United States Environmental Protection Agency Hazardous Waste Engineering Research Laboratory Cincinnati OH 45268 Research and Development EPA/530-(S)SW-86-031 Feb. 1 987 &EPA Project Summary Technical Guidance Document Construction Quality Assurance for Hazardous Waste Land Disposal Facilities Coleen M. Northiem and Robert S. Truesdale The U.S. Environmental Protection Agency's (EPA's) construction quality assurance (CQA) program for haz- ardous waste land disposal facilities is a two-part program established to en- sure that a completed hazardous waste land disposal facility has been con- structed to meet or exceed all design criteria, plans, and specifications. The first part of this program will present regulations that specify the use of con- struction quality assurance at haz- ardous waste land disposal facilities and is being developed by the Office of Solid Waste and Emergency Response. The second part of this program, ad- dressed by this Technical Guidance Document (TGD), presents the ele- ments of a site-specific CQA plan. This TGD covers CQA for hazardous waste landfills, surface impoundments, and waste piles. The major components of these facilities that are addressed in- clude foundations, dikes, low- permeability soil liners, flexible mem- brane liners, leachate collection systems, and final cover systems. The CQA plan is a site-specific docu- ment that should be submitted during the permitting process to satisfy EPA's CQA program. At a minimum, the CQA plan should include five elements, which are briefly summarized below: • Responsibility and Authority—The responsibility and authority of or- ganizations and key personnel (by title) involved in permitting, de- signing, and constructing the haz- ardous waste land disposal facility should be described in the CQA plan. CQA Personnel Qualifications— The qualifications of the CQA offi- cer and supporting CQA inspection personnel should be presented in the CQA plan in terms of the train- ing and experience necessary to fulfill their identified responsibili- ties. Inspection Activities—The obser- vations and tests that will be used to ensure that the construction or installation meets or exceeds all design criteria, plans, and specifica- tions for each hazardous waste land disposal facility component should be described in the CQA plan. Sampling Strategies—The sam- pling activities, sample size, meth- ods for determining sample loca- tions, frequency of sampling, acceptance and rejection criteria, and methods for ensuring that cor- rective measures are implemented as addressed in the design criteria, plans, and specifications should be presented in the CQA plan. Documentation—Reporting re- quirements for CQA activities should be described in detail in the CQA plan. This should include such items as daily summary reports, in- spection data sheets, problem identification and corrective meas- ures reports, block evaluation re- ports, acceptance reports, and final documentation. Provisions for the ------- final storage of all records also should be presented in the CQA plan. The TGD describes these elements in detail and presents guidance on those activities pertaining to each of the ele- ments that are necessary to ensure that a completed facility has been con- structed to meet or exceed all design criteria, plans, and specifications. It is intended for the use of organizations involved in permitting, designing, and constructing hazardous waste land dis- posal facilities, including treatment, storage, and disposal facilities. This Project Summary was devel- oped by EPA's Hazardous Waste Engi- neering Research Laboratory, Cincin- nati, OH, to announce key findings of the research project that is fully docu- mented in a separate report of the same title (see Project Report and ordering information at back). Responsibility and Authority Identifying and describing the re- sponsibility and authority of organiza- tions concerned with CQA should be the first element of a CQA plan. The princi- pal organizations involved in permit- ting, designing, and constructing a haz- ardous waste land disposal facility include the permitting agency, facility owner/operator, design engineer(s), CQA personnel, and construction con- tractor(s). Except for the permitting agency, the principal organizations will not necessarily be completely inde- pendent of each other: the facility owner/operator also may be the con- struction contractor; the CQA personnel may be employees of the facility owner/ operator, of the design engineer, or of an independent firm. Regardless of the relationships among the organizations, it is essential that the areas of responsi- bility and lines of authority for each or- ganization be clearly delineated as the first element of the CQA plan. This will help establish the necessary lines of communication that will facilitate an ef- fective decision making process during implementation of the site-specific CQA plan. It is also essential that the organi- zation performing CQA operates inde- pendently of and is not responsible to the organizations involved in construct- ing the facility. Personnel Qualifications The second element of the CQA plan should identify the required qualifica- tions of the CQA officer and the CQA inspection personnel and describe their expected duties. CQA Officer The CQA officer is that individual as- signed singular responsibility for all as- pects of the CQA plan implementation. The CQA officer is responsible to the facility owner/operator but should func- tion independently of the owner/opera- tor, design engineer, and construction contractor. The location of the CQA offi- cer within the overall organizational structure of the project, including the fa- cility owner/operator, design engineer, construction contractor, and permitting agencies, should be clearly described within the CQA plan. The CQA officer should possess ade- quate formal academic training in engi- neering, engineering geology, or closely associated disciplines and suffi- cient practical, technical, and manage- rial experience to successfully oversee and implement construction quality as- surance activities for hazardous waste land disposal facilities. Many of the re- sponsibilities of a CQA officer may also require that he or she be a registered Professional Engineer or the equivalent. Because the CQA officer may have to interrelate with all levels of personnel involved in the project, good communi- cation skills are essential. The CQA offi- cer should be expected to ensure that communication of all CQA-related mat- ters is conveyed to and acted upon by the affected organizations. CQA Inspection Personnel The CQA inspection personnel should possess adequate formal training and sufficient practical technical and admin- istrative experience to execute and record inspection activities success- fully. This should include demonstrated knowledge of specific field practices re- lating to construction techniques used for