Re: [CPEO-MEF] Irvine Desalter/TCE remediation project

[petestrauss1@home.com]

The issue at El Toro raises a larger issue for almost all cleanups in
California and perhaps elsewhere.  In CA, the State Water Resources
Control Board has generally required cleanup of all "potential drinking
water sources". "Potential" is defined by two parameters: one that you
can pump at least 200 gallons per day and the second is that TDS levels
are no greater than 3,000 mg/L.  

If TDS levels are being cleaned up at El Toro along with TCE, as Lenny's
e-mail suggests, than it makes sense to not use the TDS parameter for
all situations.  In fact, at three sites where I am working, regulators
have written off groundwater sources with greater than 3,000 mg/L -
meaning they did not have to clean up contaminants polluting these
waters. So I have an open question: should these groundwater sources be
reconsidered as potential drinking water sources, even though they do
not meet the TDS limits?  Another way of looking at this is to disregard
the state's definition and look at the practical approaches for
potential use and cost of removing TDS.

Peter Strauss 

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