Posted by: indiesfaves | January 30, 2011

Writing a State Senate Memorial on Water Quality Issues

This past week I offered to help draft legislation for the New Mexico State Legislature a Senate Memorial on protecting Water Quality in the State of New Mexico. Some folks worked on it. I worked on it and it goes through another round of citizens groups then to the legislative council service. I have submitted this back to the citizens group who are wrestling with government agency and local officials over what right  the public has in knowing where 8 million gall. of jet fuel in the groundwater aquifer is and where most of the drinking water comes from in the southern half of the Albuquerque. No telling if this will go anywhere or whether anyone in the groups will agree to it. The real measure of its life will be if it gets adopted by the legislature.

What I do know is that being denied information under the “Request for Public Documents” law these pubilc and private entities using national security and the Patriots act act as a means of withholding information is dangerous to our democracy. What is consumed  by the public is our fundamental human right. The moral reasoning behind impacting human health in the region for water storage at all costs is not acceptable. this is what seems to be at the heart of the issue. Using a means of water storage that will impact water indefinitely is too much of a risk and the ‘Precautionary Prinicpal’ should be adopted and applied. We deserve to have that right implemented several cities have already done this In order to come to terms with climate change we must start somewhere, why not now.

People need answers and they have a right to those answers. Democracy needs accountability. This is just the beginning.

A Memorial Requesting that the NM Department of Health and NM Department of NMED Evaluate in a Public Study and Report the Quality of Potable Water being delivered to the customers in the Albuquerque Bernalillo Water Utility Authority (ABCWUA) system; in comparison to all artesian groundwater productions deep-wells that ABCWUA had been using exclusively; to the quality of treated and source Rio Grande Diversion Water, and the effectiveness of the treatment process and the risks to public health on ingesting low levels contaminants.

1.  WHEREAS, The Residents have concerns over the water quality issues; whom had previously known good health and that some of the deep aquifer water being of a good pH value.

2. WHEREAS, An additional water source of the SAN JUAN/CHAMA/ RIO GRANDE RIVER has now been diverted that includes treated effluent from several cities upstream and

4. WHEREAS, the drinking water delivered by ABCWUA to an estimated 500,000 people for consumption includes infants, seniors, the infirmed and others with weakened or underdeveloped immune systems and

5. WHEREAS, It is the responsibility to the ABCWUA to provide public information, (to be posted on their website and inserted through their billing information), including the water testing the quality of source water and treated water ready for delivery (before and After treatment) and tap water; that the ABCWUA water treatments are under the maximum contaminant levels (MCLs) and is better or equal to the deep water production wells and is safe for those infants, seniors the infirmed and other with weakened or underdeveloped immune systems and

6. WHEREAS, there has been no public hearings or public commenting periods on water quality studies, testing, permits and independent analysis by which the ABCWUA is now doing their testing and treatment; members of the public has lost confidence in the ABCWUA ability to provide healthy water, and

7. WHEREAS, The public has been denied and has experienced difficulties in obtaining public information and detailed information of the water quality and as to where each well is and what pollutant impacts the municipal productions wells are experiencing and has adopted policies and practices that supersede the New Mexico State law NMSA 1978 Chapter 14 Request for Public Documents act, and

8. WHEREAS, The need for transparency in government with regard to treatment technologies used and its reliability, and

9. WHEREAS, The hydrological studies on Aquifer Storage and Recovery (ASR) that the ABCWUA as the permittee from the Office of the State Engineer (OSE) and the New Mexico Environment Department (NMED) have not proved the impacts on seeps and springs within the hydrological area of influence nor has it proved that the pH, water temperature difference in order to preserve the natural conditions of groundwater or impacts on surface water and other water rights holders through their beneficial use, and

