Puerto Rico Aqueduct and Sewer Authority	NPDES NO. PR0020737

Naranjito 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

FACT SHEET

NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM

Naranjito WWTP
PERMIT No. PR0020737

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 and Environmental 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 January 31, 2023, DNER provided in the Water Quality Certificate (WQC) 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 WQC are met. In accordance with CWA section 401, EPA has incorporated the
conditions of the WQC into the draft permit. Any changes to the WQC will be incorporated into the final issuance
of the permit. The WQC 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 WQC 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 on its Naranjito WWTP National Pollutant Discharge Elimination System (NPDES) permit. The Permittee
is discharging pursuant to NPDES Permit No. PR0020737. The Permittee submitted Application Form 1, and 2A
dated December 17, 2021, and applied for an NPDES permit to discharge treated wastewater from Naranjito
WWTP, Naranjito, 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 the wastewater treatment plant which provides secondary 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 Naranjito WWTP is a publicly owned treatment work (POTW) that treats sanitary wastewater through
secondary treatment of the domestic sewage from the Municipality of Naranjito. It has a capacity of 0.8 MGD
(design flow rate) and provides secondary treatment and discharge its effluent to the Guadiana River. It was
designed to remove 85% of BODs and TSS.

Sanitary wastewater is processed through the following units, see Attachment A (Schematic Flow Diagram for
more details:

>	Influent Pump Station and Bar Screens

>	Receiving tank for septic discharges

>	Grit Chamber

>	Aeration Tanks (2)

>	Final Clarifiers (3)

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>	Chlorine Contact Tanks (2)

>	Dechlorination

>	Aerobic Digester Tank (1)

>	Sludge Drying Beds (5)

Sludge is thickened, dewatered and disposed in a landfill.
Summary of Permittee and Facility Information

Permittee

Puerto Rico Aqueduct and Sewer Authority (PRASA)

Facility contact, title, phone

Mr. Edgardo Bermudez-Valentin, Executive Director
Environmental Compliance, Health and Safety
(787) 620-2277, ext. 2893 and 2427

Permittee (mailing) address

Puerto Rico Aqueduct and Sewer Authority
P.O. Box 7066
Barrio Obrero Station
Santurce, Puerto Rico 00916-7066

Facility (location) address

PR 164, Km 2.9, Guadiana Ward
Naranjito, P.R. 00719

Type of facility

Publicly-owned Treatment Works

Pretreatment program

Yes

Facility daily average flow

0.259 MGD (in million gallons per day) (May 2021)

Facility design flow

0.8 MGD (in million gallons per day)

Facility classification

Minor

B. Discharge Points and Receiving Water Information

Wastewater is discharged from Outfall 001 to the Guadiana 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

Secondary treated
municipal wastewater.

18°, 18', 11" N

66°, 14', 2" W

Guadiana River, Class SD waters

As indicated in the Puerto Rico Water Quality Standards (PRWQS) Regulations, the designated uses for Class
SD receiving waters include:

>	Primary and secondary contact 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 been
determined to have water quality impairments for one or more of the designated uses as determined by
section 303(d) of the CWA. Total maximum daily load (TMDL) has been developed and approved by
EPA for Fecal Conforms.

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C. Compliance Orders/Consent Decrees

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.

E. 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

>	PRWQS (August 2022).

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 PRWQS. 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 1.206 MGD as a Daily
Maximum. Monitoring conditions are applied pursuant to 40 CFR 122.21 (j)(4)(ii) and EQB's Water Quality
Certificate. 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.	pH: The effluent limitation for pH is based on technology-based secondary treatment standards for
POTWs specified for Class SD C 2.d. of PRWQS, and the WQC. 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.

5.	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 of PRWQS, and the WQC.

6.	Enterococci: The effluent limitation is based on the water quality criterion for Class SD waters as
specified in Rule 1303.2 C.2.c of PRWQS, and the WQC.

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7.	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 PRWQS, and the WQC.

8.	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.

9.	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 PRWQS, and the WQC.

