530-SW-85-013
                              DRAFT



                    Mininum Technology Guidance

                                on

                       Single Liner Systems

                               for

         Landfills,  Surface Inpoundrents, and Waste Piles—

                Design, Construction, and Operation
U.S. Environmental Protection Agency
Region 5, Library (PL-12J)
77 w«st Jackson Boulevard. 12th Floor
Chicago.it 60604-3590
                                                Second version
May 24,1985

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                                                   OSWER POUCT DIRECTIVE NO.

                                                                   A-
— o
                                                 OSWER POLICY DIRECTIVE NO.

                                                9480-00-1
   MEMORANDUM

   SUBJECT*   Draft Guidance on Implementation of the Minimum
             Technological Requirements of the Hazardous and
             Solid Waste Amendments of 1984

   FROMt      John H. Skinner,  Director
             Office of Solid Waste (WH-562)

   TOt        Division Directors,  Regions 1-10
        Attached is the second draft of our guidance for implementing
   the minimum technological requirements of Sections 3004(o) and
   3015 of the Resource Conservation and Recovery Act, as amended
   by the Hazardous and Solid Waste Amendments (USWA) of 1984.

        As you know,  Sections 3004(o) and 3015 require,  for hazardous
   waste landfills and surface inpoundwents, installation of two
   or more liners and a leachate collection system above (in the
   case of landfills) and between such liners.  As of November 8,
   1964, permits cannot be issued to landfills and surface impoundments
   unless they address these requirements.  Certain interim status
   landfills and surface impoundments had to meet these requirements
   by May 8, 1985.  In addition,  Section 3015 requires certain
   interim status waste piles to meet our existing single liner
   and. leachate collection system requirements that had previously
   been in effect for only new permitted waste piles.

•A:.~--:"S^MFh«) second draft of our guidance for implementing the
   minimum technological requirements is a result of our review
   and incorporation  of eone 100  sets of comments that we received
   on the first draft,of the^guidance from the Regional Offices,
   States,  facility owners an* operators,  environmental  groups,
   liner irjinufacturers and installers,  and others.  The first
   draft was cade available for comment in two portions,  on
   December 20,  19£4,  and on February 1,  1985.

        Following is  a brief list of major comments received on the
   firat draft of the guidance and a statement of how the comments
   were uaed in developing the second draft.

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  OSWER POLICY DIRECTIVE i\G.
-•U
                                                  1 tt ,V Q
                                                OSV  • POEICY i
                                 2

                                              94.S •:) « 00- 1   00
      *  Many  comments  asked for clarification as to the
        applicability  of the minimum technological requirements
        to various  unit-apeci.fic situations.   we have riaae rr;ore
        clear the discussion of applicability iu the guidance
        and have included a series of questions  anu answers
        addressing  the key cor.icients raised.

      *  Comnienters  asked that the recommendation that the unit
        be above the seasonal high water table be deleted.  This
        guidance was not changed because installation of the
        double liner systems described in the guidance below the
        water table could change the function/objective  of these
        designs.  however,  double liner systems  in saturated soils
        may be acceptable depending on site-specific consideratons.

      *  Sore  conur.enters  stated that the primary  leachate collection
        system should  cover  the siciewalls as  well as the base of the
        unit.   This comment was adopted in the guidance.

      *  Gome  cotomeriters  recommended deletion  of  the synthetic/
        conpacted soil double liner system from  the guidance
        because this design would require a contacted soil layer
        of impractical thickness,  and because it is not  aa
        protective as  the synthetic/composite double liner design.
        We retained the  synthetic/compacted soil design  in the
        guidance because it  is  similar to the interim statutory
        design of Section 3004(o)(5)(B).

        Comrrtenters recorwnended that the  compacted soil component
        in  the  composite bottom liner should  be  chemically
        rtsistant to the waste  and leachate in the unit.   We
        adopted this recoiwuendation.

      *  Several commenters  asked that the minimum six inches of
        bedding naterial  recommended  in  the guidance  as  a protective
        layer  for synthetic  liners be increased  to twelve inches.
        We  adopted this  recommendation.

     This  second draft  of our  guidance  updates  the December 20,
1984, and February 1,  1S85,  versions.   The attached  guidance  is
in the  form of a draft  Reauthorization  Statutory Interpretation
document, which discusses policy  and interpretational issueo,  and
two attachments that  contain detailed technical  guidance for  the
design,  construction,  and operation  of  both  single  and  double
liner and  leachate collection  systems.   Attached is  the  following
guidance:

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                                                     POLICY DIRECTIVE HO.

                                                                 NO.
                                               9*80-00-1   Qs
     Draft Guidance on Implementation of the Minijauzu Technological
        Requirements of HSWA of 1984, Respecting Liners and
        Leachate Collection Systems; Pe authorization Statutory
        Interpretation *5D; EPA/530-SW-4J5-012;  (earlier draft
        issued February 1, 1985)

     Draft Minimum Technology Guidance on Double Liner Systems
        for Landfills and Surface Impoundments — Design, Construction,
        and Operation; EPA/530-SW-85-014; (earlier draft issued
        December 20, 1934)

     Draft Minimum Technology Guidance on Single Liner Systems
        for Landfills, Surface Impoundments, and Waste Piles —
        Design, Construction, and Operation; EPA/530-SW-65-013;
        (earlier draft guidance issued July 1982)

     We will shortly be proceeding with final  clearance of the
guidance.  If you have any comments or questions on this draft,
please  contacts  Robert Tonetti, Land Disposal Branch, Waste
Management and Economics Division, Office of Solid Waste (WH-565E),
Washington, D.C. 20460, phone (202) . 382-4654.

     Within the next two or three months,  we expect to propose
a rule  (the "proposed codification rule") that will meet the
requirements of Section 3004 (o) (5) (A) and include one or more
double  liner and leachate collection system designs.  When
promulgated in final form, this rule will supersede the interim
statutory double liner standard of Section 3004 (o) (5) (B) .  Our
current plans are for final promulgation of the rule in the
spring of 19 8G.  At that tiiae, it will likely be necessary to
update  the attached guidance further.

Attachments
WH-565EsBob Tonetti*pm:S206: 382-4654: WSMi 5/23/85
                                                                       i

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                           Minimum Technology Guidance on
                              Single Liner Systems for
                        Landfills,  Surface Inpoundments,  and
                                    Waste Piles
                                 TABLE  OF CONTENTS

                                                                    PAGE

  INTRODUCTION                                                         1

  I.  Leachate Collection and Removal  Systems  for  	              9
      Landfills and Waste Piles

       A.  Guidance 	              9

       B.  Discussion....	             11

 II.  Liner Specifications 	             16

       A.  Guidance	             33

       B.  Discussion	             47

III.  Construction Quality Assurance 	             47

       A.  Guidance 	             47

       B.  Discussion 	             49

  References   	             54

  Suggested Reading List 	             57

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                                        Introduction








           On November 8,  1984,  the President  signed  into  law the Hazardous and Sol.



      Waste Amendments of  1984  (HSWA).   Section  3015(a) of HSWA contains rainiirum



      technology requirements for  interim  status waste piles.  Such waste piles are



      initially required by  ^3015  to meet  the  existing EPA requirements under $264. '<



      i.e.,  certain interim  status waste piles must have single liner systems.  The



      new requirements for interim status waste  piles apply to new units and replace



      and lateral expansions of  existing units.  In addition, the existing single



      liner  standards  of $264.221(a), for surface impoundments, and §264.301(a), for



      landfills,  still have  applicability to portions of existing units that are not



      covered  by waste at  the time of permit issuance.  The single liner design



      requirements of  Part 264 are expressed in  terms of the performance to be achie



      by  the unit design rather than specific design standards, such as type and



      thickness  of liner naterial.  This guidance docutmit is intended to provide



      -guidance for owners/opera tors and  EPA and  State regulatory personnel on design:



      that the Agency  believes meet the  requirements of $$264.221(a), 264.251(a),



      and 264.301(a).  This document identifies  design, construction, and operation



      specifications that  can be used by owners  and operators in order to comply



     with the requirements of $§264.221(a), 264.251(a), and 264.301(a).



          The designs included in this guidance are by no means intended to cover th



     entire spectrum of acceptable liner systems.  CVners or operators wishing to



     use a different design, but one that contains the basic design components of



     $§264.221(a), 264.251(a),  or 264.301(a), i.e.,  liners and/or leachate collectic



	systems,  may be able to demonstrate compliance with  the performance requirement




     for the specific facility components.  An  easy way to demonstrate compliance

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  with the performance requirements would be to show that  the  specific ^esi^n



  for a particular unit provides the same level of performance as would the



  design contained in this guidance if it were  installed under similar circumstances



  (such as waste characteristics,  location,  rainfall,  etc.).   The Agency will



  accept convincing performance  equivalency  demonstrations to  the specifications



  in this guidance as adequate demonstration of compliance with the appropriate



  performance statenents of §S264.221(a),  264.251(a), or 264.301(a).



       The designs included in this  guidance are intended only for use in the



  unsaturated zone (i.e., above the high water  table).  This does not mean that



  the Agency has ruled out  the location of facilities in the saturated zone.



 However, permit applicants seeking to locate  in the saturated zone cannot



 necessarily rely on the designs specified in this guidance but rather must



 demonstrate that their intended design meets the applicable standards of



 S§264.221(a), 264.251(a), or 264.301(a) in their specific location.



      The Part 264 single liner regulations require that landfills, surface



 impoundments, and waste piles  have liners designed to prevent migration to the



 adjacent subsurface soil or ground water or surface water during their active



 lives.  In the case of a storage or treatment  unit (i.e.,  a waste pile or a



 surface impoundment from which wastes and waste residues  will be removed or



 decontaminated at closure),  the liner may be constructed  of materials that may



 allow  wastes to migrate  into the liner (but not into the  adjacent subsurface



 soil or ground water or surface water)  during  the active  life of the unit,



provided that  the liner is removed at closure.  (The active life of  the unit



includes  all closure activities, but  does not  include the post-closure care



period.)  '"hug, -in ^pproprMtf  si niHti'-.m.b,  "lay nr artmittcd  materials may be	
acceptable liner materials  (Figures  1 and  2).   In the  cases  of landfills

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 and  surface inpoundnents used to dispose of hazardous waste, the regulations



 provide that the liner must be constructed of materials that prevent wastes



 from passing into the liner (Figures 3 and 4).  Synthetic liners are the only  "



 conrncnly used raaterials of which EPA is aware that would meet this standard.



     This guidance is intended to incorporate the current state-of-the-art



 regarding the design, construction, and operation of hazardous waste land dispos



units.  The attenpt has been made to include an element of practicality in



specifying how to construct a unit.   However, this guidance does not address



all conrponents of facility design, construction, operation, and closure.  For



exanple, it does not address the final cover requirements for landfills and



certain surface impoundments,  nor does it discuss considerations for freeboard



in impoundment design and operation.  The Agency's previously issued guidance



(July 1982) continues to be applicable in these areas.

