ENVIRONMENTAL
STATUS REPORT
for the
COMMONWEALTH
OF
PUERTO RICO
May 1983
&EPA
INITED STATES ENVIRONMENTAL PROTECTION AGENCY
IEGION II
-------
PUERTO RICO
ENVIRONMENTAL STATUS REPORT
MAY 1983
-------
TABLE OF CONTENTS
SECTION PAGE
LIST OF FIGURES AND TABLES ' iv
AIR QUALITY
Measuring Air Quality Trends 1
Progress in Control of Conventional Pollutants 1
Status of Air Quality 2
Priority Air Quality Problems 6
Summary Table . 6
Detailed Discussion of Priority Problems 7
0 Total Suspended Particulates in Catano 7
0 Sulfur Dioxide in Guayanilla 7
0 Lead in San Juan and Guaynabo 7
8 CO in San Juan ' 7
SURFACE WATER QUALITY
Progress in Water Quality 8
Status of Water Quality 11
Priority Water Quality Problems 13
Summary Table ' 13
Detailed Discussion of Piority Problems 14
0 Conventional Pollution Problems Associated 14
with Municipal Discharges
0 Impact of Non-Point Sources on Water Quality 17
0 Surface Waters Contaminated by Toxics 21
0 Loss of Wetlands 21
SURFACE DRINKING WATER
Status of Public Water Supply Systems 23
Priority Drinking Water Problems 26
0 Insufficient Quantity 26
0 Need for Certified Laboratories to Analyze 26
PWS Samples
GROUND WATER
Status of Groundwater Resources 28
11
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TABLE OF CONTENTS (continued)
SECTION PAGE
Priority Groundwater Problem 30
0 Contamination of Wells with Organotetrachloride
in the Barceloneta Area 30
HAZARDOUS WASTE
Status of Hazardous Waste Disposal 31
Priority Hazardous Waste Problems 32
Class I Violators of RCRA Requirements 32
Siting of Hazardous Waste Facilities 32
Status of Uncontrolled Hazardous Waste Sites 33
Priority Superfund Problems 33
0 Uncontrolled Sites on the National Priority List 33
0 Potential Priority Candidates • 35
Spills of Oil and Hazardous Materials 35
PESTICIDES 36
RADIATION 36
ill
-------
LIST OF FIGURES AND TABLES
1 Number of Values Above
24-Hour TSP Standards Islandwide 2
2 TSP Long-Terra Trends
Catano Non-Attainment Area 3
3 TSP Long-Term Trends
Guayanilla Non-Attainment Area 3
4 The Puerto Rico Air Quality
Control Board Region . 4
5 Hydrographic Regions of Puerto Rico 8
6 Incidence of Bilharzia 18
7 Public Water Supplies 23
8 Size Distribution of CWS's 24
9 Percentage of Community PWS's in Violation 25
10 Community PWS's with Turbidity and
Bacti Violations 25
11 Groundwaters in Puerto Rico 28
12 Major TSD Facilities in Puerto Rico 31
13 Superfund Sites in Puerto Rico 33
Tabli? Page
1 Summary of Source Control
Priorities by AQCR 6
2 Trend Analysis of Surface Water Data
Using 1972 To 1981 Monitoring Data 10
3 Summary of Ambient Surface and Grcundwater
Problems by Hydrographic Regions 12
4 Summary of Source Control Priorities
by Region 13
5 Number of Known Pollution Sources in
the Hydrologic Regions Reflected by The
Surface Network 14
6 1981 Water Quality Standards Violations 15
7 Discharges of Point Sources of
Pollution to Lakes and/or Tributaries 16
8 Groundwater Quality in Puerto Rice 29
9 Characteristics of Priority Superfund
Clean-up Sites 34
IV
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AIR QUALITY
MEASURING AIR QUALITY TRENDS
Several indicators can be used to provide a picture of the
trends in air quality in the Commonwealth, For standards
based on an annual average concentration at each monitoring
site, the average can be plotted for a period of years to
determine the trend in air quality. Standards that use a
shorter averaging time, in addition to the annual average,
can be examined by several different methods. Two of these
methods are listed below.
0 Number of Times the Standard is Exceeded - This indicator
gives a direct assessment of how often the national air
quality standard was exceeded. Since these exceedences
are often associated with rare or low frequency meteoro-
logical events, the number of exceedences may vary widely
over time due to changes in weather from year to year.
0 Second Highest Value - The averaging time for certain
standards (i.e., TSP, SC>2, CO, and 03) is less than one
year. These standards allow one exceedence per year and
the second highest value is the value that must be at
or below the national standard for a location to attain
the air quality standard. It is often better to use this
value than the highest value observed. The highest value
"is not as important because, by itself, it does not indicate
a violation of the standard. Also, the highest value can
be variable from year to year as it is often more closely
linked to rare meteorological events than is the second '
highest value.
These indicators are used in the following discussion of the
air quality problems in Puerto Rico.
PROGRESS IN CONTROL OF CONVENTIONAL AIR POLLUTANTS
Although continuous total suspended particulate (TSP) measure-
ments have been performed in Puerto Rico since 1974, continuous
monitoring of gaseous pollutants and lead (Pb) is a relatively
recent addition to the island's air monitoring network.
Moreover, nitrogen dioxide is not continuously monitored in
Puerto Rico. As a result, sufficient dependable data do not
exist on gaseous pollutants and Pb to permit a meaningful
analysis of trends over the last decade. The following
discussion provides an islandwide overview of available data
on the progress achieved to date in controlling TSP in Puerto
Rico.
-------
FIGURE 1
VIOLATIONS OF SHORT-TERM TSP STANDARDS
(1974 - 1981)
NUMBER OP VRLUES RBOVE 24-HOUR TSP STRNDRRDS
ISLflND WIDE
60-1
54
Legend
EZ3 FRIMflRY
• SECONDflRY
31
19
1974 1975 1976 1977 1978 1979 1980 1981
YEflR
Since 1974, Puerto Rico has benefitted from a general decrease
in the frequency of violations of the short-term (twenty-four
hour) primary and secondary TSP standards. Figure 1 depicts
this general progress. Figures 2 and 3 display trends in
annual average TSP concentrations at four sites in the Catano
air basin, and three sites in the.Guayanilla air basin.
Although the Catano basin still experiences violations of
the TSP primary standard, the improvement in the Guayanilla
basin has been sufficient to prompt the Environmental
Quality Board to apply for redesignation of ths Guayanilla
air baiiin to attainment of the TSP secondary standard.