10.	Copper, Cyanide, Mercury, Residual Chlorine, and Sulfide (undissociated H2S): The effluent
limitations is based on water quality criteria established in PRWQS Rule 1303.1 .J.1 of PRWQS and the
WQC.

11.	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 PRWQS, and the WQC.

12.	Total Dissolved Solids: The effluent limitation is based on the water quality criterion for Class SD waters
as specified in Rule 1303.2 C 2.g of PRWQS, and the WQC.

13.	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 PRWQS, and the WQC.

14.	Surfactants: The effluent limitation is based on the water quality criterion for Class SD waters as
specified in Rule 1303.2 C.2.i of PRWQS, and the WQC.

15.	Total Phosphorus: The effluent limitation is based on the water quality criterion for Class SD waters as
specified in Rule 1303.2 C.2.n of PRWQS, and the WQC.

16.	Total Nitrogen: The effluent limitation is based on the water quality criterion for Class SD waters as
specified in Rule 1303.2 C.2.m of PRWQS, and the WQC.

17.	Total Ammonia Nitrogen: The effluent limitation is based on the water quality criterion for Class SD
waters as specified in Rule 1303.2 C.2.I of PRWQS, and the WQC.

18.	Oil and Grease: The effluent limitation is based on the water quality standards as specified in Rule
1303.1 .H of PRWQS, and the WQC.

19.	Suspended, Colloidal or Settleable Solids: The effluent limitation is based on the water quality
standards as specified in Rule 1303.1.E of PRWQS, and the WQC.

20.	Solids and Other Matters: The effluent limitation is based on the water quality standards as specified in
Rule 1303.1 .A of PRWQS, and the WQC.

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

322
383

30.0
45.0

n/a

30.0
45.0

TBEL

BOD5 percent removal

%

Daily minimum

88

85

n/a

85

TBEL

Color

Pt-Co

Daily Maximum

30

21

n/a

15

WQBEL

Copper

Mg/i

Daily Maximum

19

15

n/a

11.67

WQBEL

Cyanide, Free

Mg/i

Daily Maximum

4

6.3

n/a

-

WQBEL

Cyanide, Total

Mg/i

Daily Maximum

-

-

n/a

4.0

WQBEL

Dissolved Oxygen

mg/L

Daily Minimum

4.7

>3.0

n/a

>5.0

WQBEL

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Parameter

Units

Effluent limitations

Averaging
period

Highest
Reported
Value (1)

Existing
limits

Interim
limits

Final
limits

Basis

Enterococci

col/100 mL

Average monthly

166

35

n/a

35 col/100
mL

WQBEL

90th
Percentile

of the
samples

Average monthly

1860

130

n/a

130

WQBEL

Flow

MGD

Daily maximum

0.327

0.8

n/a

0.8

WQBEL

Oil and Grease

Mg/L

Daily maximum

3.8

Monitor

n/a

Monitor

WQBEL

pH

SU

Daily maximum

6.02-7.57

6.0-9.0

n/a

6.0-9.0

WQBEL

Mercury, Total

Mg/i

Daily maximum

0.024

0.061

n/a

0.050

WQBEL

Residual Chlorine

Mg/i

Daily maximum

0

11

n/a

11

WQBEL

Settleable Solids

ml/L

Daily maximum

0

-

n/a

-

WQBEL

Sulfide (undissociated H2S)

Mg/i

Daily maximum

2.2

3

n/a

2

WQBEL

Surfactants

Mg/i

Daily maximum

71

100

n/a

100

WQBEL

Temperature

°c

Daily maximum

31.5

32.2

n/a

30

WQBEL

Total Ammonia Nitrogen

mg/L

Daily maximum

7880

Monitor

n/a

0.21

WQBEL

Total Disolved Solids

mg/L

Daily maximum

600

559

n/a

500

WQBEL

Total Nitrogen (N02, N03,
TKN)

Mg/i

Daily maximum

26180

2936

n/a

1,700

WQBEL

Total Phosphorus

Mg/i

Daily maximum

3030

160

n/a

160

WQBEL

TSS

mg/L

Average monthly
Average weekly

536
1000

30.0
45.0

n/a

30.0
45.0

TBEL

TSS percent removal

%

Daily minimum

76

85

n/a

85

TBEL

Turbidity

NTU

Daily maximum

9.8

50

n/a

50

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 November 30, 2020, to November 30, 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.	These waters shall be free from other pathogenic organisms different to conforms and enterococci.

e.	Solids from wastewater sources shall not cause deposition in or be deleterious to the existing or
designated uses of the waters.

f.	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.