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 Leachate
Collection
   and
 Removal
 System
                                                                FIGURE 1
                                         SCHEMATIC OF A COMPACTED SOIL SINGLE LINER SYSTEM
                                                            FOR A WASTE PILE
                     Protective
                    Soil or Cover
                     (optional)
                                                               Thick Layer"
                                                      Compacted Low Permeability Soil
                                                                                                                                        C
                                                                                                                                        I
                                                                                                                                        n>
     Liner
(compacted soil)
                                                                                                              Filter Medium
        'Thickress to be determined by break-through time.
                     (Nut to Scale)

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                                                    FIGURE 2
                              SCHEMATIC OF A COMPACTED SOIL SINGLE LINER SYSTEM
                                                      FORA
                            TREATMENT. STORAGE, OR DISPOSAL SURFACE IMPOUNDMENT
                        IQ
      Protective
     Spil or Cover
      (optional)
                                                       Thick Layer*
                                               Compacted Low Permeability Soil


                                                    Native Soil Foundation

    Liner
(compacted soil)
Thickne ,s to be determined by break through time.
                                                                                                            (Not to Scjle)

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Leachate Co lection
      and
 Removal System
                                                    FIGURE 3
                                    SCHEMATIC OF AN FML SINGLE LINER SYSTEM
                                                 FOR A LANDFILL
                                                                                                                  ua
                                                                                                                  c
                                                                                                                   OJ
          Protective
          Soil or Cover
           (optional)
                                      IIMIMIH	'"
                                                Native Soil Foundation
                                                                                                     (Nut

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                                          FIGURE 4
                           SCHEMATIC OF AN FML SINGLE LINER SYSTEM
                                           FORA
                   TREATMENT. STORAGE. OR DISPOSAL SURFACE IMPOUNDMENT
to
c
CD

4*
 Protective
Soil or Cover
 (optional)
                                   Native Soil Foundation
                                                                                          (Not to Scale t

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       I.  Leachate Collection and Removal Systems for Landfills and
           '^'aste Piles

                                    Contents

                                                                Page

      A.   Guidance  	      9

           Objective 	      9
           Design specifications 	      9
           Construction specifications 	     11
           Operation specifications 	     11

     B.  Discussion 	     11
     A.  Guidance

      Overall Design,  Construction/  and Operation Objective

      The system should be designed  to ensure that the leachate depth above

 the liner does  not exceed one foot;  be constructed of materials that can

 withstand the chemical attack that  results  from waste liquids or leachates;

 be designed and constructed so as to withstand the stresses and disturbances

 from overlying  wastes,  waste cover materials,  and equipment operation;  be

 designed and operated to function without clogging through the scheduled

 closure  period;  and be  operated to collect  and remove leachate through

 the scheduled closure of the landfill or waste pile.   Components should be

 properly installed  to assure that the specified performance of the leachate

 collection  system  is  achieved.

      Design

     The leachate collection and removal system should have:

      (a) At  least a 30 centimeter (12 inch)  thick granular drainage layer that

 is chemically resistant  to  the  waste and leachate,  with a hydraulic conductivity_
not less than 1 x 10"2 cm/sec with a minimum bottom slope of 2 percent.

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 Innovative leacbate collection systems  incorporating  synthetic  drainage  layers
 or nets rray be used if they are shown to te  equivalent  to  or more  effective  tha
 the granular design,  including chemical cortpatibility,  flow under  load,  and
 protection of the flexible membrane liner (FML)  (e.g.,  from puncture) if an
 EML is included in the design.
      (b) A graded granular or synthetic fabric filter above the drainage
 layer to prevent clogging.   Criteria for graded granular filters and for
 synthetic fabric filters  are found  in numerous publications such as the
 Geotextile Engineering Manual available from the Federal Highway Administration
 and others.   The granular drainage  material  should be washed to remove fines
 before installation.
      (c) A drainage system of appropriate pipe size and spacing on the bottom
 of  the unit to  efficiently collect  Ieachate.  These pipe materials should be
 chemically resistant  to the  waste and Ieachate.  The  piping system should be
 enouch to withstand the weight of the waste materials and  vehicular traffic
 placed on or  operated on  top of  it.
      (d)  The  Ieachate collection system should cover  the bottom and sidewalls
 of  the unit.
      (e)  A sump in  each unit or  cell should be capable  of  automatic and  continue*.
 functioning.  The sump should contain a conveyance system  for the  removal of
 Ieachate from the unit such  as either a sump pump and conveyance pipe  or gravity
 drains.
      (f)  A written  construction  quality assurance (OQA) plan prepared  by the
 owner/operator  to be  used during construction of the  liner system including the
 leachaLe  col lection dial leuuv/dl  bysLem.—See SecLiou  III,  "Construction  QuaiAty—
Assurance", for specific  details.

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       Construction




       (a) The owner/operator siculd use the  ccnstruction quality assurance



  plan to monitor and document the quality of materials  used and the conditions



  and manner of their placement during construction  of the  leachate collection



  and removal system.   See Section III,  "Construction Quality Assurance",



  for specific details.




       (b) The documentation  for the OQA program should  be kept on-site in the



  facility operating record maintained  for the landfill or waste pile unit.



      Operation



      The following operational procedures should be followed:



      (a)  The leachate removal system should operate automatically whenever leachate



 is present  in the sump and should remove accumulated leachate at the earliest



 practicable time to minimize the leachate head on the liner (not to exceed



 12 inches);




      (b) Inspect weekly and after major storm events for proper functioning



 of the leachate collection and removal system and for the presence of leachate



 in the  removal sump.   The owner or operator should keep records on the system



 to provide sufficient information that the leachate collection system is



 functional and operating properly.   We recommend  the amount of leachate collected



 be recorded in the facility  operating record on each unit on  a weekly basis;



      (c)  Clean out collection lines  periodically; and



      (d)  A storage permit for collected leachate, if required.



      B.   Discussion




      The  Agency believes  that practical designs for leachate  collection and



removal ayatoms ran maintain  a loar-hat-^ ctepth of  one foot or  less,  excep_t	
perhaps temporarily (for a few days) after major storms.   The specifications



presented here, judiciously applied, are expected to accomplish that requirement.

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      The :.iir.i:T_Lm thickness (2C ^ent^-etters or ^2 inches)  of the drainage  layer

 allows sufficient cross sectional area for transport of drainage leachate.   The

 two-percent minimum slope is also intended to proncte drainage.   In most  cases,-

 the Agency believes thicker drainage layers and greater slopes will be selected

 owners and operators to maximize the efficiency of the leachate collection  and

 removal system.   The hydraulic conductivity of not less than 1 X 10~2  on/sec was

 chosen because materials widely used as  drainage media are  coarse enough  that

 their hydraulic  conductivities are estimated to be 1 X 1CT2 cm/sec  or  greater.

      It is not clear if the statutory requirements of §3004(o) (1) (A) (i) require

 the primary leachate collection to be on the sidewalls of a landfill.  The  curre

 Part 264 requirements in §264.251(2)  and 264.301(2)  require a collection  and rem

 system iinnediately  above the liner to collect and  remove leachate.  The previous

 single liner guidance dated July 1982, did not specify whether the  leachate colli

 system was  only to  cover the bottom or also the sidewalls of the unit.  The Perm

 Writer's  Guidance Manual for Hazardous Waste Land  Treatment,  Storage,  and Dispose

 Facilities, October 1983,  indicates  that the need  for a leachate collection syste

 on the sidewalls at a landfill should be based on  site-specific  conditions  on

 expected  leachate flow over the life  of  the facility.   Generally, we encourage dr

 installation of leachate collection systems on both  the base and sidewalls. The

 designs in this guidance recommend  leachate collection system on the sidewalls

because it allows leachate to drain to the sump faster and  minimize ponding of

 leachate within the waste on 'the side of the liner.

     The following  is a list of  factors  that affect liquid  transmission in

the leachate collection system drain  layer:

     * Impingement  rate of-liquid-on  the collection drain layer;
     8 Slope of the drain layer;
     * Diameter and spacing between the  drainage pipes;
     8 Coefficient of hydraulic  conductivity of the saturated sand  or
       gravel drain layer; and              _       	
     0 Cleanliness  (lack of  fines) of the  sand or  gravel.

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 A method  for estimating quantity of liquids collected and aepth above the  liner  is



 presented in Landfill and Surface Impoundment Performance Evaluation,  SW-369,



 April 1983 (EPA 1983).



      Drain pipe diameter and spacing are inportant because they affect the



 head that builds up on the liner between pipes.   The closer the pipes are



 together, the less the head.   Also,  the pipe diameter should be large enough



 to efficiently carry off the collected leachate.   Since  the philosophy for



 all aspects of liner design is to minimize liquid transmission through the



 liner system,  the head on the liner should be minimized.   But the spacing



 and size of the drainage piping system necessary  to acconplish this depends



 on other characteristics of the drainage layer (e.g.,  hydraulic conductivity)



 and on the iirpingement rate of liquids,  vduch is  a function of precipitation.



 The Agency is,  therefore,  not specifying minimm  spacing or pipe diamet«r  in



 this guidance.   However,  EPA believes  that designs incorporating 6-inch



 diameter perforated or slotted pipes spaced 50 to 200  feet (15 to 60  meters)



 apart will effectively minimize head on  the liner system in most cases.



 Information on  leachate collection is  presented in Appendix V of Lining of



 Waste Iirpoundment  and Disposal Facilities,  EPA 1983A.  The owner or operator



 should demonstrate through  appropriate design calculations in his application



 that the maximum one-foot head requirement will not be exceeded.



      The leachate  collection  and removal system should be overlain by a graded



 granular filter or synthetic  fabric filter.   The  purpose  of this is to prevent



 clogging of the voids  in the  drain layer by infiltration  of fines from the waste.



 If a granular filter is used,  it is important that the relationship of grain



 sizes of the filter medium and the drainage layer be appropriate if the filter	



is to fulfill its  function to prevent  clogging of the  drainage layer  and not



contribute to clogging.  Criteria for  graded-granular  filters and for synthetic

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 fabric filters  are found  in numerous sources such as:

 Graded granular filters:

      - Earth Manual.   1984.  Bureau of Reclamation, U.S. Department of the
        Interior.   Government Printing Office, Washington, DC.

      - Geotextile  Enginnering Manual, Training Manual, Federal Highway
        Administration.

 Geotextiles:

      - Koerner, Robert M., and J.P. Welsh.  1980.  Construction and Geotechnical
        Engineering Using Synthetic Fabrics.  John Wiley and Sons,  New York.

      - Horz, R.C.  1984.  Geotextiles for Drainage and Erosion Control at
        Hazardous Waste Landfills.  EPA Interagency Agreement No.  AD-96-F-1-400-:
        U.S. EPA, Cincinnati, Ohio.

      - Geotextile Engineering Manual, Training Manual, Federal Highway
        Administration.

      Innovative leachate collection systems that are equivalent to, or more

effective than,  the granular system described above may be used.  These

innovative systems such as plastic nets can be very thin, on the order of

one-inch thick,  and have the drainage capacity of a sand layer one-foot

thick.  These systems should be capable of maintaining a leachate head of one

foot or less.  The following criteria should be addressed for determining

equivalence:

     0 Design

          - hydraulic transmLssivity (i.e., the amount of liquid that
            can be removed)

          - compressibility (i.e., ability to withstand expected overburden
            pressures while remaining functional)

          - conpatibility (chemical)  with waste liquid

          - compatibility (mechanical)  with the liner (i.e., will not
            deform the  FML under the expected overburden)	
          - slope stability.

     0  Construction

          - construction characteristics (i.e., ease of construction).

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                                       15
      0 Operation/performance characteristics

           - drainage or flow characteristics  (i.e.,  how  fast  liquids will
             flow and what volume  will  flow)

           - time required to return  the  leachate  head  to one  foot or less
             after a  rainfall event

           - material creep

           - useful life of system

           - ability  to  resist clogging

           - ability  to  verify performance.

     An owner or operator wishing to use a leachate  collection system other than

the recommended  one  should compare the properties of his design against the

recommended design using  the above criteria.  If equivalent or better, he

should proceed;  if not, he should abandon the alternate design.  If one or

more of the  factors  is  not equivalent, the collection system will probably

not perform well, and will potentially become a source of constant trouole

to its owner/operator.

     If a waste pile is very  small a separate drainage layer below the waste

may not be needed.  Instead,  merely using a liner and sloping the liner so

that any leachate will flow to a sump  that provides leachate collection and

removal and meets the maximum one-foot head requirement is adequate.

