Puerto Rico Aqueduct and Sewer Authority NPDES NO. PR0026549 Culebra WWTP United States Environmental Protection Agency Region 2 Caribbean Environmental Protection Division City View Plaza ll-Suite 7000, #48 Rd. 165 km 1.2 Guaynabo, Puerto Rico 00968-8069 Draft FACT SHEET NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM Culebra WWTP PERMIT No. PR0026549 This Fact Sheet sets forth the principle facts and technical rationale that serve as the legal basis for the requirements of the accompanying draft permit. The draft permit has been prepared in accordance with Clean Water Act (CWA) section 402 and its implementing regulations at Title 40 of the Code of Federal Regulations (CFR), Parts 122 through 124, and the Water Quality Certificate (WQC) issued by the Puerto Rico Department of Natural Resources (DNER) pursuant to CWA section 401 requirements. Pursuant to 40 CFR 124.53, the Commonwealth of Puerto Rico must either grant a certification pursuant to CWA section 401 or waive this certification before the U.S. Environmental Protection Agency (EPA) may issue a final permit. On November 17, 2022, DNER provided in the IIWQC that the allowed discharge will not cause violations to the applicable water quality standards at the receiving water body if the limitations and monitoring requirements in the IIWQC are met. In accordance with CWA section 401, EPA has incorporated the conditions of the IWQC into the draft permit. The IIWQC conditions are discussed in this Fact Sheet and are no less stringent than allowed by federal requirements. Additional requirements might apply to comply with other sections of the CWA. Review and appeals of limitations and conditions attributable to the IIWQC were made through the applicable procedures of the Commonwealth of Puerto Rico and not through EPA procedures. PART I. BACKGROUND A. Permittee and Facility Description The Puerto Rico Aqueduct and Sewer Authority (PRASA) (referred to throughout as the Permittee) has applied for renewal of its National Pollutant Discharge Elimination System (NPDES) permit. The Permittee is discharging pursuant to NPDES Permit No. PR0026549. The Permittee submitted Application Form 1, and 2A, dated May 28, 2021, and applied for an NPDES permit to discharge treated wastewater from Culebra WWTP called the facility. The facility is classified as a minor discharger by EPA in accordance with the EPA rating criteria. The Permittee owns and operates wastewater treatment plant which provides tertiary treatment. Attachment A of this Fact Sheet provides a map of the area around the facility and a flow schematic of the facility. The treatment system consists of the following: The Culebra WWTP is a publicly owned treatment work (POTW) that treats sanitary wastewater through tertiary treatment of the domestic sewage from the Municipality of Culebra. It has a capacity of 0.2 MGD (design flow rate), and provides tertiary treatment and discharge its effluent to an unnamed intermittent creek. Sanitary wastewater is processed through the following units, see Attachment A (Schematic Flow Diagram for more details: > Grit Removal System > Sequencing Batch Reactor, also known as SBR (aeration, mixer and decanter) > Sedimentation Tanks > Granular Media Filter > Chlorination System > Artificial Wetland > Sludge is thickened, dewatered and disposed in a landfill. NPDES Fact Sheet 1 ------- Puerto Rico Aqueduct and Sewer Authority NPDES NO. PR0026549 Culebra WWTP Summary of Permittee and Facility Information Permittee Puerto Rico Aqueduct and Sewer Authority (PRASA) Facility contact, title, phone Mr. Edgardo Bermudez Valentin Compliance and Quality Control (787) 620-2270 Permittee (mailing) address Puerto Rico Aqueduct and Sewer Authority P.O. Box 7066 Barrio Obrero Station Santurce, Puerto Rico 00916-7066 Facility (location) address San Isidro Ward Culebra, P.R. 00775 Type of facility Publicly-owned Treatment Works Pretreatment program N/A Facility monthly average flow 0.227 MGD (in million gallons per day) Facility design flow 0.20 MGD (in million gallons per day) Facility classification Minor B. Discharge Points and Receiving Water Information Wastewater is discharged from Outfall 001 to the Bairoa River, a water of the United States. The draft permit authorizes the discharge from the following discharge point(s): Outfall Effluent description Outfall latitude Outfall longitude Receiving water name and classification 001 Tertiary municipal wastewater. 