists at the designated swimming beaches by monitoring 

the presence and level of enterococci bacteria, a key indicator of contamination in marine water. 

Enterococci contamination leads to skin illnesses in bathers, and enterococci serve as an indicator 

of other related contaminants that can lead to gastrointestinal and respiratory illnesses in exposed 

swimmers. Waterborne pathogens such as bacteria, viruses and parasites can contaminate the 

water and sand at beaches and threaten human health. Contact with or accidental ingestion of 

contaminated water can cause vomiting, diarrhea and other illnesses, and may be life-threatening 

for susceptible populations such as children, the elderly and those with impaired immune systems. 

Beach pollution comes from many sources: nonpoint source pollution from failing septic 

systems, pollutants from urban and agricultural land that run into surface water, and pollutants 

from the boating community. In conjunction with numerous troubled components of the USVI 

public sewer system, these sources may be creating exposure health risks to swimmers at the 

territory beaches. Also, extensive coral reefs surround the USVI and are protected by the 

Endangered Species Act. The presence of fecal contaminants has been linked to coral disease. 

The DPNR is responsible for sampling the 43 monitored beaches on a weekly basis, and when a 

monitored beach exceeds the fecal contamination limit an advisory is issued for that beach in the 

1 33 U.S.C. § 1346(h). 

14-P-0155 2 
 

 

 

 

Friday press release. There were about 2,236 scheduled sampling events in 2012, the most recent 

year for which complete data are available. The DPNR issued beach advisories 36 times. The 

DPNR issued advisories for six of the 23 beaches on St. Thomas and St. John, including four 

advisories at Vessup Bay and two at Coki Beach. 

Beach Monitoring on St. Thomas and St. John Ceased for Two Weeks in February 

In violation of the terms of its BEACH Act grant with the EPA, the DPNR did not monitor 

beaches on St. Thomas and St. John between February 3–16, 2014. A lapse in sampling can pose 

health hazards to humans and may endanger the environment. 

Region 2 was aware that the DPNR did not have a contract with the company collecting beach 

monitoring samples and had not paid the company for sampling work since July 2012. Region 2 

senior officials provided documentation that they had contacted the DPNR repeatedly regarding 

this issue over the past year, with no results. However, neither the DPNR nor Region 2 had 

developed a contingency plan for collecting samples, analyzing results and posting warnings 

should the sampling cease, as eventually happened in February 2014. When we discussed the 

lapse in sampling with the responsible Region 2 staff on February 6, 2014, the person was 

unaware that sampling had not taken place. 

We have noted that the absence of a valid sampling contract that establishes standards and 

performance requirements could call into question the validity of beach monitoring samples 

collected without a contract and creates risk. However, Region 2 stated in its response to this 

report that it does not believe the validity of the sample collection was compromised due to the 

lack of a contract. Since we issued our draft report, EPA Region 2 informed us that DPNR has 

assigned department employees to collect samples until they develop a permanent arrangement 

for sampling. 

When the sampling lapsed, the DPNR issued press releases, which two USVI newspapers printed 

on February 7 and 14, 2014, indicating that beaches in St. Thomas and St. John had not been 

monitored for those weeks.2

 This followed DPNR procedures for public notification. However, 

this may not be adequate notice for tourists visiting the USVI, as they may not read the local 

newspapers and thus may be unaware of beach safety. 

The absence of beach monitoring on St. Thomas and St. John can pose a potential health hazard 

to swimmers at those beaches. Under the BEACH Act, the EPA must conduct a monitoring and 

notification program in the absence of an active program by the USVI. Consequently, the EPA 

needed to ensure that the USVI beach monitoring program resumed, and that contamination is 

reported to the public in a manner that is easily accessible to both residents and tourists. 

2

 Virgin Island Daily News available at http://virginislandsdailynews.com, and VI Source - St. John available at 

http://stjohnsource.com. 

14-P-0155 3 
 

 

 

 

Recommendations 

We recommend that the Regional Administrator, Region 2: 

1.	 Immediately take steps to ensure that the USVI beach monitoring and public notification 

meet EPA guidelines and continue. 

2.	 Determine whether the DPNR has a sustainable beach monitoring program in place 

(for example, with valid contracts for sampling and lab analysis) that will provide 

continuous beach monitoring and adequate public notification. If it is determined that the 

USVI beach monitoring program is not sustainable, the EPA should manage the program 

according to the BEACH Act until the DPNR can demonstrate it can meet all EPA 

guidelines. 