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                                       16
                           II.   Liner Specifications
                                    Contents
                                                             Page
      A.   Guidance	      16
           Requirements  	      16
           Design 	      17
               a.   Disposal	      18
               b.   Storage and  treatment	      22
           Construction	      24
               a.   FML	      24
               b.   Low  permeability  soil  	      25
           Operation	       32
      B.   Discussion	      33
     A.  Guidance
     Regulatory and Statutory Requirements for Overall Design, Construction,
     and Operation
     For interim status waste piles, at least one liner must be installed
for new units or replacement or lateral expansion of an existing unit.
Permitted waste piles must have a single liner that meets §264.251(a)(1).
Both interim status and permitted waste piles that are inside or under a
structure are not subject to the liner requirements.  One liner is also
required at tine of permit issuance for those portions of existing units at
landfills and surface impoundments that are not covered by waste at the
time the permit is issued.  The liner must be designed, constructed,  and
installed to achieve containment of the waste in the liner during the active
life of the unit, thus preventing the escape of hazardous constituents.   The
liner for a disposal unit must be designed and constructed of materials  to

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                                        1 /
  prevent the migration  of any hazardous constituents into such  liner except



  for de minimus  infiltration of waste  constituents during the active life of



  the unit (including the  closure period).  For a storage unit (i.e., a pile



  or surface  inpoundment from which wastes and waste residue will be removed



  or decontaminated at closure),  the liner may be constructed of materials



  that nay allow  wastes to migrate into the liner but not into the adjacent



  subsurface  soil or ground water or surface water at any time during the



  active life  (including the closure period) of the unit.  The liner materials



  must be resistant to the hazardous constituents the liner will encounter,



  and be of sufficient strength and thickness to withstand the forces it will



 encounter during construction and the active life.   The foundation must be



 prepared to ensure that the structural stability of the subgrade is sufficient



 to support the liner and to prevent failure due to pressure gradients.   The



 liner must cover all areas likely to be exposed to  waste and leachate.



      Design



      e  This  liner system should be constructed conpletely above the seasonal



 high water table (i.e., in unsaturated soil).



      0  Liners for disposal surface  inpoundment  and  landfill units  should oe



 designed with a  single  flexible membrane  liner  (FML).



      0 The liner for storage or treatment  inpoundments, and storage piles



where the waste will be removed at closure should consist of a  single FML



or  ccnpacted low permeability soil  liner.



      ' The following are single liner specifications which  the  Agency



believes will produce stable construction and which will prevent  the release



of hazardous constituents.                               :               :

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                                       13
      (a) A FML liner:
      (1) The FML should be of  at  least  30 mils  thick; however,  if the liner
 is to be exposed to the weather for an  extended period before  it is covered
 by a protective soil layer or  the waste, or  if  the  liner  is  to be operated
 without a protective cover,  it should be at  least 45 mils  in thickness.
 Many units will require a  thicker liner to prevent  failure while the unit is
 operating, including any closure  period.  The adequacy of the  selected thickne
 should  be demonstrated  by  an evaluation considering the type of FML material
 and site-specific  factors  such as:  expected operating period of the landfill
 or surface impoundment  unit, pressure gradients, physical contact with the
 waste and leachate,  climatic conditions (environmental factors), the stress
 of installation, and the stress of  daily operation  (e.g., placing wastes  in
 the landfill or sludge  removal  in surface impoundments}*  Stresses tend to
 be higher for surface impoundment units than for landfill units.  Several
 factors  can increase liner stresses in  surface impoundments such as:  (1)
 cleaning or maintenance  activities;  (2) thermal stress; (3) hydrostatic
 pressure (head  and wave  action);  (4) abrasion;  (5)  weather exposure (ultraviole
 light, oxygen,  ozone, heat, and wind);  and (6) operating conditions (inlet
 and outlet flow, active  life,  exposure  to animals,  treatment processes).
 Because  of these factors,  uncovered surface  impoundments generally require
 thicker  liners  than  the  45 mil  minimum.  Thicknesses of 60-100 mils have
 teen  necessary  in some applications.  A protective  layer  covering the liner
 in surface impoundments  can reduce  the  stresses on  the liner.   The Agency
will  consider appropriate  historical data and actual test data regarding  the
performance of  liner materials  of the designed  thickness  as  part of  the
evaluation of the permit application.

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                                        19
       (2)   Liners  must  be  chemically  resistant to  the waste and  leachate



  managed at the unit.   Generally,  test data will be required because the



  demonstration of  chemical resistance should be based on representative waste



  effects.   The EPA Test Method 9090 (October 1, 1984, proposal or revised



  editions)  or an Agency approved equivalent test method should be used to



  test chemical resistance of liners.  Complete copies of Test Methods for



  Evaluating Solid Waste which contains the sampling and analytical methodologies



  addressed  in the October I, 1984, proposed rules  (including Method 9090) are



  available from the National Technical Information Service (OTIS), 5285 Port



  Royal Road, Springfield,  Virginia  22161, (703)  487-4650. The document number



  is PB-85-103-026.   In judging chemical compatibility of wastes and membranes,



 the Agency will consider appropriate historical  data or actual test data if



 obtained under longer or more severe.test conditions*



      (3)  The National Sanitation Foundation (NSF)  presents liner material



 properties and factory seam requirements in their Standard Number 54 for Flexible



 Membrane  Liners, November 1983.   The  Agency suggests  that material and seam



 specifications such  as  those in  the National Sanitation Foundation standard be



 used  to assure material quality  from  the liner manufacturer.   Liner materials



 listed  by  the National  Sanitation Foundation for  industrial service,  or liner



 materials  that are not  listed but consistently meet the specifications of the



 NSF Standard 54, are  acceptable  for assuring quality  from the  manufacturer.



 Test methods used  to  estblish these requirements should comply with applicable



 American Society of Testing and Materials (ASTM) procedures, recommended methods



 in EPA document SW-870 Lining of Waste Iirpoundment and  Disposal Facilities (tables



VIII-1 to 7) (EPA  1983a), or an equivalent method  when  available.—The-FMLs	



covered by NDF Standard 54 include  at least  the following:

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                                        Tl
       0  Jciyvinyl Chloride  (?VC)
       "  Pclyvinyl Chion.de Oil Res is cant  (7VC-GR)
       0  Chlorinatea Polyethylene  (CPE)
       *  Butyl Rubber  (IIR)
       0  Polychloroprene  (CR)
       0  High Density Polyethylene (HDPE)
       0  Ethylene-Propylene Diene Terpolymer (EPDM)
       0  Epichlorohydrin Polymers  (CO)
       6  Polyethylene Ethylene Propylene Alloy (PE-EP-A)
       0  High Density Polyethylene Elastomeric Alloy (HDPE-A)
       0  Chlorosulfonated Polyethylene (CSPE)
       0  Chlorosulfonated Polyethylene, Low Water Absorption (CSPE-LW)
       8  Thermoplastic Nitrile - PVC (TN-PVC)
       0  Thermoplastic EPDM (T-EPDM)
       0  Ethylene Interpolymer Alloy (EIA)
       0  Chlorinated Polyethylene Alloy (CPE-A)

 The address for the National Sanitation Foundation is:

                    3475 Plymouth Road
                    P.O.  Box 1468
                    Ann Arbor,  Michigan 48106  USA

      (4) FMLs  should be free of  pinholes, blisters, holes,  and contaminants,

 which include,  but  are not  limited to,  wood,  paper, metal,  and nondispersed

 ingredients.

      (5) The compounding ingredients used in  producing FMLs should be first

 quality, virgin materials providing durable and effective fornulations for

 liner applications.  Clean  rework materials containing encapsulated scrim or

 other fibrous materials  should not  be used in the manufacture of FMLs used

 for hazardous waste containment.  Clean rework  materials  of the same virgin

 ingredients generated  from the manufacturer' s own production may be used by

 the same manufacturer, provided that the  finished products  meet the material

 specification requirements.

      (6)  FMLs in landfill and waste pile  units,  and in surface impoundment

units with the minimum i-onotmqnded  thickness, should  be protected from damage

from above and below the membrane by a  least  30 centimeters (12 inches)

nominal,  25 centimeters  (10  indies) miniitum of  bedding material (no coarser

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  than r;nifieci Soil Classification System (USCS) sand (SP) with 100 percent cf

  the washed, rounded sand passing the 1/4-inch sieve)  that is free of rock,

  fractured stone, debris,  cobbles,  rubbish,  and roots,  unless it is known

  that the FML material is  not physically inpaired by the material under  load.

  The surface of a completed substrate should be properly conpacted,  smooth,

  uniform,  and free from sudden changes in grade.   A low-permeable soil may

  serve as  bedding material when in  direct contact with  FMLs if it meets  the

  requirements specified herein.   Polymeric materiala such as  geotextiles and

  synthetic drainage layers may also serve as  bedding materials when  in direct

  contact with either surface  of the FML,  if they  provide equivalent protection.

  In determining equivalent protection given by geotextile or  other specific

 materials, the Agency will consider historical data and actual test data

 that relate to site-specific conditions.  To demonstrate that a  synthetic

 drainage layer can serve  as bedding material, it  should be shown that the

 synthetic drainage layer does not exhibit brittle failure under overburden

 stresses and stresses caused by equipment used for construction or waste

 placement.

      Note:  In most cases  a F74L should not be in contact with native, in
             situ soil.

      Note:  Light geotextile bedding material may require an additional
             precaution if  the slopes  are exposed to high velocity winds.

      (7)   For surface  impoundment and landfill units in which the sidewalls

will  be uncovered and exposed for extended  periods before wastes are placed,

the design of the  bedding  material  used below the liner should be highly

permeable and  include gas  venting if  the potential for gas generation under
the liner exists, or if the slopes or a  surface iitpoundment will be

exposed to high velocity winds.

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 ti.ne to Breakthrough:  liner thickness, water content,  capillary forces,  and

 unsaturated hydraulic conductivity at various depths in the liner over tinre.

 Conservative assumptions should be used in estimating the necessary liner

 thickness to prevent migration of any constituent through the conpacted low

 permeability soil bottom liner.  Examples of assurrptions that should be made

 are as follows:

      (i)  Inpingement rate on the liner would be equivalent to the rate of moisture
          infiltration into the waste pile,  and,  for surface impoundments,  the head
         would be equal  to the maximum operating head for the impoundment;

     (ii) Leakage into the liner would occur throughout  the active life;

    (iii) Nature  and quantity of the  waste would be  considered;

     (iv) Any  allowance for attentuation should take into account  the nature of the
         waste and any factors that  may reduce attenuation.

      (v) The  effective porosity would be  0.05;  and

     (vi) The  compacted low permeability soil liner  and  adjacent soil strata would
         be initially  unsaturated.

The compacted material must be  free  of rock,  fractured  stone, debris,  cobbles,

rubbish, and  roots, that would  increase hydraulic conductivity or serve to

promote preferential leachate flow paths.

      (2) The owner/operator should document methods used  to estimate  the

necessary liner thickness.  These evaluations  should also  cover the  following:

     (i) Horizontal hydraulic conductivity within and between the  individual
         lifts (Brown et  al, 1983 Boynton, 1983);

    (ii) Variability in the hydraulic conductivity of the compacted soil  liner
         in the field (Eaniel, 1984);

   (iii) The potential for long term changes in hydraulic  conductivity resulting
        from loss of moisture by the liner due to climatic conditions or the
        equilibrium moisture content in the adjacent soil deposits; and

    (iv) The effect of liner aging on the long term equilibrium hydraulic
        conductivity of  the liner (Mitchell et al,  1965; Dunn and Mitchelll
        1984. Boynton,  1983).