18°, 19", 9.971" N 65°, 16', 56.712" W Unnamed Intermittent Creek, Class SD waters As indicated in the Puerto Rico Water Quality Standards (PRWQSR) Regulations, the designated uses for Class SD receiving waters include: > intended for use as a raw source of public water supply; > Primary and secondary recreation; and > Propagation and preservation of desirable species, including threatened and endangered species. CWA section 303(d) requires the Commonwealth of Puerto Rico to develop a list of impaired waters, establish priority rankings for waters on the list, and develop TMDLs for those waters. The receiving water has not been determined to have water quality impairments for one or more of the designated uses as determined by section 303(d) of the CWA. C. Compliance Orders/Consent Decrees The Permittee has a Consent Decree with the Agency (civil action no 06-16-24 (sec)) in which the facility is included. This consent decree does not affect this permit action. D. Summary of Basis for Effluent Limitations and Permit Conditions - General 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 > PRWQSR (August 2022). NPDES Fact Sheet 2 ------- Puerto Rico Aqueduct and Sewer Authority NPDES NO. PR0026549 Culebra WWTP PART II. RATIONALE FOR EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS CWA section 301(b) and 40 CFR 122.44(d) require that permits include limitations more stringent than applicable technology-based requirements where necessary to achieve applicable water quality standards. In addition, 40 CFR 122.44(d)(1)(i) requires that permits include effluent limitations for all pollutants that are or may be discharged at levels that cause, have the reasonable potential to cause, or contribute to an exceedance of a water quality criterion, including a narrative criterion. The process for determining reasonable potential and calculating water quality-based effluent limits (WQBELs) is intended to protect the designated uses of the receiving water, and achieve applicable water quality criteria. Where reasonable potential has been established for a pollutant, but there is no numeric criterion for the pollutant, WQBELs must be established using (1) EPA criteria guidance under CWA section 304(a), supplemented where necessary by other relevant information; (2) an indicator parameter for the pollutant of concern; or (3) a calculated numeric water quality criterion, such as a proposed state criterion or policy interpreting the state's narrative criterion, supplemented with other relevant information, as provided in 40 CFR 122.44(d)(1)(vi). The effluent limitations and permit conditions in the permit have been developed to ensure compliance with all federal and state regulations, including PRWQSR. The basis for each limitation or condition is discussed below. A. Effluent Limitations The permit establishes both Technology-based Effluent Limitations (TBELs) and WQBELs for several pollutants and the basis for these limitations are discussed below. 1. Flow: An effluent limitation for flow has been established in the permit for 0.20 MGD as a Daily Maximum. Monitoring conditions are applied pursuant to 40 CFR 122.21 (j)(4)(ii) and IIWQC. The frequency monitoring for flow shall be continuous with a flow meter 2. 5-Day Biochemical Oxygen Demand (BODs): The effluent concentration and percent removal limitations are based on technology-based secondary treatment standards for publicly owned treatment works (POTWs) specified in 40 CFR 133.102(a). The permit also requires influent monitoring and reporting in accordance with 40 CFR 122.44(i) to meet the requirement of the percent removal limitation (see section C.1.—Monitoring Requirements— of this Part). 