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WASTE DISCHARGE REQUIREMENTS -5- 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 that compliance with Section 2531(b)(1) is unreasonably and unnecessarily burdensome and would cost substantially more than the proposed engineered alternative which meets the criteria of Section 2510(b). 19. The Discharger demonstrated that the proposed engineered alternative is consistent with the performance goal of Section 2531(b)(1) and affords equivalent protection against water quality impairment because quarterly monitoring data has indicated no ground water contamination downgradient from WMU A, no leachate has been found in the leachate control system for WMU A, and an impermeable cover system will be installed as part of the closure plan for WMU A. 20. DHS and the U.S. Environmental Protection Agency (EPA) approved the closure p 1 an f or WMU A on 23 September 1988 and a 1 so approved mod i f i cat i ons to th i s closure plan on 23 May 1989. The approved closure plan includes the Closure Plan submitted by the Discharger, dated September 1987, Responses to Notice of Deficiency, dated March 1988, the DHS -issued Closure Conditions, Forward Inc., dated 13 September 1988, and the modifications approved 23 May 1989. 21. The closure of WMU A will consist of an engineered cover system and a ground water and vadose zone monitoring system. The engineered cover system will consist of four components: the foundation layer, the compacted clay layer, the vegetative/drainage layer, and a culvert drainage system. 22. The foundation layer will bring the existing temporary cover up to a minimum 3% grade. The foundation layer will be made of native and imported soils, which may contain nonhazardous levels of waste contaminants, and will be compacted to prevent settling. 23. The compacted clay layer will be a minimum of two feet in thickness and have a permeability of 1x10 or less as verified by field and laboratory testing. 24. The vegetative soil layer will be no less than 18 inches in thickness and will be planted with a suitable grass mixture to prevent erosion or root penetration into the clay layer. The culvert drainage system is designed to gather runoff from the vegetative layer and route the water into a holding pond.