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      (3) The foundation subsoil that underlies the soil liner should  be
 structurally immobile during construction and operation of  the unit  (including
 any closure period).
      (c) The owner/operator should prepare a written construction  quality
 assurance plan to be used during construction of  the liner  system.  Section
 III, "Construction Quality Assurance,"   should be used  to assure that the
 conpleted liner system meets the design  criteria  and specifications.
      Construction
      8  The earth substrates and base materials should be maintained in a
 smooth, uniform,  and compacted  condition during installation  of the liner
 and  components*
      0  Waste pile,  surface impoundment,  and landfill units  should  be  constructed
 with liners  that  meet the following,  as  a minimum:
      (a)  FML liners:
      (1)  The liner  should be installed (seamed) at ambient  temperatures within
 the  range specified by the manufacturer  of the particular liner.   Temperature
 extremes  may have an effect on  transportation,  storage,  field handling,
 placement, seaming,  and backfilling  (where required).
      (2)  When the field seaming of the FML is  adversely affected by moisture,
 portable  protective structures  and/or other methods  should  be used to maintain
 a dry sealing surface.
      (3)  Liner installation should be suspended when wind conditions  may
adversely affect  the  ability of the  installers to maintain  alignment  of
seams and integrity of membranes  and  seams.	
     (4) Field seaming of  FMLs  should be performed when weather conditions
are favorable.   The contact surfaces  of  the FML should  be free of  dirt,

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                                       25
 dust, and moisture including films resulting from condensation in weatner



 conditions of high humidity.  Seams should be made and bonded in accordance



 with the supplier's recommended procedures.  Both destructive and nondestructive



 testing methods should be used to evaluate seam integrity.  All on-site



 seams should be inspected by nondestructive testing techniques to verify their



 integrity.  Periodic samples should be removed from both factory and field



 seams and tested for seam integrity by destrictive tests (tension and peel



 tests).   On-site nondestructive seam samples should be made and evaluated with



 identical liner material, adhesive/ and technique prior to actual field seaming



 each day,  or when conditions change.



      (5)  Proper equipment should be selected in placing bedding material



 over FMLs  to avoid undue stress.



      (b)  Low permeability soil  liners:



      (1) EPA is  conducting studies  to evaluate the construction criteria



 that most  significantly influence the hydraulic conductivity of compacted



 low  permeability soil  liners.   Until  specific research and/or demonstration



 data are available, the following are suggested as the best available procedures



 for  optimizing construction of  compacted soil liners:



      (i) Remove  all lenses,  cracks, channels,  root holes,  or other structural



 nonuniformities  that can increase the nominal in-place saturated hydraulic



 conductivity of  the liner above 1 X 10~^ cm/sec.



     (ii) Construct the  liner in lifts not exceeding 15 centimeters (6 inches)



after compaction to maximize the  effectiveness  of  compaction throughout the



 lift thickness.  Each lift should be  properly interfaced by scarification
between lifts.

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                                       26
     (iii) Scarify sufficiently between each lift so as not to create a zone
 of higher horizontal hydraulic conductivity at the interface of the lifts.
     (iv) Break up clods and homogenize the liner material before conpaction
 of each lift using mixing devices such as pug mills or rotary tillers.   All
 oversized materials (such as trash,  large roots,  wood, or large clods)  should
 be removed in order to facilitate moisture control operations,  maximize
 conpaction,  reduce heterogenity,  and minimize overall hydraulic conductivity
 of the corpacted liner.
      (v) Thoroughly mix  in moisture  needed to bring the liner to the desired
 water  content using mixing devices such as pug mills, rotary tillers, or
 other  effective methods.
     (vi) Compact the liner after  allowing a sufficient time  for added water
 to penetrate  to the center of  the larger diameter clods while not allowing
 so much time  after water  addition that the exterior of the larger clods
 becomes drier than optimum.  The  larger clods should be field checked for
 moisture distribution.
   (vii)  Take the  necessary precautions to assure that the desired moisture
 content is maintained  in  the compacted liner to avoid desiccation crackinq.
 Precautions that are effective at preventing desiccation cracking should be
 taken both between  the placement  of  lifts and after completion of the liner.
   (viii) Construction should not  take place using frozen or  other indurated
 soil/ and precautions should be taken to assure that the liner is not allowed
 to freeze after placement.
    (ix) Sidewalls  should be constructed so as to minimize flow between the
lifts.  EPA believes this can best be accomplished with lifts that are laid
down parallel to the slope.

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                                      27
      (x) A demonstration should be made that sidewalls can be effectively
 compacted at the maximum slope to be used in the design.   The Agency suggests
 a maximum slope of 3 horizontal to 1 vertical.
     (XL) Consideration should be made of the vector of compactive effort
 when calculating the number of passes necessary to obtain a certain degree
 of compaction on sidewalls.
    (xii) The uppermost lift should be scraped and steel rolled to produce a
 smooth  surface prior to placement of the leachate collection and removal system.
      (2) EPA recommends that a representative test fill be constructed using
 the soil,  equipment, and procedures to be used  in construction of the compacted
 low permeability soil liner in the full scale facility.  The test fill should
 be used to verify that the specified density/moisture content/hydraulic
 conductivity values  can be consistently achieved in the full scale facility.
 Test fills have been used to validate both design and construction procedures
 for critical earthen structures around dams  and nuclear power plants.  In
 order for  the data collected from the test fill to be useful,  however,
 construction control of the test fill must be strict and  well documented.
     Previously-developed data that describes the performance of an installed
 liner can  be used, provided documentation is available on all the factors
 discussed  above.  EPA is not,  however aware  of  any facility that currently
 has  this data on hand.
     All information gathered  during construction and subsequent testing of
 the  test fill  should be documented.   The CQA program to be followed during
 construction of the  full scale facility should  be strictly followed during
construction of the test fill  (Corps of  Engineers,  197T)~.   Recommended" minimum
test fill construction details are as  follows:

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                                       28
       (i) Construction using the same compactable materials, compaction equicm
 and exact procedures as will be used to construct the full scale facility lin
 All applicable parts of the quality assurance plan should be precisely follow
 to monitor and document construction of the test fill.
     (ii) The test fill should be constructed at least four times wider than tfr
 widest piece of equipment to be used in construction of the full scale facilit
    (iii) The test fill should be long enough to allow construction equipment t
 reach normal operating speed before entering the area to be used for testing
 (see Figure 5).
     (iv) Construction so as to facilitate the use of field hydraulic conductiv
 tests  and/or a complete quantification of all underdrainage.   Field hydraulic
 conductivity tests should be conducted on the compacted test fill material as
 a  verification of results of laboratory tests conducted on undisturbed samples
 taken  from  the compacted- test fill  material.   The field hydraulic conductivity
 tests  need only verify that the hydraulic conductivity i& 1 x 10~7 cm/sec or le
 not  its  actual value.   These undisturbed samples can then be  used for compacted
 liner/leachate compatibility testing.
     (v)  Construction  so as to determine the  relationship of  the following to
 the moisture  content/density/hydraulic  conductivity  values obtained in the fielc
     0 Compaction method (detailed  specifications of the compaction equipment);
     0 Number of  passes  of  the  compaction equipment;
      0 Mixing method  (and resulting maximum clod size);
      0 CcniMCtion equipment speed; and
     4 Uhconopacted and compacted  lift  thickness.
   (vi) A set of index properties should be  selected  that  will be used to monitc
and document the quality of construction obtained in  the test fill.   These inde>
properties should include at least the following:
       Hydraulic conductivity  (undisturbed samples);
       In-place density and water content;
       Maximum clod size;
       Particle size distribution; and
       Atterberg limits.

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       >>»»>))»>»»»» >»»»»))
       LEAST THREE SIX-INCH THICK LIFTS OF COMPACTED SOIL
      DRAINAGE LAYER OR  UNDERDRAINAGE  COLLECTION SYSTEM	
a.
C
0>

u»
                                                                           Ul
                                                                           a.
                                                                           3
                          2:1  SLOPE
L-  DISTANCE REQUIRED FOR CONSTRUCTION EQUIPMENT  TO REACH NORMAL
      NNING SPEED
W- DISTANCE  AT LEAST FOUR TIMES WIDER  THAN THE  WIDEST PIECE  OF
   CONSTRUCTION EQUIPMENT

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                                        30
  Data from these tests shall be used as standards for comparison with values
  obtained on samples from the full scale liner to indicate inplace  field
  hydraulic conductivity.
       (3) All lifts of the compacted low permeability soil liner that are
  part of the 3-ft minimum thickness, should  have  an in-place  hydraulic conduct
  of 1X10~7 cm/sec or less.   This hydraulic conductivity value should  be
  verified both in the test fill liner and by  comparison of index property
  values  between the test  fill  and each lift  in the  full scale liner.   The valu<
  obtained should be numerous enough to fully document the  degree of variability
  of all  the index properties in both the test  fill  and each lift in the full
  scale liner.
      Conservative  assumptions  should be used  in  estimating the  compacted low
  permeability  soil  liner  thickness because of  the lack of  precision with which
  such estimates  can be made.  There are several difficult  to  estimate variables
  that affect the  thickness needed  to prevent migration of  hazardous constituent
  over the operational life of the  soil liner.  Examples of the conservative
  assumptions that should be used to estimate soil liner thickness are as follow:
      1.  The  leakage/impingement  rate of leachate  to the  soil liner  should
          be based on an estimate of active  life  and  closure  period conditions.
      For waste piles during the active  life the  leakage into the compacted
 soil liner should be based on the  rate of moisture/liquid infiltration into
 the waste pile considering  (1) leachate collection and removal  by the leachate
 collection system under proposed removal conditions,  and  (2) the compacted
 soil liner surface conditions.
~     For treatment and storage surface  impoundments  during the  active 1 tfe
 the leakage rate into the compacted soil liner should be  based  on  (1) the

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                                        31
  maximum designed operating head for the inpoundment, and (2) the compacted



  soil liner surface conditions.



       2.  Nature and quantity of the waste should be considered.



       Volume of leachate released by the waste as decomposition by-products will



  depend on  the total organic content of the waste.  The higher the organic content



  of a waste, the greater would be the fraction of the waste which could be liquifiec



  during its decomposition.  The total quantity of organic materials in the facility



 would affect the total volume of leachate that could eventually be generated from



 decomposition of the waste.



      Composition of a waste will affect the composition of the leachate.   High



 concentrations of certain leachate components may increase the rate at which a



 soil  liner transmits  leachate (Anderson,  1982).   If a waste has a flow rate through



 the compact soil  liner faster than water this should also be considered in the



 evaluation of required liner thickness.



      3.  Any allowance  for attenuation of the waste constituents by the soil



         liner should take into account the nature of the waste and any factors



         that  may reduce attenuation.



      Some waste constituents  (such as  cations) can be strongly attenuated by



 soils under ideal conditions  (EPA,  1983c).   The  extent to which many of these



 are  attenuated can, however, be greatly decreased in the acidic and anaerobic



 conditions  that are often present near soil  liners.   Other  waste constituents



 (such as  anions) nay not be appreciably attenuated by soil.   Movement of  waste



 constituents^will also  be affected by  the  effective porosity of the soil  liner.



 There  are a number of other conditions under which attenuation can be greatly



 reduced.  In addition,   the conditions  that optimize attenuation of one constituent



may promote leaching of another (Lindsey,  1979).

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                                       32
        4.  The effective porosity would be 0.05.
        Total porosity of a contacted soil will usually be less than 0.5
  (Anderson et al., 1984; and Brown and Anderson, 1983).  Effective porosity
 can be much less than total porosity in fine-grained soils (Gibb et al.,      ~
 1985).  Green et al., (1985) found that in some compacted sanples only 10% of
 the total porosity was effective in transmitting liquids.  Ten percent of
 even the highest total porosity likely in a compacted specimen would result
 in an effective porosity of no greater than 0.05.
       5.   The compacted low permeability soil liner and adjacent soil strata
           would be initially unsaturated.
       Design criteria given elsewhere in this document state that the "liner
 system should be constructed completely above the  seasonal high water table
 (i.e.,  in unsaturated soil)."  Under these conditions, the soil strata
 immediately  adjacent to the liner would probably also be unsaturated.
      (c)  The owner/operator should implement a written quality assurance
 plan  to monitor and  document the quality of liner  materials used and the
 conditions and  manner of  their placement during construction.   See Section III
 "Construction Quality Assurance",  for specific recommendations.
      (d)  The documentation  for the CQA program for construction of the liner
 should  be kept  on-site  in the facility operating record.
   Operation
   The  following operational criteria are  suggested:
     (a)  The placement of removable coupons of the FML (if this type of liner
 is used)  above  the top  liner is a technique for providing waste/liner chemical
compatibility infonnation during the operating period.   Coupons are samples
of the FML used in the construction of  the  liner that are placed in contact
with wastes or leachate in the landfill, waste pile,  or surface impoundment.