3. Total Suspended Solids (TSS): The effluent concentration and percent removal limitations are based on technology-based secondary treatment standards for POTWs specified in 40 CFR 133.102(b). The permit also requires influent monitoring and reporting in accordance with 40 CFR 122.44(i) to meet the requirement of the percent removal limitation (see section C.1.—Monitoring Requirements— of this Fact Sheet). 4. Color: The effluent limitation is based on the water quality criterion for Class SD waters as specified in Rule 1303.2.C.2.e of PRWQSR, and the IIWQC. 5. Dissolved Oxygen (DO): The effluent limitation is based on the water quality criterion for Class SD waters as specified in Rule 1303.2.C.2.a of PRWQSR, and the IIWQC. 6. Enterococci: The discharge consists of domestic sewage that is a source of pathogens. To ensure that the recreational use of the water body is met, effluent limitations for Enterococci are established in the permit and are based on the water quality criterion for Class SD waters as specified in Rule 1303.2.C.2.C of PRWQSR, and the IIWQC. EPA establishes a monitoring frequency of the enterococci density in terms of geometric mean of at least six representative samples taken sequentially shall not exceed 35 colonies/100 mL. No single sample should exceed the upper confidence limit of 75% using 0.7 as the log standard deviation until sufficient site data exist to establish a site-specific log standard deviation. 7. pH: The effluent limitation for pH is based on technology-based secondary treatment standards for POTWs for Class SD waters as specified in Rule 1303.2.C.2.d of PRWQSR, and the IIWQC. In no case the pH will lie outside of 6.0 to 9.0, standard pH units, except when it is altered by natural causes. 8. Solids and Other Matters: The effluent limitation is based on the water quality standards as specified in Rule 1303.1.A of PRWQSR, and the IIWQC. 9. Surfactants as Methylene blue active substances (MBAS): The effluent limitation is based on the water quality criterion for Class SD waters as specified in Rule 1303.2.C.2.i of PRWQSR, and the IIWQC. 10. Suspended, Colloidal orSettleable Solids: The effluent limitation is based on the water quality standards as specified in Rule 1303.1.E of PRWQSR, and the IIWQC. NPDES Fact Sheet 3 ------- Puerto Rico Aqueduct and Sewer Authority NPDES NO. PR0026549 Culebra WWTP 11. Taste and Other Producing Substances: The effluent limitation is based on the water quality criterion for Class SD waters as specified in Rule 1303.2.C.2.h of PRWQSR, and the IIWQC. 12. Temperature: The effluent limitation for temperature is based on the water quality criterion for all waters in Puerto Rico as specified in Rule 1303.1 .D.1 of PRWQSR, and the IIWQC. 13. Turbidity: The effluent limitation is based on the water quality criterion for Class SD waters as specified in Rule 1303.2.C.2.f of PRWQSR, and the IIWQC. 14. Copper, Cyanide (CN), Lead, Residual Chlorine, Sulfide (undissociated H2S), and Zinc: The effluent limitations are based on the water quality standards for Class SD waters as specified in Rule 1303.1 .J.1 of PRWQSR, and the IIWQC. 15. Pentachlorophenol: The effluent limitations is based on water quality criteria established in PRWQS Rule 1303.1 .J.2.a of PRWQS and the IIWQC. 16. Total Ammonia Nitrogen (TAN): The effluent limitation is based on the water quality criterion for Class SD waters as specified in Rule 1303.2.C.2.I of PRWQSR, and the IIWQC. 17. Total Nitrogen (TKN, NO2, NO3): The effluent limitation is based on the water quality criterion for Class SD waters as specified in Rule 1303.2.C.2.m of PRWQSR, and the IIWQC. 18. Total Phosphorous: The effluent limitation is based on the water quality criterion for Class SD waters as specified in Rule 1303.2.C.2.n of PRWQSR, and the IIWQC. 