STATUS OF AIR QUALITY
Although the entire island of Puerto Rico is defined as one
Air Qucility Control Region (AQCR) , air basins and air quality
maintenance areas have been further delineated to address
attainment and maintenance of ambient air quality standards
(Figure 4).
TSP is the only air pollutant for which any pa:rt of Puerto
Rico hc.s been designated as non-attainment. The Catano
and Guc.yanilla air basins are the areas where :hese violations
occurred. In addition, the municipalities of Dorado and
Ponce e.re designated "unclassif iable" with respect to attain-
ment of the TSP standards.
"Unclassifiable" status has also been accorded to the Catano
air basin for sulfur dioxide (302), and to San Juan and Ponce
for carbon monoxide (CO).
-------
FIGURE 2
175-
ISO-
125-
TSP
CRTRNO
LONG-TERM TRENDS
NON-RTTRINMENT RRER
8=5
50-
as-
Legend ^
GZ3 URB. LAS VEGAS—CATANO
• USGS-FT. BUCHANAN
C33 URB. SERRA BAYAMdN
nm PUMP HOUSE—GUAYANABO
BH LEVmOWN—TOA BAJA
STflNDRRD
1974 1975 1976
1977 1978
YERR
1979 1980 1991
FIGURE 3
TSP LONG-TERM TRENDS
GURYRNILLR NON-RTTRINMENT RRER
175-1
150-
Legend
ZZ MAGAS ARRIBA
mm PLAYA GUAYANILL^
MONTE STELLA
PRIMflRY STRNDflRD
1974 1975 1976 1977 1978 1979
YEflR
1980 1981
-------
FIGURE 4
THE PUERTO RICO AIR QUALITY CONTROL REGION
Catano
Air Basin
Guayanilla
Air Basin
-------
The entire AQCR of Puerto Rico is in attainment of the nitrogen
dioxide (NC>2) and ozone (03) ambient standards.
Total Suspended Particulates
While the Catano air basin is the only area of Puerto Rico
that is not attaining the primary TSP standard, most monitoring
sites in Puerto Rico have recorded violations of the secondary
TSP standard in at least one of the last three years. In
general, the particulate concentrations in the cities of
Puerto Rico are near the secondary standard.
Further, dispersion modelling has indicated that the municipal-
ities of Dorado and Ponce may have the potential for air quality
contraventions. These two municipalities, therefore, have
been designated "unclassifiable" and are targeted for better
air quality monitoring, growth tracking, "hot spot" analysis
and enforcement against non-compliance.
Significant TSP sources in Puerto Rico include both point and
area sources. Point sources include power plants, refineries,
mineral processing plants and open burning dumps; area sources-
include fugitive dust and residential open burning.
Sulfur Dioxide
No locations in Puerto Rico are designated as non-attainment
for SC>2.
The Catano air basin, however, is designated "unclassifiable"
with respect to the attainment of the ambient S02 standard
because dispersion modelling has indicated a possibly of
violations of the standard. Nevertheless, limited ambient
S02 data from predicted "hot spots" have not revealed
elevated SC>2 concentrations. Major sources of SC>2 emissions
in the air basin include power plants and refineries.
The Guayanilla air basin has several major sources of SC>2 and
modelling work is being done to allocate the remaining Prevention
of Significant Deterioration (PSD) increment among the new sources,
Carbon Monoxide
Although no locations in Puerto Rico are designated as non-
attainment for CO, one site in the San Juan Metropolitan Area
recorded many violations of the 8-hour CO standard in 1981.
Additional analysis of traffic and ambient air quality is
necessary to better define the nature and extent of the
potential CO problem in this area.
-------
Ozone and Nitrogen Dioxide
The entire island is designated in attainment of the ambient
air quality standards for these two pollutants. NC>2 is not
monitored on Puerto Rico but is also not expected to be a problem.
The ambient ozone standard was exceeded once at Toa Baja
(downwind of San Juan). The monitor has been relocated to a
better site and further data are being collected.
Lead
Lead concentrations may be above the air quality standards
in parts of San Juan and Guayanabo, since the limited data
from trace metal monitoring sites in these areas showed
violations of the standards in the past. A new lead network,
started in January 1982, will help determine the attainment
status of these areas.
PRIORITY AIR QUALITY PROBLEMS
Table 1 presents a summary of Puerto Rico air quality source
control priorities. As the table indicates, there is only
one high priority air quality problem: TSP in Catano.
TABLE 1
SUMMARY OF SOURCE CONTROL PRIORITIES BY AQCR
Source
Control
Problem
Air
Basin
Point Sources
Area Sources
Catano
Air
Basin
H*(TSP)
M (SO2)
L (others)
H*(TSP)
L (S02)
L (others)
Guayanilla
Air
Basin
M (TSP)
M (.802)
L (others)
M (TSP)
L (S02)
L (others)
Remainder
of
AOCR
M (TSP)'
L (S02)
L (others)
M (TSP)
L (S02)
L (others)
* Priority rating may change depending upon results of receptor analysis
H - High Priority
M - Medium Priority
L - Low Priority
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Detailed Discussion of Priority Problems
0 TSP in Catano
The TSP primary air quality standard has been exceeded in the
Catano air basin at a minimum of one monitoring site every yea:
since sampling began in 1974. The Puerto Rico Environmental
Quality Board has asked EPA to help it solve the problem
with a source-receptor analysis.
0 Sulfur Dioxide in Guayanilla
The Guayanilla air basin has a potential problem with S02
concentrations. The basin is being modelled and monitored
to assure that air quality remains better than the ambient
air quality standards.
0 Pb in San Juan and Guaynabo
Violations of the lead standard were recorded at the EPA trace
metals sites in the San Juan and Guayanabo areas. Routine
monitoring of lead levels started in January 1982, and after
providing a year or two of data, should reveal whether a
problem exists with airborne lead.
0 CO in San Juan
One 'carbon monoxide monitoring site in San Juan has reported
many violations of the 8-hour average air quality standards.
Additional monitoring data will be needed to determine the
extent of this automotive pollution problem in Puerto Rico.