Agency Comments and OIG Evaluation 

We received comments on the draft report from the Region 2 Administrator (appendix A). The 

agency agreed with our recommendations and said actions it already has underway achieve the 

purpose of the recommendations. 

In response to recommendation 1, Region 2 stated it held a conference call with the DPNR to 

discuss the lapse, during which the DPNR stated it intended to continue using its staff to perform 

sample collection until a contract is in place. The region also requested that the DPNR prepare a 

written contingency plan that will go into effect if its beach grant contractors—either sample 

collection or analytical—become unavailable for any reason. Region 2 said that the DPNR plan 

shall include prompt notification to the EPA in the event that a contractor is no longer 

performing services. Region 2 requested that this plan be submitted by February 28, 2014, and 

the DPNR provided a plan on that date. Region 2’s actions are responsive to this 

recommendation. Recommendation 1 is resolved and closed. 

In response to recommendation 2, EPA Region 2 concurred with the importance of having a 

sustainable beach monitoring program in the USVI. Region 2 said that, “Programmatically, 

Region 2 believes the DPNR to be capable of running a beach monitoring program with adequate 

public notification.” However, Region 2 also included in its response a detailed description of the 

issues surrounding the DPNR’s ability to operate such a program. The deficiencies described by 

Region 2 included financial issues, lack of a current contract for beach sampling, issues with 

laboratory availability and capacity, and issues with maintaining and updating signs on beaches. 

The region’s response also described several areas where the region and the DPNR are working 

to address the beach monitoring program deficiencies. 

In a meeting to discuss the region’s comments on our draft report, Region 2 indicated it would 

complete its actions in response to recommendation 2 by September 30, 2014. The region 

provided acceptable corrective actions for recommendation 2 and the recommendation is 

resolved and open pending completion of corrective actions. 

14-P-0155 4 
 

 

 

We have no objections to the further release of this report to the public. We will post this report 

to our website at http://www.epa.gov/oig. 

If you or your staff have any questions regarding this report, please contact Carolyn Copper, 

Assistant Inspector General for Program Evaluation, at (202) 566-0829 or copper.carolyn@epa.gov; 

or Dan Engelberg, Director, Water Evaluations, at (202) 566-0830 or engelberg.dan@epa.gov. 

14-P-0155 5 
 

 

 

 

 

 

 

 

 

Status of Recommendations and 

Potential Monetary Benefits 

POTENTIAL MONETARY 

RECOMMENDATIONS BENEFITS (in $000s) 

Rec. 

No. 

Page 

No. Subject Status1 Action Official 

Planned 

Completion 

Date 

Claimed 

Amount 

Agreed-To 

Amount 

1 

2 

4 

4 

Immediately take steps to ensure that the USVI 

beach monitoring and public notification meet EPA 

guidelines and continue. 

Determine whether the DPNR has a sustainable 

beach monitoring program in place (for example, 

with valid contracts for sampling and lab analysis) 

that will provide continuous beach monitoring and 

adequate public notification. If it is determined that 

the USVI beach monitoring program is not 

sustainable, the EPA should manage the program 

according to the BEACH Act until the DPNR can 

demonstrate it can meet all EPA guidelines. 

C 

O 

Regional Administrator, 

Region 2 

Regional Administrator, 

Region 2 

2/28/14 

9/30/14 

O = recommendation is open with agreed-to corrective actions pending 

C = recommendation is closed with all agreed-to actions completed 

U = recommendation is unresolved with resolution efforts in progress 

14-P-0155 6 

1 
 

 

 

 

 

 

Appendix A 

Agency Comments on Draft Report 

February 28, 2014 

MEMORANDUM 

SUBJECT: Region 2 Comments on OIG Quick Reaction Report 

FROM: Judith A. Enck 

 Regional Administrator 

TO:	 Carolyn Copper 

Assistant Inspector General 

Office of Program Evaluation 

Thank you for the opportunity to comment on the Office of the Inspector General’s Quick 

Reaction Report on the U.S. Virgin Islands Department of Planning and Natural Resources 

(DPNR) Beaches Monitoring and Notification Program, dated February 19, 2014. 