19. Whole Effluent Toxicity (WET): The permit establishes a requirement for the Permittee to conduct accelerated testing and develop a Toxicity Reduction Evaluation (TRE) Workplan as Special Conditions. These requirements are necessary to ensure that the Permittee has a process for addressing effluent toxicity if toxicity is observed. B. Effluent Limitations Summary Table 1. Outfall Number 001 Parameter Units Effluent limitations Averaging period Highest Reported Value (1) Existing limits Interim limits Final limits Basis BOD5 mg/L Average monthly Average weekly 216 282 (maximum daily) 5.0 45.0 - 5.0 45.0 TBEL kg/day Monthly average Weekly average 11 28 3.78 34.06 - 3.78 34.06 TBEL minimum % percent Average monthly 59 (lowest reported value) 85 - 85 TBEL Color Pt-Co Daily Maximum 70 15 - 15 WQBEL Copper Mg/i Daily maximum 93 9.3 - 9.32 WQBEL Cyanide (CN) Mg/i Daily maximum 4.24 5.2 - 4.0 WQBEL Dissolved Oxygen mg/L Daily Maximum 7.25 >5.0 - >5.0 WQBEL Enterococci col/100 mL Daily maximum 45 Geometric mean of series of 5 samples shall not exceed 35 - Shall not exceed 35 colonies/100 ml in any 90- day interval WQBEL NPDES Fact Sheet 4 ------- Puerto Rico Aqueduct and Sewer Authority NPDES NO. PR0026549 Culebra WWTP Effluent limitations Parameter Units Averaging period Highest Reported Value (1) Existing limits Interim limits Final limits Basis col/100 mL Sample maximum 2420 No sample shall exceed upper confidence limit of 75% or a maximum of 130 - 90th percentile of the samples taken shall not exceed 130 colonies/100 ml in the same 90-day interval WQBEL Flow MGD Daily maximum 0.137 0.20 - 0.20 WQBEL m3/day Daily maximum 518.60 757.08 - 757.08 TBEL Lead Mg/i Daily maximum 1.42 3.2 - 3.2 WQBEL Pentachlorophenol Mg/i Daily maximum - 1 - 1 WQBEL pH su Daily maximum 6.5-8.86 6.0-9.0 - 6.0-9.0 WQBEL Residual Chlorine mg/L Daily maximum - 0.011 - 0.011 WQBEL Solids and Other Matter - - - - - Monitor only WQBEL Sulfide (undissociated H2S) Mg/i Daily maximum 3.6 2 - 2.0 WQBEL Surfactants (MBAS) Mg/i Daily maximum 197 100 - 100 WQBEL Suspended, Colloidal or Settleable Solids mL/L Average Monthly Maximum Daily 8 Monitor only - Monitor only WQBEL Taste or Odor-producing Substances - Average Monthly Maximum Daily - Monitor only - Monitor only WQBEL Temperature °F Daily maximum - Shall not exceed 90 - Shall not exceed 86 WQBEL °C Daily maximum 32.6 32.2 - 30.0 WQBEL Total Ammonia Nitrogen (TAN) mg/L Daily maximum 75900 Monitor only - 0.08 WQBEL Total Nitrogen (TKN, N02, N03) Mg/L Daily maximum 51870 1,700 - 1,700 WQBEL Total Phosphorus Mg/L Daily maximum 6640 Monitor only - 160 WQBEL mg/L Average monthly Average weekly 208 1200 (maximum daily) 30 45 - Monitor only TBEL TSS kg/day Monthly average Weekly average 12 28 30 45 - 22.70 102.06 TBEL minimum % percent Average monthly 88 (lowest reported value) 85 - 85 TBEL Turbidity NTU Daily maximum 15 50 - 50 WQBEL Zinc Daily maximum 847 119.82 - 119.82 WQBEL NPDES Fact Sheet 5 ------- Puerto Rico Aqueduct and Sewer Authority NPDES NO. PR0026549 Culebra WWTP Parameter Units Effluent limitations Averaging period Highest Reported Value (1) Existing limits Interim limits Final limits Basis 2-Methyl-4,6-Dinitrophenol Mg/i - - 13 - - WQBEL Cadmium Mg/i - - 0.27 - - WQBEL Oil and Grease mg/L -- 2.4 Monitor - - WQBEL Silver (Ag) Mg/i -- - 3.8 - - WQBEL Sulfates mg/L -- - Monitor - - WQBEL Notes. Footnotes and Abbreviations Note: Dashes (--) indicate there are no effluent data, no limitations, or no monitoring requirements for this parameter. (1) Wastewater data from DMRs dated September 30, 2020 to August 31, 2022. 2. Outfall 001 Narrative Limitations a. The waters of Puerto Rico shall not contain any substance, attributable to the discharge at such concentration which, either alone or as result of synergistic effects with other substances, is toxic or produces undesirable physiological responses in humans, fish, or other fauna or flora. b. The waters of Puerto Rico shall be substantially free from floating nonpetroleum oils and greases as well as petroleum derived oils and greases. c. The waters of Puerto Rico shall not contain floating debris, scum, or other floating materials attributable to discharges in amounts sufficient to be unsightly or deleterious to the existing or designated uses of the water body. d. Solids from wastewater