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Action Alert
Background Information

Aguadilla Waste Water Treatment Plant:
Comments Due Dec. 6th, 2000
NPDES NO. PR 0023736

The Aguadilla Waste Water Treatment Plant discharges 8 million gallons of improperly treated sewage per day, less than one half mile from shore and in less than 50 ft of water. The plant has a poor history of compliance to even primary removal standards. There are dieing corals and popular surfing areas in the vicinity of this outfall.

Click on any of the photos below to see a larger view.

This is a photo, and an enlargement of same photo, of the Aguadilla Waste Water Treatment Plant [WWTP] receiving waters located off of the coast of Aguada, Puerto Rico. The photo was taken by NOAA on March 26, 1999 at 10:00 AM. The arrow demarcates the "boil" of diffuser effluent and, in the enlargement, the "Y" shape of the diffuser and discharge from the individual ports becomes obvious. Adjacent coral reefs can be seen outside of the Culebrina’s River’s enormous sediment plume.

Please click on this photo to see enlargement and read caption.

aguada1.jpg (121546 bytes)

  • These photos illustrate that the discharge plume is visibly "boiling" on the surface. This poses serious public health risk to nearby surfers and other water recreators. This is of special concern in the tropics where to date we lack an adequate sewage indicator organism to protect human health.

  • These photos document that the receiving waters are extremely stressed by sediment from the adjacent Culebrinas river mouth. The EPA scientists reviewing the permit application INCORRECTLY CONCLUDE that the receiving waters are not-stressed. (Analysis of the Section 301(h) Secondary Treatment Waiver Application for the Aguadilla WWTP NPDES No. PR 0023736 Puerto Rico. August 10, 2000, page 42).

  • EPA Region 2 has never been able to implement or enforced the Clean Water Act in Puerto Rico or the U.S. Virgin Islands. The same month and year [March 1986] that EPA denied the first round Clean Water Act Waiver application for the Aguadilla WWTP, the plant began operations AND DISCHARGING without a permit. EPA documented the problem with EPA Region 2, 10 years ago in an EPA Internal Audit.

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Caribbean U.S. Territories, Public Waste Water Treatment Plants


The Clean Water Act

Large public primary waste water treatment plants with shallow ocean discharge have been contaminating the tropical coastal waters of Puerto Rico and the US Virgin Islands for decades. The only pending Clean Water Act or Secondary Treatment Waivers for primary plants are located in EPA Region 2, Puerto Rico and the U.S. Virgin Islands. Primary waste water treatment has long been considered obsolete waste water treatment technology since the Clean Water Act was passed by U.S. congress almost 30 years. This is of particular concern in tropical waters where corals and other natural resources are nutrient sensitive, and where scientists have yet to establish an adequate indicator organism to detect pathogens from sewage in the water.

Secondary Treatment Waivers/ 301(h) in Puerto Rico and the U.S. Virgin Islands

To date EPA, Region 2 has failed to either grant or deny these waivers to primary waste water treatment plants in Puerto Rico and the U.S. Virgin Islands.

2000 - 1982 = 18 years.

A decade old EPA Internal Audit documented this failure and yet EPA Region 2 has done nothing to alter their approach with local governments.

EPA Green Washing: Click here to read the EPA press release green washing their clean water failures in Puerto Rico and US Virgin Islands. They announce the signing of a Memorandum of Agreement of questionable legality with the Government of Puerto Rico to allow them an additional 20 years to come into "voluntary" compliance to CWA standards and they make this agreement sound like a great clean water accomplishment! Are we all living in Texas now and nobody told us? This ads up to a 50 year extension for Puerto Rico to come into Clean Water Act discharge standards when recent scientific evidence suggests that even CWA standards are not sufficient to protect human health and the environment in the tropics!

WWTP’s in Puerto Rico, Environmental Justice and Development. Most disturbing about the Puerto Rico primary WWTP’s is that the new NPDES permits pending final approval by EPA are asking to DOUBLE the cumulative discharge into Puerto Rico’s coastal waters from 200 million gallons per day to 400 million gallons per day. This increase will demonstrate a false infrastructure to support more development. In the process of development, tropical vegetation will be cleared and eventually result in more silt dumping from river mouths onto the coast.

Historically, the Puerto Rico primary plants were built to address sewage bubbling up in poor coastal communities. The plants were constructed and then used to demonstrate infrastructure for more inland development. The Carolina WWTP, for example, services the municipality of Carolina and inland pharmaceutical companies, but the primary plant itself was constructed and impacts the coast of Loiza. Loiza is a poor afro-antillian coastal community that relies heavily on subsistence fishing in the area of the Loiza outfall. Although the government promised the plant would service this community, to date less than 30% of Loiza has been hooked up and the Loizeńos still have sewage bubbling up into their streets and washing directly into their coastal waters.

Essential Fish Habitat and Endangered Species: EPA is tentatively approving this Clean Water Act Waiver with no Government Agency comments on the impacts to this area for Essential Fish Habitats. A letter dated June 4, 1987 from the National Marine Fisheries Service [NMFS] and a letter dated May 11, 1987 from the U.S. Fish and Wildlife Service [USFWLS]compiled the following list of endangered species that may occur in the area of the Aguadilla outfall:

Finback Whale, Balaenoptera physalus

Humpback Whale, Megaptera novaeangliae

Sperm Whale, Physeter catodon

Green Sea Turtle, Chelonia mydas

Hawksbill Sea Turtle, Eretmochelys imbricata

Giant Leatherback Sea Turtle, Demochelys coriacea

Loggerhead Sea Turtle, Caretta caretta

Olive (Pacific) Ridley Turtle, Lepidochelys olivacea

….and the brown pelican, Pelecanus occidentalis

Env. Defense Technical Review: Aguadilla WWTP

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