  1. The chemical analysis of river water does not include calcium and magnesium, which prevents determination of an ion balance in the water, the scaling tendency of the water or the sodium adsorption ration. The scaling tendency indicates the probability of forming (or Removing) a calcium carbonate layer of the downstream distribution system. It also indicates the compatibility with other waters, which the product water may be mixed with.
  2. Consideration should also be given to understanding the effects of mixing pumped groundwater with treated river water, Chemical analysis of proposed well field groundwater source will provide invaluable information for understanding and predicting potential adverse conditions.
  3. Bromide concentration in the water had not been specified; even the modest concentrations of bromide in the feed water can be significantly promoting the formation of Disinfectant By Products (DBPs). It is not clear what the Total Organic Carbon (TOC) consists of. The TOC of the river water is high enough that one must worry about the formation of DBPs. Some of the organic carbon will be removed during the coagulation process, but not all.
  4. It is not clear what residence time would exist between the addition of chlorine and addition of ammonia to convert the chlorine to monochloramine. One of the advantages of using chloramines for disinfection is the lowered tendency to form DPBs. However, if the period of time that the water is exposed to chlorine is too long, this advantage is dissipated. Reference is made to the hazards of use of chlorine gas as disinfectant.  Further investigation and study is needed to prove the viability of these ABCWUA ASR projects and whether they have the ability to provide safe and verifiable water source is require and that any permit already issued without these considerations should be pulled.

10. WHEREAS, and update to the EPA Source Water Assessment (SWA) that includes the raw diversion source water and there has been not information provided to the public by NMED or ABCWUA on the status of a request to update the assessment, and

11. WHEREAS, This region of the Rio Grande suffers from of radionuclides contamination, as proven by independent analysis; that migrations in air and water from the national laboratories and other sources and the allowable levels of these contaminants are higher than those recognized and recommended in the study on radionuclide’s in the Rio Grande  by DR. A. Makhanjani of the Institute for Energy and Environmental Research.

12. WHEREAS, The ABCWUA water treatment and delivery system is antiquated and corroded and does not include contemporary filtration systems found in other metropolitan cities; and that the system is in need of a complete overhaul. Some of the municipal production wells are not made to standards that include annular casings to keep contaminates from entering the water delivery system and being consumed by the public, and

13 WHEREAS, the EPA is now considering maximum contaminant levels (MCLs) and testing for Perchlorates, Chromium 6, PPCP’s and other Volatile Organic Compounds (VOC s), AND

14. WHEREAS, The some of these contaminants at low levels have and accumulative effect that cause serious health effects years later.



  1. The NM Health Department in conjunction with the NMED Safe Drinking Water conduct a study of the quality of the source water and quality of Rio Grande Diversion water and the treated water in the delivery system with comparison to the artesian deep water aquifer; that all testing be conducted by an outside independent source.
  2. Consideration should be given to the legislated Federal and state environmental and cultural resource requirements and their impacts on the ARS, testing, new treatment facilities and delivery infrastructure, projects scope, schedule and costs. Studied (such as the environmental impacts statements and other NEPA compliance studies, Section 106 of the National Historic Preservation Act, compliance studies and Air Quality and Stormwater requirements) required on these projects are time-consuming and must be identified and planned for.
  3. That a Feasibility Study not included on projects that need compliance risks significant increases in the total estimated costs of the projects which can be substantial.
  4. A report on the treatment system with updated technologies and redesign to include fail safe features. This report is to include the Rio Rancho waste water treatment facility outflow and its contaminant releases and how they impact the Rio Grande surface water quality; to be completed within one year as an open public document on the governmental websites with three informational meetings on the status of the Public study report.
  5. The Public Study Report should examine the impacts of the ABCWUA ASR plan and permit to the aquifer ground and surface water, beneficial use plans and examine the impacts of raw river water, treated effluent and tap water; the report to include recommendations.
  6. Be it further resolved, that the EPA Primary and Secondary and Emerging contaminants be included in the report; to include other contaminants now being studied for MCLs by the EPA and Global Water community of Water quality specialist e.g. FUNGI, CHROMIUM 6, NANO PARTICLES, PHARMACEUTICALS, ETC.).
  7. This public study and report review includes member’s appointed by from environmental organizations and concerned qualified citizens.

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