sources shall not cause deposition in or be deleterious to the existing or designated uses of the waters. e. Taste and odor-producing substances shall not be present in amounts that will interfere with primary contact recreation, or will render any undesirable taste or odor to edible aquatic life. f. No toxic substances shall be discharged, in toxic concentrations, other than those allowed as specified in the NPDES permit, Those toxic substances included in the permit renewal application, but not regulated by the NPDES permit, shall not exceed the concentrations specified in the applicable regulatory limitations. C. Monitoring Requirements NPDES regulations at 40 CFR 122.48 require that all permits specify requirements for recording and reporting monitoring results. The Part III of the Permit establishes monitoring and reporting requirements to implement federal and state requirements. The following provides the rationale for the monitoring and reporting requirements for this facility. 1. Influent Monitoring Requirements To calculate percent removal values, influent monitoring is required for BODs and TSS in accordance with 40 CFR 133.102. Influent monitoring must be conducted before any treatment, other than de-gritting, and before any addition of any internal waste stream. 2. Effluent Monitoring Requirements Effluent monitoring frequency and sample type have been established in accordance with the requirements of 40 CFR 122.44(i) and recommendations in EPA's TSD. Consistent with 40 CFR Part 136 monitoring data for toxic metals must be expressed as total recoverable metal. Effluent monitoring and analyses shall be conducted in accordance with EPA test procedures approved under 40 CFR Part 136, Guidelines Establishing Test Procedures for the Analysis of Pollutants Under the Clean Water Act, as amended. For situations where there may be interference, refer to Solutions to Analytical Chemistry Problems with Clean Water Act Methods (EPA 821-R-07-002).A licensed chemist authorized to practice the profession in Puerto Rico shall certify all chemical analyses. All bacteriological tests shall be certified by a microbiologist or licensed medical technologist authorized to practice the profession in Puerto Rico. NPDES Fact Sheet 6 ------- Puerto Rico Aqueduct and Sewer Authority NPDES NO. PR0026549 Culebra WWTP The sampling point for Outfall 001 shall be located immediately after the primary flow measuring device of the effluent of the treatment system. D. Compliance with Federal Anti-Backsliding Requirements and Puerto Rico's Anti-Degradation Policy Federal regulations at 40 CFR 131.12 require that state water quality standards include an anti-degradation policy consistent with the federal policy. The discharge is consistent with the anti-degradation provision of 40 CFR 131.12, 72 Federal Register 238 (December 12, 2007, pages 70517-70526) and DNER's Anti-Degradation Policy Implementation Procedure in Attachment A of PRWQSR. In addition, CWA sections 402(o)(2) and 303(d)(4) and federal regulations at 40 CFR 122.44(1) prohibit backsliding in NPDES permits. Further, the Region 2 Antibacksliding Policy provides guidance regarding relaxation of effluent limitations based on water quality for Puerto Rico NPDES permits. These anti-backsliding provisions require effluent limitations in a reissued permit to be as stringent as those in the previous permit with some exceptions where limitations may be relaxed. • The proposed NPDES permit contains water quality-based effluent limitations for Other Pathogenic Organisms and Sulfates which were not included in the previous NPDES permit. Pursuant to Section 401 (d) of the Act and 40 C.F.R. 122.44 (d) and 124.55, all State certified limitations and requirements contained in a Section 401 certification must be incorporated into a NPDES permit issued by EPA. The water quality-based limitations referenced in this paragraph have been included in the draft NPDES permit, based on DNER's IIWQC. • The water quality-based effluent limitations from the previous permit for Cyanide, Temperature, Total