-------
SURFACE WATER QUALITY
PROGRESS IN WATER QUALITY
The Commonwealth of Puerto Rico is divided into the following
six major hydrographic regions (shown on Figure 5):
0 North
. ° Central
0 East
0 South
0 West
0 Offshore Islands
FIGURE 5
'Jesc Ijeion \"">'••'•"'''
'••..^ Cancral Raj
i "'";" x---'
UydrosraphLc Regions of ?uarca ;
-------
Puerto Rico's surface waters flow outward from a central
mountain range to the coast through a complex system of
tributaries. Some 100 rivers and creeks reach the coast,
but only 7 watersheds have drainage areas of over 100 square
miles (the largest being the 310-square mile drainage basin
of the Rio Grande de Loiza). Flows vary greatly as a result
of heavy and often short rain showers. Most rivers on the
south coast are dry during part of the year. A large number
of small rivers provide minimal assimilative capacity for
wastewater. The wastewater itself, whether from point or non-
point sources (NFS), when discharged to these water bodies,
often contributes a large percentage of the total flow.
The general water quality conditions of the water bodies
sampled indicate that the 1983 fishable/swimmable goal of
the Clean Water Act is not going to be achieved. Contact
recreation is precluded in many areas of Puerto Rico, both
in streams and in some coastal areas. In addition, potential
drinking water reserves, including aquifers, are contaminated
and must be protected, lakes are rapidly eutrophying, water
supply reservoir capacity is rapidly being depleted as a
result of sedimentation, and bilharzia continues to present
a potential health hazard both in lakes and streams.
There are significant water quality standards violations
islandwide; in particular they are the unacceptable coliform
levels and dissolved oxygen concentrations in surface waters.
The most common violation is of the fecal coliform standard.
Generally, this is a result of the overloaded waste treatment
facilities combined with poor operation and maintenance of
the collection, treatment, and disposal facilities. Other
contributing factors are improper on-site disposal of human
wastes in unsewered rural areas, and animal waste disposal.
Also contributing to ambient violations are raw wastewater
discharges, industrial discharges, and non-point sources
(e.g., agricultural and urban runoff).
Statistical water quality trends were analyzed using water
quality data from calendar years 1972 through 1981 (first ten
months in 1981). Mean concentrations (geometric mean in the
case of fecal coliforms) were calculated for each year for
the above parameters.
The results of the trend analysis are presented in Table 2.
Trend calculations for fifty-three out of a total of sixty-
four stations and parameters (83 percent), were not statistically
significant at the confidence level chosen. Statistically
significant upward trends were calculated at four stations,
two stations for increased total nitrogen and two stations for
increased fecal coliforms. Statistically significant downward
trends were observed at four stations, which included decreased
total phosphorus at three of the stations, and dissolved oxygen
(DO) deficit at two of the stations.
-------
TABLE 2
TREND ANALYSIS OF SURFACE WATER DATA
USING 1972 TO 1981 MONITORING DATA
U.S.G.S. Station
Number/Location
500 - 11400
Rio Guajacaca
500 - 29000
Rio Grande de Arecibo
500 - 38100
Rio Grande de Manati
500 - 39500
Rio Cibuco
500 - 46000
Rio de La Plata
500 - 48800
Rio Piedras
500 - 49106
Rio Piedras
500 - 50300
Quebrada Blasina
500 - 55000
Rio Grande de Loiza
500 - 55250
Rio Caquitas
500 - 71000
Rio Fajardo
500 - 82000
Rio Humacao
500 - 92000
Rio Grande de Pacillas
501 - 38000
Rio Guana jibo
501 - 44000
Rio Grande de Anasco
501 - 49100
Rio Culebrinas;
Parameters
DO Deficit
^
i
I
\!/
i
^
\
^
t
i
i
*
xl
t
1
^
1
*
1
I
A
i
^
\L'
A
1
i
Total Nitrogen
r
vi/
t
V
t
V
A
i
A
A
i
/i\
i
J
>i/
Vir
t
i
^
i
/T\
i
i
A
i
i
XL/
0
Total Phosphorus
i
\y
A
0
A
1
i
I
1
\j
i
\/
'^
i
^
i
,i ,
\i/
4
i
V
i
V
1
i
xV
Jr
i
^
Fecal Col i form
/N
1
./N
i
A
i
i
A
1
i
fr
j
I
V
^
i
t
/r\
i
i
^
i
i
t
/\
j
A
^
T
i
0 =
| =
A
i =
No Trend
Upward Trend (Statistically significant)
Upward Trend (Not Statistically significant)
Downward Trend (Statistically significant)
Downward Trend (Not Statistically significant)
10
-------
Although the lack of statistically significant trends makes
it difficult to make final determinations about progress in
water quality, efforts are continuing to control the effect
of point and non-point pollution sources 'on the island's
stream water quality. These efforts include the Small Com-
munities Program, the Surveillance and Complaints Division,
the Operational Program Development for Animal Waste Manage-
ment, Non-Point Sources Control Program in La Plata Lake
(Fertilizers and Pesticides), and the Non-Point Source Control
Program in Loiza Lake and the La Plata River Watershed.
In the past several years, extensive efforts have been under-
taken to remedy the illegal raw discharges along the San Juan
beachfront in the East Region. Data collected du-ring 1980,
1981 and 1982 indicate that the water quality along the Condado
and Isla Verde areas has been improved to the point of being
fit for direct contact recreation. Although progress has been
made in the Ocean Park beaches, the water along this area still
does not meet the standard for direct contact recreation.
With the implementation of delayed 201 projects at Aguadilla,
Arecibo, Camuy-Hatillo, Bayamon, Mayaguez, and Carolina,
significant water quality improvements of inland waterways
are anticipated (e.g., elimination of raw discharges). A
shortage of local matching funds has been cited as the most
significant cause of these delays.
The incidence of the waterborne disease, bilharzia, has
decreased significantly in recent years throughout the island.
Reduced human contact with freshwater streams and lakes
within Puerto Rico over the last 30 to 40 years and specific
control efforts have contributed to this decline of bilharzia.
STATUS OF WATER QUALITY
The surface water quality problems which are most pervasive
in the Commonwealth of Puerto Rico fall into the following
categories:
0 infectious agents (fecal colifontvs)
0 organic oxygen demanding materials
0 nutrients
0 sediments
11
-------
The extent and severity of the problems caused by conventional
pollutants in each of the six hydrographic regions on the
island are shown on Table 3. Insufficient toxics data are
available at this time.