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                                       33
 The coupons are tested after various exposure periods in the unit to determine

 how the properties of the liner change over the active life.  This information/

 when compared to short-term compatibility data, can provide an early warninq

 that the liner is degrading faster than anticipated and allow for corrective

 measures by the owner.  The Agency recommends that landfill, waste pile,  and

 surface impoundment owners consider removable coupon testing if wastes are

 likely to vary somewhat during operation.

      (b) The owner should have on-site guidelines for operation and maintenance

 of  the liner system,  which include recommendations on such subjects as:

      - Frequency and  documentation of inspection,
      - Testing and repair of liner,
      - Animal and plant control,
      - Erosion control,
      - Unacceptable practices,
      - Placement of waste,  and
      - Coupon test schedule (optional).

      B.   Discussion

      The EPA believes that a FML  should meet  the following criteria:

      - A minimum thickness depending on the service;

            0  For buried FMLs the  minimum thickness should be 30 mils when the
              membrane will  be covered within  three months by a protective layer
              against  mechanical and weather conditions.

            0  For membranes  that will be  buried,  but left unprotected for periods
              greater  than 3 months,  the  minimum thickness should be 45 mils.

            0  For all  liners used  in impoundments that are left uncovered and
              exposed  to the weather and experience light work on the surface,
              the minimum thickness  should  be  45 mils.

            •  The thickness  of scrim layer,  geotextile backing, or other
              reinforcing material should not  be used in computing a minimum
              reoommendation.

            0  For many units,  particulary surface impoundments with exposed
	surfaces, FMLs  of  60-100 mils may be required to meet the mechanical
             stress requirements.~

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                                      34
             3 The stresses on exposed liners are generally greater for surface
              impoundments because of exposure to more severe environmental
              conditions  (climate)/ loading and unloading during daily operati
              and sludge  removal.  Because of the more severe operation condit
              surface impoundments require substantially thicker liners.  A
              protective  layer covering the liner can reduce the stresses on
              the liner.

       -  Sufficient strength to prevent failure due to pressure gradients
          (including static head and external hydrologic forces, stresses of
          installation, and the stresses of daily operation);
        - Compatibility with the waste to be managed in the unit;
        - Low permeability; and
        - Capable of being seamed to produce high-strength, liquid-tight seams
          that retain their integrity during liner installation and on exposure
          to wastes for the duration of the operating life of the unit, includi
          the closure period.

      One of the primary reasons for failure of synthetic liners is damage

 (i.e., punctures,  rips, and tears).   Damage occurs during installation and/or

 during operation.   The owner/operator needs to demonstrate that the selected

 FML thickness is adequate for the site-specific conditions the liner will

 encounter while the unit is in operation (including any closure period).

      EPA believes  thickness and strength of the liner material are major

 factors in maximizing serviceability and durability.  However, the lack of

 current technical  data relating liner thickness for specific material types

 to successes and failures of liner systems prevents more specific guidance

 on thickness.   The following is a list (EPA, 1983) of potential failure

 modes that should  be considered in selecting the FML polymer type and thickness

 to maximize liner  serviceability and durability:

      Physical Modes of Failure

      Abrasion
      Creep
      Differential  settling
	Hydrostatic pressure	
      Puncture
      Stress-cracking (partly chemical)
      Tear stress
      Thermal stress

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                                        35
      Chemical Modes of Failure

      Extraction of plasticizer and soluble ingredients
      High pH>10
      Hydrolysis
      Attack by ionic species
      Low pH<2
      Ozone-cracking
      Attack by solvents and organic chemical species
      Ultraviolent light attack

      Biological Modes of Failure

      Microbial attack (of plasticizers in FML compounds)

      Liner failure mechanisms are addressed in a U.S. EPA Technical Resource

 Document/ Lining of Waste Impoundment and Disposal Facilities, SW-870,

 March 1983.   This document describes and discusses the categories and charac-

 teristics of liner failure in a service environment.  The document is available

 from the U.S.  Government  Printing Office, publication number S/tt 055-000-00231-2,

 $11.00,  Superintendent of Documents,  Washington, D.C.  20460.  Kays (1977)

 also provides  detailed discussion en liner failure mechanisms and methods to

 avoid failures for cut-and-fill reservoirs.

    To help guard  FMLs  against damage,  such as  punctures, tears, and rips

 due to contact with sharp objects or  other conditions,  it is good practice to

 protect  them from above and below by  a minimum of  12 inches  of bedding material.

 In  landfills,  the  act of  placing  wastes sometimes  causes damage (e.g., due to

 dropping of wastes or driving of  vehicles on the liner) ; also, over extended

 time periods the wastes themselves may be capable  of causing damage to the

 FML and  to the leachate drainage  and collection system because they contain

 sharp objects or abrasives.

         landfill nnil-q, a  Iparhat-a rtrainaqft and ffQilerfcinn  and removal __
system must be placed above the liner.  This  layer can be made of materials

that meet both bedding and drainage material  requirements.  However, EPA

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                                       36
 suggests that for these units an additional layer of bedding material be
 installed above the top filter layer as well as below the FML, unless it is
 known that the FML is not physically impaired by the materials and operating  "
 practices.  The drain pipes in the collection system should be adequately
 protected against damage caused by waste placement and/or equipment operating
 on the working surface.
      Bedding layers should consist of materials that are no coarser than
 sand (SP) as defined by  the Uniform Soil Classification System (USCS).   Use
 of a sand layer is cannon practice for protection of membranes and pipes
 from damage due to contact with grading equipment and materials,  sharp  material
 in the soil,  etc.
      For surface impoundments,  a bedding layer above a FML also protects the
 FML from damage due to exposure to sunlight and wind while the unit is  in
 operation.   However,  the bedding material is not always necessary above the
 top liner,  since direct  contact with the liquid wastes does not represent
 the same potential  for puncture that is present in landfills.   Nevertheless,
 the liner can be damaged,  for example during sludge  removal, other dredging
 operations, or  normal  operating practices.   Where mechanical equipment  is
 used, EPA recommends a minimum  of 45 centimeters (18 inches) of protective soil
 or  the equivalent covering the  liner,  unless it is known that  the FML will not
 be  damaged by the sludge removal  practices.   Some FML materials are known to be
 degraded by ultraviolet  radiation and must  be  covered.   Also,  wind can  get undei
 the edge of exposed FMLs,  causing flapping  and whipping,  which can lead to tear;
These problems have occurred most camionly  above the liquid level near  the edge
of the FML.  As a result, it is carmen practice  to cover FMLs with 6 to 12 inch*
of earthen material to prevent degradation due to sunlight and to hold the linei

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                                       37
 down.  The edges of FMLs are usually secured by anchor trenches at their perimeter
 Of course, if the design is such that wind creates no difficulties, and if it is
 known that the FML is not subject to solar degradation, then these precautions
 are not necessary.  The addition of a cover over the FML is expected to extend
 the service life of the liner.
      Chemical testing of all construction material corrponents is prudent
 because liners can be degraded by certain chemical species that may be present
 in the waste.   Because wastes and liner chemical characteristics are almost
 infinitely variable,  it is difficult to generalize concerning incompatibility
 or compatibility.   The Agency/ therefore, strongly suggests (and prefers)
 test data as  the appropriate way to demonstrate the compatibility of the
 waste to be managed and the liner materials under consideration.  Test results
 should demonstrate the acceptability of the selected liner materials.  New
 test data may  not  be needed for units that have a well defined waste composition
 and  for which  previous test data showing that  the proposed liner chemical
 characteristics  are very predictable.
     Waste liner material compatibility tests  should be conducted using
 representative samples of wastes and leachates  to which the liner is to be
 exposed.   Several methods for obtaining samples of hazardous waste are discussed
 in Section one of Test Methods  for Evaluating Solid Waste  (SW-846).
     An acceptable  test method  for assessing the compatibility of waste
 liquids and FMLs is the  "Immersion Test of Membrane Liner  Materials for
Chemical Compatibility with Wastes," found in EPA's Method 9090.  In this  test,
samples of the candidate FMLs are  immersed at two temperatures in samples
of the waste liquid to be managed and exposed  for  four months.   After exposure
for one-month intervals, a FML sample is  tested  for important strength

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                                       38
 characteristics (tensile,  tear,  and puncture)  and weight  loss or  ..ain.  The



 Agency ccnsiders any significant deterioration in any of  the measured propertie



 to be evidence of incorrpatibility unless a convincing demonstration can be



 made that the deterioration exhibited will not inpair the liner integrity      !



 over the life of the facility.   Even though the tests may show the amount of



 deterioration to be relatively small,  the Agency is concerned about the



 cumulative effects of exposure over very nuch  longer  periods than those



 actually tested.



      At present,  no standard test method is available for assessing the



 compatibility of  specific  low permeability soils with a given waste liquid.



 Nevertheless,  the compatibility  of a soil with a waste liquid has been measured



 by conparing  the permeability of the soil to water and to the waste liquid.



      The Agency incorporated the National Sanitation  Foundation's (NSF)



 standard specifications fox flexible membrane  liners  into this guidance to



 provide suggested  minimum  values for physical  properties.  A NSF committfie has



 been  studying the  subject  for some time,  and EPA believes  that the specifications



 developed are reasonable and well thought out.  Compliance with the NSF



 standard attests only to the basic quality of  the liner itself and not to



 the advisability of  its application under any  given set of waste and unit-



 specific circumstances.



     A  EML is required to  be designed to prevent migration of constituents



 of the wast«  liquid  into the liner during the  active  life of the unit  (including



 the closure period) except for de minimis  leakage.  CPA recognizes that



membranes will not always have zero leakage and that  de minimis leakage may



occur.  De minimis leakage can occur as  a result of vapor passing through  the



 liner, very small imperfections  in the liner that occur very rarely, or a  seam

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                                        41
       (1) There are no clear criteria or techniques available for making breakthrough



  determination.  While several methodologies have been suggested,  the Agency  is  not



  aware of any methods which have undergone rigorous field-verification testinc,.



       (2) It is not clear whether it would be economically feasible to construct



  a low permeability soil liner thick enough to prevent breakthrough during  the



  active life of the unit assuming adequate flow from the overlying waste pile or



  surface inpoundment to maintain continuous unsaturated (capillary) flow through



  the soil liner.



       (3) Hydraulic conductivities of 1  X 10"? cm/sec or less have not been routinely



  and consistently obtained in the past on an overall in-field scale liner system.



  A number of studies have suggested  that actual field scale hydraulic conductivities



  may be  in the  range of 10 to 1000 times higher than the 1  X  10~7  to 1 X 10"8 on/sec



  values  that are  routinely obtainable in laboratory tests.  The Agency believes  that



  if a testfill  (described in the  section on construction of low permeability soil)



  is used,  a  hydraulic conductivity of 1  X 10"? can  be achieved in  the liner.



       (4)  The capability of current  testing methods  to verify with a high degree of



  confidence  the actual  field performance of a compacted low permeability soil



  liner has not been demonstrated.



 Consequently, the Agency currently believes  that the best  method would  include



 construction of a test fill and the collection of  field hydraulic  conductivity



 data.