Ammonia Nitrogen (TAN) and Total Phosphorous have been replaced with a more stringent water quality-based limitation in the Intent to Issue a IIWQC issued by the DNER. Pursuant to Section 401 (d) of the Act and 40 C.F.R. 122.44 (d) and 124.55, all State certified limitations and requirements contained in a Section 401 certification must be incorporated into a NPDES permit issued by EPA. The water quality-based effluent limitations referenced in this paragraph have been included in the draft NPDES permit, based on DNER's IIWQC. • Existing effluent limitations for 2-Methyl-4,6-Dinitrophenol, Cadmium, Silver and Sulfates have been removed based on CWA section 402(o)(2)(B)(i). CWA section 402(o)(2)(B)(i) authorizes the backsliding of effluent limitations if information is available which was not available at the time of permit issuance that would have justified the application of a less stringent effluent limitation at the time of permit issuance. Based on review of effluent data since issuance of the existing permit, the modified discharge does not show a reasonable potential for the exceedance of water quality criteria for these parameters. PART III. RATIONALE FOR STANDARD AND SPECIAL CONDITIONS A. Standard Conditions In accordance with 40 CFR 122.41, standard conditions that apply to all NPDES permits have been incorporated by reference in Part IV.A.1 of the permit and expressly in Attachment B of the permit. The Permittee must comply with all standard conditions and with those additional conditions that are applicable to specified categories of permits under 40 CFR 122.42 and specified in Part IV.A.2 of the Permit. B. Special Conditions In accordance with 40 CFR 122.42 and other regulations cited below, special conditions have been incorporated into the permit. This section addresses the justification for special studies, additional monitoring requirements, Best Management Practices, Compliance Schedules, and/or special provisions for POTWs as needed. The special conditions for this facility are as follows: 1. Special Conditions from the Water Quality Certificate In accordance with 40 CFR 124.55, EPA has established Special Conditions from the IIWQC in the permit that DNER determined were necessary to meet PRWQSR. The Special Conditions established in this section are only those conditions from the IIWQC that have not been established in other parts of the permit. NPDES Fact Sheet 7 ------- Puerto Rico Aqueduct and Sewer Authority NPDES NO. PR0026549 Culebra WWTP 2. Whole Effluent Toxicity Testing EPA has imposed the semiannual testing requirement to collect data necessary to determine whether this discharge has the reasonable potential to cause or contribute to an exceedance of Puerto Rico's water quality standards for toxicity, pursuant to water quality based permitting requirements at 40 CFR 122.44(d)(1), which requires EPA and delegated states to evaluate each National Pollutant Discharge Elimination System (NPDES) permit for the potential to exceed state numeric or narrative water quality standards, including those for toxics, and to establish effluent limitations for those facilities with the "reasonable potential" to exceed those standards. These federal regulations require both chemical specific limits, based on the state numeric water quality standards or other criteria developed by EPA, and whole effluent toxicity effluent limits. 3. Best Management Practices (BMP) Plan In accordance with 40 CFR 122.2 and 122.44(k), BMPs are schedules of activities, prohibitions of practices, maintenance procedures, and other management practices to prevent or reduce the pollution to waters of the United States. The Permittee is required to develop a BMP Plan in Part IV.B.3.a of the permit to control or abate the discharge of pollutants. 