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WASTE DISCHARGE REQUIREMENTS -8- FORWARD INC.,FORWARD LANDFILL SAN JOAQUIN COUNTY construction(e.g.,WMU D93). The vertical expansion of WMU D over WMUs B, C, D87, D88N, D88S, D89, and Eastern Ash Disposal Pit WMU E occurs in Phase H. The lateral expansion of WMU D to the west happens in Phase III. The filling of WMU D to final grades occurs in Phase IV. The construction of WMU H, the landfill unit south of Littlejohn Creek, occurs in Phase V. The phases will not necessarily be completed sequentially. 31. The active life of Forward landfill facility is estimated-to be 13 years based.on refuse capacity of 9.4 million cubic yards and a refuse fill rate of 3,800 tons per day, 312 days per year and an in place density of 1250 pounds per cubic yard. WM[1 D has an estimated refuse capacity of 10.1 million cubic yards and a;service life of I I years. WMU H will have a refuse capacity of 1.78 million cubic yards and an estimated service life of two years. The estimated service He of the units is based on disposal rates and will change if disposal rates are significantly different than predicted. 32. WMU E, the coal ash landfill unit, has a design capacity of 520,000 cubic yards. 33. Petroleum contaminated soils are treated in WMU G, a Class H land treatment unit. Contaminated soils are also stored in the VMU G.area prior to treatment. Stored soils are kept in piles and covered with plastic sheeting until they are spread for treatment. Following treatment,the sus are:usedas..Zaily orinter ediate cover in compliance with Title 14 regulations, or discharged to WMU D or H. WMUG may be moved to a new iocadon-on the facility a&landfill WMUs are-built,..as shown on Attachment B_ DES13N-0 WASTE MANAGEMENT UNITS Engineered Alternatives 34. Section 2510 of Chapter 15 requires the submittal of a demonstration that a prescriptive standard is not feasible because it is unreasonably and unnecessarily burdensome or impractical. The engineered alternative must afford equivalent protection against water quality impairment. The Discharger provided the demonstrations required by Section 2510 in its Waste Discharge Requirements Revisions and Technical Equivalency Report dated 4 December 1995. Furthermore, the Board has routinely approved the substitution of geosynthetic clay liners (GCLs)for field constructed clay liners at other sites since March and there are no significant differences in the characteristics of already approved liners and the liners proposed for this facility.