INVOLVES THREE SEPARATE REMOVAL ACTIONS CONDUCTED BY EPA, AT THE REQUEST OF THE DEFENDANT: ON MARCH 27, 1998, THE USVI DEPT OF HEALTH REQUESTED EPA ASSISTANCE IN THE REMOVAL AND PROPER DISPOSAL OF OUT DATED CHEMICALS STORED IN ONE OF THEIR BLDGS AT THE OLD MUNICIPAL FACILITY IN CHARLOTTE AMALIE, SAINT THOMAS. ON NOV. 9, 1999, THE EPA RECEIVED A REQUEST FROM THE USVI DEP OF HEALTH TO CONDUCT A TIME CRITICAL REMOVAL ACTION ON TWENTY-EIGHT DRUMS LOCATED AT THE VI DEP OF AGRICULTURE SITE IN ESTATE LOWER LOVE, KINGSHILL, ST. CROIX. IN 1999, THE USVI REQUESTED THAT EPA CONDUCT A REMOVAL ACTION AT A SUPPLIES WAREHOUSE IN THE SUB BASE AREA OF ST. THOMAS, OPERATED BY THE USVI DEPT OF PROPERTY AND PROCUREMENT, CONTAINING DRUMS OF WASTE OIL, HERBICIDES, AEROSOL CANS OF SOLVENT-BORNE PAINT, CAUSTICE, AND DRUMS OF UNKNOWN SUBSTANCES. IN EACH OF THESE CASES, EPA COMMITTED THE APPROPRIATE FEDERAL FUNDING AND CONDUCTED THE REQUESTED REMOVAL ACTION WITH THE EXPRESS UNDERSTANDING THAT THE USVI COMMITTED TO REIMBURSE EPA FOR THESE REMOVAL ACTIONS.
AT EACH OF THE SITES, EPA CONDUCTED AND COMPLETED REMOVAL ACTIVITIES AND SHIPPED THE WASTES TO DISPOSAL SITES IN THE U.S. IN EACH OF THESE CASES THE USVI HAS NOT REIMBURSED THE EPA FOR THE REMOVAL ACTIVITIES.