Region 2’s responses to each recommendation in the report are as follows: 

OIG Recommendation #1 

"We recommend that the Region 2 Administrator immediately take steps to ensure that the USVI 

beach monitoring and public notification meet EPA guidelines and continue.” 

Region 2 Response 

Region 2 concurs and has addressed the Beaches program with DPNR. A conference call between 

EPA and DPNR was held on February 21, 2014. DPNR informed EPA that its beach grant 

sampling contractor for St. Thomas/St. John stopped collecting samples for a two-week period due 

to the failure of DPNR to make payment. DPNR is now using its own staff, trained in sample 

collection, to perform these duties. DPNR estimates it will take up to six months to effectuate a 

new contract for sample collection. DPNR intends to continue using its staff to perform sample 

collection until a new contract is in place. 

EPA requested from DPNR a written contingency plan in the event its beach grant contractors, 

either sample collection or analytical, becomes unavailable for any reason. The plan is to contain 

prompt notification to EPA in the event a contractor is no longer performing services. The 

14-P-0155 7 
 

 

 

timeframe for prompt notification is to be defined. EPA requested this plan be submitted by 

February 28, 2014. 

OIG Recommendation #2 

"We recommend that the Region 2 Administrator determine whether DPNR has a sustainable 

beach monitoring program in place (for example, with valid contracts for sampling and lab 

analysis) that will provide continuous beach monitoring and adequate public notification. If it is 

determined that the USVI beach monitoring program is not sustainable, the EPA should manage 

the program according to the BEACH Act until DPNR can demonstrate it can meet all EPA 

guidelines.” 

Region 2 Response 

Region 2 concurs with the importance of having DPNR maintain a sustainable beach monitoring 

program. We are aware of the financial management problems that have plagued DPNR. On 

September 30, 2011, EPA issued an audit resolution letter addressing DPNR’s response to findings 

raised in Single Audits performed by Ernst & Young LLP, Certified Public Accountants, as 

required by the Single Audit Act, for Fiscal Years 2007 and 2008. These audits raised numerous 

compliance and crosscutting internal control issues relating to all of DPNR’s programs. Our letter 

suspended DPNR from Automated Standard Application for Payments and placed it on a 

reimbursement method of payment. Shortly thereafter DPNR objected and claimed it would be 

unable to pay its bills in advance of receiving EPA funds, and requested relief. In addition, DPNR 

stated that it had implemented adequate internal controls and procedures for managing federal 

funds. In 2012 EPA agreed to place all of DPNR’s grants on a “modified reimbursement” method 

of payment. Also, at the DPNR Commissioner’s request, EPA conducted an on-site review in 

January 2012 to verify whether DPNR had implemented appropriate corrective actions and 

adequate internal controls and procedures for managing federal funds. The on-site review resulted 

in numerous findings and additional questioned costs. Region 2 has been working with DPNR 

since fiscal year 2011 to address its financial and grant management issues and we continue to 

press for improvements. 

EPA’s ongoing reviews of DPNR’s payment requests continue to identify significant concerns and 

have resulted in questioned and disallowed costs. Since being placed on the modified 

reimbursement method of payment, DPNR has been slow in submitting payment requests for the 

Beach program. Requests that have been submitted are missing information and are lacking 

approvable supporting documentation. Among other issues, DPNR did not provide copies of valid 

contract agreements as part of the supporting documentation. EPA’s October 30, 2013 response to 

its payment request package is attached. 

Beginning in June 2012, Region 2 received calls from the owner of DPNR's contract laboratory 

(Ocean Systems labs), who was pleading for our assistance in receiving long-overdue payments for 

water sample analyses the company did for the PPG and beach grants. She explained that she had 

not been paid by DPNR and was on the verge of going out of business because she was unable to 

pay her bills. Similarly, beginning in February 2013, the owner of the water sampling firm (Auset 

Water Testing) contacted the Regional Administrator’s office on numerous occasions over the past 

14-P-0155 8 
 

 

year regarding lack of payment from DPNR (see attached correspondence). While EPA has no 

jurisdiction over DPNR’s legal relationships with its contractors, we have tried to help facilitate 

the discussion between these firms and DPNR . In fact, DPNR now has a current contract with its 

contract laboratory, and Region 2 has recently authorized payment for the lab services. We have 

not yet authorized payment for the sampling services, however. We are waiting for sufficient 

documentation demonstrating that DPNR adhered to proper procurement regulations. It is 

important to note here that DPNR’s problems with delayed payments to its contractors predate the 

imposition of the modified reimbursement method of payment and that the sampling and reporting 

of beach water monitoring results continued until recently, even with this problem. 

