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11 <br />rndlvldual discrarcer <br />,. i nat lndrvldualar ►s bar;errt �r o <br />e};jsrn� a -,d P": `ntlal s? of Che e�r,ei1�e Gf all <br />� r =. the of f er+ten ,., � o� <br />t t l ., - .,.,a, . , resour �- d <br />en r e� tc tn.� �ame c- ='gin; rs r�Gt <br />ppll r who has Controlor rder :t,ons, 0es`_ribtd aDove,` or a wat�i <br />su total of the water within its distribution system. <br />Under the law, a discharger of W;V .5tp dor Y <br />diccharae requlrrrnents, to 21d chernrcalssto at body of watpermer tript absent waste <br />not own or totally control, especially when such chemicals provrdero�benefhe eit <br />to the water resource nor to the Subsequent users of thar water. The <br />chloroform was not placed in the ground water in the process of eliminating <br />pathoq?ns and toes not belong in 9 <br />ground ti�ater for any other reason. The users <br />of the v, ­n to <br />e noLei E'I I l 11 illi} the exist er"--e 01, the C. dor oto o r.l <br />in the water nor from the process which caused <br />the water. Additionally, if a discharger Is permitted to place THMstinothe water <br />enter <br />thea <br />supply up tO the TTHM ; standard and if that raw water must be disinfected <br />prior to use as domestic supply, the chlorination process could cause the TTHM <br />concentration at the tap to exceed the TTHM standard. <br />Because the contaminant entered the water resource as the result of improper <br />waste discharge to land, the recuirements of Article <br />� be applied. 1 led. a2 � 5 of Subchapter ',5 may <br />PP 558, Corrective Action Program, requires that a discharger who <br />has caused degradation of surface or ground water must engage in a remedial <br />action program to restore the quality of the water resource to the "water <br />quality protection standards". Water quality protection standards are defined <br />in S2552(b) as "background concentrations ... before wastes are discharged". <br />There are other instances wlsere water quality criteria more stringent than <br />MCLS are applied to protect the beneficial uses of a water resC'l1rCe. it is <br />common practice to requir,� compliance with aquatic life criteria for heavymetal contaminants in surface waters that are often iower than MCLS for the <br />same contaminants. <br />In summary, the appropriate water quality goal for application to the <br />protection of an ambient source of domestic s�_rpply from chloroform is th <br />10.6 ecancer risk level. This is consistent with the use of such criteria for <br />other VOCs, like TCE. The use of the TTHM NCL in contaminated site cleanupsdoes not protect the beneficial u;e of tl'.e grater resource. The TTHM MCL <br />should only be applied to drinkingwater as jt is delivered to the consumer <br />afterdisi?f&ction MCLs in general are not d;;iGned to proiect ambient vvater <br />quality and are not necessarily intended for use as goals of cleanup efforts. <br />The precedent for :,pplyjng criteria more stringent than MCLs to protect <br />San Francisco, personal communication (23 July 1985). oe <br />Q31 <br />