      Minimizing the flux of  liquid through the conpacted soil to prevent break-



 through can be accomplished as follows:



	(1) minimizing the hydraulic gradient under which leachate will move; and



      (2) minimizing hydraulic conductivity of the conpacted  soil.



 There are tvo ways to minimize the hydraulic gradient: 1)  reduce  the depth of

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  standing liquids in ti'r.a Leacoate collection syste.-rs;  and  2)  construct a thicke

  ccnpacted soil liner.   Besides lowering the hydraulic gradient, constructing a

  thicker ccnpacted liner should reduce  the probability that a blemish of any kii

  would penetrate all the way through  the conpacted soil.                      ]

       Whether referred  to as blemishes,  macrofea tares, or  structural non-unifor-

  mities,  construction imperfections may increase the overall  saturated hydraulic

  conductivity by several orders of nnagnitude.  Methods to  reduce actual in-the-

  field hydraulic conductivity of a conpacted soil should be included in the

  construction inspection program to both prevent and detect these imperfections.

  Details of  the  infornation  that should be gathered before, during, and after

  construction of a conpacted soil (which should serve to reduce the number of

  these  inperfections) are given under "Construction Quality Assurance" (section

      Hydraulic  conductivity testing on  the  in-plaoe conpacted low permeability

  soil is reconmended because  of concern  that laboratory tests tend to underestirrv

  the actual hydraulic conductivity in the field by a factor of 10 to 1000.   The

  following recent references discuss the causes and magnitude of differences

 between field-measured and laboratory-measured hydraulic conductivity:

      0 Daniel, D. E., 1984.  Predicting Hydraulic Conductivity of Clay Liners.
        ASCE, Journal of Geotechnical Engineering,  110(2) : 285- 300.

      9 Griffin, R. A. et. al. 1984.   Migration of Industrial Chemicals and Soil-
        Interactions at Wilscnville,  Illinois.  In Proceedings of the Tenth Annua
        Research Symposium on Land Disposal of Hazardous Waste. (EPA 600/9-84-007
        USEPA Municipal Environmental Research Laboratory,  Cincinnati,  OH  45268.

      9 Herzog, B. L. and W. J.  Morse.   1984.  A Comparison of Laboratory and
        Field DeLernilned Values of Hydraulic Conductivity at a Waste Disposal
        Site,  Iri Proceedings of the  Seventh Annual Madison Waste Conference.
        University of Wisconsin-Extension, Madison,  Wisconsin, p. 30-52.
- "  Boutwoll,  G.C.  and V.R.  Donald,  L982. — ronpart or? riay rin^r* for Industri
        Waste Disposal,  Presented ASCE National Meeting Las Vegas, April 26, 1982

      One reason why higher hydraulic conductivities are often obtained with

 field tests  is  that samples  used in laboratory tests can be more readily

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                                        39
  that  has a very small crack or hole.  Although FMLs are nonporous-homoger.eous
  materials vapor diffusion can transmit water and other liquids with dissolved
  constituents through synthetic liners.  The transmission involves 1) sorption
  the constituents of the waste liquid into the membrane, 2) diffusion through the
  FML, and 3) evaporation or dissolution of the constituents on the downstream
  side of the membrane.  The principal driving force for permeation through a FML
  is the gradient across the liner in concentration/ chemical potential,  or vapor
 pressure of the individual constituents in the liquid or vapor.  Permeability of
 an individual permeant depends upon its solubility and diffusion characteristics
 in a specific liner.  De minimis leakage can also occur because of small and
 infrequent breaches in the liner that were not detectable during construction
 with current  practical state-of-the-art construction quality assurance  programs.
      EPA believes  that current state-of-the-art technology for FML installation
 allows for hazardous waste management units to be built that will have  very
 low leakage rates  at installation.   EPA does not have a specific maximum de
 minimis leakage rate that can be  recommended.   However, based on currently
 available preliminary field data, laboratory test results,  and professional
 judgment, EPA believes  that de minimis leakage should be  approximately
 1 gallon/acre/day  or less.  This  rate should not be taken as a hard and fast
 rule because  there  are conditions where vapor transmission potentially  could
 exceed  this value.   Also,  this value does  not apply to organic liquids, many
 of which can permeate a FML independently  of the water in waste liquid.  Some
organic constituents can  transmit at considerably higher rates than water,
 if the organic constituents are soluble in the membrane and organic concentration
on the downstream side of the rnamfiraisr is  essentially zero;—Dr. H. August-et al,
 (1984), has shown laboratory permeation rates for concentrated hydrocarbons on

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                                       40
 1 mm thick HLPE FMLs were between 1 and 50g/m2/day varying with the waste  chemical



 structure and its affinity to the HCPE.  Another finding of this study was  that



 very dilute hydrocarbon solutions sometimes give high permeation rates of  the



 hydrocarbons because of the relatively high solubility of the hydrocarbons  compared



 to water in the HDPE.  The concentration of organic waste in the liner surface can



 be higher by several orders of magnitude than the adjacent leachate or liquid



 waste containing hydrocarbons.  Current laboratory tests cannot be  related  directly



 to estimate field rates of permeation because the tests do not  simulate the ability



 of soil under the liner to transport the waste away from the liner.   (See the



 suggested reading material list for additional information.)  Review of information



 from recently constructed double synthetically lined surface impoundments shows



 that current state-of-the-art technology for installing synthetic liners is close



 to achieving 100% containment efficiency.   The liner installations  studied  had



 extensive construction quality control to assure  the seams did  not  leak.



     Soil liners will normally be of clay.   For purposes of this guidance,  "compacted



 soil" is  not meant to include materials such as soil cement,  lime soil mixtures,



 or fly  ash soil mixtures.   EPA recoimends that an owner or operator who wishes to



 install a compacted  lew permeability soil liner to comply  with  the  requirements of



 §264.221(a)  or 264.251(a)(l)  use this  guidance to determine the thickness of the



 bottom  liner.  EPA's  recommendation for soil  liners  is  :  (1)  that it consist of a



 minimum 90 centimeters (3  feet)  of compacted soil with  an  in-place  saturated hydraulic



 conductivity of not more than 1 X 10~7  cm/sec;  and (2)  that it  is sufficiently thick



 so as to prevent any  constituent  from migrating through the bottom  of the compacted



 soil liner prior to the end of the closure  period.   In  cases were the active life



of the unit covers an extended time period  the Agency has  reservations concerning



the likelihood that such a design is either economically or technically feasible.



Some of the issues underlying these  reservations  are as follow:

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                                       43
  prepared without  the defects  that can greatly affect actual hydraulic conductivity.



  Methods  that  are  used  to prepare soil liners in the field are difficult to



  siirulate in the laboratory.  One exanple is the method of conpaction.  Soil



  liners are often  compacted in the field with a kneading action through the



  use  of sheepsfoot rollers.  In contrast, soil liner sanples are usually



  prepared in the laboratory using impact conpaction.  Even though identical



  densities nay be  obtained with different methods of conpaction,  the soil



  sanples conpacted by different methods may have very different hydraulic



  conductivities (Mitchell, 1976).



      There are a variety of other reasons for the large discrepancies reported



 between laboratory and field tests.   Sanples prepared in a laboratory are



 not subject to the climatic variables (such as cracking due to either freezing



 or desiccation)  (EPA 1984A).   There  way also be a tendency to run laboratory



 tests on sanples of selected finer textured soil materials (Olson and Daniel



 1981).  It is  often suggested, however,  that the most  inportant reason for



 observed  differences is that field tests can evaluate  much larger and,  hence,



 more  representative sanples  than is  practical in laboratory tests.



      EPA  believes  that  field hydraulic  conductivity tests  are essential to



 verify the requirement  to have an in-place  hydraulic conductivity of 1X10~7



 cm/sec or less.  Currently available field  hydraulic conductivity tests,  if



 conducted on the actual conpacted soil  liner may, however,  cause substantial



 delays in construction  and result in other  problems due  to prolonged exposure



 of the liner.  In  addition, it would be  extremely costly if it were determined



 from field tests on the actual liner that it did not meet  or exceed performance
standards.  Much tima and effort, can Be saved if, prior to construction of—



the actual liner, a test section of the liner is prepared and tested.   These



tests can be used to document the capability; of the proposed materials and

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                                       44
 construction procedures that result in a corrpaoted soil liner that rreets  the



 desired performance standards.  Therefore,  the EPA recornnends that a test



 fill be constructed using the same borrow soil,  compaction equipment,  and



 construction procedures as proposed for the full scale facility.   The test



 fill is also recommended for use in demonstrating the actual in-place hydraulj



 conductivity of the compacted soil liner.



      Test fills have been used by the geotechnical engineering community  to



 evaluate the design of soil liners used in cooling ponds for the  nuclear



 power industry.  Test fills have also been used  during the design stage of



 dams to obtained information on engineering properties of the compacted soil



 such as density,  strength,  and hydraulic conductivity (Barron,  1977).



 Construction control of test fills mist be  very  strict and well dooznented



 or the data  obtained will  be of questionable value (Corps of Engineers, 1977).



      Field hydraulic conductivity tests of  the compacted soil in  the test fill



 are necessary to  assure that the materials  and procedures used in the field



 will result  in  a  compacted soil liner with  a hydraulic conductivity of 1X10"7



 on/sec  or  lower.  Field testing is not intended  to preclude the use of laboratc



 testing in the  design or construction phase or as  a means of evaluating



 liner-leachate  compatibility.   It is  expected  that the overall  design and



 construction quality assurance  (CQA) program will  include a mixture of both



 field and  laboratory hydraulic  conductivity tests.



     As appropriate  methods are developed and  verified,  the EPA intends to



 require field hydraulic conductivity  tests  be  conducted on the full scale



 facility.  Field hydraulic  conductivity testa  can be  performed in the test



 fill without causing delays during construction  of the full scale facility.



The field test used  should be capable of verifying that the hydraulic conducti\



of the compacted soil  liner is  1X10"7 cm/sec or  less.

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                                        45
       Field infiltroneters capable of measuring  very  low hydraulic  conductivities

  in conpacted soil liners  have been developed and  reported by Anderson et al

  (1984),  Day (1984)  and Day et al  (1985).  An alternative to the use of  field

  infiltrometers  is the use of  a system for capturing and collecting all under-

  drainage fron the test fill.   Day (1984) used such an underdrain to evaluate

  the accuracy of results obtained  from field  infiltrometers.  While the field

  infiltrometers were found to  accurately measure hydraulic conductivity, the

  underdrain was considered even more accurate.

      Both infiltration  and underdrainage tests should be conducted until

  stable flow and/or drainage rates are obtained.  Where  infiltrometers are

  used, there should be enough replicate tests to document area! variability

  in the hydraulic conductivity of the liner to the test  fill.  A sufficient

 number of index property tests (listed earlier in this  section) should be

 conducted to accomplish the following:

      (1)  verification of the aspects of the OQA plan related to conpacted
          soil liners;  and
      (2)  document the degree of variability in each of  the properties tested
          in the compacted soil liner for both the test  fill and full scale
          facility.

      In addition to being used as  a site for field hydraulic conductivity

 tests,  the test  fill should be used to verify all elements of the design and

 construction of  the soil liner. These elements should include at least the

 following!

      (1)  verification  that the proposed soil material is uniformly suitable
          to be conpacted into  a liner (i.e.  no cobbles,  sand lenses,  or indurated
          materials).

      (2)  verification  that the equipment and procedures  for breaking up
	cl
         consistently achieving the required hydraulic conductivity specifi-
         cation.

