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Draft Supplemental Environmental Impact Report Page III-21 Forward Inc.Landfill 2014 Expansion Project have been adequately treated, the soil can be used for daily cover, intermediate cover, or foundation layer for the closure cap. If necessary, the treated soils can be disposed in a Class II or Class III WMU. �• Although there are currently no Land Treatment Units (LTUs) at the site,LTUs have been constructed in the past and may be utilized in the future. A LTU is an area constructed with a liner,berm, stormwater collection system, and monitoring system, in which a layer of «. contaminated soil is placed for treatment. LTUs for contaminated soil are permitted within WMU G-North or G-South. These treatment units may also be used to treat other nonvolatile organics that are suitable for bioremediation such as PNAs (polynuclear aromatic i hydrocarbons). Although Forward is not currently treating gasoline-contaminated soil,these soils have been treated in the past and may be treated in the future. Gasoline-contaminated soils would be r. treated in WMU G-North or G-South by a vapor extraction and thermal oxidation technique in accordance with San Joaquin Valley Air Pollution Control District regulations on uncontrolled air emissions. To verify that vacuum extraction has sufficiently reduced soil contaminant levels below the designated level for disposal, soil samples would be collected from the cell at the ` initiation of remediation and then monthly to monitor the remediation process. The samples would be analyzed for total petroleum hydrocarbons (TPH) as gasoline and benzene, toluene, ethylbenzene,xylene (BTEX). Approval for final disposition of the material would be requested from San Joaquin County Environmental Health Department(SJCEHD). Upon verification that the soil in a cell has been adequately cleaned, the soil would be removed and disposed onsite in an appropriate waste cell or used as daily or intermediate cover. These treatment units may i, also be suited for other volatile organic compounds such as halogenated volatile aromatics,etc. Sludge Treatment and Disposal Sludge treatment is allowed in WMU G. If treated,the sludges would be spread and dried on a one-foot thick clay pad and then transferred to a waste management unit for disposal. *� Asbestos Disposal The existing Forward Landfill handles and disposes Asbestos-Containing Materials(ACM)in accordance with applicable federal and state regulations. All ACM delivered to the existing Forward Landfill must be scheduled in advance and accompanied by the proper documentation, which is checked by the scale-house attendant. All ACM is landfilled in an area separated from other waste types. Bagged ACM is dumped only onto the active working face of the asbestos disposal area and not onto the flat compacted landfill area. Bulldozers and front-end loaders cover the ACM on the working face with soil. Landfill equipment is not allowed to come in contact with ACM,to reduce the risk of contamination. At least six inches of soil covers the disposal cell within one hour of being disposed. All employees involved in the handling and disposal of ACM are equipped with protective clothing. The employees receive annual training,and initial and annual medical examinations to comply with OSHA Standards. Ash Disposal s The existing Forward Landfill accepts ash for disposal,if proper documentation is submitted (consisting of analytical results from a state-certified laboratory,laboratory chain-of-custody forms, .• and/or a waste characterization form,signed by the generator). The ash is disposed directly in the appropriate WMUs,following the general landfill operation procedures discussed in Landfill r. a.