Espino WTP EJ Analysis


ESPINO WTP EJ ANALYSIS
1. Introduction and summary

A. Briefly describe EO 12898, "Federal Actions to Address Environmental Justice in Minority
Populations and Low-Income Populations/' etc.

The U.S. Environmental Protection Agency (EPA), Region 2, has performed an Environmental
Justice (EJ) analysis in accordance with the President's Executive Order 12898 "Federal
Actions to Address Environmental Justice in Minority Population and Low-Income
Populations" following the Regional Policy. Environmental Justice is the right to a safe,
healthy, productive and sustainable environment for all, where "environment" is considered
in its totality to include the ecological, physical, social, political, aesthetic and economic
environments.

Executive Order 12898 (the "Order") was signed by President Clinton on February 11, 1994,
to focus federal attention on the environmental and human health conditions of minority and
low-income populations with the goal of achieving environmental protection for all
communities. The Order directed federal agencies to develop environmental justice
strategies to help federal agencies identify and address disproportionately high and adverse
human health or environmental effects of their programs, policies and activities on minority
and low-income populations. The Order is also intended to promote nondiscrimination in
federal programs substantially affecting human health and the environment, and to provide
minority and low-income communities' access to public information in matters relating to
human health. The Order underscores certain provisions of existing law that can help ensure
that all communities and persons across the nation live in a safe and healthful environment.

It is important to note that the major tenet of environmental justice is the fair treatment and
meaningful involvement of the affected community in carrying out the Agency's and the
Region's programs, policies and activities. Fair treatment and meaningful involvement should
not be understood to mean preferential treatment for certain communities. Rather, these
principles should be understood to mean the Agency and Region will continue to provide
equal protection and access to information to all served communities. Fair treatment and
meaningful involvement may include, but not be limited to ensuring to the extent possible
and practicable, the following:

•	that notices about public meetings are disseminated in local media used by the
community, and that such notices are translated into appropriate languages other than
English, if a community is largely non-English speaking;

•	that environmental laws are enforced equally in all communities;

•	that Regional managers and their staff understand and are aware of cultural differences
and unique dependence some communities, such as tribal nations and indigenous
peoples, have upon their land for subsistence fishing and hunting; and

-------
• that communities have access to accurate, timely and reliable information.

B. Summarize the factual conclusions of the EJ analysis and any linkages to proposed permit terms or
other permit outcomes

After considering the EJ indexes, demographic information and proximity to residential areas
(as shown in maps below), the community that directly surrounds (2 miles ration) the Espino
WTP would be considered a community with issues of EJ concern.

2. Proposed permitted activity and regulatory framework (Worksheet section

A. Describe the requested permit action (e.g., new permit or renewal), the facility and the
applicable regulatory framework (e.g., CAA/PSD, CWA/NPDES, SDWA/UIC, RCRA, TSCA)

Renewal of CWA/NPDES minor permit for PRASA Espino WTP in Puerto Rico.

The effluent limitations and permit conditions in the permit have been developed to ensure
compliance with the following, as applicable:

>	Clean Water Act section 401 certification requirements;

>	NPDES regulations (40 CFR Part 122); and

>	PRWQS (August 2022).

B. Note other types of permits required by EPA statutes (e.g., PSD, NNSR, NPDES, UIC, RCRA,
TSCA) that are in place or are being sought for the same facility, and the agency responsible
for issuing that permit or identified by the permit applicant (e.g., EPA, state or local agency),
as indicated by EPA's ECHO database [ httos://echo.eoa.aov. select "Single Facility Search]

There are no other permits required by EPA Statutes. However, the Permittee has a Consent
Decree with the Agency Civil Action No 3:15-CV-02283(JAG)) in which the facility is included.
This consent decree does not affect this permit action.

3. Geographic area(s) identified by screening step per Regional
Implementation Plan	

A. Identify area(s) (with maps, if practicable) near the facility that the EJ in Permitting screening
process has prioritized for EJ analysis.

