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KLEINFELDER <br />■ Upgradient drainage volumes that would have to be carried by a pipe replacing the <br />■f channel. <br />■ Feasibility of installing the pipe in light of potential concerns/requirements that may be <br />imposed by F&G or the COE. <br />Rather than specify one plan that may ultimately prove to be infeasible or contain unnecessary <br />measures, a phased plan was prepared where development of the facility drainage system will <br />be related to the effectiveness of the previous phase. <br />Regardless of how stringently the site is remediated, there will most likely be some residual <br />level of asbestos fibers in the runoff or in the channel waters when they leave the site. It <br />would be unreasonable to require a zero discharge since the most recent upgradient monitoring <br />found asbestos fibers at a concentration of 165 million fibers per liter (SW -1). The February, <br />1991 compilation of water quality goals prepared by the CVRWQCB lists two surface water <br />quality goals for asbestos. The first is an EPA primary maximum contaminant limit (MCL) of <br />7 million fibers per liter (MFL) for fibers greater than 10 microns in length. The second <br />standard listed is a one -in -a -million cancer risk estimate of 30,000 fibers per liter (from the <br />EPA National Ambient Water Quality Criteria). There is a large difference in the standards <br />and it does not appear that both could be used as water quality goals at the same time. <br />Another EPA document "Drinking Water Criteria Document For Asbestos, March, 1985" <br />contains a section on the presence of asbestos in drinking water supplies and food products. A <br />study of the water supply in San Francisco (originating from Lake Crystal Reservoir) was <br />discussed. It was found that a total of 34 finished (treated water ready for human <br />consumption) water samples were found to contain > 1 MFL. Fifty percent of those samples <br />had asbestos in excess of 10 MFL. In another study presented in the 1985 EPA report, <br />asbestos concentration in over 1500 water samples from 406 cities in 47 states were assessed. <br />The authors found that 18% of the samples had asbestos concentrations in excess of 1 MFL. <br />10% of the samples had asbestos concentrations in excess of 10 MFL. <br />Food products were also found to contain high levels of asbestos fibers. The following was <br />taken from Table IV -II in the 1985 EPA report: <br />CR14-92-12 Page 32 of 39 24-220109-809 <br />Copyright 1992 KLeinfetder, Inc. <br />