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                                       -tO
       (3) verification tiiat tiie CGA plan is sound in all respects.   The prcpos
          CQA. plan for construction of the full scale facility should be
          followed exactly as applied to construction of the test fill.   If
          methods to iitprove the CQA plan are documented during construction
          and testing of the test fill,  these inproveitients should be incorpors
          into the CQA program inplemented during full scale facility construe

      Technical personnel who will be in charge of day to day inplementation '

 of the OQA plan on the full scale facility should also monitor and thoroughly

 document construction and testing of the test fill.   This docunentation

 should include at least the following:

      (1) a detailed description of for  the type of equipment used during the
          borrow and construction operations,

      (2) location of work,  including borrow and construction sites;

      (3) size,  location,  number,  and identification of test sanples collected
          and results of all tests performed;

      (4) a diary of all relevant climatic and working conditions that may
          affect construction of the  full scale liner;

      (5) index of all  tests and'lfesults that will be used to compare
          the liner  constructed  in the test fill to the full scale liner;  and

      (6) a  test fill report that compiles  all docunentation on the constructs
          of the test fill and includes  all raw data and test results.

      Laboratory hydraulic conductivity  tests  should be conducted on undisturb*

 sanples  collected from the  soil liner in the  test fill.   Care should be

 taken to avoid  conditions that  bias  test results.   Examples of these conditior

 include  excessive effective confining pressure (Boynton and Daniel,  1985;

 Anderson, 1982)  and  sidewall  flow (Daniel  et  al,  1985).   Methods for collectir

 undisturbed sanples of  soil liners have been suggested by Anderson et al

 (1984) and Day  (1984).  The undisturbed sanples may not provide hydraulic

 conductivity values  that precisely reflect field values.  However,  comparison
of values obtained from the test  fill and  full scale- liners- should provide

an indicator of gross changes in  either the materials or procedures used in

construction.

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                                       47
      EPA believes  that  additional testing is warranted to evaluate the hydraulic

 conductivity of  landfill and surface impoundment sidewalls.  Especially in

 surface impoundments, the sidewalls ray be the predominant pathway by which

 leachate can migrate beyond the liner systems.  At this time however,  the

 Agency is not asrare of a suitable method for evaluating hydraulic conductivity

 of the sidewalls other than by construction of a costly scale inpoundment.

 There would need to be separate underdrains for the sidewalls and bottom

 portions of the liner or it would be difficult to determine how much each

 portion was contributing to the total underdrainage.   EPA is temporarily

 deferring the recommendation for sidewall testing to allow interested  parties

 to develop economical and effective test methods.   Comments are requested on

 the following:

      (1) Are tests  of the hydraulic conductivity of landfill and surface
         impoundment  sidewalls  necessary?

      (2) Are there  methods  available for evaluating the hydraulic conductivity
         of  sidewalls?

      (3) Are there  additional methods  that  should be developed to facilitate
         this testing?

      In construction  of  EMLs, consideration should  be given to the effects

 from humidity in  the air.  Seaming of EMLs with some solvent cements at

high levels of relative humidity can result in moisture condensation on  the

adhesive surface during the seaming process and may result in poor adhesion.

A relative humidity requirement may not be necessary for seaming  techniques

that rely on heat to bond the liner sheets, as the heat could prevent  moisture

from condensing on warm surfaces of the FML.

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                                       43
                      III.   Construction Quality Assurance

                                 Contents

                                                                       Page

   A.   Guidance  	       47

          Objective 	       47
          Design and Construction	       47
             0  Elements of a CQA  plan

   B.   Discussion	       49
     A.
     Overall Design/ Construction, and Operation Objective

     Certain surface impoundment and landfill units and most interim status an

permitted waste piles most have a single liner with a leachate collection

system above the liner for landfills and waste piles.  The liner must be desig

constructed, and installed to prevent any migration of wastes out of the unit

during the active live (including closure period).  The Leachate collection

system nust be designed,  constructed, maintained, and operated to collect and

remove leachate from the landfill or waste pile.  To assure that a corrpleted

liner system meets or exceeds all projected design criteria, plans, and

specifications, a construction quality assurance (CQA) program is necessary.

In addition, the regulations for permitted units (§§264.226, 264.253, and

264.303) specifically require liners to be inspected during construction for

uniformity,  damage,  and imperfect Jons (e.g., holes, cracks, thin spots, or

foreign materials);  immediately after construction, EMLs must be inspected to

ensure tight seams and joints, and the absence of tears, punctures, or blister:

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                                       49
      As  part, of  the CQA program for conpacted soil liners, a test fill should



 be constructed using the sane rraterial procedures and equipment that will be



 used in  the full scale facility.  The CQA plan to be followed during the full



 scale facility construction should be exactly followed during construction of



 the test fill.



      Design and Construction



      (a) The owner/operator should submit and inplement a written construction



 quality assurance plan to be used during construction of the leachate collection



 system (for landfills and waste piles)  and liner.   The plan should be used in



 monitoring and documenting the quality  of materials used and the conditions



 and manner of their placement.   The plan should be developed,  administered,



 and documented by a registered professional civil  or geotechnical engineer



 with experience in hazardous waste disposal facility construction and construction



 site  inspections.   While the specific content of the  construction quality



 assurance plan will depend  on site-specific factors,  the following specific



 components  should  be  included,  at  a mininun:



      0 Areas of responsibility  and lines  of authority in executing the CQA



       plan;



      0 Qualifications of CQA personnel;  •



     0 Specific construction quality control  (CQC) activities, observations,



       and  tests - preconstruction, construction, and post-construction



       testa to verify that materials and equipment will perform to specifications,



       and that the performance of the individual parts  of the liner  system



       conform to design specifications.  As completed,  the  individual parts



	of the liner installation should t«  tested for functional integrity^



       For FMLs,  joints, seams, and mechanical seals  should  be checked both

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                                        50
         during and after installation.  A variety of testing methods can be
         used such as:

            - hydrostatic
            - vacuum
            - ultrasonic                                                       :
            - air jet
            - spark testing.

       For soil liners, the conpacted soil should be tested to verify that it

       has an in-place field hydraulic conductivity of 1X10"7 cm/sec or less.

       Testing should include undisturbed samples taken from the compacted soil

       layers during contruction of the liner.  The collection layer should be

       tested to  assure the components are functioning as designed.

     0  Sampling program design; the frequency and scale of such observations and

       tests,  acceptance-rejection criteria,  corrective measures, and statistical

       evaluation.

     0 Documentation of CQA should include daily recordkeeping (observation and

      test data sheets,  problem reporting and corrective measures data sheets),

      block evaluation reports for large projects,  design engineer acceptance

      reports  (for errors, inconsistencies,  and other problems), and final docum

      tation.  After completion of the liner system,  a final documentation repor

      should be prepared.  This report should include summaries of all construct.

      activities, observations, test data sheets, problem reports and corrective

      measures data sheets,  deviations from design  and material specifications,

      and aa-built drawings.

      (b) The documentation for the OQA program for the construction of the unit

 should be kept en-site  in the facility operating record.

	&*—Discussion	
      Construction quality assurance (OQA) during construction of the liner

 system is essential to assure,  with a reasonable degree of certainty, that

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                                       Dj.
 the system meets the design specifications.  This involves inspecting and

 documenting the quality of materials used and the construction practices

 employed in their placement.   OQft. serves to detect deviation from the design

 caused by error or negligence on the part of the construction contractor,

 and to allow for suitable corrective measures before wastes  are disposed.

 Without proper construction quality assurance, problems with the  leachate

 collection system,  and FML or soil liner due to  construction nay  not  be

 discovered until the system fails during operation.

     A recent survey of hazardous waste  surface  inpoundment  technology has

 found  that rigorous  quality assurance  is  necessary to achieve good unit

 performance (Ghassemi,  et  al  1984).  Liner failures  at several  impoundments

 were attributed  to various factors including "failure to execute proper

 quality assurance and control."  The success of  surveyed facilities that have

 performed well is attributed to many factors including "the use of competent

 design, construction, and  inspection contractors, close scrutiny of all

phases of design, construction,.and QA inspection by the owner/operator,

excellent QA/QC and recordkeeping during all phases of the project, and good

connunications between all parties involved in constructing the units."

     Specific problems that can cause failure of the liner system and that

can be avoided with careful construction quality assurance include:

     Collection System

     *  The use of naterials other than those specified in the approved design;

     *  Foreign objects (e.g.,  soil) left in drain pipes,  which plug or restrict
       flow and may not be removable using currently available maintenance
       procedures;
     * Neglecting to install materials at locations specified in the design;

     * Neglecting to follow installation procedures specified in the design;

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                                  52
 0 Siltation of drainaye material  resultiny  from  inproper upgradient drair.a
   during construction and/or  careless construction techniques;

 8 Inprcper use of construction equipment causing crushing or misalignment"
   of pipes;

 0 Inprcper layout of  the system,  including  misalignment of pipe joints
   or inproper slopes  and elevation of pipes; and

 0 Use of unwashed gravel or sand  in drain layers.

 EMLs Used as  the  Liner

 0  The use of  materials other than those specified in the approved design;

 0  Inproper preparation of the  supporting surface (usually soil subgrade)
   to receive  the  liner;

 0  The use of  inprcper installation techniques and procedures by the
   contractor;

 0  The inproper use of construction tools and equipment;

 *  Inadequate  sealing  and anchoring of the liner  to structures, pipes,
   and other penetrations tlirough  the liner;

 *  Installation of the liner during inclement weather; and

 0  Inproper repair  of  defects in the installed liner resulting from
   manufacturing processes and  installation methods.

 Low-Permeability Soil Liner

 0  The use of materials other than those specified in the approved design;

 0  Inproper conpaction equipment;

 *  Inadequate conpactive  effort;

 0  Inproper corrpaction procedures;

 9 Inadequate scarification between lifts;

 0 Excessive lift thickness;

0 Inadequate liner thickness;

e Excessive field hydraulic conductivity;
0 Inadequate method of water addition;

8 Inadequate time allowed for even distribution of moisture;

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                                        53
       0 Iriadequate method used to raintain the optimum moisture content  in
         the liner between construction of each lift and after conpletion of
         the liner; and

       c The use of an inadequate quantity of added fine-grained materials
         (important with bentonite/soil liners).

       The ability of the hazardous waste disposal unit to meet  its  designed

  regulatory performance goals depends on adherence to approved  design plans

  and specifications during construction.   Confidence in the  ability of

  installed liners to perform properly is attained through a well-developed,

  well-implemented,  and well-documented CQA program.   The program should  be

  developed by the design engineer,  who can focus  the emphasis of quality

  assurance on those elements of the design that are critical  to FML or low-

  permeability soil  liner performance.   Implementation of the  OQA program should

  include participation by the design  engineer in  resolving construction  or

  design  problems  that rnay be identified during construction.  Timely identifi-

  cation  of such problems  during construction allows  corrective  measures  to be

  taken before  construction  is completed and wastes are deposited.   Confidence

  in the  liner  is  established through:

      *  Careful  documentation  of:

           - Construction scheduling,  conditions,  and progress;

           - Site inspections;

           - Material/equipment testing results and  data verification; and

           - As-built conditions.

      ' The owner/operator providing the opportunity for review,  inspection,
        and approval by appropriate regulatory and permitting agencies.

      Each of the elements identified as components  of the written  construction

"quality assurance plan will be described in detail  in all upcoming  document	

 on the subject of construction quality assurance  for hazardous waste land

 disposal units.   The document will address"the components listed below:

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                                54
0 Low-permeability soil liners;



° Flexible membrane liners (EMLs) or synthetic meniarane liners;




9 Dikes;



' Low-permeability soil caps and cover systems; and



8 Leachate collection systems.

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                                       55
                                    References

  Anderson,  D.C.  (1982),  Clay Liner-Hazardous Waste  Compatibility.  Report  to
    the U.S.  EPA,  K.W.  Brown and Associates, College Station, Texas.   (EPA
    Contract * 68-01-6515)

  Anderson,  D.C.,  J.O.  Sai,  and A.  Gill  (1984), Surface  Impoundment Soil
    Liners:   Permeability and Morphology of a Soil Liner Permeated by Acid  and
    Field Permeability  Testing for  Soil  Liners.  Report  to U.S. EPA, K.W.
    Brown and Associates, College Station, Texas.  (EPA  Contract # 68-03-2943)

  August, H., R. Tatzky,  G.  Pastuska, and T. Win (1984),  Study of the Permeation
    Behavior  of Commercial Plastic  Sealing Sheets as a Bottom Liner for Dumps
    Report No.  103 02 208, Federal  Minister of the Interior, Berlin, West Germany.