TABLE 3
SUMMARY OF AMBIENT SURFACE AND GROUNDWATER
PROBLEMS BY HYDROGRAPHIC REGIONS
(Except where indicated the reference is
AMBIENT PROBLEMS REGIONS
East South West North
Organic Oxygen
Demanding
Materials H H H H
Infectious
Agents
Groundwater H M MM
Surface H H H' H
Nutrients
Groundwater H * * M
Surface H M M M
Toxxcs
Groundwater * H * H
Surface * * * *
Thermal
Discharges L L L L
Sediments
Groundwater M M * M
Surface H M M- H
Petroleum
Products (oil) M M L L
Hazardous
Wa:3te * * * *
H - High Priority
M - Medium Priority
L •- Low Priority
* - Unknown
surface water)
Offshore
Central Islands
H M
* *
H M
* *
M L
* *
* *
L L
* *
H L
L L
* *
12
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PRIORITY WATER QUALITY PROBLEMS
Table 4 summarizes for each hydrographic region the source
control problems that are high priority relative to other
problems in Puerto Rico.
TABLE 4
SUMMARY OF SOURCE CONTROL PRIORITIES BY REGION
MAJOR /HYDROGRAPHIC
SOURCE / REGION
PROBLEMS/
Municipal Discharges
On-lot Disposal
Sedimentation
Animal Wastes
Illegal Interconnections
of S-anitary & Storm
Sewers
Environmentally Unsound
Development
Direct Industrial
Discharge
Surface Water Supply
Quality
Surface Water Supply
Quantity
-P
X
X
X
X
X
X
X
X
5
&
X
X
X
X
X
X
X
•P
w
n
X
X
X
X
X
5
I
X
X
X
X
X
X
X
rH
1
$
X
X
X
X
X
X
M W
O T3
4-1 H
m U)
O H
X
X
X
13
-------
Detailed Discussion of Priority Problems
0 Conventional Pollution Problems Associated with Municipal
Discharges
The fecal coliform and DO problems exist islandwide and are
largely cue to discharges from municipal wastewater treatment
facilities. These problems are mainly the result of poor
management practices in these facilities. Some of the more
serious problems include poor operation and maintenance,
lack of preventive maintenance, and the need for more effective
controls on indirect industrial dischargers.
The situation is further compounded by industrial and raw
wastewater discharges. Illegal industrial wastewater discharges
are widespread in parts of the island, particularly in the
East and South regions. The apparently large number of non-
filers oi: NPDES permits (illegal discharges) presents a
problem. 'Enforcement against these specific discharges is
being carried out.
According to Table 5, the largest number of known point
sources of pollution are located in the East region. Based
on the magnitude of the DO and fecal coliform standards vio-
lations, the worst water quality conditions were also observed
in this region (see Table 6).
TABLE 5
NUMBER OF KNOWN POLLUTION SOURCES
REGIONS REFLECTED
POLLUTION SOURCES
Sewage Treatment
Plants (STPs)
Water Treatment
Plants
Oxidation Ponds
Industries
STPs discharging
to or near coastal
waters
IN THE HYDROLOG
1C
BY THE SURFACE NETWORK
1981)
NORTH
11
13
15
2
11
REGIONS
EAST SOUTH
27 2
20 1
27
27
31 12
WEST
7
5
1
2
11
14
-------
TABLE 6
1981
WATER QUALITY STANDARDS VIOLATIONS
FECAL COLIFORM
HYDROGRAPHIC
REGION
North & Central
East
South
West
Coastal
# OF
STATIONS
16
23
8
9
59
# OF
SAMPLES
68
91
36
19
326
% OF STATIONS
W/VIOLATIONS
75
91.3
87.5
66.7
54.2
% OF
SAMPLES
55.9
76.9
63.9
47.4
26.1
CO
% OF STATIONS
W/VIOLATIONS
12.5
34.8
50
11.1
10.2
% OF
SAMPLES
8.2
23.8
27.8
4.5
4.?
The discharge of untreated or inadequately treated wastewater
contributes to the high coliform levels, eutrophication,
sedimentation and the prevalence of bilharzia in the lakes in
Puerto Rico. Of the twenty-eight lakes and two lagoons,
nineteen are classified as eutrophic. ' Of these, seven are
used as potable water supplies.
The eutrophication problem is more serious in the lakes and
ponds in the East and South regions as compared with the
West and North regions. The increase in human activities
centralized in these areas and the consequent increase of
nutrient concentrations affect the lakes' trophic state.
In 1980 and 1981, significant violations of the total phosphorus
criteria, which apply only to water bodies upstream of lakes
and reservoirs, were observed in the basins of the East,
North, and South regions.
Table 7 presents an inventory of known point sources discharging
pollutants to the lakes (or their tributaries) used as potable
water supplies. Lakes Loiza and La Plata are the principal
reservoirs utilized_by the Aqueduct and Sewer Authority, and have
the most point source discharges. Four of the six sewage treat-
ment plants that discharge in the La Plata basin are discharging
more wastewater than their design capacity. However, the
lake with the most severe pollution problems is Lake Loiza.
15
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TABLE 7
DISCHARGES OF POINT SOURCES OF POLLUTION TO LAKES AND/OR TRIBUTARIES
Name of
tre Lake
Li. Plata
iarraizo
Carraizo
Cidra
Guajataca
Las Curias
Las Cuevas
Luchetti
Tea vaca
Carite
Garza
Patillas
Parameters
Regulated
Point Source
PRASA STP
Aibonito
PRASA STP
Ccmerio
PRASA STP
Cidra
PRASA STP
Barranguitis
PRASA ST?
Cayey
Consolidated
Cigar (Cayey)
Consolidated
Cigar (Corerio)
viclcs
Life Savers
Manufacture
Johnson 5
Johnson
Psncor Ire.
Las Piedras
Las Piedras
Industrial Park
PRASA STf
Pueblo del Rio
PRAS STP
Gurabo
PRASA STf
San Lorenzo
RCA Corp.
PRASA STi'
J uncos
PRASA ST!'
Caguas
PRASA ST!1
Aguas Duenas
RefrescoH de
Puerto R:.co
Cidra Viista
Monte
PRASA SIT
Lares
No Point Source
No Point Source
No Point Source
No Point Source
No Point Source
No Point Source
No Point Source
2
^
35
W -O
$ - if
i 5. g*
XXX
X
X X
XXX
X X
X
X X
X X
X X
X X
X
X X
XXX
X X
X
X
X X
X X
X X
X X
1
c Z
§ • 2
f S) u • " Si IS
fl> c) fi ^7 J3 ««
-'-'>. 3 >•?»>• "S i 'o I§ *
-------
Although Puerto Rico has been relatively successful among
tropical areas in combating waterborne diseases, a problem
persists with the parasitic disease called bilharzia (or
schistosomiasis). While heavy incidence of the disease is
concentrated in certain parts of the island, especially rural
areas (see Figure 6), it is generally prevalent throughout
Puerto Rico so that all inland surface waters can be assumed
to be contaminated with the parasite. Between 1 and 10 per-
cent of the island population is estimated to be infected
with bilharzia.