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g. 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.

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 EQB's Anti-Degradation Policy
Implementation Procedure in Attachment A of PRWQS. 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 effluent limitations in the permit are at least as stringent as the effluent limitations in the existing permit,
with the exception of effluent limitation for Dissolved Oxygen. The effluent limitation for this pollutant is less
stringent that those in the existing permit. This relaxation of effluent limitation is consistent with the anti-
backsliding requirements of CWA section 401 (o), 40 CFR 122.44(1), EPA Region 2's Anti-backsliding Policy
dated August 10, 1993, and Puerto Rico's Anti-Degradation Policy Implementation Procedure established in
PRWQS. CWA Sec. 402(o)(2)(B)(i) allows backsliding if information is available which was not available at
the time of permit issuance and would have justified a less stringent effluent limitation at the time of permit
issuance. EPA has determined that it is appropriate to relax the effluent limitation for these parameters
without violating anti-backsliding provisions of the CWA, in accordance with section 402(o)(2), since one of
the exceptions to the provisions has been satisfied; and section 402(o)(3) since it complies with DNER's WQS
which include antidegradation requirements. The DNER WQC constitutes a determination that the limit is
sufficient to assure that the water quality standards are or will be attained.

•	Existing effluent limitations for Free Cyanide has 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

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permit, the modified discharge does not show a reasonable potential for the exceedance of water quality
criteria for these parameters.

• The water quality-based effluent limitation from the previous permit for Color, Total Cyanide, Temperature,
Total Dissolved Solids, Total Mercury, Total Nitrogen, Total Copper, Sulfide (Undissociated Hydrogen)
and Total Ammonia Nitrogen have been replaced with a more stringent water quality-based limitation in the
Intent to Issue a WQC 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 Intent to Issue a Water
Quality Certificate.

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 WQC in the permit
that DNER determined were necessary to meet PRWQS. The Special Conditions established in this
section are only those conditions from the IWQC that have not been established in other parts of the
permit.

2.	Whole Effluent Toxicity Testing

EPA has imposed the semi-annual 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.

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5. Other Special Conditions

The permit establishes additional special conditions for biosolids management and pretreatment
requirements.

PART IV. COMPLIANCE WITH APPLICABLE PROVISIONS OF OTHER FEDERAL LAWS OR
EXECUTIVE ORDERS

A.	Coastal Zone Management Act

Under 40 CFR 122.49(d), and in accordance with the Coastal Zone Management Act of 1972, as amended,
16 United States Code (U.S.C.) 1451 etseq. section 307(c) of the act and its implementing regulations (15 CFR
Part 930), EPA may not issue an NPDES permit that affects land or water use in the coastal zone until the
Permittee certifies that the proposed activity complies with the Coastal Zone Management Program in Puerto
Rico, and that the discharge is certified by the Commonwealth of Puerto Rico to be consistent with the
Commonwealth's Coastal Zone Management Program. As this activity is not located in any coastal zone of Puerto
Rico, the regulation does not apply to this permit.

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

EPA has performed an Environmental Justice (EJ) Analysis for the discharge in accordance with Executive Order
12898, Federal Actions to Address Environmental Justice in Minority Population and Low-Income Populations,
and EPA's Plan EJ 2014. EJ 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. In the NPDES permitting program, the public participation process provides opportunities
to address EJ concerns by providing appropriate avenues for public participation, seeking out and facilitating
involvement of those potentially affected, and including public notices in more than one language where
appropriate. The facility is in an area characterized as a Community of Concern and therefore is subject to the EJ
requirements. In the EJ Analysis, but there is no potential for a disproportionate and/or adverse environmental
burden in the area.