4. Compliance Schedules A compliance schedule has not been authorized for any pollutant or parameter in the permit on the basis of 40 CFR 122.47. PART IV. COMPLIANCE WITH APPLICABLE PROVISIONS OF OTHER FEDERAL LAWS OR EXECUTIVE ORDERS A. Coastal Zone Management Act - Not Applicable. B. Endangered Species Act Under 40 CFR 122.49(c), EPA is required pursuant to section 7 of the Endangered Species Act (ESA), 16 U.S.C. 1531 etseq. and its implementing regulations (50 CFR Part 402) to ensure, in consultation with the National Marine Fisheries Service (NMFS) and U.S. Fish and Wildlife Service (USFWS) that the discharge authorized by the permit is not likely to jeopardize the continued existence of any endangered or threatened species or adversely affect its critical habitat. On April 16, 2009, EPA designated PRASA (a non-Federal representative) to conduct informal consultations or prepare a biological assessment for Section 7 Consultations, according to 50 CFR 402.8. In the past, no federally listed endangered or threatened species, or critical habitat, are in the vicinity of the discharge. Therefore, it has been determined that the discharge is not likely to affect species or habitat listed under the ESA. C. Environmental Justice - Not Applicable. D. Coral Reef Protection - Not Applicable. E. Climate Change EPA has considered climate change when developing the conditions of the permit. This is in accordance with the draft National Water Program 2012 Strategy: Response to Climate Change that identifies ways to address climate change impacts by NPDES permitting authorities (77 Federal Register 63, April 2, 2012, 19661-19662). Climate change is expected to affect surface waters in several ways, affecting both human health and ecological endpoints. As outlined in the draft National Water Program 2012 Strategy, EPA is committed to protecting surface water, drinking water, and ground water quality, and diminishing the risks of climate change to human health and the environment, through a variety of adaptation and mitigation strategies. These strategies include encouraging communities and NPDES permitting authorities to incorporate climate change strategies into their water quality planning, encouraging green infrastructure and recommending that water quality authorities consider climate change impacts when developing water load and load allocations for new TMDLs, identifying and protecting designated uses at risk from climate change impacts. The 2010 NPDES Permit Writers' Manual also identifies climate change considerations for establishing low-flow conditions that account for possible climatic changes to NPDES Fact Sheet 8 ------- Puerto Rico Aqueduct and Sewer Authority NPDES NO. PR0026549 Culebra WWTP stream flow. The conditions established in the permit are consistent with the draft National Water Program 2012 Strategy. F. National Historic Preservation Act - Not applicable since this is a renovation. G. Magnuson-Stevens Fishery Conservation and Management Act - Not Applicable. PARTV. PUBLIC PARTICIPATION The procedures for reaching a final decision on the draft permit are set forth in 40 CFR Part 124 and are described in the public notice for the draft permit, which is published on EPA's website at www. e pa. q o v/req i o n 02/wate r/pe rm its. htm I. Included in the public notice are requirements for the submission of comments by a specified date, procedures for requesting a hearing and the nature of the hearing, and other procedures for participation in the final agency decision. EPA will consider and respond in writing to all significant comments received during the public comment period in reaching a final decision on the draft permit. Requests for information or questions regarding the draft permit should be directed to Lalitssa Lopez EPA Region 2, Caribbean Environmental Protection Division Permit Writer Email: lopez.lalitssa@epa.qov ATTACHMENT A — FACILITY MAP AND FLOW SCHEMATIC The facility map and flow schematic are attached as provided by the discharger in the application. NPDES Fact Sheet 9 ------- Flow Diagram Culebra WWTP NPDES # PR0026549 Secondfloc-Cla rfiers Scdi-jm Hyprajitaritie & Sodium HydnyMte Room BWR - Biologic*! Nu?rieni& Removal RAS - Fielwr-ed Activated Skidge WAS - Wasted Activated Sludge Artificial Wetlands fHaniirai* Sittftg* 3ac*t> ------- ------- |