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

[doobage@localnet.com]

The question should be separated into its parts. At the outset, I agree
with the CA Water Resources Control Board that all "potential drinking
water sources" should be cleaned up; I'll go beyond this and say that many
other bodies of water must be viewed as "natural resources" and if
contaminated by a PRP, said PRP should bear the cost of clean up.

But it depends on the source of the contamination. 1) If high TDS occurs
naturally, there is no PRP and therefore no cleanup should be required. If
that source of water is needed for potable/agricultural use, then the
user/WRCB should pay the cost for cleanup; 2) If the high TDS occurred
because of contamination by human sources, then the PRP is responsible for
the cost of cleanup. In the cse of El Toro, the Navy is responsible for the
TCE contamination but not TDS; therefore it should not be tagged for
cleaninig up the TDS, which might be naturally occurring or was caused by
another PRP; 3) Practical approaches for potential use and cost for
removing TDS is a horse of a different colour and much debate on those
points has occurred - I personally prefer that the regulators play hard
ball on those points. - MC.

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