Programmatically, Region 2 believes DPNR to be capable of running a beach monitoring program 

with adequate public notification. In addition to postings in local newspapers, DPNR’s Beaches 

workplan states, “the press releases are printed in the local news papers, aired on the local radio 

news, posted on the department’s website and published on other local online periodicals.” This 

meets the performance criteria as stated in the June 2002 National Beach Guidance and Required 

Performance Criteria for Grants, Chapter 5: Public Notification and Risk Communication, 5.3.4 

How to Notify: “A functional equivalent at the point of access could be a visual notice or personal 

interaction such as a flag at a beach or interaction with beach or park personnel. Other functionally 

equivalent measures not provided at the point of access include mass media (newspapers, 

television, and radio), Internet web sites, telephone hotlines, and technical reports.” DPNR has 

issued press releases in a timely manner. We agree that a sign at the beach would increase public 

notification, however DPNR has had difficulties maintaining and updating signs. We will urge 

DPNR to come up with a plan to address this issue. 

The lack of a current contract for sample collection is an issue that we will work to resolve. 

However, this situation does not compromise the validity of beach monitoring results, as the 

samples were collected in accordance with an approved quality assurance project plan, and 

analyzed by a laboratory that has demonstrated proficiency in performing analyses for 

microbiological contaminants. The OIG should be aware that Ocean Systems Laboratory, with 

facilities on both St. Thomas and St. Croix, is the only commercially available laboratory in the 

U.S. Virgin Islands (VI) that can provide analytical services for microbiology. Due to the short 

holding times involved from sample collection to analyses for microbiology (six hours), off-island 

laboratories cannot provide such services. Two years ago, Region 2 initiated a Caribbean Science 

Consortium, designed to encourage coordination between governmental, academic and private 

laboratories and foster growth in laboratory capabilities in the Caribbean. A workshop will be held 

this September in Puerto Rico bringing together interested parties. 

As a member of the Science Consortium, the University of the Virgin Islands (UVI) had expressed 

an interest in doing laboratory analysis to support environmental programs in the VI. In February 

2013, Region 2 conducted an on-site gap analysis of the UVI Environmental Analysis Laboratory 

located on the St. Thomas campus and held a “Laboratory Considerations” meeting on the St. 

Croix campus for their planned laboratory. The approach to the Laboratory on the St. Thomas 

campus was to assess the organization and operations against the guidance and requirements of 

EPA’s “Manual for the Certification of Laboratories Analyzing Drinking Water,” fifth edition, and 

identify any gaps. EPA issued a report listing these gaps and noted actions needed to help guide 

the laboratory. There was no UVI Laboratory Facility on St. Croix; however, plans were underway 

14-P-0155 9 
 

 

 

for the construction of one. The EPA review team held a meeting on the St. Croix Campus with 

VIDPNR and University representatives to review analytical needs and discuss the next steps 

needed to develop a laboratory program. Additional efforts will be made by Region 2 to bring 

additional critical laboratory services to the VI. 

Because tourists are frequent beachgoers in USVI, it is important to have signage or other 

information at the beach site to inform beachgoers who are not likely reading local media 

reports. Although the Beach Act does not require the closing of a beach, other states, such as New 

Jersey, have adopted into their State Sanitary Code the requirement that all coastal bathing beaches 

close when bacteria levels exceed water quality standards. Once a beach is closed, signage is place 

at the beach site and people are not permitted to enter the water. This approach would be the most 

protective of public health and should be evaluated. 

If you have any questions on the attached comments, please contact me at 212-637-5000 or John 

Svec of my staff at (212) 637-3699. 

Attachments 

14-P-0155 10 
 

 

Appendix B 

Distribution 

Office of the Administrator 

Regional Administrator, Region 2 

Agency Follow-Up Official (the CFO) 

Agency Follow-Up Coordinator 

General Counsel 

Associate Administrator for Congressional and Intergovernmental Relations 

Associate Administrator for External Affairs and Environmental Education 

Deputy Regional Administrator, Region 2 

Audit Follow-Up Coordinator, Region 2 

14-P-0155 11