Before the Water Quality Appeals Board Department of Administration in and for the State of Arizona the Appellants (Listed below) filed a
Notice of Appeal and Request for Hearing
Proposed Significant Amendment to Arizona Minerals Inc. Aquifer Protection Permit Inventory.
Arizona Department of Environmental Quality (ADEQ)
- Patagonia Area Resource Alliance
- Defenders of Wildlife
- Arizona Mining Reform Coalition
- Borderlands Restoration Network
- Center for Biological Diversity
- Friends of the Santa Cruz River
- Friends of Sonoita Creek
- Save the Scenic Santa Ritas
- Sky Island Alliance
- Tucson Audubon Society
Summary and Conclusions
- All downstream aquifers, including those in Harshaw and Sonoita creek valleys, must be protected by a system of early-warning POCs (Point of Compliance) upgradient of the first drinking water well monitored on a Daily basis.
- POC-4 must be constructed, and baseline data collected for at least one full year prior to any large discharge from WTP2 to capture the range of natural variation in the system. This POC is important for tracking any changes in water quality that might result from the addition of 4500 gpm into Harshaw Creek, regardless of the compliance status of that discharge.
- Two additional POC monitoring wells should be installed between Outfall2 and the first shallow drinking water well in Harshaw Creek.
- EPA Secondary standards are critical for protecting the existing uses of Harshaw and Sonoita Creek aquifers. These aquifers are presently used without treatment except disinfection. Any additional load of sulfate, for example, may require local residents who depend on these sole-source aquifers to implement expensive treatment or seek a replacement (eg. bottled water) supply.
- AMI has not conducted a thorough and complete hydrologic study to assess the predicted impacts of pollutant releases on downstream drinking water aquifers. Am integrated hydrologic/hydraulic flow and fate/transport model should be used to assess the short-(hours to days) and long-term (months) nature and extent of pollutant release(s) at the Hermosa Property, as the surface and subsurface hydrologic system along Harshaw and Sonoita Creeks are strongly coupled. A much more rigorous hydrolooogic evaluation is needed, and a protection plan commensurate with those results must be developed.
- Compliance monitoring requirements should be consistent with AWQS and federal SDWA standards where they are stricter. Radionuclide monitoring should be required at all POCs, including Outfalls 1 and 2.
Outreach Efforts on Manhole #86
By Blue Evening Star
FOSCR has been endeavoring to inform people that Manhole #86 is likely to be the next one to fail in monsoon flooding. To do this, we have been taking out ads in the Nogales International with catchy phrases that will alert people to the dangers we face with every monsoon flood. Board member Ben Lomeli has been interviewed several times about the IOI. See links below to stories on NPR and KOLD News.
We observe the IBWC and ADEQ trying to get a quick fix solution pushed through (and leave all further costs and liabilities to a proposed new “Water Management District”) so we are fighting that too. The real federal agenda is to get the question of who will pay (for the IOI repairs and maintenance) out of the courts, because they know they will lose there. We are in the process of releasing a press release, and also a longer letter addressing this.
Residents Warn of Threat to Santa Cruz River if Sewer Pipe Ruptures Again
Last year, rains caused a breach in a pipeline that carries raw sewage from Mexico to the U.S. Residents in Santa Cruz county are warning that the same pipeline carrying raw sewage from Mexico into the United States could rupture again, as it did last year during the monsoon.
Arizona Must Act Fast to Replace Cross-Border Pipeline, Official Says
The 8-mile IOI, which spewed raw sewage into the Nogales wash last year, is 25 years past its expected lifespan.
Who’s going to pay for international sewage line through Nogales?
Just about everyone with a connection to the Nogales Wash and the International Outfall Interceptor would like to see some improvements to prevent potential breaches and breaks, but the various organizations and individuals involved can’t seem to agree on who is go to pay for the fix.
ARIZONA PUBLIC MEDIA:
Nancy Montoya reports on a crucial sewage pipeline that runs from Nogales, Sonora to a water treatment facility in Rio Rico.
Friends of the Santa Cruz River has been concerned for some time that the binational sewage pipe, the International Outfall Interceptor (IOI), could be breached by floods in the Nogales Wash under which it lies. A pipe break would spill raw sewage into the communities of Nogales, Rio Rico, Tubac and further north along the Santa Cruz River. Our warning is encapsulated in a short video we had made and started distributing earlier this year, called “Flirting With Disaster“.
We are sad to say this eventuality has now come to pass. The waters of the Wash and the Santa Cruz River into which it flows are now heavily contaminated. An easy fix is not in sight; and even when repairs to this breach are eventually made, there is a good likelihood that a similar disaster will happen again somewhere else along the 9-mile IOI, possibly even this summer.
Although the International Boundary and Water Commission (IBWC) has developed a plan to insert a resin sleeve into the existing IOI, and FOSCR supports this repair strategy, it will not solve the persistent problem of the location of the IOI.
This binational sewage pipe must be removed from the bed of the Wash if future public health disasters like this one are to be avoided in the future. IOI relocation will not come cheap or easy. However, barring a major overhaul of the entire Nogales Wash watershed (most of which is in Mexico), repeated erosive floods will inevitably threaten the IOI with rupture and thus threaten the health of all Santa Cruz County residents as well as the ecological health of the Santa Cruz River ecosystem. Furthermore, since most of Santa Cruz County’s residents depend for their drinking water on the aquifer that underlies the river, our drinking water supply also faces a long-term and significant threat from repeated discharges of contaminated water into the river.
This is a matter of true national security; if we don’t have clean drinking water and are not protected from public health threats, how secure are we? The IBWC must take responsibility for this border crisis and first, repair the IOI. But second and more importantly, they must get the IOI out of the Nogales Wash.