The persistence of waterborne diseases on the island is due
to a number of factors: a relatively dense rural population
with inadequate sanitary facilities, population centers with
substandard sewage collection and treatment systems, climatic
hydrologic factors favorable to parasite survival, and a public
too often unaware of the danger of infection.
Research in Puerto Rico has shown that primary sewage treatment
removes up to 80 percent of the schistosoma eggs and that
secondary treatment removes over 98 percent. Post-treatment
chlorination can kill all the eggs provided a sufficient
concentration is applied and adequate contact time is main-
tained. Effluent chlorination is'probably the best means
presently available for combating schistosoma egg discharge.
On-lot disposal of domestic waste in numerous small and
isolated communities has also contributed to the problems
mentioned above. The contamination of inland streams and
rivers by raw discharges from these communities has posed
serious water quality problems. Economic problems, lack of
awareness of the health hazards of raw discharges, and terrain
and soil characteristics have all contributed to the lack of
sanitary waste disposal systems in these communities.
0 Impact of Non-Point Sources on Water Quality
Non-point source (NPS) impacts are widespread throughout the
island. The major NPS categories include urban runoff (over-
land and through storm sewers), agricultural runoff, sediment
runoff from construction and mining, and on-lot disposal.
Problems associated with these dispersed sources range from
bacterial contamination (e.g., runoff from feedlot areas)
and waterborne diseases (e.g., on-lot disposal), to lake
eutrophication, sedimentation of reservoirs (e.g., agricultural,
construction and mining runoff) and elevated toxics levels
(e.g., pesticides from croplands). Because of the extremely
variable nature of NPS pollution, its effects have been
difficult to quantify.
17
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FIGURE 6
ISLA OC PUERTO HICO
INCIDENCE DE BILHARZIA
INCIDENCE OF BILHARZIA
i
0 - 4 8 %
5- 9.3 %
10-14.9%
IS -19.9 X
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Approximately sixty-eight percent of the lakes in Puerto Rico
are classified as eutrophic. Many of these lakes are directly
affected by rural communities lacking adequate wastewater
disposal, the presence of water hyacinths, inadequate agricul-
tural wastewater disposal (especially from livestock enterprises),
the presence of host snails for the parasite that causes
bilharzia, and mining and construction activities lacking
pollution control practices.
In the East region, San Juan is the major area of concern.
The water resource problems of the San Juan area relate
directly to rapid growth and intense socio-economic activities.
The resultant erosion and sedimentation are not only affecting
the water supply quality (e.g., high turbidity), but also
water supply quantity by reducing the holding capacity of
the San Juan area reservoirs.
Most of the San Juan metropolitan area receives water from
two major reservoirs in Puerto Rico, Lakes Loiza and La
Plata. Both of these reservoirs are losing holding capacity
rapidly as the result of increased sedimentation. In Lake
Loiza this problem is particularly severe (see more detailed
discussion below).
High bacterial and nutrient levels and low DO levels result
in part from the uncontrolled and poor waste disposal
operations of the thousands of dairy, hog and poultry farms
which generate approximately 763,000 dry tons/year of animal
waste. An estimated 99 percent of the oxidation ponds utilized
for livestock waste disposal are. poorly operated or lack
sufficient capacity. The bulk of the dairy farms are located
in the North region while hog and poultry farms are more
numerous in the East region.
In general, agricultural and urban runoff has a significant
impact on the fecal coliform loadings to surface waters in
the East region. In the South region, agricultural runoff
and industrial discharges contribute less to surface water
coliform violations but are mainly responsible for violations
of the ambient DO standards. The impact of NPS on fecal coli-
form loadings in the West Region is not considered significant.
Lake Loiza and Lake La Plata
As discussed above, erosion occurring in water supply reservoir
watersheds is causing a rapid depletion of storage capacity.
Lakes Loiza (Carraizo) and La Plata are the major sources of
potable water for the San Juan metropolitan area (80 percent),
serving approximately two million people. Lake Loiza, constructed
in 1953, has already lost 60 percent of its capacity and is
expected to be completely filled by the year 2020.
19
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Lake La Plata, built nine years ago, has been estimated to
have a higher rate of sedimentation than Loiza. Both sedi-
mentation and eutrophication are problems in the La Plata
River watershed. Inadequate practices in the handling of
dairies, plantations, hog farms, poultry farms, extraction
of sand and gravel, and construction of bridges and urban-
ization, among others, contribute to aggravate the problem.
The La Plata river watershed has been identified by the water
quality management program (under Section 208) and by other
studie:; as being seriously threatened by nutrient enrichment.
Improper use of fertilizers may be an important causative
factor. In addition, levels of pesticide concentrations have
been measured in the basin waters and sediment. This situation
is considered an emergency because this watershed is a major
potable water supply.
The problems affecting this watershed are not uncommon. They
are representative of problems encountered throughout the
island. The major pollutant sources in the watershed have
been defined.as non-point in origin. Agricultural activities
appear to contribute the major portion of nutrient and
pesticide contamination.
A lack of defined operating procedures and general education
programs often results in the overdosing of cultivated land
with fertilizers and pesticides in an attempt to achieve
maximum crop productivity. The Environmental Quality -Board's
(EQB's) control program for the La Plata river watershed is
directed towards the implementation of regulatory controls in
the application of fertilizers and pesticides. Its principal
objective is to develop a model non-point source control
program with regard to fertilizers and pesticide application
in the La Plata watershed area.
Through initial and continuing planning funded by Section 208
grants, programs on the control of dairy,' hog and poultry
wastes; for the protection of water quality have been or will
soon be developed. Existing legislation involving dairy farm
compliance with public health standards is being utilized by
EQB to review and approve dairy farm best management practices
(BMP) as part of the farmer's procedure for obtaining a required
operating license from the Puerto Rico Department of Health. In
addition, EQB is working with the Soil Conservation Service to
provide farmers with technical advice for implementation of
BMPs, and with the University of Puerto Rico - Cooperative
Extension to promote improved knowledge of BMPs. A similar
program is being sought for the control of hog and poultry wastes.
