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

[petestrauss1@home.com]

Perhaps I was not totally clear.  As doobage described below, the
question should be separated into parts.  However, one of the parts must
be the following: if groundwater is contaminated with a chemical
contaminant by a PRP, but is not a potential drinking water source
because of naturally occurring high total dissolved solids (TDS), should
the PRP be required to clean up the chemical contamination. In most
cases I am familiar with, PRPs are not required to do so unless of
course there are other pathways to humans or animals besides drinking
water. 

Peter Strauss

doobage@localnet.com wrote:
> 
> 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.
> 
> At 01:11 PM 7/31/2001 -0700, petestrauss1@home.com wrote:
> >
> >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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