hazardous waste land disposal facili- ties, all codes and regulations concern- ing material and equipment installation, observation and testing procedures, equipment documentation procedures, and site safety. Consultants Authorities in engineering geology, geotechnical engineering, civil engi- neering, and other technical disciplines may be called in from external organiza- tions in the event of unusual site condi- tions or inspection results. The CQA plan should present detailed documen- tation of consultant qualifications when expert technical judgments are ob tained and used as a basis for decision in some aspect of construction quality assurance. Expert opinions should not be used as a substitute for objective data collection and interpretation when suitable observations and test proce- dures are available. Inspection Activities The third element of the CQA plan should describe the inspection activities (observations and tests) that will be per- formed by the CQA personnel during hazardous waste land disposal facility construction. The scope of this discus- sion should address only the construc- tion and installation of all facility components and the manufacture/fabri- cation of various components and sub- components when pertinent. It is assumed that the site has been charac- terized adequately, including evaluation of the hydrogeologic environment. It is also assumed that a site-specific facility design has been prepared that meets regulatory requirements and is accept- able to the facility owner/operator and that this design has been evaluated to ensure its technical correctness and fea- sibility. This element should address the in- spection activities that are necessary to ensure that the facility has been con- structed to meet or exceed all design criteria, plans, and specifications. The first part of this section of the TGD ad- dresses general preconstruction activi- ties applicable to all facility compo- nents. Subsequent subsections address each facility component separately and are further subdivided into sections on preconstruction, construction, and post- construction inspection activities unique to each component. Specific test methods that may be used to inspect the components of a hazardous waste land disposal facility are listed and ref- erenced in Appendix A. Sampling Strategies Sampling strategies should be ad- dressed as the fourth element of the CQA plan. For many materials and con- struction processes, it is necessary to estimate the quality of the overall mate- rial or process from the observed or measure quality of the representative sample that is a small fraction of the total material or process. Examples of these situations include assessment of characteristics of a soil liner (e.g., per- meability, moisture content, density, particle size distribution) and destruc- ------- live testing of FML seams. This section presents information that may be useful in the selection and implementation of an appropriate sampling strategy for evaluating construction quality. It is in- tended to provide an introduction to the concepts and assumptions behind dif- ferent sampling strategies. It is not in- tended to be a complete or comprehen- sive treatment of the subject. The current state of knowledge on sampling strategies for hazardous waste land disposal facility CQA is not developed enough to enable EPA to rec- ommend a specific approach for de- signing a sampling strategy. For in- stance, the measurement error inherent in test methods is an important piece of information when devising a statistical sampling strategy. However, the meas- urement error associated with certain important test methods (e.g., laboratory and field permeability) is not known. Until more information is available, the selection of appropriate sampling strategies should be conducted with the guidance of knowledgeable engineers and statisticians. Documentation The ultimate value of a CQA plan de- pends to a large extent on recognition of all of the construction activities that should be inspected and the assign- ment of responsibilities to CQA inspec- tion personnel for the inspection of each activity. This is accomplished most ef- fectively by documenting CQA activities and should be addressed as the fifth el- ement of the CQA plan. The CQA per- sonnel will be reminded of the items to be inspected, and will note, through de- scriptive remarks, data sheets, and checklists signed by them, that the in- spection activities have been accom- plished. During the construction of a hazard- ous waste land disposal facility, the CQA officer should be responsible for all facility CQA documents. This in- cludes the CQA officer's copy of the de- sign criteria, plans, and specifications, the CQA plan, and the original of all the data sheets and reports. Duplicate records may be kept at another location to avoid loss of this information if the originals are destroyed. Once facility construction is com- plete, the document originals should be stored by the owner/operator in a man- ner that will allow for easy access while still protecting them from any damage. An additional copy should also be kept at the facility if this is in a different loca- tion from the owner/operator's files. A final copy should be kept by the permit- ting agency in a publicly acknowledged repository. All documentation should be maintained through the operating and postclosure monitoring periods of the facility. Concluding Remarks Construction quality assurance for hazardous waste land disposal facilities is one tool that can be very valuable in improving the overall performance of landfills, surface impoundments, and waste piles. Proper site selection, credi- ble designs, knowledgeable contrac- tors, and competent operation of the completed facility, along with adequate CQA, all contribute to a facility with a reduced potential for failure. Through the thorougn application of a site- specific CQA plan, the owner/operator can ensure that the completed facility meets or exceeds all design criteria, plans, and specifications. ------- Coleen M. Northiem and Robert S. Truesdale are with Research Triangle Institute, Research Triangle Park, NC 27709. Jonathan G. Herrmann is the EPA Project Officer (see below). The complete report, entitled "Technical Guidance Document: Construction Quality Assurance for Hazardous Waste Land Disposal Facilities," (Order No. PB 87-132 825/AS; Cost: $18.95, subject to change) will be available only from: National Technical Information Service 5285 Port Royal Road Springfield, VA 22161 Telephone: 703-487-4650 The EPA Project Officer can be contacted at: Hazardous Waste Engineering Research Laboratory U.S. Environmental Protection Agency Cincinnati, OH 45268 United States Environmental Protection Agency Center for Environmt nial Research Information Cincinnati OH 452GC BULK RATE POSTAGE & FEES PAID EPA PERMIT No G 35 Official Business Penalty for Private Use $300 EPA/530-(S)SW-86-031 ------- |