On July 16, 1980, the Water Quality Planning Bureau started
a project called the "Non-Point Source Control Program in
Loiza Lake and La Plata River Basin." As part of this project,
20
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inventories were conducted to identify critical areas for the
control of erosion and sediment in agricultural, construction,
and mining activities.
Agricultural, mining and construction data were combined with
other information on the water quality of the basin's water
bodies, population in each municipality, and the distance of
the non-point sources to water bodies. A comparative analysis
of the municipalities was developed and seven municipalities
were selected as critical areas, namely:
Loiza Lake La Plata River Basin
Caguas Cidra
Gurabo Cayey
San Lorenzo Toa Alta
Aguas Buenas
0 Surface Waters Contaminated by Toxics
Municipal and industrial discharges, residual wastes (sludges),
sewer overflows, oil and hazardous material spills, landfill
leachate, and other sources contribute to the toxics in Puerto
Rico waters. To date, very little toxics monitoring has
been conducted in surface waters. As additional monitoring
is conducted, the location and extent of toxics contamination
can be determined.
Beginning in 1983, the Environmental Quality Board
(EQB) will perform montt'hly sampling and analyses for toxic
pollutants in 16 river-basins distributed islandwide. This
twelve month effort will assist EQB in determining if any
designated stream uses are impaired by toxics, as well as the
location of the use impairments. The analyses will be
performed in accordance with EQB's water quality assurance
program plan approved by EPA on April 13, 1982.
0 Loss of Wetlands
Puerto Rico's coastal and inland wetlands, including mangrove
swamps and seagrass beds, are vital natural resources of
critical importance to the people of the Commonwealth.
Wetlands are areas of great natural productivity, hydrologic
utility, and environmental diversity, providing natural
flood control, improved water quality, recharge of aquifers,
flow stabilization of streams and rivers, erosion control,
habitat and nursery areas for fish and wildlife resources,
and are the prime source of food (detritus) in the food
chain. Wetlands contribute to the production of agricultural
products and timber, and provide recreational, scientific,
and .aesthetic resources of value.
21
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The unwise use and development of wetlands will destroy many
of their special value qualities and important natural func-
tions. The piecemeal alteration and destruction of wetlands
through draining, dredging, filling, and other means have had
an adverse cumulative impact on natural resources and on the
quality of human life. The destruction or degradation of
wetlands respresents an irreversible and irretrievable loss
of valuable aquatic resources.
The watland areas of Puerto Rico that have been assigned
greater priority due to their importance to wildlife include
the ::ollowing:
° Torrecillas, Pinones, Vacia Talega Complex (Carolina),
part of a mangrove system,
0 Tortuguero Lagoon (Manati and Vega Baja), and
0 Tiburones Swamp.
The mangrove areas of Puerto Rico have suffered as result of
industrialization and economic development on. the island.
Largo petrochemical complexes established on the south coast,
active development in the San Juan port area and urban expan-
sion led to the destruction of three quarters o.f the mangrove
areas;. Of those remaining, the most serious threat is to the
mangroves along the northeast coast from Boca de Cangrejos to
Fajardo, where development pressures are intense.
The Department of Natural Resources of Puerto Rico is presently
developing a comprehensive updated inventory of existing mangrove
areas, „
22
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SURFACE DRINKING WATER
STATUS OF PUBLIC WATER SUPPLY SYSTEMS
The sources of drinking water in Puerto Rico include rivers,
reservoirs, streams, lakes, and groundwater. There are 231
active public water systems islandwide. The systems are
characterized in Figure 7 by type of system, water supply
source, and population served.
FIGURE 7
PUBLIC WATER SUPPLIES IN PUERTO RICO
PUBLIC WflTER SUPPLIES
PUERTO RICO
PWS SOURCE
POPUUU10N SERVED
PWS TYPE
GROUND HATER
83 (36%)
GROUND HflTER
(157.)
The majority (85 percent) of Puerto Rico's population uses
surface waters as the primary source of drinking water; the
remainder uses ground water. The larger systems are usually
well operated and experience relatively few violations of
drinking water standards. As shown in Figure 8, there are
numerous small and very small systems throughout the state.
Most violations of drinking water standards occur in these
smaller systems.
23
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FIGURE 8
SIZE DISTRIBUTION OF GUIS ' S
PUERTO RICO
(50-i
SO. 2%
X DISTRIBUTION
•-» cu i* »••
3 O O O O
1 1 I.I .1
137.
i
0.22
3.82
•L
**
*>
37
22V.
Legend
CZ3 CWS'e
•• POP SERVED
SIZE CATEGORY
Overall, the quality of drinking water provided in these public
systems is good (Figures 9 and 10), despite the
poor quality of surface water sources. Hiah
bacterial counts are characteristic of many rivers throughout
«=™i 'R1C?' In 1981' however' 90 percent of the water
supply systems were in full compliance with the national
drinking water standards pertaining to microbiological quality
violates W?n%nrrmittent Vi°lat0^ and "one wire per^isteni
thi hn-MH-^ ^he same year, 78 percent of the systems met
the turbidity standard, 14 percent were intermittent violators
and 8 percent were persistent violators. violators,
I1 \~\ ^ >• • •
water ^^^f^^°^ Z^^*^.^
drinking water standards.
available on the radiation
In addition to drinking water quality specific to the
contaminants there has been an increasing concern in I
water°svste^ ^H^06 ^ Regulated contaminants in public
water systems. Although there are no enforceable standards for
its and they are not monitored under federal
they constitute a growing problem. As a result
sampling survey of all public water svst-»m<= in
Puerto Rico was conducted in 1982. ?his survej included
24 -
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FIGURE 9
PERCENTRGE OF COMMUNITY PWS'S IN 'VIOLATION
PUERTO RICO
40-
32X
QJ
CD
cn
C-3
ce:
UJ
o_
10-
Legend
ZZ3 1980
•i 1981
SIZE CflTESORY
FIGURE 10
COMMUNITY PWS'S WITH TURBIDITY
PUERTO RICO
60-1
BflCTI VIOLflTIONS
ZERO 1-3 >3
NUMBER OF VIOLflTIONS
Legend !
