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Unors for Cl%sa III 1.-.nA -2— 29 Janunxy IM <br /> under saturated conditions. A T greater than or equal to the active life <br /> of landfill is considered "long"; while a F less than the active life is <br /> short". The minimum active life of a municipal solid waste landfill is <br /> assumed to be 20 years. Units with a "long" r may use the natural <br /> geology as a liner. Those with a "short" F units must have an <br /> engineered liner. Category IV units must have a synthetic liner over a <br /> clay liner. <br /> Dischargers are already required to provide the information necessary <br /> to calculate these two factors in -the waste management unit <br /> characteristics part of the report of waste discharge (see Subchapter <br /> 15, §2595). These factors could be used to determine the need for a <br /> liner under a Class III unit as follows: Units falling into Categories I or 11 <br /> would not be required to be lined. Category 11 units might be required <br /> to have leachate collection and rerhoval systems (LSRSs). Category III <br /> units would be required to have the minimum one-foot thick clay liner <br /> and LCRS (to prevent hydraulic head build-up, Subchapter 15, §2543[a] <br /> requires an LCRS whenever a liner is required); while those in Category <br /> IV would need a liner of greater than this minimum thickness and an <br /> LCRS. <br /> Is scheme appears to be a reasonable and workable approach to this <br /> problem, what are your thoughts? <br /> e <br />