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KLEINFELDER <br /> 3.3 LOCATION OF WMUS WITH RESPECT TO 100-YEAR FLOOD PLAIN <br /> Plate 3-1 depicts location of J-M Mfg. facility with respect to the 100-Year flood plain. As <br /> can be seen on the plate, the J-M Mfg. facility is within the 100-Year shallow flood plain <br /> where flood depths are between one (1) and three (3) feet. <br /> WMUs at the J-M Mfg. site contain essentially inert waste and an unclassified status is <br /> proposed. In light of the shallow 100-Year flood waters and the inert quality of the waste, <br /> Kleinfelder does not believe that protection against inundation or erosion caused by flooding is <br /> necessary. Therefore, no protective flood measures have been considered in the closure plan <br /> design. <br /> 3.4 WMU CONSTRUCTION <br /> Original designs for construction of the landfills specified that excavation side slopes would be <br /> graded no steeper than 1-to-1. The landfills are approximately 18 to 20 feet deep and there is <br /> no indication that liners or leachate collection systems were installed. <br /> Neither of the two surface impoundments are lined. At the western end of each impoundment <br /> is a small pit. These pits were originally installed to accept alkaline wastewater from the plant <br /> should a catastrophic discharge occur. These pits were reportedly never used. <br /> 3.5 VVMU CLASSIFICATION <br /> Waste placed in the WMUs is essentially inert. Asbestos fibers are largely bound in a cement <br /> matrix. Monitoring evidence to date does not support the presence of VOCs or heavy metals <br /> in these WMUs. Kleinfelder requests that the WMUs shown in Plate 2-1 be designated as <br /> unclassified WMUs in Waste Discharge Requirements. <br /> CR14-92-12 Page 8 of 39 24-220109-1709 <br /> Copyright 1992 Kleinfelder, Inc. <br />