KZ2 1980
Mi 1981
25
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volatile organic compounds and trihalomethanes. To date 40
percent of the samples collected have been analyzed. Although
trace levels of volatile organics were identified, no
significant contamination has been found as yet. On the
other hand, recent surveys have found organic contaminants
in water supply wells throughout the island. This problem is
being investigated further at this time.
PRIORITY DRINKING WATER PROBLEMS
0 Insufficient Water Quantity
A problem related to water supply is diminishing reservoir
capacity. Erosion occuring in water supply reservoir water-
sheds is causing a rapid depletion of storage capacity. Lakes
Loiza (Zarraizo) and La Plata are the major sources of potable
water for the San Juan metropolitan are (80 percent), serving
approximately two million people. Lake Loiza has already lost
60 percent of its capacity. It will be completely filled by
2020 at current sedimentation rates. Lake La Plata, built
nine years ago, has been estimated to have a higher rate of
sedimentation than Loiza. The continued erosion and resulting
sedimentation of the reservoirs has the potential for depleting
the water supply of 80 percent of the metropolitan San Juan
population. The most critical sediment sources, islandwide,
have been identified as uncontrolled residential, commercial
and public facilities, construction activities, sand and
gravel mining operations, and cropland erosion. This problem
is especially acute in areas with steep slopes, where many of
these activities occur. Moreover, pesticides and fertilizers
attached to soil particles are transported to the lakes and
threaten the quality of the waters.
° Need i:or Certified Laboratories to Analyze Public Water Supply
Samp l«js
Since some of Puerto Rico Department of Health's (DOH) old
laboratory equipment became inoperative in 1982. DOH has
not been performing the analyses required in the national
interim primary drinking water regulations. Another problem
encountered by DOH is that three chemists and one microbiologist
have leflt the program and have not been replaced. In addition,
the Puerto Rico Aqueduct and Sewer Authority's (PRASA) chemistry
laboratory which also performs some analyses as the purveyor
for public water supplies has not been able to achieve DOH
certification.
In order- to solve the equipment problem, DOH requested and
received additional funds from EPA for the procurement of
laboratory equipment. DOH and EPA have recently agreed upon a
26
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recertification plan which requires DOH to have the laboratory
equipment on line by June 1983 and to hire and train three
replacement chemists. In addition, DOH is to take presecribed
steps to achieve recertification of their laboratory by
September 1983. If recertification is not obtained as planned,
EPA will require DOH to cut the chemist positions and contract
with a certified private lab for the require analysis.
As for PRASA's water supply laboratory, DOH is going to assess
the capability and certification potential of their laboratory.
If it is determined to be non-certifiable, DOH will require
PRASA to contract with an approved private laboratory to
conduct the required analysis.
27
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GROUND WATER
STATUS OF GRQUNDWATER RESOURCES
The major aquifers in Puerto Rico, shown in Figure 11, are
located along the northern and southern coastlines. Prelimi-
nary croundwater sampling done in late 1981 indicated varying
degrees of purity in these aquifers (Table 8). However,
this sampling effort can by no means be considered complete;
additional monitoring and groundwater intensive surveys .are
needed, c
FIGURE 11
GROUNDWATERS IN PUERTO RICO
AHEAS IN ?u£nTO rtico
The results of this preliminary survey are as follows:
- high salinity, indicated by high chloride con-
centrations, is a major problem in groundwaters
throughout Puerto Rico;
- bacterial contamination, in the form of fecal coliform,
was; present in about one-third of the wells and
springs sampled;
28
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TABLE 8
GROUNDWATER QUALITY IN PUERTO RICO
Range of Value Found by Region
Parameter
Temp.
pH
Cadimium
Magnesium
Sodium
Potassium
Bicarbonate
Chloride
Sulfate
Sulfide
Fluoride
Silica
North
23.5-27.5
6.8-7.7
68-130
1.8-88
5.9-620
0.1-24
243-337
9.4-1200
0.5-160
<0.1-0.2
<0.1-0.2
3.8-18
Total Organic 0.1-1.5
Carbon
Phenol
Nitrates/
Nitrites
Iron
Manganese
Cyanide
Coliform
-total
-fecal
NOTE: All
TOC
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- trace organics were detected in several wells, indicating
tha': more serious contamination of the aquifers could be
occuring; and
- high manganese concentrations, probably due to natural
leaching of rocks, is a common problem in ground waters
from aquifers in the southeast part of Puerto Rico.
Furthe:: groundwater surveys are currently underway in Puerto
Rico.
PRIORITY GROUNDWATER PROBLEM
0 Contamination of Wells with Organotetrachloride in the
Barcoloneta Area
Approximately 15,000 gallons of a mixture of carbontetrachloride
and acetonitrile leaked from an underground storage tank into
the ground water. As a result, municipal wells at Tiburones
and Garrochales were closed by the Department of Health in
addition to the industrial well at the UpJohn facility.
Attempts to locate the plume of contamination for possible
remedial action have been unsuccessful to date.
30
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HAZARDOUS WASTE
STATUS OF HAZARDOUS WASTE DISPOSAL
Hazardous waste generation and disposal in Puerto Rico is a
surprisingly large problem for a tropical island. Four
decades of planned industrialization have brought oil, petro-
chemicals, plastics, dyestuffs, Pharmaceuticals, electrical
and electronic machinery, and other hazardous waste generating
industries. There are 104 on-site treatment, storage and/or
disposal (TSD) facilities on Puerto Rico. Of these, the
facilities of most concern are those close to residential
areas, those which threaten groundwater aquifers or surface
water supplies, or those which have unique types and concen-
trations of chemical wastes. There are 26 of these major
facilities on the island (Figure 12). 'The TSD facilities
can include storage tanks, drum storage, lagoons, landfills
and/or incinerators on site.
FIGURE 12
MAJOR TSD FACILITIES IN PUERTO RICO
X - STORAGE / TREATMENT FACILITY
OR SURFACE IMPOUNDMENT
A- INCINERATOR
O - LAND DISPOSAL FACILITY
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PRIORITY HAZARDOUS WASTE PROBLEMS
° Class I Violators of RCRA Requirements
Region II is experiencing significant problems in having TSD
facilities comply with the monitoring and financial respon-
sibility requirements of the RCRA regulations. Monitoring
is needed at selected TSD facilities to determine if that
facility is havi.ng an impact on ground waters. In financial
requirements, many TSD facilities have not posted insurance
to cover damages associated with releases of hazardous materials
If not resolved, these Class I violations could lead to
future environmental problems.