-------
vvEPA

United States
Environmental Protection
Agency

EJScreen Report (Version 2.1)

1 mile Ring Centered at 18.189806,-65.964682, PUERTO RICO, EPA Region 2

Approximate Population: 10,406
Input Area (sq. miles): 3.14

eOB

¦Ml e, -t«t am

B. Explain how the area(s) were identified (e.g., use of EJSCREEN; information contained in the
permit application or developed by the permitting program indicating areas of pollution
impacts/plumes)

Satellite maps were found using the facility information on the NPDES application and
EJSCREEN, which was also used to create a 2-mile buffer around the facility. Based on the
image above, we can conclude that the area surrounding the water treatment plant is
partially residential.

4. Description of communities identified by screening step (Worksheet
section 4)

A. Social Demographics. This information, in conjunction with the health information below,
may help identify a community's potential vulnerabilities.

-------
A United States A ..

EJScreen Report {Version 2.1)

1 mile Ring Centered at 18.189806,-65.964682, PUERTO RICO, EPA Region 2
Approximate Population: 10,406
Input Area (sq. miles): 3.14

Selected Variables

Value

State

%ile In

USA

%lle in

Avg.

State

Avg.

USA

Socioeconomic Indicators

Demographic Index

87%

83%

35%

People of Color

100%

99%

40%

Low Income

73%

72%

30%

Unemployment Rate

10%

15%

Limited English Speaking Households

69%

68%

Less Than High School Education

24%

22%

12%

Under Age 5

Over Age 64

19%

20%

16%

The area around Espino WTP includes a 100% minority population, a largely linguistically
isolated population, and an 73% low-income population. This indicates that the area could
be a community of EJ community.

B. Environment/Land Use Information. This information can help determine whether a
community may be considered overburdened from other sources of pollution not directly related
to the action being permitted and also identify potential pathways for exposure.

The Environmental indicators surrounding the Espino WTP are shown in the Table below. Indicators
as the National-Scale Air Toxic Assessment (NATA) is EPA's ongoing, comprehensive evaluation of
toxics in the United States. EPA developed this tool to prioritize air toxics, emissions sources and
location of interest for further studies. It is important to mention that NATA provides broad
estimates of health risks over geographic areas, not definitive risks to specific individuals or locations.
These indicators are lower in the Espino WTP surrounding area than the rest of the Island. Therefore,
EPA concludes that the potential for a disproportionate and/or adverse environmental burden in the
area is minimal to none in this area.

-------
UnrtedStales	^	... , . ..

^rrfl i^^nnitTttKim.	EJScreen Report (Version 2.1)

1 mile Ring Centered at 18.189806,-65.964682, PUERTO RICO, EPA Region 2
Approximate Population: 10,406
Input Area (sq. miles): 3.14

Selected Variables

Value

State

%ile in

USA

%ile in





Avg.

State

Avg.

USA

Pollution and Sources

Particulate Matter 2.5 (pg/m3)

N/A

N/A

N/A

8.67

N/A

Ozone (ppb)

N/A

N/A

N/A

42.5

N/A

Diesel Particulate Matter' (pg/ms)

0.0326

0.108

38

0.294

<50th

Air ToxiCS Cancer Risk (lifetime risk per million)

20

23

0

28

<50th

Air Toxics Respiratory HI"

0.2

0.21

0

0.36

<50 th

Traffic Proximity (dai&y traffic count/distance to road)

340

610

58

760

58

Lead Paint (% Pre-1960 Housing)

0.19

0.14

73

0.27

47

Superfund Proximity (site count/km distance)

0.14

0.15

75

0.13

77

RMP Facility Proximity (facility count/km distance)

1.5

0.97

81

0.77

84

Hazardous Waste Proximity (facility count/km distance)

0.7

0.9

59

2.2

50

Underground Storage Tanks (count/km1)

1.3

1.7

70

3.9

51

Wastewater Discharge (toxicity-weighted concentration/in distance)

0.0074

5

61

12

67

For additional information see: https://www.epa.gov/ejscreen

-------