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

[doobage@localnet.com]

Peter,

Yes, I now see your point. My answer still holds, i.e., the groundwater
should be viewed as a resource. Irrespective of the Water Boards'
definition of 200 gpm and TDS concentration, I would urge the regulators to
play hard ball and have the PRP clean up the chemical contamination. One
never knows the future use of high TDS GW and safeguarding it now would be
my call. Perhaphs if one views the contamination as Natural Resources
Damage one would find it more palatable to play hard ball. For instance,
the Hudson River, General Electric, PCBs, EPA have been in the news this
past week. EPA's ROD specifies a $460 million cleanup and GE over the past
couple of years has been fighting the fight for No Action and has probably
expended in excess of $25 million for TV, radio and print advertisement to
excite the ignorant in the population that the conclusion of good science
is to leave the PCBs in place. But if GE thinks the game is over, it is in
for a big surprise when the EPA and New Yor State presents it with the bill
for Natural Resources Damage (assuming that those agencies will have the
guts for that fight).

Now I take this opportunity to climb up on my soap box. Because of the
great expense involved with clean up of aquifers, and shortfall in funding,
all and sundry (including the EPA and State agencies - shame on them for
abdicating their responsibility under the law and regulations)have opted
for the easy way out - walk away from the contamination and introduce space
age tochnologies as natural attenuation - an EPA invention. You may have
noted that the USDOD, USDOE and a wide range in the private sector have
grabbed on to natural attenuation as the preferred remedy. Although the EPA
has defined methods for ensuring natural attenuation (identifying the
zone(s) of highest concentrations (geoprobes), multiplicity of wells and
much laboratory analysis to ensure that contaminants are dissociating into
daughter products, I'll wager that the greater percentage of natural
attenuation remedies nationwide has not observed those requirements. Also
there has has been a focus on innovative technology - some of which work
and others duds, e.g., molasses for  remedy of metals - I have seen pilots
studies for such fail miserably, phyto-remediation - simply dig and haul
instead og going through those gyrations - a bloody waste of time as far as
I am concerned. - Doobage.

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