0 Siting of Hazardous Waste Facilities
Currently, adequate commercial hazardous waste disposal
facilities do not exist in Puerto Rico. Legally, generators
of hazardous waste must either ship these wastes to the
continental United States (to approved facilities) or utilize
ocean dumping permits where available. The added cost of
operation with respect to the shipment of hazardous waste to
the "mainland" could eventually drive many of these generators
(many of which are major industrial concerns on the island) to
close their operations in Puerto Rico. The impact of these
closings on Puerto Rico's economy could be severe.
Unfortunately, much of the hazardous waste generated in
Puerto Rico is suspected of being illegally deposited along
with non-hazardous wastes at municipal sanitary landfills
throughout the island. Such illegal disposal practices may
result, in severe impacts on public health and the environment.
It is estimated that two large state-of-the art commercial
hazardous waste treatment, storage and disposal facilities on
the island will provide the capacity necessary to manage and
safely dispose of the hazardous waste generated by Puerto
Rico's 330 generators.
32
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STATUS OF UNCONTROLLED HAZARDOUS WASTE SITES
In December 1982, EPA published a list of the worst 418
uncontrolled hazardous waste sites in the country. EPA
asked for public review of and comment upon this list, which
is known as the National Priorities List. The list included
5 sites within Puerto Rico. These sites are shown on Figure
13 and described in Table 9. Several of these sites threaten
public drinking water supplies or they are located in sub-
stantially populated areas, or both.
FIGURE 13
SUPERFUND SITES IN PUERTO RICO
RCA Del Carite
Minicipality of. Barceloneta
1 Barceloneta Landfill
(•Xinicipality of Barceloneta
Juncos Landfill
Municipality of Juncos
Frontera Creek
Municipality of Hunacao |
IGeneral Electric
ICcnpany Wiring Devices
Irtmicipality of Juana Diaz
PRIORITY SUPERFUND PROBLEMS
0 Uncontrolled Sites on the National Priorities List (NPL)
As mentioned above, there are 5 sites in Puerto Rico on the
NPL. Each of these is a high priority to both the Region
and Puerto Rico.
33
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TABLE 9
Site Name
Frontera Creek
Juncos Landfill
PUERTO RICO
CHARACTERISTICS OF FRIGRITj: SUMKRHUND CLEAN-UP SITES
National Priorities List December 30, 1982
Potential Contaminants
Surface Water
0 Mercury
Potential Impacts
Groundwater
0 Mercury
General Electric Groundwater
Co. Wiring Devices ° Mercury
of Puerto Rico
Barceloneta
Landfill
0 Phenol
Groundwater
0 Chloroform
0 Toluene
0 Potential contamination of a small creek
which drains into the Caribbean Sea.
0 Potential for mercury entering the
food chain and contaminating fish,
humans and the endangered brown pelican.
0 Potential contamination of a public
water supply serving 30,000 people.
-* Potential contamination of public and
private wells serving 10,000 people
with water for drinking and irrigation
purposes.
0 Potential contamination of public
water supplies serving 12,000 people.
Clean-Up Action
0 GE has contracted
with a consultant
to determine the
extent of contamination
Water Supply
0 Chloroform
0 Toluene
0 Potential contamination of inter-
mittent stream located downgradient
and used for recreational purposes.
RCA Oil Caribe
Groundwater
0 Sileniuim
0 Chromium
0 Iron Chloride
0 Potential contamination of aquifer
serving 12,000 people via public supply
wells.
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0 Potential Priority Candidates
In addition to these sites, the Puerto Rico Environmental
Quality Board (PREQB) and EPA have identified other
uncontrolled hazardous waste sites that, although not
included on the National Priorities List, may also require
some clean-up effort. Some of these are TSD facilities.
Ongoing investigation at many of these sites will define
the hazards that they pose. As more information is ob-
tained from these investigations, EPA may add some or all
of these sites to the National Priorities List; this action
depends upon' the degree of hazard of the sites. Other-
wise, these sites will be assigned a lower priority and
will be addressed in the future either by the PREQB or,
as appropriate, by the Superfund program.
SPILLS OF OIL AND HAZARDOUS MATERIALS
Unintentional spills of oil and hazardous materials have
significant impacts on waterways throughout Region II. Both
surface and ground waters are affected.
All oil spills in Puerto Rico for 1980 and 1981 were minor
(less than 100,000 gallons). In 1980, 101 spills occurred;
93 occurred in 1981. Most were in San Juan, on the northern
shore of the island, and several were in Guayanilla and Ponce,
on the southern shore. In 1981, just over 24,000 gallons
were spilled.
Groundwater spills from underground storage tanks are also of
concern in Puerto Rico, but are not quantifiable at this time.
For example, in September 1982 a leak occurred from an
industrial facility in Barcelonetta: an estimated 15,000
gallons of a carbon tetrachloride-acetonitrile mixture
was released into surrounding soils and groundwater. Local
water supply wells had to be closed as a result. Cleanup
operations are currently underway.
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PESTICIDES
The EPA. pesticide programs are directed toward oversite of the
federally funded, state implemented programs.
The Puerto Rico programs are mainly concerned with certi-
fication of pesticide applicators and monitoring the proper
manufacture, sale and use of pesticides to assure safe
storage, handling and application of these items.
There are approximately 15 pesticide manufacturers in Puerto
Rico. They produced about 5.3 million pounds and 6 million
gallons of pesticides in 1981.
Puerto Rico has ascertained that violations of local and
federal laws fall into the following categories: marketplace
inspections 47.3%, producer establishment inspections 3303%,
non-agricultural use inspections 12.2% and agricultural
use inspections 7.2%
RADIATION
There are no existing radiation sites or nuclear power reactors
operating in Puerto Rico. However, the EPA has, as part of its
Environmental Radiation Ambient Monitoring Systems (ERAMS),
milk and drinking water sampling stations at San Juan.
The system is comprised of a network of sampling sites,
situated throughout the United States, to reflect ambient
radiation levels caused by nuclear activities. Samples of
environmental media (such as milk and drinking water), by
which rc.dioactivity can reach the general public, are collected
periodically from these locations. These samples are analyzed
at the Eastern Environmental Radiation Facility (EERF) in
Montgomery, Alabama.
The maintenance of the ERAMS network is gaining increased
importance because of heightened concern over radiation by
the general public. Both the baseline and unusual activity
data provide quantitative information on trends and poten-
tial population exposure.
36
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