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u L� KLEINFELDER Monitoring activities will still occur although the emphasis will be on establishing if the channel sediments are adding asbestos to surface water. The effectiveness of the sedimentation ponds will also be monitored. If it is found that the channel sediments are causing a problem, then Phase III of the drainage plan will be implemented. This final phase involves replacing the channel with a pipe. The pipe ' would isolate storm water flows from contaminated sediments that may be present in the channel. Before this phase could begin, the concerns and uncertainties discussed in Section 6.3.2 would have to be addressed. Plate 6-3 is a flow chart showing the conditions under which the individual phases would be implemented. At some point in the future, J -M Mfg. may choose to design and install the pipeline instead of following the phased approach described previously. 6.3.2.4 Off-site Assessment and Remediation It is possible that the channel sediments downstream of the J -M Mfg. site may contain asbestos concentrations capable of elevating surface water concentrations in excess of the 7 MFL (> 10 microns) water quality goal. In such a situation, the surface water meeting the water quality goal at the downstream site boundary could exceed the water quality goal by the time it reaches the off-site downstream monitoring point (SW -4, Drawing 2). If such a situation occurs, J -M Mfg. will meet with the RWQCB to discuss possible approaches to mitigating the problem. Refer to Section 6.5.1 which describes the surface water monitoring program that will be used to assess asbestos concentrations in surface water both on and off site. Construction of the cap for the WMUs will not be as complex as construction of a full Chapter 15 cap because no barrier layer will be needed in the cap used at J -M. Therefore, the main QA/QC functions will be to check the thickness of the cap (make sure it is at least one foot thick) and also to check the grade. J -M will incorporate a simple QA/QC program in the cap construction process. A QA/QC program manual will be submitted to the CVRWQCB for review and approval before closure activities begin. CR14-92-12 Page 34 of 39 24-220109-F09 Copyright 1992 Kleinfelder, Inc.