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Ll WASTE DISCHARGE REQUIREMENTS FORWARD INCORPORATED WASTE MANAGEMENT FACILITY CLASS II LANDFILLS CLASS III LANDFILLS CLASS II SURFACE IMPOUNDMENT CLASS II LAND TREATMENT UNIT CLOSURE OF CLASS I LANDFILL SAN JOAQUIN COUNTY -4- petroleum hydrocarbons have dropped below those given in Discharge Specification 41, the soil will be used as daily or intermediate cover. 14. Leachate from the landfill units and liquid wastes described in Discharge Specification B.7 are proposed for discharge to WMU F, a Class II surface impoundment. These wastes are classified as 'designated wastes' using the criteria set forth in Subchapter 15. The location of WMU F as shown on Attachment B is tentative and may be changed. This final location will be specified in WMU F design and construction specifications that will be submitted to the Board for approval. 15. WMU A was constructed in 1979 and operated until October 1984. WMU A received permits necessary for construction and operation before 27 November 1984, the effective date of Subchapter 15. WMU A contains a mixture of designated and a minor amount of hazardous wastes. Hazardous waste discharge to this unit ceased in 1984. This WMU is undergoing closure under the direction of the State Department of Health Services (DHS). 16. Section 2531(b)(1) of Subchapter 15 requires that waste management units for hazardous waste (Class I units) be underlain by natural geologic materials which have a permeability of not more than 1x10"' cm/sec, and which are of sufficient thickness to prevent vertical movement of fluid, including waste and leachate, from waste management units to water of the State as long as wastes in such units pose a threat to water quality. 17. Hydrogeologic data submitted by the Discharger indicate that WMU A, which contains hazardous waste, is located in a geologic setting which does not meet the siting criteria for a Class I WMU. 18. In a letter dated 20 October 1988, the Discharger requested approval of the facility's closure plan as an engineered alternative under Section 2510(b) of Subchapter 15. In this letter, the Discharger demonstrated that compliance with the prescriptive standard through closure by waste removal would require excavation and removal of approximately 500,000 cubic yards of hazardous material and cover soil. The estimated cost for disposal of this material at an existing, permitted Class I landfill, such as Kettleman Hills, would cost $100 to $150 million. The Discharger has demonstrated