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• <br />• <br />WASTE DISCHARGE REQUIREMENTS -5- <br />FORWARD INCORPORATED <br />WASTE MANAGEMENT FACILITY <br />CLASS II LANDFILLS CLASS III LANDFILLS <br />CLASS II SURFACE IMPOUNDMENT <br />CLASS II LAND TREATMENT UNIT <br />CLOSURE OF CLASS I LANDFILL <br />SAN JOAQUIN COUNTY <br />would require excavation and removal of approximately 500,000 cubic yards <br />of hazardous material and cover soil. The estimated cost for disposal of <br />this material at an existing, permitted Class I landfill, such as Kettleman <br />Hills, would cost $100 to $150 million. The Discharger has demonstrated <br />that compliance with Section 2531(b)(1) is unreasonably and unnecessarily <br />burdensome and would cost substantially more than the proposed engineered <br />alternative which meets the criteria of Section 2510(b). <br />19. The Discharger demonstrated that the proposed engineered alternative is <br />consistent with the performance goal of Section 2531(b)(1) and affords <br />equivalent protection against water quality impairment because quarterly <br />monitoring data has indicated no ground water contamination downgradient <br />from WMU A, no leachate has been found in the leachate collection system <br />for WMU A since the temporary soil cover was constructed in 1984, and a <br />1 ow permeab i 1 i ty cover system wi 11 be i nsta 11 ed as part of the c 1 osure p 1 an <br />for WMU A. <br />20. DHS and the U.S. Environmental Protection Agency (EPA) approved the closure <br />plan for WMU A on 23 September 1988 and also approved modifications to this <br />closure plan on 23 May 1989. The approved closure plan includes the <br />Closure Plan submitted by the Discharger, dated September 1987, Responses <br />to Notice of Deficiency, dated March 1988, the DHS -issued Closure <br />Conditions, Forward Inc., dated 13 September 1988, and the modifications <br />approved 23 May 1989. <br />21. The closure of WMU A will consist of an engineered cover system and a <br />ground water and vadose zone monitoring system. The engineered cover <br />system will consist of four components: the foundation layer, the <br />compacted clay layer, the vegetative/drainage layer, and a culvert drainage <br />system. <br />22. The foundation layer will bring the existing temporary cover up to a <br />minimum 3% grade. The foundation layer will be made of native and imported <br />soils, which may contain nonhazardous levels of waste contaminants, and <br />will be compacted to prevent settling. <br />23. The compacted clay layer will be a minimum of two feet in thickness and <br />have a permeability of 1x10 or less as verified by field and laboratory <br />testing. <br />24. The vegetative soil layer will be no less than 18 inches in thickness and <br />will be planted with a suitable grass mixture to prevent erosion or root <br />