D.	Coral Reef Protection

Under Executive Order 13089, Coral Reef Protection, EPA is required to ensure that discharge authorized under
the permit will not degrade any coral reef ecosystem. No corals or coral ecosystems are in the vicinity of the
discharge.

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

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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
stream flow. The conditions established in the permit are consistent with the draft National Water Program 2012
Strategy.

F.	National Historic Preservation Act

Under 40 CFR 122.49(b), EPA is required to assess the impact of the discharge authorized by the permit on any
properties listed or eligible for listing in the National Register of Historic Places (NRHP) and mitigate any adverse
effects when necessary in accordance with the National Historic Preservation Act, 16 U.S.C. 470 et seq. EPA's
analysis indicates that no soil disturbing or construction-related activities are being authorized by approval of this
permit; accordingly, adverse effects to resources on or eligible for inclusion in the NHRP are not anticipated as
part of this permitted action.

G.	Magnuson-Stevens Fishery Conservation and Management Act

Under 40 CFR 122.49, EPA is required to ensure that the discharge authorized by the permit will not adversely
Under 40 CFR 122.49, EPA is required to ensure that the discharge authorized by the permit will not adversely
affect Essential Fish Habitat (EFH) as specified in section 305(b)(2) of the Magnuson-Stevens Fishery
Conservation and Management Act (MSFCMA), 16 U.S.C. 1801 etseq. As this activity has been permitted in the
past, a reopener clause has been established that allows the permit to be modified or revoked based on the
consistency determination. Therefore, a reopener clause has been established that allows the permit to be
modified or revoked based on the findings of the Endangered Species Act consultation as it relates to the
Magnuson-Stevens Fishery Conservation and Management Act.

H.	Clean Water Act, Section 403 Ocean Discharge.

CWA Section 403 requires EPA to consider guidelines for determining potential degradation of the marine
environment when issuing NPDES permits. These Ocean Discharge Criteria (40 CFR 125, Subpart M) are
intended to "prevent unreasonable degradation of the marine environment and to authorize imposition of effluent
limitations, including a prohibition on discharge, if necessary, to ensure this goal". Based on the available
information, EPA has determined that the discharge will not cause unreasonable degradation of the marine
environment. A reopener provision has been included in the permit Part IV.B.5 that provides EPA the right to
modify or revoke the permit based on any new data.

PARTY. 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 which is published on EPA's website at
https://www.epa.qov/npdes-permits/puerto-rico-npdes-permits. 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

Eng. Carlos R. Villafane-Gonzalez, MEM, PE

EPA Region 2, Caribbean Environmental Protection Division

Permit Writer Phone: 787-977-5858

Permit Writer Email: villafane.carlos@epa.gov

NPDES Fact Sheet


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Puerto Rico Aqueduct and Sewer Authority	NPDES NO. PR0020737

Naranjito WWTP

ATTACHMENT A — FLOW SCHEMATIC AND FACILITY MAP

The facility map and flow schematic are attached as provided by the discharger iri the application.

NPDES Fact Sheet	A-2


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Puerto Rico Aqueduct and Sewer Authority
Naranjito WWTP

NPDES NO. PR0020737

SCHEMATIC FLOW DIAGRAM
NARANJITO WWTP
NPDES PR0020737

INFLUENT
0.8 MGD

I

SCREEN

PIT



PUMP

	*=k

STATION



GRIT
CHAMBER y

Splitter Box

AEROBIC
DIGESTOR

FINAL CLARIFIERS (3)

COVERED SLUDGE DRYING BEDS (5)

11*

Chlorine Contact
Chambers (2)

CC

Dechlorination

cc

1 I

DRY SLUDGE
TO LANDFILL

EFFLUENT

Pars hall Pl ume

Dtschapge Flow Meter

0.8 MGD

DISCHARGE 001 TO
GUAD1ANA RIVER

NARANJITO WWTP
NPDES # PR0020737
Schematic Flow Diagram
August 2021 Page 1of 1

NPDES Fact Sheet

A-2


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