  Barron,  R.A.  (1977),  The Design of Earth Dams.  (Chapter 6) In (A.R. Golze,
    ed)  Handbook of Dam Engineering. Van Nostrand Reinhold Company, N.Y. p.
    291-318.

  Boutwell, G.P. and V.R. Donald (1982), Compacted Clay  Liners for Industrial Waste
    Disposal, Presented ASCE  National Meeting, Las Vegas, April 26, 1982.

  Boynton, S.S. (1983), An Investigation of Selected Factors Affecting the
    Hydraulic Conductivity of Compacted  Clay.  M.S.  Thesis, University of
    Texas, Geotechnical Engineering Thesis GT83-4, Geotechnical Engineering
    Center, Austin, Texas. 79 p.

  Boynton, S.S. and D.E. Daniel  (1985),  Questions Concerning Hydraulic Conductivity
    of Compacted Clay.  Journal of Geotechnical Engineering, Vol. Ill, No.  4.

  Brown, K.W. and D.C.  Anderson.  (1983), Effects of Organic Solvents on the
    Permeability of Clay Soils.  United  States Enviromental Protection Agency.
    Grant No. R806825010.  153 p.

  Brown, K.W., J.W. Green, and J.C. Thomas, J.C. (1983), The Influence of Selected
   Organic Liquids on  the Permeability of Clay Liners.  In Proceedings of
    the Ninth Annual Research Symposium on Land Disposal oT Hazardous Waste,
    (EPA-600/9-83-018).  p. 114-125.

 Corps of Engineers (1977),  Earth-fill and Rock-fill Construction.  (Chapter 5)
    In Construction Control for Earth and Rock-Fill  Dams.  U.S. Army Engineer
   Manual EM1110-2-1911

 Daniel, D»B» (1984),  Predicting Hydraulic Conductivity of Clay Liners.
   Journal of Geotechnical Engineering, Vol. 110, No. 2 p. 285-300.

 Daniel, D.E., D.C.  Anderson and S.S. Boynton  (1985), Fixed-Wall vs Flexible-Wall
	Permeameters.   In Hydraulic HarHo>r« In Qni 1 and Hnrkr ACT* STP 874 (In	
—Press).

 Day,  S.R.  (1984),  A Field Permeability Test for Compacted Clay Liners.  M.S.
   Thesis/  University of Texas, Austin, Texas 105 p.

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                                       56
 Day, S.R., D.E. Daniel,  and S.S.  Boynton,  (1985),"Field  Permeability  Test
   for Clay Liners.  Jin Hydraulic Barriers  in Soil  and  Rock, ASTM  STP  874
   (In Press).

 Dunn, R.J. and J.K.  Mitchell (1984),  Fluid Conductivity  Testing of  Fine-Grain
   Soils.  Journal of Geotechnical Engineering,  Vol.  110,  No.  11,  p. 1648-1665
                                                                             i
 Earth Manual. (1984), Bureau of Reclamation,  U.S.  Department  of the Interior.
   Government Printing Office, Washington,  D.C.

 EPA (1982),  Test Methods for Evaluating Solid Waste.   United  States Environme
   Protection Agency, Washington,  D.C.   (SW-846).

 EPA (1983),  Landfill and Surface  Impoundment  Performance  Evaluation United
   States Environmental Protection Agency,  Washington,  D.C.  (SW-869),  April  19;
   (S/N 055-000-00233-9,  $5.00), Superintendent  of  Documents,  U.S. Government
   Printing Office, Washington,  D.C. 20402, 69 pages.

 EPA (1983A),  Lining  of Waste Impoundment and  Disposal  Facilities.  United Stai
   Environmental Protection Agency, Washington,  D.C.  (SW-870), March  1983.
   (S/tt 055-000-66231-2,  $11.00),  Superintendent of Documents, U.S. Government
   Printing Office, Washington,  D.C. 20402, 448  pages.

 EPA (1984B),  Procedures  for  Modeling Flow  Through  Clay Liners to  Determine
   Required Liner Thickness.   (Draft Technical Resource Document for Public
   Comment) United States Environmental  Protection  Agency, Washington, D.C.
   (EPV530-SW-84-001). 32 p.

 EPA (1984A),  Soil Properties, Classification, and  Hydraulic Conductivity
   Testing.  United States Environmental Protection Agency, Washington,  D.C.
   (SW-925). 167 p.

 EPA  (1983C),  Hazardous Waste Land Treatment.  United States Environmental
   Protection  Agency,  Washington,  D.C.   (SW-874).

 Geotextile Engineering Manual, Training Manual, Federal Highway Administration

 Ghassemi, M., M.  Haro, and L. Fargo (1984), Assessment of Hazardous Waste
   Surface  Impoundment Technology  Case Studies and  Perspective of  Experts.
   Report to the U.S.  EPA, MEESA,  Torrance, CA.  (EPA Contract 169-02-3174).

Green, J.W.,  K.W. Brown,  J.D. Thomas  (1985),  Effective Porosity of  Compacted
  Clay Soils  Permeated with  Organic Chemicals.  ^n_ Land  Disposal  of Hazardous
  Waste/ Proceedings  of  the  Eleventh Annual Research Synposium, pp. 270-271.

Griffin, R.A. et  al.  (1984),  Migration  of  Industrial Chemicals and  Soil-waste
   Interactions  at Wilsonville,  Illinois.   In  Proceedings of  the Tenth Annual
  Research Symposiumon Land Disposai-olHazdtUuus Wasle (CPA COO/9 04—0074-
  USEPA Municipal Environmental Research Laboratory,  Cincinnati, OH 45268.

Griffin, R.A., N.F. Shrimp, Attenuation of  Pollutants in Municipal Landfill
  Leachate by Clay Minerals, EPA-600/2-78-157,  U.S.  EPA, MERL, Cincinnati, OH
  {OTIS PB 287-140/AS].

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                                       57
 Griffin, R.A., R.E. Hughes, L.R. Follmer, C.J. Stohr, W.J. Morse, T.M. Johnson,
   J.K. Bartz, J.D. Steele, K. Cartwright, M.M. Killey and P.B. DuMontelle
   (1984), Migration of Industrial Chemicals and Soil-Waste Interactions at
   Wilsonville, Illinois.  In;  Proceedings of the Tenth Annual Research
   Symposium on Land Disposal of Hazardous Waste, (EPA 600/9-84-007).

 Herzog, B.L. and W.J. Morse (1984), A Comparison of Laboratory and Field
   Determined Values of Hydraulic Conductivity at a Waste Disposal Site.  In:
   Proceedings of the Seventh Annual Madison Waste Conference, University of
   Wisconsin-Extension, Madison, Wisconsin/ pp 30-52.

 Horz, R.C.  (1984)/ Geotextiles for Drainage and Erosion Control at Hazardous Waste
   Landfills.  EPA Interagency Agreement No. AD-96-F-1-400-1.  U.S. EPA,
   Cincinnati, Ohio.

 Johnson,  Russell and Eric Wood, (1984), Unsaturated Flow Through Clay Liners.
   Report to the U.S.  EPA, GCA Corporation, Bedford., MA. (EPA Contract
   #68-01-6871).

 Johnson,  Russell and Eric Wood, (1984), Unsaturated Flow Through Clay Liners
   (Letter Report).   Prepared for the Office of Solid Waste, Washington, D.C.,
   OCA Corporation,  Bedford,  MA.  (QCA-TR-85-01-G) 29 p.

 Kays,  W.B.  (1977),  Construction of Linings For Reservoirs, Tanks, and Pollution
   Control Facilities.   John Wiley & Sons, Inc. NY.  379 p.

 Koerner,  Robert  M., and J.P.  Welsh (1980), Construction and Geotechnical Engineer!™
   Using Synthetic Fabrics.   John Wiley and Sons, New York.

 Lindsey,  W.L.   (1979),  Chemical Equilibria in Soils.  John Wiley and Sons, Inc.,
   449  p.

 Mitchell, J.K.  (1976),  Fundamentals of Soil Behavior.  John Wiley and Sons,
   Inc.-, N.Y.  422p.

 Mitchell, J.K.,  D.R. Hooper,  and R.G.  Campanella (1965), Permeability of
   Compacted Clay.   Journal of the Soil Mechanics and Foundations Division,
   ASCE, Vol.  91,  No. SM4. p.  41-65.

 NSF  (1983), Standard Number  54,  Flexible Membrane Liners.  National Sanitation
   Foundation, Ann Arbor, Michigan.  69p.

Olson, R.E. and D.C. Daniel  (1981), Field and Laboratory Measurement of the
   Permeability of Saturated and Partially Saturated Fine-Grained Soils.  In_
   Permeability and  Groundwater Contaminant Transport,  ASTM STP 746.
                                               U.S. Environmental Protection Agenc»
                                               Region 5, Library (PL-12J)
                                               77 West Jackson Boulevard, 12tfl Flow
                                               Chicago. It.  60604-3590

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                                         58
                               Suggested Reading List


 Flexible Membrane Liner Permeation

 Haxo, H. E., j. A. Miedema, and N. A. Nelson  (1984),  Permeability of Polymer,*
 Membrane Lining Materials for Waste Management Facilities.  In Proceedings
 of the Education Symposium on Migration of Gas,  Liquids, and~sblids in Elastome
 Denver, Colorado.  Sponsored by Rubber Division, American Chemical Society,
 Oct. 23-26, 1984.

 August, H., R. Tatzky, G.  Pastuska, and T. Win (1984),  Study of the Permeation
 Behavior of Commercial Plastic Sealing Sheets as a Bottom Liner for Dumps
 Against Leachate, Organic Solvents, and their Aqueous Solutions.   Research
 Report No.  103 02 208, Federal Minister of the Interior, Berlin,  West Germany.

 Mitchell,  J.  K., D.  R. Hooper, and R. G. Campanella,  (1965), Permeability of
 Compacted Clay.  Journal of Soil Mechanics Foundation Division, ASCE, 91 (SM4):
 41-65.

 Statistical earthwork control

 Hinterkorn, H., and  H. Y.  Fang.  Foundation Engineering Handbook,  Van-Nostrand-
 Reinhold,  Publishers (1975),  See Chapter 7 by Jack W.  Hilf,  section 7.4:
 Control of  Compaction.

 Lee,  I.  K., W.  Mute,  and  0.  G.  Ingles.   Geotechnical Engineering,  Pitman Publi:
 (1983),  See Chapter  2, Soil Variability; and Chapter  9,  Soil Treatment:
 Quality Assurance.  (Good general introduction to the  use of  statistics).

 Representative  samples

 U.S.  Environmental Protection Agency.  Test Methods for the  Evaluation of
 Solid Waste.  SW-846,  Washington,  D.C.,  July 1982 Second Edition.

 U.S.  Environmental Protection Agency.  Draft Solid Waste Leaching Procedure
 Manual.  Washington, D.C.,  1983.

 Graded granular filters

 U.S.  Environmental Protection Agency.  Guide to  the RCRA Land Disposal Permit
 Writers' Training Program, Volume  1,  Sept.  1984,  Chapter 3,  p.   3-38 to 3-41.

 Synthetic fabric filters

U.S. Environmental Protection Agency.  Guide to  the RORA Land Disposal Permit
Writ-ptrs's Training Program, Volume 1,  Sept.,  1984, Chapter 3, p.   3-44 to 3-46.
U.S. Federal Highway Administration.  Geotextile  Engineering Manual.

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